The Washington State Legislature was scheduled to convene in one week, and pre-session jitters were amplified by a questionable CCRS update coming in for a landing on the same day.
Here’s a look at cannabis-related policymaking events on the calendar in the week ahead.
Monday January 2nd
The State of Washington (belatedly) recognizes the New Year’s Day holiday.
Tuesday January 3rd
WSLCB - Board Caucus
On Tuesday at 10am PT, the weekly Washington State Liquor and Cannabis Board (WSLCB) Board Caucus was scheduled to recur.
- [ Event Details ]
Wednesday January 4th
WSLCB - Board Meeting
On Wednesday at 10am PT, the bi-weekly WSLCB Board Meeting was scheduled to recur.
- [ Event Details ]
- After publishing the agendas for both the board caucus and the board meeting early on Thursday December 29th, a revised agenda for the board meeting was published late on Friday December 30th. The only change was the removal of Director Rick Garza’s recognition of Director of Communications Brian Smith for 30 years of service at the agency.
- The board still planned to receive an update from Chief Information Officer George Williams on the Cannabis Central Reporting System (CCRS), the State-owned alternative to traceability which remained scheduled for revision on Monday January 9th - incidentally, the first day of the Washington State Legislature regular session.
- The latest reminder broadcast to licensees on Wednesday December 28th indicated WSLCB staff planned to roll out several breaking changes, most prominently the elimination of the webform for documentation of manifests in preference for uploads of comma separated value (CSV) files, settling on the same technique used for all other CCRS data exchange.
- Exactly how prepared the cannabis sector is for these reporting changes remains unclear.
- It’s Cannabis Observer’s understanding that the previous manifest webform did not perform rigorous data validation - users could input values freely and a PDF manifest would be generated automatically. By way of contrast, the CSV upload process performs data validation - introducing new ways for processes to fail, especially in the absence of data from business partners.
- It’s also our understanding that the CSV upload process generates a PDF manifest which is emailed to the user upon successful completion of the upload, validation, and ingestion processes. We’ve heard how feedback emailed to users in the event of failures along the way can take hours to arrive - if feedback is provided at all. WSLCB does not provide a service-level agreement (SLA) to licensees nor their software integrators, therefore the agency has no obligation to provide information in a timely fashion nor guarantee uptime of its services.
- Yet, the emailed manifest is regarded by the agency as the official document for transportation purposes, and software integrators are not allowed to generate identical manifest documentation from their own data they attempt to report to the agency.
- Exactly how prepared the cannabis regulators are for these reporting changes similarly remains unclear.
- Late on Thursday December 29th, WSLCB staff posted an update to the CCRS landing screen which stated, “ATTENTION: On 12-29-22, LCB became aware that all emails coming from outside the agency to the LCB Service Desk were being rejected. The IT Team is working to identify and fix the issue. Until the problem is solved, you can call our Service Desk at ITS Service Desk at (360) 664-1776. We apologize and thank you for your patience.”
- That message was modified the following afternoon (the same day the board meeting agenda was revised), “ATTENTION: On 12-29-22, LCB became aware that some emails coming from outside the agency to the LCB Service Desk were being automatically sent to a quarantine folder. The IT Team is working to identify and fix the issue. The team is also checking the quarantine folder frequently to check for service requests. We apologize and thank you for your patience for any delays in response.”
- Less than an hour later, the revised message was completely removed from the CCRS landing screen.
- In the same way that agency staff characterized the shift away from MJ Freeway as a change sought by industry (without qualifying that no one requested nor had any input on CCRS), the revision to accept manifests as CSV files was sought by the sector in the spring of 2022.
- The approach to technology development thus far evidenced by agency staff consists of accepting some concepts but implementing them with minimal communication or feedback from stakeholders. Design processes and execution could be improved.
- If licensees are suddenly confronted with hour-long delays (or longer) to obtain an “official” manifest form containing the very same data their software integrators sent to the agency - I anticipate there might be some feedback about that.
- New tensions may be created between otherwise amiable business partners simply due to following different schedules for reporting data to WSLCB. The agency has only stated reports must be submitted weekly, but it’s our understanding that requests to generate manifests containing data that hasn’t been reported yet will fail.
- A consistent theme agency staff have heard from the cannabis sector for years is the necessity for the agency to get out of the way of business transactions. A reporting system which tries to retain elements of control over business processes is a traceability system.
- CCRS was built on a poorly chosen technological stack coupled with poorly executed code - a combination which creates bad trouble. Yet, WSLCB staff seem convinced the Monday January 9th release will be the final revision to the CCRS system. No dedicated budget request was made to support additional work. And information technology staff cobbled together for the CCRS project are likely to be re-assigned to more pressing efforts like the social equity retail program launch and the Systems Modernization Project (SMP) which was granted $34M in Governor Jay Inslee’s proposed biennial budget.
- What will happen? Well, perhaps we’ll get a preview on Wednesday given the additional time granted for the board meeting.
Thursday January 5th
WA LEB - Board Meeting
On Thursday at 10am PT, the Washington State Legislative Ethics Board (WA LEB) was scheduled to convene.
- [ Event Details ]
- At the WA Legislative Ethics Board (WA LEB) on Monday December 19th, members debated a question which had been presented to them asking when the Ethics in Public Service Act applies to newly appointed or elected legislators. They agreed that it occurs on the appointment effective date or when the election is certified, finding the swearing in was a "ministerial" performance, and published an ethics alert to that effect on December 21st.
- On Thursday December 28th, the WA LEB published a new complaint opinion for a question filed by the Washington Association of Sheriffs and Policy Chiefs (WASPC) about a social media interaction involving outgoing Representative Jesse Johnson.
- “Question/Complaint: Has RCW 42.52.070 been violated when a member, in a personal social media account, responds to a radio personality with a comment regarding law enforcement killing people and the executive director of a law enforcement association alleges harassment?
- Summary: No. There is no allegation that the Complainant or her board, which asked her to file the complaint, were harassed. Further, RCW 42.52.900 is an intent section and does not confer jurisdiction on the Board.”
WSLCB - Work Group - QC Standards - Public Meeting
On Thursday at 2pm PT, the WSLCB Quality Control Standards Work Group (WSLCB - Work Group - QC Standards) was scheduled to convene.
- [ Event Details ]
- The WSLCB Quality Control Standards Work Group was established in December 2022 to evaluate the effectiveness of updated cannabis quality control standards contained in administrative rules which took effect on April 2, 2022. Their first meeting was scheduled the week after the closing of the retail sell-down period.
Friday January 6th
WA Pharmacy Commission Legislative Committee - Public Meeting
The monthly Washington State Pharmacy Quality Assurance Commission Legislative Committee (WA Pharmacy Commission Legislative Committee) public meeting was cancelled.
- [ Event Details ]