Traceability got you down?
Traceability got you down?
As of 11pm PT on Saturday July 13th, MJ Freeway’s Leaf Data Systems was down for maintenance. A critical point of interoperability and data transfer between third-party software providers serving licensees, the centralized traceability system remains necessary to document supply chain events and business-to-business transactions within the I-502 marketplace. Operators are legally required to use a traceability “system” specified by the Washington State Liquor and Cannabis Board (WSLCB) as defined in WAC 314-55-083(4). The stipulation that “All costs related to the reporting requirements are borne by the licensee” may be more poignant today as the extended outage drags on through Tuesday morning.
How did we get here? Readers of Cannabis Observer will have seen Leaf release 1.37.5 coming for some time as it was originally contracted for delivery on November 6th, 2018 and first publicly mentioned as postponed on October 31st. Multiple missed deadlines later, on June 17th the agency announced Monday July 15th as the target upgrade date following an outage of “approximately 30 hours” (33 for those counting). But it wasn’t until Thursday July 11th that the WSLCB shared plans to further extend the outage “for at least 48 hours” (57 actually), first at the Integrator Work Session and later in the day via official announcement. While the third-party software providers suggested a 24/33 hour outage would best be situated on a Sunday to minimize disruption across the industry, there was no public conversation about potential impacts of a further extended outage that spanned across a Monday at the start of a business week.
Here’s a look at the week ahead, including our best knowledge about the WSLCB’s decision points for the release of MJ Freeway’s Leaf Data Systems version 1.37.5.
TODAY: On Monday July 15th @ 4:30pm PT, MJ Freeway and the WSLCB expected to complete the code revision and execution of a suite of “Data Fix Scripts” on the production environment. They planned to then evaluate whether or not desired outcomes were achieved.
At 10pm PT, the agency planned to convene a “Go/No Go Meeting” with the vendor to make the call on moving forward with the release as implemented. If it’s a “Go,” release 1.37.5 was projected to be available by 11:30pm PT. If not, a rollback to the previous release (1.36.5) would be implemented by early Tuesday morning @ 1:30am PT.
TUESDAY: On Tuesday July 16th at 8am PT, the WSLCB informed the regulated community to expect the new version of MJ Freeway’s Leaf Data Systems to be up and running. The discrepancy in available times shared with the third-party software providers (Monday @ 11:30pm) versus licensees (Tuesday @ 8am) was likely intended to provide integrators a brief window to synchronize their systems and data caches with the significantly revised data in Leaf. The massive number of overnight requests to the Leaf API will put the new release and its operational environment to a very real-world test.
WEDNESDAY: On Wednesday July 17th at 10am PT, a Special Board Meeting has been scheduled outside of the normal bi-weekly cadence. We expect to see a new rulemaking project opened with the filing of a CR-101 for the agency to develop a new consultation program to emphasize education above enforcement, an outcome of the passage of SB 5318 this past legislative session.
Later on Wednesday at 1:30pm PT, the Cannabis Advisory Council meets for the first time since January 16th. The Council is composed of members from industry, tribal nations, and others who provide perspective for the agency. It’s our understanding that there has been some turnover on the Council and discussions with Board Sponsor Ollie Garrett about creating new seats to bring in new perspectives. Bailey Hirschburg, a citizen observer with Cannabis Observer, has represented the consumer perspective on the Cannabis Advisory Council from its inception.
Importantly, it appears that both of these meetings will NOT be hosted at WSLCB’s new headquarters. We had been wondering based on public conversations we’ve observed at the agency and our own assessment of the unfinished state of the new board room. And this morning we see the posted agenda for Tuesday’s Board Caucus includes discussion of an “Off-Site Schedule for Wednesday, July 17, 2019.” Cannabis Observer will share details on the improvised location for both meetings no later than our release on Wednesday morning and will observe both meetings.
On Wednesday July 17th, the bi-weekly WSLCB Executive Management Team Meeting has been canceled.
THURSDAY: On Thursday July 18th at 10am PT @ WSLCB, the Marijuana Traceability Project (MTP) Advisory Committee meeting recurs, still meeting every month through delivery of the new release. This is not a formal public meeting, but is open to the public. I’ve been a member of the Traceability Advisory Committee since early 2018 representing the Cannabis Alliance. The committee most recently met on June 13th to discuss the 1.37.5 release and alternative approaches to contemporary seed-to-sale systems.
FRIDAY: On Friday July 19th, the Washington SunGrowers Industry Association (WSIA) hosts its annual meeting in Omak. WSLCB Board Member Russ Hauge, Cannabis Examiner Manager Kendra Hodgson, and Cannabis Policy and Rules Coordinator Kathy Hoffman are traveling to speak at the event, as are Washington State Department of Agriculture (WSDA) Organic Program Manager Brenda Book and David Bryson with the WSDA Pesticide Management Division. I’ll be speaking about traceability and government transparency at the event.