WSLCB - Executive Management Team
(October 13, 2021) - CCRS Update

Cannabis Central Reporting System (CCRS) - SNAFU

CFO Jim Morgan told agency leadership CCRS remained on track and testing revealed no significant bugs; meanwhile, an informal integrator group formed to facilitate data exchange.

Here are some observations from the Wednesday October 13th Washington State Liquor and Cannabis Board (WSLCB) Executive Management Team (EMT) meeting.

My top 3 takeaways:

  • Chief Financial Officer (CFO) Jim Morgan brought the board up to speed on the transition to a Cannabis Central Reporting System (CCRS), stating that the project was on schedule for launch by mid-December and had no “show stopper” problems (audio - 8m, video).
    • The software responsible for tracking the state’s legal cannabis, Leaf Data Systems, and the vendor providing it, MJ Freeway, had been blamed for numerous problems which were not adequately addressed by the program’s last update, release 1.37.5 in July 2019. Additional development was halted in favor of maintaining a comparatively stable system. The Traceability 2.0 Work Group, organized to help the agency chart a path away from its reliance on traceability technology, last met on March 2nd to explore a minimized Cannabis Traceability Requirement Repository. The move to CCRS was announced publicly on August 11th during staff discussion about a communications plan to accompany the system launch.
    • Morgan started off his presentation by saying the “project is going very well” and staff had concluded both “development work on the system” as well as “initial internal testing.”
    • “The first phase of external testing has been completed,” stated Morgan, involving a “one week pilot” with a group of six integrators, three licensees, and two accredited cannabis laboratories that had been “selected for their interest and their engagement.” The problems this group identified didn’t include any "show stoppers, and they have all been resolved,” he said. Morgan reported that CCRS testing was subsequently “opened up” to all “licensees, integrators, and labs.” The “ongoing” process had found more issues, “and they have also been resolved,” he noted, leaving “no outstanding issues that we’re aware of.”
      • While reporting to WSLCB under the CCRS regime would largely be conducted via comma-separated value (CSV) files following a set of defined formats, licensees would still be required to submit transportation manifest details via a Drupal-based web form prior to movement of products. The form was reportedly situated behind a CAPTCHA specifically intended to preclude automated submissions. At publication time, the web form still had not been published and it remained unclear why agency staff would necessitate its usage in a manner distinct from all other reporting requirements.
    • Morgan said there had been “targeted communications to keep our stakeholders informed” and the project remained on track for "a mid-December go live date." A CCRS webinar on September 8th included the participation of "several hundred folks,” Morgan told the team, and provided an “overview of the project” including “where we’re going.” A second webinar on October 4th also had “good participation,” focusing on the “technical aspects of the project, inform[ing] people of where they can find project resources” - although he cautioned that “I’m not the technical guy.”
      • In between the two webinars Morgan cited was another hosted for pilot test participants on September 20th.
    • Amongst the “common themes” he’d heard, one “has been concern about the schedule.” Staff remained “very confident that things are going to work and...licensees should be able to make that transition without a lot of trouble,” Morgan observed, in part because “we’re getting out of their way.” He suggested that MJ Freeway software could “cause business disruptions" whereas a “reporting only” process had conceptually been "very well received."
    • There had been complaints about “how product will be moving” between licensees, said Morgan, as that process had been facilitated by Leaf Data Systems and “now they’ll have to find different ways to do that.” However, handing over this responsibility to the cannabis sector would create “a level playing field with all of our other licensees,” he argued, as “we don’t get in the middle of transaction flows for liquor licensees or tobacco licensees.”
    • Morgan had heard "fairly limited" concerns that “that’s going to be a burden on some folks,” but assured the group that staff were looking to “avoid any significant disruption" to the industry. However, Morgan admitted, “we're not in a position to make it pain-free for them." Agency officials were working to “set them up for success as much as possible,” he believed, but "there will be some inconvenience."
    • During the transition to Leaf Data Systems there had been licensee disruptions that were “no longer going to be possible” as a result of CCRS, Morgan remarked. Although he considered it unlikely, if the CCRS system was not functional “on day one, they continue to do business, and we’re just not going to be receiving their files.” He asserted that "our ability to...cause problems for the industry" is something “that we're addressing with this system.”
  • Board Chair David Postman had a couple of questions for Morgan, and Director Rick Garza offered remarks on the effort later in the meeting.
    • Postman was curious about “the types of things” testing had identified as problems and asked for an example of something “that we’re able to fix.” Morgan found the issues to be ”pretty minor things" such as ensuring the proper CSV file format, and a “few instances” where the “appropriate message” was not sent to an individual making a report, “or, no message got sent back.” He summarized them as “fine tuning collecting the data and how we communicate back to the licensees” (audio - 1m, video).
    • Postman said he’d made “a pitch for people to engage [in] the additional testing” earlier that morning at the October 13th board meeting, and asked to confirm that “at this point it’s wide open” to all licensees, labs, and integrators. Morgan agreed, noting most participation had been from third-party software providers creating interfaces for their products. While wanting broader engagement, he reported that staff had "exercised the system well enough" to flush out issues and he expected “lots of support” would be available for those who had yet to try out CCRS. Postman thanked Morgan for acknowledging “we can’t make it completely painless, there’s always some bumps” and promised the board would seek further briefings as the transition progressed (audio - 2m, video).
    • During his update later in the meeting, Garza praised Chief Information Officer (CIO) George Williams, selected on May 11th, who had worked with Morgan and staff on CCRS to “figure out how we transition” to the reporting system (audio - <1m, video).
  • Just prior to the EMT meeting, the Washington Cannabis Integrators Alliance (WCIA) announced its formation and initial participant trade associations, testing labs, and third-party integrators intended “to enable interoperability between members' technology platforms that allows supply chain traceability for easier compliance, as well as improved data accuracy for cannabis licensees.”
    • The press release stated that WCIA was formed in direct response to the “upcoming transition to” CCRS. Participants in the group aimed to define “open standards and technical specifications so data can be exchanged easily between platforms without manual data entry” as a means of improving “the accuracy of information and facilitating more efficient traceability and compliance.”
    • The release goes on to identify WCIA’s initial participants:
    • WCIA participants had the following to say about the situation:
      • Travis Steffen, GrowFlow Chief Executive Officer (CEO): “Ensuring that operations are smooth and seamless is essential for cannabis licensees. The Washington Cannabis Integrators Alliance is a step we’ve opted to take to help make this a reality for business owners and is an important way for GrowFlow to live up to one of our values of putting customers first.”
      • John Yang, Treez CEO: “WCIA represents a significant advancement for the cannabis supply chain in Washington. By delivering interoperability capabilities, cannabis owners can simplify their information flow, increase efficiency by minimizing manual data entry and make compliance faster and easier.”
      • Zach Goldberg, GrowFlow Chief Technology Officer (CTO): “GrowFlow has been disappointed by the LCB's approach to the rollout of CCRS and the lack of communication with licensees and integrators on key decisions in this process.  We're doing everything we can, including forming an alliance with other integrators via WCIA to ensure minimal disruption for all licensees.  We welcome a more open dialog with the LCB about how we can manage this transition in a way that is beneficial to the industry. Minimizing business disruptions should be the top priority for everyone involved in the cannabis supply chain.”
      • Micah Sherman, Washington Sun and Craft Growers Association (WSCA) Board Member: “When the WSLCB announced their plans to shut down Leaf, the leadership at the Washington Sun and Craft Growers Association (WSCA) immediately had concerns about our licensee members continuing to be able to do ordinary business once Leaf had been turned off. We knew our software integrators would be able to ensure that we reported what the WSLCB needed, but our ability to transfer to all other licensees was not being discussed. We are very pleased to be a part of organizing our software providers into collective action to solve this problem in collaboration and cooperation. Time is short and there is a lot of work to be done to make sure this very short timeline doesn't disrupt our industry unnecessarily. Without the action of the individuals and groups that now make up the WCIA no one would be concerned with licensees continuing to be able to do business during this change. We are glad to be a part of that effort.”
    • At publication time, direct participation in WCIA was open to third-party and licensee/lab software integrators as well as supporters. Indirect participation would be enabled by utilization of data format specifications and transfer protocols which would be freely published on the WCIA website. But given the early stage of specification development, additional perspectives at the table would be welcomed and influential. And given the very short window of time allowed by the WSLCB for the cannabis sector to take over responsibility for reliable transfer of product information, manifests, lab results, and other data between multiple vendors and standalone licensee systems - the emergence of a vehicle for collaboration was a promising sign.

Information Set