Here are some observations from the Thursday April 11th WSLCB Traceability Advisory Committee meeting. The committee has been meeting since January 2017 and is currently composed of staff from WSLCB, MJ Freeway (the State’s traceability software vendor), the Office of the Chief Information Officer (OCIO), a project quality assurance vendor, and industry representatives. The committee is currently scheduled to meet monthly, but had not met since January 2019.
My top 3 takeaways:
- MJ Freeway and WSLCB provided a revised release schedule for Washington’s version of Leaf Data Systems (audio – 4m).
- Version 1.37.5 – Contracted for release in early November 2018, 1.37.5’s release date was re-baselined to June 14th in March, and has been further pushed out to July 1st, 2019. WSLCB has implemented a 10-day regression testing process to validate software release candidates and MJ Freeway has failed to provide an acceptable release candidate through eight testing cycles. During MJ Freeway’s status update, they reported the ninth release for testing would be delivered to WSLCB no later than May 7th (audio – 2m). Change management procedures have been implemented to constrain the scope of releases, but new bugs continue to be identified. Recently, David Busby’s team at WeedTraQR identified a feature in the live system which has further compromised traceability data integrity. Version 1.37.5’s scope has been expanded to include a patch for that issue.
- Version 1.37.6 – WSLCB intends to begin using the Qlik data analytics platform to facilitate a system of automated alerts. This narrow release is scheduled for June 6, 2019 and targets the Secure Access Washington single sign-on platform.
- The potential for an automated alert system based on data provided through the traceability system was the subject of a Washington State Auditor’s Office (SAO) report requested by WSLCB and delivered in August 2018. The SAO presented their findings to the Joint Legislative Audit and Review Committee (JLARC) I-900 Subcommittee in late September 2018. The Traceability Advisory Committee discussed the report and alert system in September 2018 and November 2018.
- Version 1.40 – the next release is scheduled for September 20th, 2019. This release is intended to encompass the features MJ Freeway originally agreed to deliver in the contract signed on July 11, 2017. Once this release is achieved, the vendor relationship transitions to annually assessed “subscription services” at a rate of $600K per year. However, the system still won’t be complete.
- Version 1.41 – To control the scope of releases, the change management process implemented by WSLCB and MJ Freeway scuttles most bug fixes and potential features to the subscription services phase of the project. Release 1.41 is the first planned release after entering subscription services, and includes bug fixes and “data quality related to MJF caused bugs.” It is targeted for release on December 27th, 2019.
- TBD – Yet another additional release is anticipated after 1.41 for “Data Quality related to LCB caused issues.” No dates have been hazarded for this release.
- WSLCB Project Manager Clare Olson provided an overview of the agency’s initial planning for a traceability “Data Quality Effort” (audio – 3m).
- Throughout 2018, industry representatives on the Traceability Advisory Committee have steadily escalated concerns about the integrity of the data within MJ Freeway Leaf Data Systems. WSLCB has recognized the necessity to take ownership of efforts to remediate traceability data in collaboration with MJ Freeway, third-party software providers, and licensees.
- Olson prefaced by saying the data quality project was in its initial planning phase. WSLCB staffer Matt Rein was responsible for creating a planning document for delivery to project sponsors the week of April 15th.
- Olson cautioned, “we don’t really know how big the breadbox is yet” and said WSLCB was attempting to gain an assessment “a little more finite than ‘everything is bad.’”
- Olson said her perspective on the data challenge was informed by conversations with WSLCB Enforcement staff: “talking to the enforcement guys has been a real eye-opening experience for me. It is the reason I stay here late at night trying to get these things sorted out.” WSLCB Business Process Manager and Board liaison Mona Moberg witnessed traceability issues during a ride-along with agency enforcement officers the day prior.
- Olson and Rein suggested a seemingly straightforward process:
- Assess: identify data quality issues
- Analyze: perform root cause analysis to “group like things” and try to fix things “systemically”
- Resolve: log defects and use existing change request processes to create a history of work
- Monitor: use data quality metrics to monitor progress
- Olson anticipated repeating the data quality effort every two years to “ensure that everything is as it needs to be.”
- According to the schedule provided, remediations from the data quality effort were not planned for deployment until version 1.41 at the end of 2019 – and beyond.
- Gregory Foster suggested the committee undertake documentation of the history of traceability in Washington State and prepare for the future of cannabis supply chain transparency in coordination with the Board’s Cannabis 2.0 initiative (audio – 13m).
- Rather than recount my own testimony, I’ll briefly describe my intent.
- Without knowledge of the past, it’s more difficult to chart a wise path towards a desirable future. I’m advocating for documentation of the history of traceability in Washington State so we can better understand the decisions that have been made which have led us to the present moment.
- With a vision for the future, it’s easier to raise one’s gaze from the minutiae of the moment. Traceability is supply chain transparency by another name. Consumer desire for knowledge about the origin of the products they buy, the conditions under which those products were grown and manufactured, and the practices of vendors along supply chains is growing – especially for products we ingest into our bodies. Traceability in that sense is not going away with federal legalization. However, the structural constraints of monolithic, centralized, state-designed and -managed traceability systems are not compatible with participation in a dynamic network of interstate and international trade. Nor, for that matter, will trade be constrained to a cabal of states utilizing the same or similarly mediocre state-managed traceability systems. There are other, more sensible, and easier paths ahead – and it’s time we began making our way towards them.
- When the time is right, move. WSLCB Board Chair Jane Rushford initiates her Cannabis 2.0 project this week. As I understand it, Cannabis 2.0 is an effort to assess the agency’s regulation of cannabis over the past five years, incorporate lessons learned (including from states which legalized after the trail blazers), and develop an inclusive legislative program for the 2020 session which better positions Washington State for success in the years ahead. I am advocating for a future centered on exquisite, Washington-grown, craft cannaseur cannabis; local economies and future talent boosted by homegrow, direct sales, tourism, and social consumption; and furtherance of the already extant reputation of the PNW as the home of the finest cannabis exported around the world.
- I encourage you to listen to the recording linked above and the subsequent discussion (audio – 15m).
- I also encourage you to make your own voice and perspectives known to WSLCB staff, the Board, and Cannabis Observer.
Here are shared documents for your review:
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