WSLCB – Traceability Advisory Committee
(May 9, 2019)

The next MJ Freeway Leaf release was pulled forward to June 6th and the WSLCB was considering a traceability workflow for importing CBD additives for marijuana products.

After publishing the last Traceability Advisory Committee meeting update on April 16th, WSLCB Director of Communications Brian Smith reached out the same day to express concern about Cannabis Observer’s recording of the meeting. In subsequent conversation with WSLCB staff, it appears that the agency received negative feedback regarding unspecified aspects of the April meeting. We speculate it may have concerned the announcement that MJ Freeway Leaf Data Systems release 1.37.5 had been pushed back another month.

Technically, the meetings of the Traceability Advisory Committee are not formal open meetings as defined in the Open Public Meetings Act. While open public meetings are subject to audio and video recording by the public (1998 Att’y Gen. Op. No. 15), the Traceability Advisory Committee is more of an agency workgroup inclusive of designated industry stakeholders. At the beginning of this month’s meeting, Smith stated, “We did have a discussion, if I might throw that out, about whether or not it was appropriate that you do this because it’s not an open public meeting. But we decided that we had, I had talked to you about this, and we had at one point been okay with it. But – today’s good, but maybe we’ll revisit that after this.

It’s too soon to say whether this is a bellwether of decreased transparency at WSLCB. But the subject of recordings of WSLCB meetings was also prominently highlighted by Board Member Russ Hauge during his introduction at the Tribal Advisory Council public meeting on April 24th (audio – 2m). It sounds like we’ll find out more at the next Traceability Advisory Committee meeting – but that’ll have to wait until July as another outcome of this month’s meeting was a shift in cadence from monthly meetings to convening every other month (audio – 9m).

Here are some observations from the Wednesday May 9th WSLCB Traceability Advisory Committee meeting.

My top 3 takeaways:

  • The release of MJ Freeway Leaf Data Systems version 1.37.5 has been advanced to June 6th (audio – 2m).
    • In late April, WSLCB completed their automated regression testing of the Leaf API interface and manual testing of the “free” user interface. On May 1st, after nine rounds of back and forth with MJ Freeway, the agency celebrated deployment into the integrator testing environment. The code will remain in the third-party software provider test environment for 20 business days. In the absence of setbacks, the agency plans to enter a “quiet period” for five business days before launching release 1.37.5 into production.
    • Since the release was deployed into the integrator test environment, at least two defects have been identified, reported, and were being worked for inclusion in the 1.37.5 release.
    • At the April 11th Traceability Advisory Committee meeting, we learned that WSLCB pushed back the production release date from June 14th to July 1st. After renewed efforts to achieve a viable release candidate, the launch date was moved forward to June 6th, coinciding with the minor 1.37.6 release. There were no changes to subsequent release dates.
    • I inquired about the release of external training materials to enable licensees to prepare for what had been characterized as a substantial release (audio – 5m).
    • Smith indicated some changes have been highlighted in WSLCB’s newsletters to licensees. In early April, the agency stated: “Release 1.37.5 will include a variety of workflow improvements, especially related to waste reporting, inventory type attributes, lab results, inventory transfers, and the ability to adjust previously entered sales data. General improvements will include numeric standardization that will standardize decimal values pertaining to weights and the replacement of drop-down menus with “type-ahead” search fields for batches, inventories and inventory types.”
    • Smith said licensee training videos have been prepared and updates were being made to the WSLCB website to make the videos more accessible.
    • In response to a request from Db3 Corporation Operations Manager Lindsay Short, a Traceability Advisory Committee member, Smith had also prepared “plain talk” release notes detailing new features. Smith planned to share those documents with licensees after code freeze—one week prior to production deployment—as the agency did not want to “jump the gun.” I asked if Smith could make information available sooner but he knew from experience what happens when agency software releases do not go as planned. Deputy Director Megan Duffy asked if a higher-level summary could be provided and Smith agreed. At publication time, the agency had not yet followed up on the request.
  • MJ Freeway and WSLCB were evaluating creation of an official workflow for importing CBD products into Leaf Data Systems for use as marijuana product additives (audio – 13m).
    • On May 6th, Cannabis Observer described the background of the new hemp law and suggested potential opportunities for cannabis producers and processors. In subsequent conversations at the WSLCB, Cannabis Observer confirmed that Washington-sourced hemp-derived CBD products could be introduced into the I-502 system as additives for marijuana products under HB 2334’s (2018) law (RCW 69.50.326) and rules (WAC 314-55-109)
    • During open discussion at the Traceability Advisory Committee meeting, I described SB 5276 (2019) and its creation of an isolated hemp supply chain as well as the potential for CBD additives to be introduced into the I-502 supply chain. I inquired about the status of the Leaf Data Systems workflow needed to enable licensees to document usage of CBD additives in the traceability system.
    • MJ Freeway Project Manager Todd Caldwell said the vendor planned to deliver estimated cost and schedule impacts to WSLCB on May 10th – the day after this meeting.
    • As this work is outside the scope of the original contract and WSLCB has recently demonstrated some restraint on feature creep, Project Manager Clare Olson asserted any work would have to wait until a subsequent subscription services release. No dates have been set for those releases, but it would be well into 2020 – too late for quick turnaround of CBD products created from this fall’s hemp harvest.
    • I asked if the agency was aware of any workarounds being utilized by licensees to exercise the powers granted by the law while remaining compliant with the traceability mandate, as I have heard rumors that some licensees are adding CBD to marijuana products in a way that is compatible with Leaf’s available functions. The WSLCB staffers present were not aware of any workarounds. Deputy Director Duffy asked to hear from licensees willing to share workarounds for this use case.
    • At publication time, I had not heard back on my inquiry about WSLCB’s analysis of MJ Freeway’s estimate on delivery of this functionality. The agency does seem interested in evaluating what can be done.
  • WSLCB remained open to collaboration with third-party software providers on the process of testing Leaf releases – but with caveats (audio – 10m).
    • In response to a suggestion by WeedTraQR and OpenTHC developer Matthew Walther, I asked the Traceability Advisory Committee about the possibility of enhanced coordination between the agency, MJ Freeway, and third-party software providers during the testing process for Leaf Data Systems releases.
    • The free user interface, allegedly used by 25% of licensees, is manually tested by the vendor and the agency. Development and testing of this interface—effectively a completely separate software development project in its own right—burns more time and expense across the overall project.
    • In contrast, the Application Programming Interface (API) is utilized by all of the third-party software providers. MJ Freeway and the WSLCB have automated the testing of this interface, and that testing can be completed in a single day.
    • The codebase for both interfaces is MJ Freeway’s intellectual property and inaccessible for review or collaboration. However, the codebase for the automated API test cases is owned by WSLCB and could be opened up in some form.
    • WSLCB CIO Mary Mueller was quick to respond: “we offered that before, and I had zero, zero people respond.”
    • In the lead up to the launch of Leaf Data Systems in February 2018, Mueller asked the software integrators to “come in help us write test cases, give us theirs so we’ll test those scenarios.” She expressed frustration: “they say they want it, but then when we offer it, there’s no interest.”
    • Mueller said she worked with The Cannabis Alliance in early 2018 to “test the Integrator systems against what’s in Leaf. And that led into, can we do collaborative test case development for our API with a subset, or the full range, or volunteers from the Integrator community.” She pursued the idea at an integrator work session, attempted to start discussion in WSLCB’s SharePoint collaborative work environment, and called several individuals who said they didn’t have the time nor interest in providing test cases to competitors for free.
    • Mueller said open source development processes “are not going to happen” because of the state’s security requirements: “There’s some test cases I’m not, you know, they’re testing security functions and I’m not going to allow anybody to see what we are or are not testing that could be a security risk.
    • While Mueller agreed collaboration with third-party providers in some form would be ideal, it was clear the agency expended effort on this in the past and wasn’t keen to do so again on their own initiative. I suggested I bring the topic up at the next bi-weekly Integrator Work Session to gauge renewed interest.
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