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tothe

07/10/17 7:53 PM

#33162 RE: Fivespeedchatter #33155

80% of Cannabis Startups fail in 3 years!!!
I think we are in pretty good shape unless we lose all our clients at once.
see page 32
http://www.oregon.gov/oha/PH/DISEASESCONDITIONS/CHRONICDISEASE/MEDICALMARIJUANAPROGRAM/Documents/rules/333-007-008-064-HO-Report-FINAL.pdf

Fivespeedchatter

07/10/17 7:57 PM

#33163 RE: Fivespeedchatter #33155

Lori Glauser, EVIO Labs

Summary of what Lori and team proposed...

Ms. Glauser also submitted written comments in support of her oral comments and those of Henry Grimmett who testified at the Portland hearing. Her written comments are attached to this report as “Exhibit 2”.

Ms. Glauser made a number of specific recommendations and provided related discussion that are detailed in her written comments. These recommendations include: (1) do not adopt the changes to testing concentrates annually as every batch of concentrates should be tested, (2) do not allow for testing a randomly selected number of batches, instead increase batch size to 15 pounds, (3) do not insert proposed OAR 333-007-0360(1)(c) which allows for the unlimited combination of batches of product of the same strain for the purpose of reducing the number of potency tests, (4) keep the term “uniform in strain” from the definition of “Harvest Lot”, (5) reintroduce microbiological contaminant and add mycotoxin screening, (6) allow labs to track samples among subcontracted labs and maintain the same METRIC ID throughout the testing process for all test types and (7) increase labeling margin for edibles from +/-5% to +/-10%.




Summary of Agency's response to the specific inquiry brought by Lori and EVIO:

OHA did not adopt a once annual randomized pesticide testing scheme for concentrates and extracts and did not reduce the frequency of pesticide testing on useable marijuana being supplied into the adult use market.

Batch sizes were increased from a maximum of 10 pounds to 15 pounds.

Samples of different batches of the same harvest lot of usable marijuana may be combined for purposes of testing for potency if the batches are the same strain.

The definition of a “Harvest Lot” no longer includes the words “uniform in strain”.

Testing for microbiological contaminants remained under OAR 333-007-0480 Audit and Random Testing. The agencies may also request testing for other contaminants that may pose a risk to public health and safety.

OHA does not regulate the tracking of products in METRC.

The labeling margin for the amount of THC and CBD on a label was increased from +/- 5% to +/- 10%.



Not bad!!