Hello,

I am writing from the Hemp Food Association with concerns about the Senator’s proposed “Cannabinoid Safety and Regulation Act.”
In particular, “allowing up to 5 milligrams per serving and a maximum of 50 milligrams per container across all types other than beverages. Hemp drinks could have up to 10 milligrams of THC per container.”
While I agree FDA regulation and the budget for that is critical, this Bill as written will confuse consumers and wholesale buyers of hemp’s current largest legal industry, namely food from the grain.
Hempseed foods are in virtually every grocery store in the nation, including Walmart and Costco, and have been for decades. FDA accepts hempseed as a Generally Recognized As Safe (GRAS) food.
THC gummies chemically synthesized from foreign CBD and sold to teens from gas stations are not considered “hemp food.” Of course, trading the success of one hemp segment for the devastation of another is an unhelpful zero-sum process.
A workaround might include:
1) require a max THC of 10 ppm in hemp foods, currently it is 3,000 ppm (0.3%);
2) allow compliant foods to be labelled “THC-free”; and
3) designate the common and usual name of the primary shelled hempseed product as “hempnut,” since the grain is in fact botanically a nut. That saves label space and codifies a standard of identity for the hempseed material which sells the most.
For background, over 30 years ago I was the first food professional to pivot to hemp foods in America with branded perishable foods sold in the US and Canada, like HempRella and Hempeh Burgers (made for us by your Turtle Island Foods/Tofurky, my old friend Seth Tibbott).
In just a few years food became hemp’s largest legal segment. In 1998 I started the Hemp Food Association (the-hfa.org) to develop the fledgling industry, and currently publish “The Richard Rose Report.” (therichardrosereport.com) That’s a leading hemp news outlet with tens of thousands of educational and technical posts on hemp and CBD since 2019. (x.com/TheRRreport)
Thank you for your consideration of this unintended consequence of the CSRA.
If you have any questions or want background on any hemp issue, feel free to contact me anytime.
Sincerely,
Richard Rose
Hemp Food Association
(linkedin.com/in/thehempnut)