Proposed Federal Regulation Framework

This is a proposed Federal Regulation Framework for Cannabis policy in the U.S., the efforts of the Federal Regulatory Framework (FRF) Working Group, a collaboration between the Foundation of Cannabis Unified Standards (FOCUS) and the Association of Food and Drug Officials (AFDO).

The Working Group’s goal is to develop a comprehensive and relevant roadmap for the regulatory framework of these unique consumer packaged goods (CPG), addressing critical challenges and enhancing consumer confidence in the safety of the products they purchase and consume. The complexity within the food and beverage industry stems from cannabis not having approval as a food additive, and as a result, cannabis companies are producing new consumer products categorized as food without comprehensive regulation or oversight by food safety experts and regulatory bodies.

It’s a great start, here are my suggestions for improvement:

1) In hemp, there is no “0” nor should there be. While a Type V is theoretically possible, where is an example today? And further, why “0”? Even if hemp today is 3,000 ppm (0.3%), if the testing LOQ is say 1 ppm (0.00001%) then why is “0.000000” necessary? It’s just reefer madness, use of seed certified to be compliant by a government agency should suffice.

2) Food and ingredients must be separated into pre- and post-harvest, USDA and FDA. Otherwise, it’s like FDA regulating soybean farming or USDA regulating UHT soymilk; it makes no sense.

3) In this age of delta-8/9/10 gummies sold to teens in gas stations in the south, hemp food needs “THC-free” labeling if compliant, such as what alcohol-free and fat-free enjoy if <0.5% and <0.5g, respectively. That’ll be on Congress to fix, like it did those two.

4) The Tenth Amendment complicates the Therapeutic/Psychotropic issue immensely, and it is ignored here. “Sub Agency” could be a federal Office of Cannabis under NIH or FDA, or maybe it’s the state which already has an entire marijuana regulatory infrastructure funded and in place?

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