New 3.0 U.S. Hemp Authority Guideline Procedures!
The U.S. Hemp Authority™ recently published a 3.0 version of their Guideline Procedures that is open for public comment. Established in 2018, the U.S. Hemp Authority™ is the Hemp industries leading regulatory body, providing excellent standards and practices followed by all major stakeholders in Hemp.
As we’ve discussed before, anyone in the market for Hemp-Derived Cannabinoids like CBD, CBG, or CBN should only purchase those products from companies that have gone through the Authority’s™ strenuous testing procedures.
While these standards lead the industry, we are in a new market that requires flexibility to stay up-to-date with the latest best practices for the Hemp industry.
That is why the U.S. Hemp Authority™ updates their Guidelines Procedures annually to ensure all requirements fit where the industry currently stands, and to be malleable enough to satisfy any future requirements the Hemp industry may need.
Today we’re going to cover the changes that have happened from version 2.0 to 3.0, provide our opinion on these changes, and how you can be involved in this entire process.
Changes to the U.S. Hemp Authority Guidelines
The new 3.0 U.S. Hemp Authority™ Guideline Procedures is a much smaller document compared to its predecessor.
Overall, the document went from 80 pages to 20. This drastic change can be explained through elimination of repeating requirements in the version 2.0.
The 2.0 Guidelines contained a lot the same requirements for each stakeholder in the document, those being Hemp Growers, Hemp Processors/Manufacturers, and Hemp Brand Owners.
We previously outlined all of those requirements, which you can find here. But, in that previous document, we actually talked about how repetitive some of these requirements were, so to see some simplification to the new 3.0 Guidelines is very much welcomed to us.
Going forward we are going to break down a few of the changes for each one of the stakeholders in Hemp, but overall we’re very happy with the updated version.
The 3.0 Guideline Procedures is more concise, direct, and to the point, which we believe better speaks to a large portion of their target audience, which is Hemp farmers. If you’ve ever met people who work on a farm for a living, they tend to prefer a much more direct approach to business, and we believe the 3.0 Guideline Procedures takes that approach.
Additions to 3.0 U.S. Hemp Authority Guideline Glossary
In total, the glossary was reduced from 59 terms to only 39. A lot of the terms eliminated were due to the reduction in the total size of the document. When you’re reducing the document size by 80%, you’re going to have some unnecessary “fluff” terminology that will naturally be cut.
For example, in the 2.0 Guidelines, they list both the definition for just THC, and the definition of THCA, which is an acid precursor to THC. They also eliminated the definition of PPM (parts per million) and PPB (parts per billion). The cutting of these terms seem to just help make the document much more concise.
However, there were some notable eliminations from 2.0 to 3.0. The 3.0 Guidance Procedures cut the definition of CBD, Hemp Country of Origin, Industrial Hemp, Seed Source, and more.
It would be just speculation for us to interpret which terms were cut and why, but there were significant terms that are no longer defined by the U.S. Hemp Authority™ Certification Guidelines.
But, it wasn’t all cutting down on this part of the document. The U.S. Hemp Authority™ also added definitions of Confidence Level (chance a result will be reliable), Hemp Extract (mixture of constituents obtained from some or all of the aerial parts of hemp by using a solvent), and Retail (any product labeled for final consumer use).
The most notable added definition is Hemp Extract, which seems to be added as a better way for the U.S. Hemp Authority™ to define any cannabinoids extracted from Hemp. The previous document had several terms that were all similar to the new definition of Hemp Extract, just a little more confusing.
Hemp Grower Changes
A lot of the guidelines have stayed consistent, but there are a few notable changes that have been issued for the new Guidance Procedure set forth from the U.S. Hemp Authority™ .
As a general observation, there are a lot more rules that reference government agencies in the new format. A few examples for Hemp Growers include;
- Farm Service Agency (FSA) crop reporting
- USDA guidelines for the import of hemp seeds and hemp plants
- International Plant Nutrition Institute’s Grid Soil Testing
- This Standard does not mandate an additional requirement for THC testing at the Grower’s operation since U.S. regulations (7 CFR 990) already require such sampling and testing by an authorized government agent
These are not all of the government related requirements for Hemp Growers, and the full list can be found here. But, it’s a very encouraging sign to see more & more government involvement with the U.S. Hemp Authority™ Certification Program, and the Hemp industry as a whole.
For far too long the government, and especially the FDA, has taken a passive role in the regulation of Hemp-Derived Cannabinoids, leading to mislabeling, bad products, and outright bad companies in the Hemp space.
With more government involvement in our industry, consumer confidence can grow, giving more Americans a willingness to try any type of Hemp-Derived Cannabinoid product.
Hemp Processor and Manufacturer Changes
There are a ton of similar requirements going from 2.0 to 3.0 in the Guidance Procedures when it comes to requirements for Hemp Processors and Manufacturers. Some of these similarities include;
- The sourcing of suppliers is the same.
- Sanitation & Hygiene requirements are virtually the same, with the exception that you now must write down what product was used to clean something, who did it, when, and how. (This extra work certainly could be due to COVID-19)
- Must be compliant with FDA Good Manufacturing Processes
- Explicit testing of heavy metals, insecticides, and pesticides.
- Quality Control of the finished product has a lot of the same wording.
- Storage, Transportation, & Distribution of Hemp falls right in line with the 2.0 Guidelines as well.
While these are all the same, there have been a few notable changes for Hemp Processors/Manufacturers.
Obviously the Sanitation & Hygiene requirements have adjusted a bit, but so have the sampling procedures.
Section 5.4.1 reads as follows, “Processor/Manufacturers must implement sampling and testing plans for hemp and hemp derivatives in a manner that is statistically significant, yields a statistically representative sample for analysis and yields a result with a minimum confidence level of 95% sourcing of suppliers is the same,.”
Section 5.4.2 reads as follows, “Sampling procedures must retain enough of the sample to enable at least one repetition of the analysis in case questionable results are obtained”
We wanted to specifically highlight these two aspects of the sampling procedure as they have put an emphasis on being able to repeat a sample, and that the sampling must have a confidence level of 95% that the sourcing of suppliers is the same.
This emphasis means more accountability on all stakeholders in the process to ensure the Hemp is free of any harmful chemicals, and that the product will be under the federal legal limit of .3% THC. This addition could’ve happened in part because of the DEA ruling about what to do with “Hot Hemp”, that is Hemp that does fall about the .3% THC level.
However, for the most part, this section has stayed consistent with the previous 2.0 guidelines and still ensures that any Hemp Processor/Manufacturer that is certified by the U.S. Hemp Authority™ is held to the highest possible standards.
Hemp Brand Owner Changes
This section of the 3.0 Guidance Procedures follows most of what we’ve been talking about so far. Compared to the 2.0 Guidance Procedures, this section has become much more concise, but a lot of the requirements are still the same.
Things like product labeling, being in line with the FDA’s Food Labeling procedures, and making no misleading claims are all still present.
The labeling requirements are one of the most important aspects of the U.S. Hemp Authority™ Certification Program, and we didn’t expect to see much change on that front. There are so many CBD companies that make false claims on their labels, or misleading information, and it’s yet another reason why consumers should only purchase products that have been certified by the Authority™ .
One of the big reductions in the new version is the Record Retention section in the 2.0 Guidelines. Previously, there was an entire page, 12 sections, all dedicated to how Hemp Brand Owners must keep records.
Now, pretty much all requirements from the old version have been translated into two sentences in the 3.0 Guidelines, which reads; “Brand Owners must maintain records to demonstrate compliance with these Guidance Procedures and have them readily available to certification body personnel. Records must be retained for at least five (5) years, or longer if required by the authority having jurisdiction. Records must be stored in such a way that they remain legible and retrievable.”
This example really shows how the entire 3.0 Guidelines have just made things much more simple for everyone involved.
Submit Comments Now For 3.0 Guideline Procedures
There is currently an Open Public Comment period for the new 3.0 Guideline Procedures. The U.S. Hemp Authority™ allows for public comment so they can ensure the optimal procedures for everyone involved in Hemp.
All comments must be submitted by October 15th, 2020. You’ll need to fill out some general information about yourself, including what type of industry you’re from.
It’s a very easy form to use, but if there’s any questions you can direct them to USHAcert@foodchainid.com.
These restrictions & requirements for all 3 stakeholders in Hemp haven’t really changed, they’ve just been laid out in a much more straightforward manner. We’re really excited for these new Guidelines to become official, as they are still the most expansive, important, and relevant certification in the Hemp industry today, and they are simply getting better with time!
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