[ALLAN HANDROW]

USDA hemp regulations
THC limit
.3% equals Delta 9 THC +( THCA X .877)
Too restrictive
.3% Delta 9 was an arbitrary amount
Small and Cronquist .1976
Small, Ernest and Arthur Cronquist 1976
Practical and Natural Taxonomy for Cannabis
Taxon 25: 4 (405 – 35)
Recommend delta-9 THC limit of . 3%
A separate THC limit of .65%
Disciplinary action limit of 1%
This is to promote and enhance terpene production
Terpenes are highly beneficial as well as allowing maximum Aroma and flavor
USDA proposed limits could potentially reduce hemp quality by 50%
Sample testing
Proposed procedure is highly discriminative and inaccurate
Skewed toward the most potent parts of the plant
CBD /THC content varies widely from top to bottom of plants and from flowers, leaves, and stems
I propose a broader sample method to achieve a more accurate sampling of what exists in the plant
This accomplishes a better average of the variations of cannabinoids existing within the plant
I suggest a 2-inch sample of the tips, from top ,middle ,and bottom branches
Each sample should use all of the parts leaves, stems, and flowers
This will provide a more accurate test result
Harvest period
A 15-day Harvest window following testing is too short most state agencies don’t have enough resources to complete this requirement it will restrict the quality of the final product
I believe these recommendations to be the fairest way to achieve a stable and fair market system who’s the best possible crop
It is my greatest hope that you will give this serious consideration
Thank you
Al Handrow A&M QUALITY CBD PRODUCTS

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