Justin Feldstein
Agrothreats to the Budding U.S.
Cannabis Industry
Overview
• New industry
• Conflict of law
• Many forms
• Agrocrime
• Agroterrorism
• Plant Disease
• California
• Colorado...
Market Background
• Newest “official” agriculture market. By 2016, will reach
$9B
• In the 1980s, it was estimated the dom...
Legal Background
• The State of California under proposition 215 and SB
420 allows “medical” marijuana and home grow
• Not...
Implications of Law on Cannabis
Agriculture
• Declared as Schedule I Drug, No federal funds can be
used to develop robust ...
Threats: Agrocrime
• Adulteration: “bulk up” weight to increase
selling price. Use lead or beads.
• NEJM Leipzig Germany l...
Threats: Agroterrorism
• In 2011, the entire 400 million base-pair genomic
sequence of Cannabis Sativa was published onlin...
Threats: Plant Disease
• For commercial Ag. Sector, strict guidelines govern the use of
pesticides, no such legislation ex...
Gray Mold and Blight
Case Study: California
• California Proposition 215; enacted, on November 5, 1996
• established MMJ program, allowed culti...
Case Study: California
• California Senate Bill 420
– clarified Prop 215
• "require[s] the Attorney General to develop and...
Implications in California
• relatively liberal use of marijuana as implemented
• no mention of agro safety or defense
– h...
Case Study: Colorado
• Colorado Department of Revenue, Marijuana Enforcement
Division, 1 CCR 212-2 Very strict guidelines ...
Case Study: Colorado
• Inventory Tracking
– MITS
– May only sell product from licensed manufacture
• Testing
– Business mu...
Case Study: Colorado
Must be stored away from chemicals
Packaging and labeling standards
Must test samples for:
• Mold, mi...
MITS Tracking System
Colorado Legislation Analysis
• Strengths:
– Very tightly controlled
– Prevents gray and black market product from enterin...
Program Audit
Feb 2013 audit in Colorado found: Budgets kept MITS from
working fully
• Do we need “micro-level” control si...
Discussion
• Clearly, Colorado is better shape than California
• California is highly susceptible to contaminated crop
• T...
Solution
The only way to ensure safe and protected product is using a
“top-down” approach
– Must be removed from Schedule ...
Solution
• Not all bad
– Clean Green Certified in California: Organic certification
– Emerging reactive legislation about ...
References
Busse, F., Omidi, L., Leichtle, A., Windgassen, M., Kluge, E., & Stumvoll, M. (2008). Lead poisoning
due to adu...
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Agroterrorism and Agro Crime to United States Cannabis Industry

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Agroterrorism and Agro Crime to United States Cannabis Industry. Discusses agrothreats from crime to terrorism to the US Cannabis Industry. Offers solutions to legislation to ensure cannabis is safe.

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  • Potential to reach levels of tobacco and alcohol, perhaps more?
    Hemp: Hemp was first cash crop grown in the colonies
    Used extensively as rope and paper
    Textiles, food, building supplies, fuel
    Used to clarify soil at Chernobyl
  • That being said, agroterrorism is unlikely at this point, maybe once population relies more on the crop
  • That being said, agroterrorism is unlikely at this point, maybe once population relies more on the crop
  • Explain Collectives
  • Paid 1.1 million but could close with aoth 400k
  • Voters have already decided it should be used recreationally
    Will create inconsistent market
    Have to go to CVS in DC, but buy at 7-11 in Colorado
    How could we regulate this?
  • Some updates in the last two weeks:
    Attorney General Eric Holder states he would be willing with the Obama to reschedule Cannabis
    Legislation introduced in CO to improve personnel reliability
  • Agroterrorism and Agro Crime to United States Cannabis Industry

    1. 1. Justin Feldstein Agrothreats to the Budding U.S. Cannabis Industry
    2. 2. Overview • New industry • Conflict of law • Many forms • Agrocrime • Agroterrorism • Plant Disease • California • Colorado • Connecticut • Unscheduled Drug • Federal Oversight • Top-down Approach • Will it work? • Other Solutions • Questions ProblemsBackground Case Studies Solutions Discussion
    3. 3. Market Background • Newest “official” agriculture market. By 2016, will reach $9B • In the 1980s, it was estimated the domestic production was $32B. In 2000s, 36B, 50% greater than corn, the next largest cash crop • Since 2006, 20 states and DC have passed laws allowing smoked marijuana to be used medicinally • Not just medical and recreational use: Hemp
    4. 4. Legal Background • The State of California under proposition 215 and SB 420 allows “medical” marijuana and home grow • Notoriously easy to obtain ID card, essentially legalizing recreational marijuana • In conflict, Federal Government asserts that marijuana is not a medicine and SCOTUS held that federal government can restrict marijuana unconditionally • Harsh criminal prosecution and fines
    5. 5. Implications of Law on Cannabis Agriculture • Declared as Schedule I Drug, No federal funds can be used to develop robust systems • No ARS, APHIS, FDA, USDA • This creates a “free-for-all”, leaving regulation to the states • Unique position not seen in any other ag. sector • Allows extreme flexibility at the state level, but is this good or bad?
    6. 6. Threats: Agrocrime • Adulteration: “bulk up” weight to increase selling price. Use lead or beads. • NEJM Leipzig Germany lead poisoning in 29 patients from adulterated black market marijuana • Salmonellosis: NEJM cites multi-state (Massachusetts to California) outbreak in early 1980s, 85 cases • Questions: how often does adulteration occur? Accidental or purposeful? At what point in production did adulteration occur?
    7. 7. Threats: Agroterrorism • In 2011, the entire 400 million base-pair genomic sequence of Cannabis Sativa was published online • Allows continued research to the medicinal effects of Tetrahydrocannabinol and Cannabanoids • Could place THC production in anything • Could create mutant strain • Similar to H7N9 controversy
    8. 8. Threats: Plant Disease • For commercial Ag. Sector, strict guidelines govern the use of pesticides, no such legislation exists for the cannabis industry • Little research on pesticides and the cannabis plant, especially a substance that is smoked and not eaten • Fungi: 88 species affect cannabis: Gray Mold and Hemp Canker, leaf spot • Nematodes: roundworm • Parasitic Plants • Viruses: Hemp Streak Virus • Bacteria: Bacterial Blight • Plagues and Pests: Lice, Wasps, Flies
    9. 9. Gray Mold and Blight
    10. 10. Case Study: California • California Proposition 215; enacted, on November 5, 1996 • established MMJ program, allowed cultivation of marijuana • established collective and cooperative distribution – qualified patients and caregivers may possess 8 ounces of dried marijuana – maintain 6 mature or 12 immature marijuana plants – local governments may allow patients or caregivers to exceed these levels
    11. 11. Case Study: California • California Senate Bill 420 – clarified Prop 215 • "require[s] the Attorney General to develop and adopt guidelines to ensure the security and nondiversion of marijuana grown for medical use" • allows counties to increase plant number
    12. 12. Implications in California • relatively liberal use of marijuana as implemented • no mention of agro safety or defense – high risk of contamination, agrocrime – No testing requirements • Permits establishment of collectives – Collectives purchase from members – No tracking of plants of “seed to sale” • “Wild west of weed”
    13. 13. Case Study: Colorado • Colorado Department of Revenue, Marijuana Enforcement Division, 1 CCR 212-2 Very strict guidelines on the retail, licensing, cultivation, facility requirements • Facility Guidelines: – Established limited access area with credentialing to visitors, ID Check, Visitor Log – Building plans must be approved by state – Separates medical and recreational marijuana – Surveillance and alarm system requirements with redundancy • Direct positioning of cameras – Physical security, locks, fences
    14. 14. Case Study: Colorado • Inventory Tracking – MITS – May only sell product from licensed manufacture • Testing – Business must provide samples for testing • Personnel – No consumption on the premises
    15. 15. Case Study: Colorado Must be stored away from chemicals Packaging and labeling standards Must test samples for: • Mold, mildew, filth • Microbial • Herbicides, pesticides, fungicides • Harmful chemicals • Solvents, poisons, toxins Testing labs are separate and have own regulations • Outlines exact testing procedure • Educational requirements of lab director and technicians
    16. 16. MITS Tracking System
    17. 17. Colorado Legislation Analysis • Strengths: – Very tightly controlled – Prevents gray and black market product from entering legitimate market – Ensures marijuana is free of contaminants at the point of testing • Weaknesses: (Production, Distribution, Retail) – Potential for insider threat still exists • No regulation on training and vetting of dispensary staff • Creation of higher demand in illegal market due to high operating cost, Purchase limit counterproductive – “gray market” of caregiving growing, becoming illegal commercial operations
    18. 18. Program Audit Feb 2013 audit in Colorado found: Budgets kept MITS from working fully • Do we need “micro-level” control since growing rec cannabis is allowed under amendment 64? • 40% of business applications have not be vetted or approved • 13 of 35 applications that were approved contained “potentially disqualifying information” • licenses issued prior to results of criminal background check – Past arrest, felony robbery and menacing with a deadly weapon
    19. 19. Discussion • Clearly, Colorado is better shape than California • California is highly susceptible to contaminated crop • This will be consistent theme under current Federal Regs.
    20. 20. Solution The only way to ensure safe and protected product is using a “top-down” approach – Must be removed from Schedule I list – Must be regulated like alcohol (w/ personal cultivation limits, selling restrictions) • Alcohol model works • FDA and USDA oversight • Will ensure legislation is consistent and effective – Categorizing it as a “Drug Store” drug won’t be effective Look beyond the US, Uruguay Federal Crop, DNA Tracked
    21. 21. Solution • Not all bad – Clean Green Certified in California: Organic certification – Emerging reactive legislation about personnel in Colorado • Legislation that is put into place must be followed through on, a federal specialty, checks and balances
    22. 22. References Busse, F., Omidi, L., Leichtle, A., Windgassen, M., Kluge, E., & Stumvoll, M. (2008). Lead poisoning due to adulterated marijuana. N Engl J Med, 358(15), 1641-1642. doi:10.1056/NEJMc0707784 Chaboya-Hembree, J. (2012). Diseases of cannabis. Retrieved March 23, 2014, from http://medicalmarijuana.com/experts/expert/title.cfm?artID=727 DRAFT permanent rules related to the Colorado retail marijuana code, R 100 (2013). Decorte, T., Potter, G. W., & Bouchard, M. (2011). World wide weed: Global trends in cannabis cultivation and its control Ashgate Publishing, Ltd. Gorski, E. (2013, ). Audit: Serious flaws in Colorado's regulation of medical marijuana. Denver Post Office of National Drug Control Policy. (2013). Marijuana resource center: State laws related to marijuana. Retrieved March 23, 2014, from http://www.whitehouse.gov/ondcp/state-laws-related-to- marijuana Compassionate use act of 1996, (1996). Russo MD, E. (2012). Cannabis genome uncloaked. Retrieved March 23, 2014, from http://www.icrs.co/content/Cannabis_Genome_Uncloaked.pdf Small, E., & Marcus, D. (2002). Hemp: A new crop with new uses for north america. Trends in New Crops and New Uses, , 284-326. California senate bill 420 "Medical marijuana program act", 11362.7 (2003).
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