Thank you for giving the public this opportunity to give the department feedback on this highly important topic of consumable hemp in the state of Texas. This will provide everyone the opportunity to suggest how we move forward in a way that keeps consumers safe and informed, producers making an incredible and safe product, and most importantly keep Texas as the number one state in addressing environmental issues as it is imperative that we do everything in our power to ensure that our future generations have a safe and clean place to call their home. Cannabis is the biggest key that this state has been given in succeeding with that.
- We need to address not only massive commercial and corporate grow operations, but home-grow and small business grow operations. Both should be allowed as long as they fall within the language of HB 1325. Participants of both types of operations need to have equal access to the benefits of this plant as that creates the fairest market system and benefit for the public. This would also mean that fees need to be kept reasonable according to the size of the operation. We cannot expect the local small business to pay a price that only a massive corporation can pay.
- That would bring up the requirement of other laws passed this session to include SB 572 regarding Cottage Food Laws. As the bill now allows dehydrated fruits and vegetables including dried beans and dried herbs or herb mixes, and HB 1325 says that consumable hemp can be a food product. Hemp would definitely fall into this category and needs to be codified as such to eliminate any confusion on the topic.
- With this in mind as an item of consumption expected to be consumed en masse, we need to ensure that credible 3rd party testing is allowed, and can take place before state testing of hemp to ensure that products meet already established farm bill and state guidelines. This allows a much smoother and efficient process for both the producer and the state, saving taxpayers massive amounts of money.
- With testing we need to also make sure we have code which will hold manufacturers accountable for products that are falsely labeled. An example would be that products that are labeled as THC free, must be absolutely THC free as this can cause massive issues for the consumer, especially in drug testing as THC can accumulate in the body and start to give positive test results.
- The public also needs code to protect employees and families involved in drug testing scenarios. These scenarios would be where a doctor has prescribed or has given a written recommendation for hemp in the same manner as one would prescribe melatonin, vitamins, or even OTC allergy medication and cough syrup. The public is going to be allowed to consume any product with 0.3% THC or lower and even that is enough to provide a positive test result. Citizens that are operating within the law should at no point be treated in a drug test as if they are a criminal.
Yet again, thank you for your time, and I wish the best of luck to those in the industry.