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Attn.: Jean Peart
Re: Industrial Hemp Regulations
Feb. 3, 1998
Dear Ms. Peart,
I am writing on behalf of Natural Hemphasis and the Six Nations Economic Development Commission in response to Health Canada’s proposed industrial hemp regulations. Following are the issues which to us seem most critical:
OECD Seed Varieties:
As was discussed in considerable detail, restricting the seed varieties eligible for importation and cultivation to only those which appear on the OECD list is a major hurdle to the initial stages of development of a Canadian industrial hemp industry. In particular, it is necessary that Canadian farmers have access to varieties which are suitable for both grain and fibre production.
OECD varieties are in very short supply internationally, they tend to favor fibre producing strains, and if you can get them, they are very expensive. As a result, we favor the recommendation that "as an interim measure, varieties not on the OECD list which have been grown in Canada under research permits be considered as approved in 1998-1999 for commercial cultivation."
In addition, we also believe that it would be in the best interest of this re-emerging industry that amendment to the definition of ‘approved cultivars’ be made to include "varieties eligible for certification in Canada, as approved by the Canadian Seed Growers Association." The sooner we can establish Canadian sources of Canadian adapted and grown seed, the greater the chance this industry will succeed.
Industrial Hemp Derivatives:
Section 2(2) of the proposed regulations which states that "these regulations do not apply to a derivative of industrial hemp [seed/grain] or a product made from a derivative, if the derivative contains less that 10 mg/g THC" is limiting to the hemp oil seed business, and seems an arbitrary measurement. We feel that a tested maximum allowable THC content is appropriate, but that 10 mg/g is too low, and threatens the viability of this industry.
We support the proposed amendment that this level be raised to 50 mg/g. At this level, we understand, there is virtually no risk of detection by drug tests which seems to be the primary concern of Health Canada (there is certainly no chance of any psychoactive effects at this level), and this is a level which is realistically achievable using standard seed cleaning processes.
Furthermore, we feel it is important to ensure that from every batch of grain that has undergone the same cleaning process, only one test of the derivative oil or cake should suffice. Our concern is that the grain, because of its short shelf life, will have to be pressed in small batches, as demand requires. If each of these batches had to be tested separately, the time and costs involved would be absolutely prohibitive.
Overall, our chief concerns are that the regulations are implemented in such a way as to minimize the cost of application and compliance. If hemp is to compete successfully with other Canadian crops, it cannot be over burdened with red tape and excessive regulations costs. As Health Canada will be introducing cost recovery measures in the near future, it is essential that these regulations be as simple and streamlined as possible. Too many amendments focused on such cost reducing measures were introduced during the workshop to be listed here. We only ask that you consider these carefully and with the best interests of a fledgling industry in mind.
Kind Regards,
David Marcus
NATURAL HEMPHASIS