The NY & Hudson Valley Cannabis Industry Association(s) Present Their Policy Paper On Regulation Of Hemp Cannabinoid Products

January 14, 2021 Presented by the Joint Committee On Hemp:

Led by Joy Beckerman Authors/Contributors: Joy Beckerman and members Kymberly Byrnes, Arlene Colangelo, Craig Delsack, Ruben Lindo, Michael McGuire, Deborah Miran, Shellise Rogers, Bruce Sterman and Douglas Trokie, and Regulatory Committee Chairs Sheri L. Tarr and James Landau

This a detailed 20 pp proposal for policy – Here are the 11 proposal headlines


Here is the introduction

Executive Summary The New York City Cannabis Industry Association (NYCCIA) and Hudson Valley Cannabis Industry Association (HVCIA) endorse and submit for your consideration this Report of their Joint Regulatory Committee and Hemp Subcommittee, which strongly supports the responsible expansion and regulatory advancement of the burgeoning Hemp Industry in the Empire State.

In addition to endorsing and promoting the policy statements and suggestions interposed by the U.S. Hemp Roundtable, many of which are reproduced verbatim herein, this Report also makes the following eleven distinct proposals which we submit would vastly improve the regulatory scheme, and better enhance the goals of public safety and consumer education and protection measures that are the hallmarks of New York’s high-quality hemp cannabinoid program:

I. Revising the definitions of essential terms under Proposed Regulation 1005.1 to better reflect the common vernacular and parlance of the hemp cannabinoid industry and the public understanding and usage of those terms.
II. Redrafting the labeling information requirements set forth in Proposed Regulation 1005.3 regarding the origins and processing of a product to bring them in line with FDA standards for providing essential information to consumers on the label of products.
III. Overhauling Proposed Regulation 1005.8 to align it with other states which allow for the production and sale of smokable hemp products, transdermal patches, suppositories, and inhaler modalities of hemp cannabinoid usage.
IV. Streamlining Proposed Regulation 1005.9 to create greater informational efficiency in product labeling by obviating duplicative messaging of FDA-mandated information by means of similar state specific labels. Not only will this avoid consumer confusion about nutritional information, but it will also avert the inclusion oflabeling data which is actually preempted from inclusion by the federal Food, Drug & Cosmetic Act.
V. Transforming Proposed Regulation 1005.10 by adoption of the Report’s specific testing recommendations to improve the laboratory process by providing Guidances rather than Rules to provide greater flexibility in promptly updating procedures to reflect best practices and present scientific thinking in the hemp cannabinoid industry.
VI. Significantly amending Proposed Regulation 1005 .11 to advance public safety concerns in the retail sale of hemp cannabinoid products without causing a chilling effect upon sales by requiring separate displays and safeguards not required of other health, wellness, or natural nutrition products. 
VII. The inclusion of additional terms and definitions to Proposed Regulation 1005 .1.
VIII. Improving Proposed Regulation 1005.7 to better conform with federal law and current Good Manufacturing Practices without imposing additional record keeping requirements.
IX. Raising the maximum milligrams per serving and total package milligram cap by revising Proposed Regulation 1005.8.
X. Altering Proposed Regulation 1005.9 to permit greater information provision by QR Code and providing greater specificity to the attractivity concerns of packaging to enhance the safety of consumers under the age of 18 years old.
XI. Modifying the “contaminate” testing and disclosure requirements under Proposed Regulation 1005.10. By heeding and incorporating the recommendations of the U.S. Hemp Roundtable and the distinct proposals of the NYCCIA and HVCIA Joint Committee set forth in this comprehensive Report, New York will continue to become a national leader in Hemp Cannabinoid product safety and consumer protection.




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