Harvesting Industrial Hemp Science - Cultivating Hemp Compliance

Your Louisiana Hemp Grower Need-To-Know matters and nitty-gritty regulatory compliance information with the down-and-dirty elements of powerful hemp science, seed to sale.

By PhD cultivation and your compliance consultancy - Dr. Matthew O. Indest PhD and Pat Jack

Successful hemp industry production is critically dependent upon the precise understanding of the “total THC” (t-THC) compliance of your flowering hemp plants -- seed to sale. The hemp grower’s constant struggle for mastery to understand Louisiana’s USDA-regulated hemp program as it pertains to compliant “total THC” levels is the bar for entry into the rapidly developing Louisiana industrial hemp markets.

Your compliance officer and your Chief of Cultivation must (or YOU must) maintain a level of masterful understanding of compliance enhancing Standard Operating Procedures (SOP) throughout every step in the execution of your hemp business model. This must be done consistently in a rapidly-changing regulatory environment. The rules and regulations of the industrial hemp industry place extreme, and often changing, demands on your business’s extended SOP, from seed to sale, from state to state, and from nation to nation.

Genetics (choosing the strain or strains of industrial hemp that you will grow) are the primary factor that will determine your industrial hemp crop’s t-THC compliance. The selection of the best strains for growing will also determine the richness of the CBD content in your finished crop, all while remaining legally compliant.

The ratio of CBD to t-THC, [THC + (THCA * 87.7%) ≤ .3%], varies from one industrial hemp strain to the next. The distinction between “THC compliant” and “t-THC compliant” must be absolutely, precisely understood to safely conduct the interstate trade of your hemp and hemp derived products.

The stability of your crop’s CBD to t-THC ratio within each seed lot is the biggest critical risk factor to a hemp grower. The genetic variance in commercialized hemp strains spells the difference between federally-compliant Industrial Hemp and a federally-illegal Schedule 1 drug. One “hot” flower in a field of 100 acres of hemp is ruinous.

Using clones instead of “feminized” seed will hedge some of the risks because clones are genetic replicas of the source mother. Thus, the variability from clones match that of the mother plants. Clones, also marketed as Unrooted Cuttings (URC) or, Liners and come at higher expense than feminized seed, but can be worth it. Assuming, ofcourse, that your vendor has verified those mother plants were not males. We’ll talk more about clones and balancing costs in future articles; keep checking “LA Hemp Growers” magazine for new content.

Our Louisiana hemp industry is in its infancy, and due diligence in strain selection for cultivation is critical and mandatory. Until true “certified variety” CBD rich and industrial hemp seed is available for sale in quantity, industrial hemp farmers and growers suffer great risk, civil and potentially criminal risk.

STRAINING TO PICK THE RIGHT HEMP STRAIN

Especially when growing from seed, the variability of current hemp strains introduces great risk, both civil and potentially criminal liabilities, into your operational equation. Your entire team, at all times, is tasked with maintaining regulatory compliance.

The propagules available for purchase (seeds, seedlings, and even cuttings) have the propensity to express wildly differing phenotypes because “Certified Varieties” of hemp are largely not yet available, and certainly not available in great abundance. It only takes one hot flower sample (t-THC non-compliant) in the crop testing inspector’s bag and you are done for.

This variability in current industrial hemp strains (better described as instability) could present as:

1.

Male plants polluting (pollinating and “seeding out”) your flowering female CBD and minor cannabinoid bearing crop.

2.

Visible differences in plant vigor and structure

3.

Dramatically different Days to Optimum Harvet Potential (DOHP) within a seed lot

4.

Most importantly, your crops final cannabinoid content (t-THC hot, or not, while maintaining CBD richness)

Have you selected the strain or strains to grow which have the greatest statistical probability of finishing as compliant hemp?

The consequences of variability in the phenotypic expression of what we see marketed as a stable variety of “feminized” hemp seed include a mountain of labor costs stacked upon losses from reduced plant count because the male plants must be pulled from the crop. You’ve got to find the males, and that’s hard work. If you fail to pull all the males (and hermaphrodites), your flower will be pollinated, your flower will fill with seed and will be worthless in the current markets. Even one, single grain of pollen can convince a plant to turn its focus away from producing cannabinoids and terpenes and suggest to the plant to prepare entirely for pollination and seed production. You can lose 40-50% or more of the potency of your crop when pollination occurs.

Non-uniform crop quality, and even the unexpected need to stagger harvests within a strain are also consequences of this variability within even the very same lot of seed, seed perhaps purported by the vendor to be a certified “variety”. Hemp strain variability can turn high expectations for lucrative marketability into a complete crop loss, the potential suspension of your license to grow, the extinguishing of your license, or worse.

Options and procedures are present to minimize your risks.

PROPAGULE COMPLIANCE DOCUMENTATION

When considering the purchase of genetics (seed and starter plant stock) the seller must offer documentation. Sometimes called a binder, a portfolio, or a “seed deck”. Seed seller or re-seller documentation should contain a full panel analysis or at least some battery or array of tests performed on the parent plant material. The seller must absolutely provide “Certificates of Analysis”, or COA. If you have to ask for the COA, that’s a red flag, walk away to the next salesman.

The hemp propagule’s parental stock documentation verifies the propagules come from t-THC compliant lineage. The Louisiana Department of Agriculture and Forestry, LDAF, demands that you prove the seed you are planning on buying and planting can meet their criteria for their stamp of approval. You must have the proper documentation from the seed seller or re-seller to prove to LDAF the strain can be grown resulting in “total THC” compliant material.

Getting your hands on high-quality photographs, or better yet, obtaining actual flower samples that represent the crop your seed will produce is a must for understanding the crop you will grow. Microscopic examination of flower samples can be very valuable, you must learn to read your flower. If the seller offers these extra bits of documentation and support, that’s a big plus in your due diligence. The bare minimum is COA; if that doesn’t come up front, that’s an issue that you should not be tasked with resolving.

QUALITY TESTING - LAB ANALYSIS

Quality testing (pre-harvest t-THC monitoring) testing in the field during the growing season differs from the regulatory tests required by LDAF. LDAF’s regulatory compliance testing starts your harvest timer; from that point on you have a 15-day window for your completed, mandated harvest. In order for you to meet any contract’s specifications in which you might be a party and to maximize your crop’s value, in-season (pre-harvest, in the field) testing is a necessary expense. Don’t roll the dice in the dirt as you are liable to be looking down into that cottonmouth.

Selecting your pre-harvest, or in-season testing lab should be done before you plant your crops. Establish a relationship with your preferred testing lab partner ASAP. What if they get too busy to do your testing? What’s their capacity, current client load, etcetera? How long have they been operating? What does their team look like? Don’t pick a lab willy-nilly; you must perform due diligence when selecting your lab and develop a strong relationship and work towards contractual agreements with your testing lab (or labs). Search google images section for the COA the lab produces, practice reading their lab reports and compare them to other labs.

Establish a reliable contact with the testing lab (the lab candidates) you choose. Your lab contact should be more than willing to work with you, continually discussing the compliance issues that surround the proper sampling and testing methods required for your industrial hemp material. Hemp rules, regulations and compliance demands change frequently, not only in Louisiana but in all states, especially in this 2014 Farm Bill, “USDA interim rules legacy sunset” year. Compliance demands change at the state levels as well, across all states.

Your testing lab’s contact person should be able to easily interpret and explain the data their lab generates - the data for which you pay. Be aware of your testing needs pre-planting so you can look for package deals with your lab of choice. Ask yourself questions such as: How many different strains will you be growing, how many different fields, greenhouses or indoor grow sites are you operating during the growing season, and then multiply those by four or five at the very least. For instance, you could make a deal for five tests over a period of the last five weeks of flowering. You can get a discount with a package deal and further secure your business relationship with your lab for the next crop, the next field, or lot, or the second and third strains you are already staggering. Dr. Matthew Indest PhD understands this process and has studied it in depth. Along with compliance analysis from his colleague Pat Jack, your statistical probability of avoiding jeopardy is increased dramatically.

HARVEST AND POST HARVEST PROCESSING

Among the final considerations for growers must be their ability to manage the harvesting of their crop and the post-harvest processing of their crop. For example, knocking trichomes off your flower is like dropping dimes and quarters slowly through a grate in the floor with every post-harvest step.CAnnabinoids are produced by trichomes growing on your flowers and some types of leaves. Mechanical harvest options exist but can severely impact crop quality, thus the value of your crop. Hand-labor is expensive but preserves harvest quality.

Scaling your harvest operation appropriately to your planting acreage will determine your ability to harvest the fruit of your season-long hard work. If you are planting 100 acres, your scale might be such that some mechanical harvesting options are required as sourcing that kind of hand labor is not fiscally prudent. At that scale you can handle some trichome loss and degradation. If you are growing 10 acres, hand labor can increase the value of your final harvest quality and provide for ROI+ on hand-labor.

Across all industrial hemp growing states, many or a few growers and farmers have seen as much as 50% of their acreage go unharvested due largely to being poorly prepared for the scale of their crop’s potential labor demands. Getting the crop in is a big concern, doing it while preserving the quality of your crop is an even bigger concern.

Staggering your harvest by planting some strains that flower earlier than others is a strategy that requires even more research and due diligence into growing multiple strains, or genetics. Planting dates can be staggered as well. You can stagger both ends of your stand as each genetic may require both different planting times, and different harvest times. The planning and budgeting of your labor force must be approached with just as much concern as any of your SOP in your operation.

LOUISIANA HEMP AND LOUISIANA AGRICULTURE

Louisiana is known for its diversity, culturally and environmentally. This has required our agriculturalists, farmers and growers in Louisiana to adapt and adapt often as any new issues and potentials, especially in the budding industrial hemp market-- can and will crop up. Cannabis (yes, industrial hemp is cannabis) like any agricultural commodity or horticultural crop, has a unique science and art that increases your statistical probability of completing successful hemp production operations. Research into the agronomic, genetic, pest and pathogenic factors that affect industrial hemp cultivation is just beginning in Louisiana, and this is hard work, a challenge within which our agricultural community thrives. We can get the work done, and there is more help than you would expect for this new crop available from many different sources, at many different levels.

We can lean on the data from other states and their universities to guide this first industrial hemp crop year, and we might best temper our expectations with a realistic outlook for our profit margins. The current price of biomass should be written on the back of your hand in grease pencil, every day. The math equation to compute the value of your crop based on CBD content should be written on your palm in red magic marker.

Louisiana presents unique climates, photoperiods, pests, and major, challenging factors in crop production. The strains of hemp available from the current crop of seed and propagule providers has never been grown in Louisiana. To an unusually large extent we do not know what challenges these factors present for our hemp growing operations in Louisiana.

Research into the factors we will face that become challenges while growing industrial hemp in Louisiana (trial and test growing, which is risky and expensive but necessary) and research on the plant growing in Louisiana must be done. If little or no research is done at the same levels as some other states, Louisiana farms will be flying blind, relying on trial and error and anecdotal practices. That is both risky and dangerous.

A lack of research burdens our Louisiana farmers with unfair risk, the grower and the farmer should not be faced with this type of risk. Unfortunately, you will be in this first year and perhaps the second year of growing industrial hemp in Louisiana. We can rise above that, and we must, in order to catch up to a market where we have been given a starting position well behind the pack of other hemp growing states.

Collaboration and effective team building are two of the biggest keys to success in our new, Louisiana hemp industry. As individuals, Dr. Matthew Indest PhD and Pat Jack were overwhelmed by the quality and quantity of information available for the entrants and stakeholders in the hemp industry. After introductions at the June 2019 MJBizCon in New Orleans, business cards were exchanged, and they quickly got to work!

MOI Consulting LLC and CBD RICH LOUISIANA LLC have never looked back and see tremendous promise for our new Louisiana industrial hemp industry.

Identifying valuable synergies and business to business opportunities within and around the industrial hemp industries is necessary to increase your chances of finding lasting success in the hemp play. From growing hemp to the sale of hemp derived products over the retail counter, from seed to sale, your team is the most important factor in your success. No one knows all of the issues that face the growers and farmers, seed and genetics breeders, and processors and transporters of industrial hemp, those that will take the risks to pioneer the industrial hemp industry here in Louisiana.

Surround yourself with flexible, open-minded, and adaptable teammates who are hungry to learn. Sure, apply the agronomic skills you have developed and leverage your farm’s previous crop experiences. But also keep your ears to the ground and be prepared for inevitable challenges and events while growing industrial hemp in Louisiana.

The key process is developing an offensive and a defensive business strategy that mitigates risk and continually increases the probability of success. Gathering the right core team around you early will give growers the edge to stay competitive, sustainable, and successful as they add value to their team year over year, from crop to crop. Our Louisiana hemp market begins in earnest as the actual growing of hemp in Louisiana commences this year, in 2020; team Hemp Louisiana, yes, that will be a real thing. Our team’s resources will be added to team hemp Louisiana.

Our work at MOI Consulting LLC and CBD RICH LOUISIANA LLC for the past two years involves the constant sifting through the wealth of data trickling in from many different sources (chiefly data generated by hemp industry activities in the states that started growing hemp as long as five years ago). We work directly with the hemp industry data available to determine its credibility and to uncover the hidden gems that mark the trail of successes other growers and hemp industry professionals have enjoyed across the U.S..

Meta-data analysis of our successors across the U.S. (and internationally) gives us an opportunity to serve the hardworking people of Louisiana. We will assist our business connections and clients with the successful navigation through the hemp industry verticals. From seed all the way up, down, sideways or crossways through the nascent hemp industry business sectors, “the verticals” (all of which are developing rapidly) we stand ready to perform with strength in the Louisiana hemp industry.

Industrial hemp offers Louisiana an incredibly diverse set of opportunities and challenges for the larger workforces in agriculture, research, medicine, health and wellness, and law enforcement. You, as a grower of hemp and as an operator in the hemp industry (at whatever additional levels) you are entering a very diverse and far reaching new business model with nearly unbelievable opportunities, including heretofore hidden opportunities we are just beginning to understand at this point in time.

With decades of cannabis and hemp stigma ingrained in the fabric of our society, industrial hemp growers are stepping into the clearing. Embracing our new hemp industries and acting decisively to enjoy the value that hemp offers our state’s people and industries is the path forward, a path that needs to be cleared and trod down. MOI Consulting LLC and CBD RICH LOUISIANA LLC always keep their tools sharp. We can clear trails.

From the Greater New Orleans area and Louisiana coastal regions to the recently tornado- ravaged northern extents of our state we love, we regularly survive the threats of hell and high-water, year-after-year. Louisianians constantly work to preserve our values of family, hospitality, tradition, community, freedom, faith, and forgiveness. We can handle hemp, and do well in these new industries.

We are proud to be Americans in both difficult and in prosperous times. Challenges are opportunities for success. Geaux Tigers and God bless hemp. Let’s clear some trail together.

CONTACT INFO

Dr. Matthew O. Indest, Ph.D. Licensed Hemp Grower, Horticultural Scientist: Plant Breeding MOI Consulting LLC moiconsultingllc@gmail.com https://www.linkedin.com/in/matthewoindest/

Pat Jack Industrial Hemp compliance, process, market analysis, hemp derived wholesale and retail. CBD RICH LOUISIANA LLC cbdrichlouisiana@gmail.com Linkedin: https://www.linkedin.com/in/patrickjack/

Disclaimer: The authors of this article are not attorneys and do not hold themselves out as such. This article is for general business information purposes and is not intended to be and should not be taken as legal advice.