Page 111 - Daggabay Magazine Issue 9

Fields of Green for ALL • Collectively Reforming South African Cannabis Laws

expressions, and/or specific genetic resources. considered in terms of existing regulations in
The potential for Legacy Hubs to add value existing applicable sectors (Agriculture, Food
and protect rights is dependent on various Safety, Environmental Safety, etc). However, issues
factors within Indigenous Knowledge Systems of safety and quality control must be balanced
legislation already in place. Legacy Hubs are by the fact that South Africans have been using
organised according to democratic and inclusive Cannabis for hundreds of years with very few
participation at the decision-making level. quality measures in place – other than the
Their Board is representative of all the activities discernment of the user – and with very limited
affiliated to the Hub, plus 1 person of authority harm to the user.
(to safeguard the ethics of the Hub, i.e. legal
professional) and 1 administrator. Cannabis is a safe relaxant and prohibition comes
from a place of fear. Members of the legislature
who will be drafting the regulations must bear
in mind the evidence on record from The Trial of
5.2.1.1 Registration Of New Hubs the Plant as to the overall safety of the plant. This
is why clear guidelines for quality control should
A minimum of 5 persons (individual be outlined and agreed to by experts and users
entrepreneurs or companies) would be required
to register a new Hub. Individuals or companies alike, and what follows is simply one out of many
that wish to set up a Hub must register it as a possible options for quality control.
non-profit company, draft up a Hubs business In this model of regulations, Hubs are in charge of
plan, and obtain registration from the Office of identifying any components or residuals that may
the Cannabis OmBUDsman, after which they can be unwanted in the finished products (pesticides,
start to operate. The only reason for the Office to herbicides, fungicides, preservatives, fungi,
refuse registration is the failure of the applicant to mould, residual hydrocarbons, contamination
present a Hub Business Plan that complies with by chemicals or any other potentially harmful
the 6 mandatory services, or the non-registration contaminants). A set of minimum standards
as a non-profit entity. The OmBUDsman keeps a that could be applied by the Hubs for product
list and records of all Hubs. It is desirable to the analysis, and could be established on the basis
authors of this document that Hubs report to the of the “Quality control minimum regulatory
OmBUDsman, but it might be that they report requirements for the registration of traditional
directly to a yet unestablished / to be determined medicines” . Quality control can be in-house at
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government body. the Hub or outsourced to a private company.

Quality control measures are of utmost
importance and must be the first priority when
5.2.1.2 Mandatory Services setting up new systems. These measures must
be accessible to all cultivators and traders and
1. Affiliation To The Hub be provided at little or no cost or included in the
Hubs must record annual affiliation of growers, Hubs fee package.
retailers and distributors. Although the
International Drug Control Conventions only A person who uses Cannabis can decide to use a
require licences for medicinal cultivation, the product that has less qualitative information or
annual affiliation certificate could be the de facto labelling, at his/her own risk. Untested, unlabelled
licence, a record of compliance for all Cannabis Cannabis should remain legal for Kasinomics,
businesses. In addition, it is suggested that the but cultivators and traders need to be educated
Hub certificate of affiliation also serves as the de on the advantages of producing a quality-tested
facto business registration for Kasinomics. product. We live in the age of technology and
experts and entrepreneurs in this field must be
encouraged to use their expertise to further the
2. Quality Control & Basic Product analysis effectiveness of “seed-to-sale” quality-control
Regulation of Cannabis and Cannabis products measures that are accessible to all.
intended for human use will need to be

CANNABIS IN SOUTH AFRICA • THE PEOPLE’S PLANT • A Full-Spectrum Manifesto For Policy Reform 67