Page 112 - Daggabay Magazine Issue 9

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

TIMELINE TO INTEGRATE KASINOMIC SECTOR INTO REGULATIONS

To facilitate a smooth, inclusive, incremental enhancement of South African quality standards, the following timeline is
proposed for the implementation of minimal requirements for Kasinomics growers. This schedule should be regularly
monitored and adjusted by the Office of the Cannabis OmBUDsman. Existing regulatory protocols (ERPs) apply to all
• other non-Kasinomic businesses in the Cannabis supply chain.
KASINOMICS ERP (EXISTING REGULATORY PROTOCOL)

year • Qualitative and quantitative • Qualitative and quantitative composition (at least the 5 main cannabinoids)
• microbiological and chemical tests
0 composition (at least the
3 main cannabinoids) • Foreign added matter
• Total ash, acid-insoluble ash and sulphated ash
• Pesticide residues
year • Water-soluble extractive
+1 • Heavy metals • alcohol-soluble extractive
• Foreign organic matter
• loss on drying
year • swelling index
+3 • soil and water analysis • Pesticide residues
• Heavy metals
• Radioactive residues
year • soil and water analysis
+5 • all other tests. • Other purity tests

Hubs could either undertake these analyses the records of cultivation provided by the growers
directly or sub-contract the product analysis to and the results of quality testing. In the case of
an external entity. In all cases, good laboratory any Cannabis product, labels and / or labelling
practices must be followed by the testing facility. guidelines provided by Hubs should reflect all or
Hubs should appoint laboratory services who part of the following information, as applicable:
are registered with the Office of the Cannabis • Name of the product (as provided by the
OmBUDsman and/or the existing regulatory body grower);
for laboratories.
• Name of the plant chemovar (or
“cultivar”/”strain”);
3. Packaging & labelling • Specifications of quality of the product (i.e.
Correct labelling of all consumable Cannabis grown using organic agricultural techniques
products is essential. Various degrees of disclosure etc.);
would apply to the respective contents and safe • Quantitative list of cannabinoids (at least the
use of products. These may vary depending on the three main cannabinoids);
regulatory requirements of the intended use of the
products, such as labelling of food products with • Absence of contaminants.
their nutritional content and adult-use products For Kasinomics products not subject to strict
with their active cannabinoid content. Adult-use quality control, a disclaimer underlining the
products will need to be packaged in a manner common law doctrine of Volenti non fit injuria –
9
that discourages use by minors. “to a willing person, injury is not done” – is
All sections of the value chain should strive for essential.
biodegradable, environmentally friendly packaging In the case of manufactured products, the Hubs
while still ensuring that packaging is smell proof should also include the following information:
and that the product stays fresh. Incentives should
be developed for Kasinomics retailers to use non- • Quantity and type of “carrier” or other added
plastic packaging, as it is usually more expensive ingredients;
and horrible for environmental sustainability. • Description of the process of manufacture
(and solvent used, if any);
Hubs are responsible for the labelling of wholesale • Prevention message or suggested dosage
products and the provision of guidelines for the (if appropriate);
labeling of retail products. These are based on
• Specific warnings, or contraindications.

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