Page 125 - Daggabay Magazine Issue 9
P. 125

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



            5.4.2 Distinguishing Products                    5.4.3  Enforcing Policies


            Thresholds to distinguish a “hemp-type”          To increase the harmonisation of NPP Cannabis as a
            Cannabis product from a “medical/adult           common agricultural crop, it is important that policy
            use-type” product have also been in debate,      measures be enforced downstream, avoiding barriers
            and subject to different approaches among        and limitations for farmers. An interesting way of
            countries. However, recently, the World Health   regulating hemp, taking into consideration the
            Organisation set a precedent, declaring that     regulation of WPP Cannabis in parallel, would be:
            “not more than 0.15% ∆9-THC by weight [...]      •  Upstream, no limitations. Farmers can start a
            has no effects indicative of potential for abuse    NPP crop as long as they do not intend to use
            or dependence” and that because “chemical           the harvest for WPP, and use adequate growing
            analysis of ∆9-THC to an accuracy of 0.15%          practices to avoid high-THC plants (requires
            may be difficult for some Member States”,           training);
            they decided to set the current standard for     •  When crops are mature a two-steps control can
            disregarding minor content of THC with no           be implemented:
            effect on health, because of “existing national
            capacities to accurately detect trace amounts       i.  a first control can be established on the basis
            of ∆9 –THC up to 0.2%.”                                of the “relative threshold” as per the UNODC
                                                                   guidelines. Crops that have a relative content
            This is the minimum standard internationally           [THC+CBN] : [CBD] < 1 could be processed and
            recognised for medical-grade products. But             sold to the general industry;
            the production of hemp products for human           ii.  if the product of the crops has a relative ratio
            consumption does not require the same extent           > 1, the “absolute threshold” method could
            of quality control as pharmaceutical-grade             apply on a 5% basis, complementing the
            products. Indeed, many countries have used             “relative” threshold (e.g.: the crop would be
            absolute thresholds for product distinction that       considered NPP if it has a ratio [THC+CBN] :
            rely on higher levels of THC in end-consumer           [CBD] < 1 AND if it has less than 5% THC on a
            products (such as Switzerland, where up to             dry-weight basis). If the crop has > 1 and more
            1% of THC is permitted), without any public            than 5% THC on a dry-weight basis, it would be
            health concern ever being raised. Establishing         considered WPP, and could only be sold to the
            a higher threshold for products could be               Hubs.
            easier to enforce, and allow for a broader
            inclusion of farmers and operations with more    After harvest: end-consumer products are tested.
            limited capacity to reach such low rates. If any   Products with a content of THC lower than 1% can
            “absolute threshold” were to be established, it   be distributed in the regular distribution systems,
            should not be lower than 5% of THC on a plant    while products with more than 1% of THC can be
            dry weight basis.                                distributed only within the Cannabis adult-use
                                                             legal retail operations. Beyond that, NPP Cannabis
                                                             products should only need to meet the standards
                                                             and regulations of the building-material, cosmetic,
                                                             health supplement, textile, plastic, fuel, fodder,
                                                             paper or whatever particular industry in which these
                                                             products are traded or sold.
                                                             It is of grave concern to all producers of WPP
                                                             Cannabis that cross pollination from hemp can
                                                             adversely affect crop quality. We do not have an
                                                             immediate solution but this matter needs to be
                                                             addressed urgently.











            CANNABIS IN SOUTH AFRICA  •  THE PEOPLE’S PLANT  •  A Full-Spectrum Manifesto For Policy Reform  81
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