Open Letter RE: Traceability
July 25, 2019
Dear Cannabis Alliance Members and Community Partners,
As you are aware, the vision of The Cannabis Alliance is to effectively represent, promote and advocate for the Washington State cannabis industry. We are actively involved in pressing issues that impact our members and 502 constituents. This week has been a struggle for all members of our community. Our open letter is intended to acknowledge and guide the justified anger, confusion and fear the industry has been experiencing – with the hope that we can take a collective breath, clear a little space in our minds, and focus on collaborative solutions. The only way to get to solutions, however, is to understand the situation as it currently stands.
On June 17, 2019 the LCB announced that MJ Freeway would release and implement Leaf Data System v.1.37.5 starting on July 13. This deployment had initially been scheduled for November 6, 2018. The planned outage to implement the release was to begin Saturday, July 13 at 11PM and continue to Tuesday, July 16 at 8AM. As anticipated, the system went live at 8AM, however, by 2PM massive errors were “causing a breakdown in the ability for licensees to do wholesale business transactions within Leaf” necessitating the LCB Traceability Project Steering Committee to shut down the system until 6:15PM. This was just the beginning of what has become a gruelling marathon impacting cannabis businesses and partners all across the state AND the system remains fatally flawed.
What Have We Done/What Are We Doing
Since the debacle of last week, The Cannabis Alliance has been in active discussion with the LCB, Board Chair Rushford, Rick Garza, Deputy Director Megan Duffy and others, including the Governor’s office. We have been elevating and communicating industry concerns and perspectives all the while striving for solutions in the near, and far, term. We have also contacted, and been in conversation with, members of the legislature, the media, and other counsel. Due to our efforts we believe a consensus is building in Olympia that the Leaf Data System is untenable.
On July 23rd the LCB instituted Board Interim Policy (13-2019). The stated purpose of this policy is to “allow licensees, integrators, and labs to develop workarounds to problems directly associated with lab test data and manifests” with the “intent to facilitate licensee’s ability to comply with state laws and regulations in light of the challenges created by [the system].” Many people pressured the LCB, including The Cannabis Alliance, to help our industry expedite product without having to wait for workaround approval. Such approval taking, minimally, 24 hours. It seems clear that the current BIP is in place for one reason: the LCB wants to get business moving and knows that the disruption Leaf has caused can’t continue. We have repeatedly told the LCB that the Leaf Data System has failed to meet contractual business expectations.
What Is The Cannabis Alliance Advocating For?
The Cannabis Alliance has identified several scenarios to help advance the organization’s effort to make an informed decision on how to advocate for you:
- Continue the contract with MJ Freeway. We are not supporting or advocating for this.
- Replace MJ Freeway with another vendor with a less complex and burdensome traceability system. This vendor will be vigorously vetted and will be held financially accountable for any disruptions its systems causes.
- Develop a full audit-based system maintained by 502 businesses. Allow the industry to evolve from state-administered traceability system to one maintained by 502 businesses and audited by the LCB.
There are other scenarios possible. The Cannabis Alliance wants to hear your ideas.
We recognize, and acknowledge, that all scenarios, including the continual contact with MJ Freeway, will create disruption. Our position is to work together to predict, prepare, and drive the scenario that best enables our industry to thrive and is flexible enough to better weather future adjustments. In order to institute the best possible transition, we need to investigate and understand the time, cost, and benefit of each scenario.
How Can I Help/ What Should I Do Now?
The days and weeks ahead will continue to be challenging for 502 businesses. Below are some suggestions for how you can ensure that we all have a vital and sustainable future together:
- Work with your fellow licensees, labs, and integrators in good faith. Expect and insist that they do the same. We’re all in this together.
- Maintain compliance with the rules, even if that means using approved workarounds in and around Leaf. Do not withhold or distort the truth. If you’re unsure if something is compliant, ask the LCB, your lawyer, your lab, and/or your integrator.
- Use the traceability system to the best of your ability. Review BIP 13-2019 carefully. If you use approved workarounds we recommend you document each instance in an email to: email@example.com and keep your own physical documentation for each instance on file.
- Donate to The Cannabis Alliance. If you’re not a member, become a member! If you are a member, consider increasing your level or an added one-time donation. The Cannabis Alliance works tirelessly for you and we need your support. Participate in surveys and provide feedback. The more we hear from you, the more we can amplify your voice and drive policy changes that meet your needs.
The last eleven days have been chaotic and miserable for the industry. The damage we’ve endured is beyond reason. The Cannabis Alliance is seeking your input to create and drive the next evolution in traceability – and land on a sustainable and permanent solution that works for you. We expect, and are braced for, additional disruption, but we KNOW in our hearts that when we come together, we can move mountains. Now is the time to contemplate and assess what serves our industry. In the LCB’s Cannabis 2.0 overhaul, the LCB is listening to your voice delivered to them by The Cannabis Alliance.
We welcome your thoughts.
The Cannabis Alliance