1. Do you support the proposed bifurcation of Industrial Hemp and Floral Hemp for regulatory purposes? Why or why not? (Industrial = fiber/grain; Floral = cannabinoid-producing)
2. How would a 1.0% Total THC pre-harvest compliance threshold impact your operations or your state’s regulatory environment? (Compared to the current 0.3% Δ9-THC standard)
3. Do you agree that USDA should regulate cultivation only, with FDA and TTB assuming oversight of cannabinoid-containing products? (Aligning responsibilities across agencies based on end-use and impairment potential)
4. What feedback do you have on the proposed “three-lane framework” (FDA for non-impairing cannabinoids, TTB for impairing cannabinoids, DEA for artificial cannabinoids)?
5. Does your organization support TTB becoming the primary regulator for impairing cannabinoid products, similar to the alcohol model? Please share any concerns, anticipated compliance challenges, or benefits.
6. Are the recommended FDA actions—such as setting serving limits, age gates, GMP standards, and labeling requirements—sufficient to ensure consumer safety for non-impairing products?
7. What additional clarity or guardrails are needed regarding artificial cannabinoids regulated under DEA jurisdiction?
8. How would the proposed national lab accreditation program (USDA + DEA) affect testing consistency and market stability?
9. Are there specific research needs (toxicology, impairment thresholds, analytical methods) that should be prioritized by NCCRE, NCNPR, or other research partners?
10. What concerns, recommendations, or suggested amendments should be considered as Congress shapes the Farm Bill and Energy & Commerce legislation?
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