NA0244- CANADIAN HEMP REGULATORY REVIEW PROJECT

  The Ontario Hemp Alliance (OHA) has officially received funding   approval for the CHRRP project under the Advancing Canadian Agriculture and   Agri-Food (ACAAF) Program.  The approval is for contribution   of up to $215,000.

  - This is subject to the   signing of a mutually-satisfactory contribution agreement which will detail   the terms and conditions of the funding.

  - It was determined that some   activities were not considered as being feasible for the completion in the   current timeframe for ACAAF (March 31, 2009).  As such, the   work plan including timeline and budget are revised.  They   totally focus on the Regulatory Review with Health   Canada.

  - Niels Hansen-Trip and   myself assumed the responsibility as Consultants to put together the following   work plan and budget including recommended Secretariat and Steering Committee   (SC).

  - We recommend that the OHA   board consider meeting before Christmas to assume appropriate action to   proceed with this project.

  - The OHA board will be   responsible recipient and administrator of this project.     The Secretariat will be hired by the OHA and answerable to the board   with the Steering Committee giving oversite (Cops), expertise, and participate   in technical meetings.

  - Recommended Secretariat :    Director/program manager-Niels Hansen-Trip; Associate   Director- Gordon Scheifele; Accountant-Bob Montgomery; Recording   Secretary-to be announced; Office manager/secretary-Gunhild Scheifele;   project office-174 S Woodstock St., Tavistock, Ont., N0B 2R0, 519 655 6277,   ;.

  - Recommended Steering   Committee (SC)  (9) : OHA   president-Dan Scheele; CHTA exec director-Anndrea Hermann; Ontario Fibre   Industry -Geof Kime ?; Manitoba/Food Processing Industry – Shaun Crew ?;   British Columbia/fibre industry/textile – Jason Finnis ?;     AB industry to be announced; Sask – fibre academic - Dr. Satya   Panigrahi; Quebec/fibre & grain industry –?; Atlantic Provinces – Atlantic   Healing Hemp Inc, Wanda Beattie.

  - The budget covers travel   and accommodation costs for all SC functions.  Each persons   contribution time is budgeted as “in-kind”.

  - The scheduled Activities   are as follows:
  -Steering   Committee Orientation meeting: Toronto Quality Suites, Toronto Airport;   January 15 & 16, 2009.

  - 4 Stakeholder Meetings: Saskatoon, Jan 20, 2009; Winnipeg, Jan 21,   2009;  Toronto, Jan 22, 2009, Montreal, Jan   23, 2009.

  - Steering Committee First Draft of Regulation Review/Recommendations document:   Toronto, Feb 12& 13, 2009.

  - Final Draft of Regulation Review/Recommendations document: Feb 20,   2009.  Reviewed via email and results returned to Director   by Feb 24, 2009.

  -  meeting with Health Canada: March 4&5,   2009.  Director, Assoc Director, CHTA exec director &   OHA president.   - Project termination date: March 31,   2009.

  - we have requested from   ACAAF Cash Advance for the first month (Jan).

  - The Accountant , Bob   Montgomery, has dealt with ACAAF on previous projects and is very familiar   with the system.  The accountant will also arrange for final   audit.

  The objectives of the CHRRP are to:
      Provide the Canadian Hemp Industry with an opportunity to evaluate the overall impact of the   Canadian Industrial Hemp Regulations, other Acts and Regulations that impact   on hemp production and marketing (e.g., Feeds Act, Seeds Act), current   production and marketing practices in collaboration with Health Canada (HC),   Canadian Seed Growers Assoc (GSGA) and the Canadian Food Inspection Agency   (CFIA). The review will be carried out to harmonize regulations with business   practices as conducted after 11 years of experience with the current regulations.

Need: The Regulatory System needs to be as user friendly as possible and ensure the   health and safety needs of the public are met in the production of and uses   of  Industrial Hemp as acreage moves forward past developing   crop status.

Challenge: The regulations were originally to be reviewed after   implementation in 1998 as the industry and regulatory bodies gained.

Objective A  Phase 1 -   Regulatory Review: Jan 2, 2009 to March 31, 2009


  a.   Planning
  - Develop Action Plan (Work Breakdown   Structure, Work Packages, Project Charter, Risk Analysis, Communications   Plan)
  - Formation of Steering Committee (9   members) and Secretariat (Director, Associate Director, Secretary (office   Manager), Accountant), recording secretary.
  - Consultation with Industry and government   regarding project management and approach

  b. Formative   Process
  - develop basic questions to guide collection of data relating to issues, concerns, and   processes or procedures that are going well

  c. Conduct interviews with strategic corporate and government representatives, distribute questionnaires.

  d. Regional stakeholder input meetings across Canada (Sask, Man, Ont, Quebec)

  e. Draft documents reporting industry recommendations ..Draft 1.

  f. Consult Stakeholders to approve the draft documents… Draft 2.

  g. Summation and writing of final report.

  h. Submission to Health Canada in meeting on or before March 31, 2009.



NA0244- ONTARIO HEMP ALLIANCE CANADIAN REGULATORY REVIEW PROJECT

Project Work Plan

Activities

Target Activity Start Date

Target Activity Completion Date

Outputs

List each activity and provide a brief description of the activity and any sub-activities (main purpose, etc.) (Budget details provided on pages 17-20 must clearly link back to each activity and any sub-activities described below).
For each activity listed, indicate what will be produced.

1A. Hire Consultants  (Niels Hansen-Trip & Gordon Scheifele) to develop project charter , work plan and project agenda for steering committee members.  Contact and recruit steering committee members and set up orientation meeting.

1B. OHA to appoint National Steering Committee (8 members including OHA and CHTA presidents).
Dec 4, 2008
Dec 31, 2008

1A. The OHA directors appoint the recommended  Steering Committee (8) and hiring of Secretariat.  Secretariat: Director, Assoc Director, Office sec, Recording sec, accountant. 1B. Industry group that gives broad-based national validity to the project.  Oversite: Approval of activities and budget.  Champions: represent areas of expertise in industry.   Participation: participate in Technical meetings.  Representatives: OHA president, CHTA exec director, AB, Sask, Mn, Ont, Quebec, Atlantic provinces.

2. Hire Secretariat (recommended Niels Hansen-Trip-Director, Associate Director-Gordon Scheifele, Office manager (secretary), Accountant & recording Secretary.
  Dec 4, 2008
Dec 31, 2008
Expert personnel that bring professional accountability and expertise to the project are engaged.

3. Develop Objective A Phase I  Project Charter, Work Plan
Dec 4, 2008
Dec 31, 2008
Preliminary Work Plan,  budget & Work Package developed by Secretariat

4. Steering Committee Orientation Meeting.
Jan 15, 2009
Jan 16, 2008
Orientation Meeting with Steering Committee in Toronto to outline the regulatory review of Industrial Hemp in Canada.  Preparation of SC for the stakeholder review meetings

5. Objective A Phase I Stakeholder consultations launched, including questionnaires, regional stakeholder meetings, website responses, etc.   There will be 4 meetings
Jan 20, 2009
Jan 24, 2009
– Regulatory Review and Recommendations with industry stakeholder across Canada(industry perspective).   4 Stakeholder meetings:  in Saskatoon, Winnipeg, Toronto and Montreal

6. Write first draft of Regulatory Review summarizing the responses from public and industry
Jan 25 , 2009
Feb. 11, 2008
Objective A (Regulatory Review and recommendations to HC): First draft.

7.   Steering Committee review of rough draft document
Feb. 12, 2009
Feb. 13, 2009
Review of rough draft of Industry review recommendation s to HC  by steering committee.

8. Final draft of industry reviewed with recommendations to H.C.

9. Preparation of document for HC
Feb. 20, 2009
Feb 25, 2009
Feb. 24, 2009
March 3, 2009
Final draft of the IRR to HC reviewed by steering committee via email. Final document prepared for HC presentation

10. Meeting with H.C. to introduce the Industry Regulation review and recommendations results.
March 4, 2009
March 5, 2009
Meeting with Health Canada, the OHA president and CHTA exec director of Steering Committee , director and assoc director to review the recommendations of the Industry and stakeholders with HC officials.

11. Finalize project
March 6, 2009
March 31, 2009
Complete report and paperwork for ACAAF and end  of project phase I, indicating that obligations of funded components have been delivered.   Completion of Project.

NOTE: Approved applicants will be required to submit quarterly progress reports.

              Reasons for Regulatory Review of Industrial Hemp Regulations

The term, Industrial Hemp, needs to be reconsidered as does the name of the     Regulations. When the Industrial Hemp Regulations were first     developed, the products of industrial hemp were largely considered to be     restricted to fibre for     industrial purposes. However, the industry has found that food and     nutritional products from the hemp grain became the most important and     successful products over time. The existing name has a negative connotation     for animal and human consumption and inhibits public acceptance and use of     these nutritional products.     Technical aspects     of the regulations may be published in the Technical Manual. This means that     a review of Health Canada’s Technical Manual for Industrial Hemp must also     take place.

        The original     Industrial Hemp Regulations were drafted and promulgated within about 3     months. There were concerns on both sides (government and industry) about     the content of the Regulations. In order to get agreement on the     Regulations, Health Canada made a statement that if the regulations could be     implemented, they would review the Regulations after a few years when both     government and industry had had an opportunity to gain some experience with     the application of the regulations.  This has never     occurred during the past 10 years.

        There are gaps in     the regulations relating to quality standards. No standards have been set     for qualification of those providing inspection and monitoring services both     public and private. No research has been done to verify the sampling methods     for live plants.     There are known     challenges with the regulations. For example, the Regulations state that the     method used to analyze samples for THC must be the method published in the     Technical Manual. However, the method given in the manual was developed for     detection of macro amounts of THC (>1%), whereas the maximum allowable     level of THC by regulation is 0.3%. This methodology is also imposed on     governments and exporters of other countries, who may be sending seed or     product samples to Canada.     There are farming     practices that can significantly enhance hemp production and increase the     viability of hemp as a crop (for example fall seeding) These methods are not     specifically considered or permitted by regulation.     The regulations     require that an applicant for a license to produce Industrial Hemp assure     that the hemp will not be produced within 1 km. of a school of place of     public assembly where youth gather. This requirement may no longer be     necessary.

        The process of     handling and licensing hemp has not yet been rationalized. There are aspects     of the movement of hemp and hemp products that were not addressed, such as     the need for a permit to carry or possess hemp seed or products, except if     the hemp is being carried by a courier or by parcel post. There is also a     requirement that the packages be clearly marked as containing hemp, which     may draw attention to the packages and make them an attractive     nuisance.

        The Regulatory     review for Industrial Hemp will provide a firm foundation for the further     development of the industry. If the regulations are not reviewed at this     time, further development may be jeopardized as the result of uncertainties     regarding permissible and potentially illegal activities if the regulations     are to be reviewed at some unknown time in the future     There is no     requirement for accreditation of laboratories or technicians who are     sampling, handling, and analyzing seed and other products for THC     content .