Frequently Asked Questions

Frequently Asked Questions

This page contains a list of questions submitted to CCRS@lcb.wa.gov. The CCRS team works to answer relevant questions on this page or individually in response to the sender. We plan to regularly update this content as more questions are submitted.

Please send questions to CCRS@lcb.wa.gov.  

We have commonly recieved questions about data reporting and timing around the transition from Leaf to CCRS. Please see the following information regarding data upload:

  • Upon the launch of CCRS licensees are expected to make their initial upload as promptly as possible and begin CCRS reporting. While there will be period of overlap between CCCRS launch and Leaf decommission; reporting in Leaf will not meet the licensee requirements for traceability reporting.
  • The window to complete the initial upload is between launch (expected Dec. 6) and Dec. 13 (one week after launch). After Dec. 13, 2021 licensees will be expected to be reporting on the appropriate frequency in CCRS.

 

Quick Links:

 

Data Elements

  • Q: Will price data be included for wholesale and retail sales activity?
    A: Sales data will be collected. Details can be found in the user guide on what content is required to be reported in the sales report fields. Please see the user guide located on the CCRS Resources page.
     
  • Q: Will there be a fixed list of inventory types? Or just broad 'equivalence' categories (eg, Clone/Seed, Plant, Bulk Material, Product)?
    A: This information can be found in resources provided on reporting submittals and data field detail on the CCRS Resources page.
     
  • Q: What date should be entered for Harvest Date if the harvest date is not yet known?
    A: This was a bug that was recently logged and has been corrected to allow for NULL or a blank entry in the Harvest Date. This should be fixed and can be tested to ensure. 
     
  • Q: One of the FAQ related to GUIDs states “generated dynamically using an approved algorithm”, but there is no reference to what algorithms are “approved” or how to get an algorithm approved.  Other documents imply each licensee/integrator is free to implement any “algorithm” they want (as long as traceability is maintained). What are these algorithm requirements?
    A: This was a reference to an algorithm that had been presented to LCB and considered.  LCB will not be approving ID algorithms.  As long as traceability is maintained and documentation supports that there is a consistent numbering convention be used licensees and integrators will not be submitted the ID algorithms to LCB for approval. 

 

Data Quality

  • Q: How will an integrator access the new system to send or review data?
    A: Please see the user guide located on the CCRS Resources page.
     
  • Q: In preparing for the transition, does reconciling data mean doing full inventory and entering correct data in existing PoS?
    A: The agency recommends reconciling the inventory data against what has been reported to Leaf. For licensees that use a point of sale integration software the amount of reconciliation work would depend on the accuracy of records currently on file.
     
  • Q: I submitted a strain .csv that had invalid data in it, but I never received the error email. The .csv was 50 megabytes in size. Can you confirm that if we have csv's that are over the email attachment size limit (~25MB) that those will be sent?
    A: A system change has been made to break error message emails into responses of 100 error records per attachment to accommodate smaller sized responses. Restrictions are based on the email service provider limitations. 

 

Data Reporting

  • Q: What will happen to data currently in Leaf? Will data be converted and retained in CCRS?
    A: Leaf data will not be converted. Please see the user guide about the initial upload. It is located at the CCRS Resources page. LCB expects to have a final backup provided before decommission of the Leaf system.
     
  • Q: Is there any expectation for license holders to submit historical data to CCRS?
    A: There will be an initial upload for required reports to start with the CCRS model. The reports will be “point-in-time” from the date of upload forward. Records maintenance requirements do not change in the switch to this new model.
     
  • Q: Currently imported CBD materials are required to be entered into the system, will that still be the case?
    A: Yes. Imported CBD is required to have the necessary tests to allow it to be added to marijuana and the records and reporting requirements continue.
     
  • Q: Will labs still be required to report their information to this system within 24 hours?
    A: Reporting requirements have not changed. It is recommended that labs use the CSV report as a per Certificate of Analysis submittal for reporting.
     
  • Q: Will the laboratory need to provide COA documents to the LCB? Physical? Digital? Links?
    A: Labs are required to provide the test results to LCB via the reports established for that purpose. Record maintenance and access remain the same for both the labs and licensees. No changes have been made on the requirement to produce the records if requested by WSLCB.
     
  • Q: For those that only grow during the summer, will they need to submit a CSV file weekly during the winter months when there are no changes?
    A: The specification files on the CCRS Resources page provide more detail on the frequency of reporting required for reports. In the instance of outdoor grows it will be expected that an initial upload take place, and that reports are then submitted when there are actions, updates and changes weekly (if those activities have occurred). It is not the expectation that reporting be submitted when there is no activity to report. A reminder that the LCB will be monitoring reporting activity. If information does not support less than weekly report submissions, the LCB will also be reaching out to confirm the reason for lack of reporting.
     
  • Q: Why does the Area specification mention that IsQuarantine is only for imported CBD? How is that related to Area data?
    A: There are no quarantine requirements for marijuana products. You will have an entry as FALSE. For imported CBD: quarantine rules are required until passing tests results as outlined in WAC 314-55-109 are on hand. Imported CBD must be put into its own room/area and marked TRUE until passing results are received.  This information can also be sourced from the User Guide on page 27, available on the CCRS Resources page.
     
  • Q: What happens if an Update operation is performed prior to an Insert operation, will it default to inserting that case? If so, can we just always specify the operation to be Update even if it is an Insert?
    A: The record doesn't exist, so an error message would be received. 
     
  • Q: Can a Lab sub-contract out their testing? If they do, who is responsible for reporting the test result?
    A: Labs may subcontract samples for a limited suite of tests and circumstances. The primary lab is responsible for reporting the test results directly to CCRS for the applicable product tested. WAC 314-55-102 (5) and WAC 314-55-102 (5) address referencing and subcontracting.
     
  • Q: In the webinar it was stated there is no API but it was stated in documentation that integrators can be granted access by licensees to upload on their behalf. How can integrators upload on behalf of licensees and are individual forms the only mechanism?
    A: CSV is the only upload method. 
     
  • Q: What is the process for seeing what has previously been reported to CCRS for a given license, so that we can align our future csv imports to use the same external identifiers?
    A: Licensees will need to request CCRS records through a Public Records request if seeking licensee specific information. There is no direct access to the data that has already been reported. The original licensee records still fall under the archive requirements found in WAC 314-55.
     
  • Q: For the inventory sheet, is ‘total cost’ the individual unit cost * quantity in stock, or the unit cost for each item in stock?
    A:  Page 28 of the User Guide explains the following: TotalCost is the total cost associated with the Inventory item: For the purposes of reporting, this field must always be $0.00. For all licensees filling out this report, the appropriate entry for Total Cost is $0.00. 
     
  • Q: If a retailer incorrectly enters the ‘FromInventoryExternalIdenntifier’ when they are receiving, how will they correct this? If we do an ‘Update’ operation, I don’t see how we could tie the values back to each other.
    A: They would perforn an "Update"  operation. That would update the record and correct the error.
     
  • Q: Can you confirm that concentrate for inhalation is an intermediate product versus an end product? Concentrate For Inhalation in LeafData was tracked as an end product that was transferred to retailers. Is this not the case with CCRS?  What should we use as an inventory type for a product that is sent as an extract to a retailer that has a unit weight?
    A: Concentrate for Inhalation is really an End Product, and we are aware of this. A “Change Request’ will be submitted to have this corrected; however, it will not be completed before launch of CCRS. So in the meantime, you will need to use the Inventory Category of “Intermediate Product” for it, as shown on page 22 of the CCRS Data Model File Specification Manual. The second question, Inventory type should be End Product.                                                                                                             
    UnitWeightGrams – weight of the sellable product unit (not including packaging). Any one sellable product may never exceed the individual carry limit allowed for a consumer.
    Unit Examples:
    Sellable product = 2 grams of flower - UnitWeightGrams  = 2 grams
    Sellable product = 1 pre roll - UnitWeightGrams = 1 gram
    Sellable product = 1 package of edibles - UnitWeightGrams = 10 grams
    Sellable product = 1 concentrate for inhalation cartridge - UnitWeightGrams = 2 grams

 

General

  • Q: Why is LCB switching to CCRS?
    A: Please see previous WSLCB communications and content from the webinar on 9/8/2021.
     
  • Q: What is the expectation of licensees using CCRS?
    A: Please see the user guide located on the CCRS Resources page and information presented during the webinar on 9/8/2021.
     
  • Q: Is three months enough time for all integrators to transition their systems and migrate all their clients to the new system?
    A: With the simplicity of the process being developed we believe that three months is sufficient for integrators to prepare their systems. If you anticipate any problems and need technical assistance on the use of CCRS, please contact our IT contact found on the CCRS Resources page.
     
  • Q: Will there be a public comment period for the technical specifications of CCRS?  Will the LCB incorporate suggestions from experienced Washington state technology vendors?
    A: The technical specifications have already been determined for the system. Feedback is always welcome. However unless there are items in the CCRS solution that would prevent reports from being submitted, there will not be major changes before the release.
     
  • Q: What does the transition between Leaf and CCRS look like? Will there be a transition period where both Leaf and CCRS are operational?
    A: There will likely be a short period of overlap. Reporting functions in Leaf will be available for a brief period after CCRS launch, but they will not replace the requirement to report in CCRS.
     
  • Q: Does the LCB anticipate CCRS being a long term solution?
    A: Whether or not this becomes a long term solution will depend on how well it meets the needs of the state. Potential replacement of this system would only come after careful consideration of LCB and stakeholder needs.
     
  • Q: Were other proprietary systems considered for state traceability, is there a possibility of the LCB doing an RFP and switching to one of those (or other) systems in the future?
    A: The agency considered many options and focused on keeping this solution as simple as possible while meeting our needs for regulating the industry. The proprietary systems would have been very complicated to implement and would have required LCB securing additional funding.
     
  • Q: Does CCRS apply to all licensees, including retailers?
    A: Yes. This applies to all cannabis license types and to certified labs.
     
  • Q: Will the agency support a legislative change to eliminate the application and renewal fee added to fund the switch to traceability vendor MJ Freeway?
    A: The license fee increases in SB 5130 were policy decisions by the legislature for funding the implementation and ongoing support of the agency’s traceability system. The ongoing $300 additional license fee will continue to be used for support of the CCRS system. The LCB does not advocate for or oppose policy decisions regarding fees.
     
  • Q: An additional $81 was tacked on as part of HB 2334 in 2018, a bill on imported cannabidiol (CBD) which the agency subsequently implemented into rule. Will the Board support industry legislation to ask legislators to rescind that fee?
    A: The additional $81 was a policy decision by the legislature to fund LCB’s costs associated with implementing HB 2334. WSLCB does not take a stand on legislative fee-setting decisions and would not support or oppose an effort to have the fee changed.
     
  • Q: In the LCB survey of licensees, how many were using the Leaf Data web interface only without third party software? How will they report data?
    A: Licensees that do not work with a third party software integrator will be able to report directly to the LCB by using their Secure Access login. Details for this are in the user guide.
     
  • Q: The Traceability workgroup has not met since early 2021 and this proposal did not include their feedback. Is the workgroup no longer being consulted?
    A: The Cannabis 2.0 workgroup was convened to discuss concepts about the future of traceability. Those concepts were considered as LCB developed CCRS and some ideas may find their way into future discussions. For the purposes of the CCRS project, the timeline involved and the model being implemented not all of those concepts fall within the project scope.
     
  • Q: How do we do a plant ID in CCRS?
    A: The plant ID will no longer be generated by the state software system.  Licensees will need to establish/choose an inventory numbering system and then assign ID's to plants. A reminder that requirements to tag plants has not changed; plants must still be tagged. The plant tag will now be the ID a licensee assigns to that plant and has recorded in the appropriate CSV file.
     
  • Q: Are there plans to make any changes or updates made based on questions or feedback during the beta testing period (now closed) or the month-long “practice” period (to start Oct. 4th). ?  Or are the template files provided and instructions/guides provided considered “final”? 
    A: All suggestions and bugs identified during the testing period are welcomed. Each will be evaluated.  The core function of CCRS will not change in its structure and operation. 
     
  • Q: What time zone should dates/times be documented in?
    A: For reporting purposes, the file name should be referenced in PST.

 

Integrators

  • Q: Does CCRS provide an integration sandbox for integrators to develop against? If so, is the sandbox data shared by all integrators, or can they use it independently?
    A: No. There is no API for CCRS. Secure Access Washington (SAW) is the authentication to the portal for the CSV report uploads.
     
  • Q: Will integrators have access to a CCRS database on a per license basis? If yes, how does authorization to the CCRS database work?
    A: Integrators will not have direct database access. If a licensee uses a third party integrator for reporting services, the licensee will need to assign permissions to their contracted integrator who will then be able to insert, update and delete information.
     
  • Q: How will licensee software vendors authenticate on behalf of licensees?
    A: Integrators will be assigned a specific ID and will need to use the Secure Access Washington to authenticate and report on behalf of a licensee.
     
  • Q: Will WSLCB staff restart regularly scheduled Integrator Work Sessions?
    A: Reoccurring integrator meetings will not be scheduled, but occasional technical work sessions may be set up for labs, licensees and integrators.
    • Also, do you have any additional documentation on other requirements for third party software vendors to be compliant with Washington regulations?
      Please see the user guide and resources located on the CCRS Resources page. With no API, integrators reporting on behalf of licensees will not necessarily have unique needs. WAC 314-55 remains the overarching set of rules in effect.
       
  • Q: Does the integrator need to be preliminarily approved or validated by LCB before it is added to the system by the licensee to enable the integrator to upload reports on the licensee’s behalf?
    A: Yes. Integrators who will be providing reporting services for licensees will need to be added to approved list in order for licensees to assign permissions to their integrator of choice. The steps for approval are listed on the CCRS Third Party Integrator Approval Process page
     
  • Q: Why do we need to do the Webform Manifest if we are integrators? We already have print outs available for our customer and this will cause a break in the flow of reporting for us.
    A: The Webform Manifest is a requirement for a licensee to report on product that is being sold/transferred. If a third party integrator is providing the service for manifest creation through their services licensees may use that manifest during transport. This does not relieve the licensee from reporting the manifest to the LCB via the Webform Manifest.  If a third party integrator is providing reporting services on behalf of the licensee the information is required in the Webform Manifest reporting.
     
  • Q: What are the criteria for integrators to be added to the LCB approved list in order for licensees to assign permissions to their integrator of choice?
    A: The process for vetting integrators is listed on the CCRS Third Party Integrator Approval Process page.
     
  • Q: For the formal integrator test process, is there any more information you can provide around what to expect, such as timing & deliverables?
    A: At this point, the environment is open for our integrators to begin testing so they can configure their systems with ours. There will be another round of testing but the timing and deliverables are still being discussed. The Agency will communicate when that will be when the time is near.
     
  • Q: If any licensees were to add an integrator within the precannabisreporting site, would they need to do so again once the live site is up?
    A: Yes. This is the process that will need to be followed after go live as well. 
     
  • Q: Can only one user be associated with our CCRS integrator account?
    A: Two users can be associated with your integrator account.
     
  • Q: What filename format does an integrator use when uploading on behalf of a lab?
    A: Integrators uploading files on a Lab's behalf would use the same Lab CSV file that the labs would use. The CCRS specification file has the naming conventions.
     
  • Q: If an integrator is submitting CSV reports on behalf of a licensee, should we expect that only the integrator will be notified of errors via email, or would the licensee get an email notification as well?
    A: Yes, the individual (integrator) uploading the csv file would be getting notified of any errors.
     
  • Q: Will the CCRS test site, along with our test integrator & test licensee accounts, remain active after the CCRS go-live, to use as a sandbox environment?
    A: The pre-production environment will be avalible and have limited suppprt between 10 a.m. and 3 p.m. for users after go-live (and prior to launch). Access will remain in place for licensees and labs just as it is now. Integrators will have accesses to the production and pre-production environment once they have gone through the appropriate approval process as outlined on the LCB website. 

 

Login

  • Q: Will there be a direct entry web interface as well, or will this specifically be manual, one-off, DropBox type submissions?
    A: Licensees will use their Secure Access Washington login (existing or created in the future) to submit the required CSV reports.
     
  • Q: How will licensees authenticate with the new system?
    A: The Secure Access Washington login will operate as the licensee’s authentication.

 

Manifests

  • Q: When can we expect the updated transport manifest form?
    A: The Drupal Webform manifest reporting will launch at the same time that the CCRS reports launch. The combination of the two (Webform Manifest and CCRS reports) are requirements for reporting.
     
  • Q: How will licensees who are not using third party software create/update these manifests?
    A: The Drupal Webform manifest will send an email with detail that can be printed and used for the required physical transportation manifest.
     
  • Q: Will there be manifests or anything to assist in inventory transfers? How will the retailer know what the FromInventoryExternalIdentifier is?
    A: Manifests must be recorded as part of the Drupal Webform Manifest. The licensee sending product is responsible for providing the FromInventoryExternalIdentifier to the receiving licensee for their use in reporting on the applicable CSV reports. 
     
  • Q: Can we get rid of the captcha so we can have bulk uploads to the form?
    A: Captcha is a standard security feature that will not be removed prior to CCRS launch. The Webform Manifest is not designed for bulk uploads. 
     
  • Q: This captcha will not prevent integrators from automating the webform on behalf of their customers, it will just make it more annoying/expensive to do so.  Can you help us understand why the LCB believes the captcha is necessary? 
    A: Captcha is an standard security feature that will not be removed prior to CCRS launch. The Webform Manifest is not designed for bulk uploads.  
     
  • Q: Is there a timeframe relative to the delivery of goods in which the manifest must be submitted via the SAW webform (assuming the licensee already generated a printed manifest for the delivery from an integrator system)?
    A: The Drupal Manifest Webform must be uploaded to the agency website prior to transporting any product.
     
  • Q: A licensee is allowed to use a printed manifest generated from an integrator system. Must the manifest ID generated from the integrator system match the ID generated when the manifest is submitted via the SAW website?
    A: There are no SAW reports that require the Drupal Manifest confirmation number, nor any SAW reports that require a manifest ID.  The Inventory Transfer report and the Plant Transfer report that are filled out by the licensee receiving product require ExternalIDs related to the product, inventory or plants being transferred.  The External IDs for the inventory, product or plants should match the detail provided on what has been transferred.  It is highly recommended that if using a third-party printed manifest that the Webform Drupal number be referenced on that document for sourcing in the event that there is a traffic stop during transportation of the material.

 

Public Records

  • Q: Will licensees be able to access analytics from CCRS?
    A: Licensees will be able to request information by submitting a public records request.
     
  • Q: Can the LCB make a copy of the entire Leaf database available once it is turned off, similar to FOIA public records requests, but with full export?
    A: Public records requests will be managed following existing processes. Full publishing of the entire backup is not likely based on specific types of data restrictions.
     
  • Q: Can we get access to all the CCRS data including products sold (in order to assess trends)? Or will the data at least be public for sales figures by license, similar to what we can access currently?
    A: Public records requests will be managed following existing processes.
     
  • Q: What is the process for seeing what has previously been reported to CCRS for this given license so that we can align our future .csv imports to use the same external identifiers?
    A: Licensees would request CCRS records through a Public Records request if seeking licensee specific information. There is no direct access to the data that has already been reported. The original licensee records still fall under the archive requirements found in WAC 314-55. 

 

Rules

  • Q: Will there be explicit rules on what can be transported between licensees?
    A: There are no changes to licensee permissions by licensee type and no changes in the types of products that can be transported between licensees.
     
  • Q: Will there be explicit rules on 'conversions' from one type to another? How will these be enforced? Leaf allowed anything to be ‘re-typed’ into anything.
    A: Rules on valid conversions have not changed per RCW or WAC. CCRS will not “enforce” conversions by the system architecture. The enforcement of conversions will be based on the detail reported to WSLCB and follow up conversations between licensees and their Enforcement Officer/Compliance Consultant.
     
  • Q: WAC 314-55 still makes reference to the sixteen digit identifiers from the BioTrackTHC era. Will we be returning to that requirement?
    A: The CCRS reports and the LCB will not be generating the IDs. Licensees will need to use reliable inventory tracking methodologies to assign IDs to their inventory and provide the ID (called external identifiers) when reporting via the CCRS reports. It is recommended that where possible to continue to use the existing ID structures. The WAC requirement going forward will be for IDs, not for IDs generated by the State.
     
  • Q: Will LCB staff undertake rulemaking to update the WAC prior to CCRS launch?
    A: The fundamental reporting requirements do not change in the CCRS model. There may be minor clarifications made to how current WAC applies to CCRS but significant rule changes are not planned for this project.
     
  • Q: How will shifting to the CCRS not place licensees in jeopardy of violation of Washington state law and administrative law in accordance with existing WAC requirements?
    A: The CCRS reporting requirements cover the WAC requirements for records retention and requirement to report to WSLCB cover the WAC language. Every system used to date by LCB has had the same inherent requirement for licensees to report to be in compliance. The underlying components of reporting remain the same.
     
  • Q: Will there be a redefinition of the concept of “failure to maintain traceability” or what it means to maintain compliance given the significant change?
    A: No. The change in systems for reporting does not change the underlying concept that reporting is required and that accurate reporting and records maintenance is expected.
     
  • Q: Are there labeling requirements for products?
    A: Labels are still required for all products and must meet the standards established in WAC 314-55 for labeling requirements. There have been no changes to label rules

 

System Support

  • Q: Is there a technical consulting company building CCRS that integrators can work with to ensure a smooth experience for licensees?
    A: No. There is not an external vendor working on this project.
     
  • Q: What support will be available for licensees using CCRS prior to launch and post launch?
    A: Please see the user guide and resources located on the CCRS Resources page and information presented during the webinar on 9/8/2021.
     

Tax

  • Q: In the WAC (314-55-089) it states “the act of keeping data completely up-to-date in the state traceability system fulfills the monthly reporting requirement” - regarding taxes - will that still be the case or will there be a new process?

    A: Reporting requirements have not changed. The statements below are specific to producer/processors (reference 314-55-089(2) and 314-55-089(3).

    • Marijuana producer / processors do not have a tax obligation to the WSLCB and the Finance Tax and Fee group is not collecting reports from this group of licensees.
       
    • Producers and Processors should contact their Enforcement and Education Officer if they have questions regarding how to report their information. To be fully compliant with the LCB, licensed marijuana retailers (reference 314-55-089(4) are required to report using LCB form LIQ1295 (Retailers Sales and Excise Tax) and pay their monthly sales/tax information by the tax due date. Retail licensees are required to submit a report to the LCB each month even if they did not have sales completed. Per WAC 314-55-092(2) failure to report and/or pay will be sufficient grounds for the LCB to suspend or revoke a license.
       

Technical Details

  • Q: Will CCRS allow integrators to use an API?
    A: No. There is no Application Programming Interface (API) for CCRS.
     
  • Q: Will CCRS allow medicinal consumers to find medically compliant product as the original traceability system allowed? This ability ceased in Oct. 2017.
    A: No. This is a reporting system, not inventory management.
     
  • Q: When will integrators get technical documentation for CCRS?
    A: The error messages and the data model specification guides are available on the CCRS Resources page.
     
  • Q: In preparing for the transition, what data, covering what time period, should licensees retrieve?
    A: Licensees and labs will have more than one report that will need to completed at the initial upload. The reports themselves will dictate what information the licensee will be responsible for providing.
     
  • Q: Will the LCB be providing any ‘cloud storage’ to facilitate digital transfer of data between licensees (such as manifests and lab results data)?
    A: This service will not be provided.
     
  • Q: Will there be a GUI for labs using the portal?
    A: Labs will be assigned a lab ID and will report information that is specific to their function. The reports the labs are responsible for will also use Secure Access Washington CSV uploads.
     
  • Q: How will lab results be tracked for retail products?
    A: Records requirements have not changed. Licensees must continue to provide the supporting documentation for all products sold at retail. Reports are being built against the CCRS data submitted for LCB’s use in reviewing test results.
     
  • Q: CSV is a known “anti-pattern” in the data interchange/interoperability realm. Since the LCB is defining a data-specification, can we use a modern format?
    A: At this time submission is by .csv format only.
     
  • Q: Will WSLCB require usage of globally unique identifiers (GUIDs) to identify products, and if so can we utilize the ULID standard as recommended by the Traceability 2.0 work group?
    A: No. The Traceability 2.0 Work Group recommended that GUIDs not be issued by a central service, but generated dynamically using an approved algorithm by third-party software providers. Agency staff reviewed the universally unique lexicographically sortable identifier (ULID) algorithm and specification suggested by a work group subcommittee which convened in November 2019.
     
  • Q: Will partial batches require unique identifiers (e.g., sublotting) for multiple companies? Or will batch identifiers be permitted to exist at multiple locations?
    A: Batches are not part of the CCRS data model. Unique identifiers will be required for each inventory and plant record being reported. Unique identifiers are specific to the licensee reporting them.
     
  • Q: Recently, the industry was able to check itself concerning the imbalance of raw bio-mass from licensed grows entering a processor facility and that processor facility producing massive amounts of THC (both Delta8 & Delta9) in abundance to what could possibly have come from that regulated bio-mass; indicating the manufacturing of THC’s from hemp bio-mass and/or converted from out-sourced CBD.  The proposed CCRS does not appear that it will be able to catch anomalies of this type. What trace system changes can be put in place as we leave Leaf that will still allow industry or the public to identify those that exploit the loop-hole in both the federal and state laws that paved the way for the practice of created THCs from unregulated sources?
    • A: The LCB reports will be built to assist the agency in its work related to regulation. This system will not be the same as the previous but meets the requirements for reporting that have been identified in RCW and WAC. Audit-based work will likely be a tool that will be employed by the agency in new ways going forward.

Testing

  • Q: How can I get involved in the testing process?
    A: Please see the user guide and resources located on the CCRS Resources page and detail presented during the webinar on 9/8/2021.
     
  • Q: Is it too late to become a tester for the new CCRS program? If not, what would I need to do to get involved?
    A: The CCRS Pilot testing effort is complete. The environment will be opened to all licensees, integrators and labs on October 4th to begin preparation of the system launch. 
     
  • Q: Will you be providing release notes for the changes that will be deployed weekly on Wednesdays?
    A: Yes! we will be posting release notes on the website for any changes to the environment. These notes are available on the CCRS Resources page under Testing Resources.
     

 

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