Q&A

Please note that this information is current as of August 2019. Information and recommendations may change as the program evolves and we learn more about industrial hemp.

Use the dropdown menus to see a listing of questions. Clicking on hyperlink will jump to that particular question.

Laws/Regulatory

THC Testing/When to Harvest/Destroying crop from failed test

If we have to cull plants before harvest or prune leaves, can we compost this on-site, feed to chickens, or are there other ways to destroy and dispose of the plants?

As a producer of CBD hemp seed can I put my 30-day harvest notification for the harvest window that we intend our varieties to be harvested at and then potentially harvest slightly later to allow the seeds time to mature? Since the seeds of maturity is after the flower of maturity for CBD?

Is a notice required if taking a sample to a private lab to be tested before the initial DATCP test?

How much of the top of each plants gets cut off from each sample? One inch or more?

Why do you need so much material for compliance testing? Doesn’t HPLC require an extremely small amount of material?

Can you harvest before you receive test results? I’m going to assume this means that you have sent in, it’s been tested and then can you harvest before you receive the results back saying you’re clear?

After submitting our 30-day harvest notification, can we harvest only harvest only our crop, no transfer to processors? So I assume it’s asking can we harvest after submitting our 30-day harvest notification, before the 30-day window expires and DATCP has not sampled the crop, after the 30 day when window expires and DATCP still has not sampled the crop, where after DATCP has sampled the crop before we received are fit for commerce certificates.

Do we have to harvest our crop within a certain amount of time after we’ve received that fit for commerce certificate?

Can growers stagger their harvest over several days or even weeks once it has been inspected and approved for harvest?

How soon until you offer remediation plan options for hemp that fails? I know DATCP compliance testing, in other words if it fails is there a non-destruction option?

After crop has been inspected by DATCP and issued a fit for commerce certificate, can growers bring their harvest to an off farm drying facility for drying?

If we are drying plants off farm, what do we need to do for legal documentation? (ie report location, post license its site at GPS at DATCP or something more)

I think all of us farmers are concerned about testing because it can literally ruin our whole crop. Do you anticipate that the average grower using reputable seed will have much to worry about? Also, to my knowledge, the emergency rule that regulates the hemp industry in Wisconsin does not mention deep carving or altering the hemp in any way prior to testing for THC. Is this a concern or do you expect anyone to challenge the results of the tests based on that?

Wondering if we will have clear legislation to protect us from the fact that THCA degrades into THC over time?

If you have a plot that is covered side by side by multiple hoop houses for early flower, aka light deprivation, with the same strain can this be tested with one tests?

Can we transport plant material from one location to another that are both registered under the same growers license without a fit for commerce certificate?

Selling

Could you sell a crop that tests over 0.3% to a company outside Wisconsin that allows for a higher total of THC?

Can we sell seedlings to other licensed growers who may not have a space to start seeds?

Can I sell hemp flowers such as pre-rolls?

Getting started/Other

When do you think you might have a more complete summary of planted acres?

Can we grow on a residentially zoned property outside of a residence? (ie a garage, out building, or greenhouse)

I would like to see a private use grow license? For example, two plants. Is this something coming or possible in the future?

If the industrial hemp is to help small farmers, why is the fee for over 30 acres only $5 per acre?  It should be $500 per acre. This will support small farmers.  Their fee thought process.

When will DATCP be updating the accepted seed variety list?

We have a lot of kids help us on the farm with hay or rock picking, etc. do the workers have to be 18 years of age to handle hemp?

What has to be done for state testing a hemp compliant plant strain kept in a vegetative state? I think it’s bringing back to our conversation actually before the webinar. Ones that are kept as mother plants and used only for vegetative cloning, it’s not best practice to let them flower.  It can cause hermaphroditism in future genetics. Yes, all this makes sense. So what is the state’s position on how to test or establish regulation on a hemp compliant strains that are allowed to flower finished crop? Will the state of Wisconsin prefer licensed hemp growers to manage/document the production of the entire completed crop female hemp plants back into the vegetative growing stage and then flowering and creating a second crop ten to twelve weeks later at the same plants to be tested twice within the second crop to date? I think it’s just to talk about the mother plants.

Does the greenhouse need to have a growing permit to grow from seed till transplanting into the fields?

What measures is DATCP taking to protect consumers from residual toxins from remaining soils? What notice is being given to producers about risks of tainting batches during processing and how will a consumer in Wisconsin buying a Wisconsin product know of there are dangerous toxins in their products?

Agronomics

Harvesting

Drying & Processing

Miscellaneous

10:55
Could you sell a crop that tests over 0.3% to a company outside Wisconsin that allows for a higher total of THC?

In Wisconsin, you cannot move a crop off the property that it is grown on if it tests above 0.3%. It does have to be destroyed unfortunately.

11:20
As a producer of CBD hemp seed can I put my 30-day harvest notification for the harvest window that we intend our varieties to be harvested at and then potentially harvest slightly later to allow the seeds time to mature? Since the seeds of maturity is after the flower of maturity for CBD?

Yes, you should be able to do that. As long as we know what you’re trying to do we will just you’ll try to work with you. Our concern often for hemp is that that it is enough below the 0.3% that when you market it to a processor, once you’ve harvested it, it’s still below the 0.3% for marketing and processing primarily.

12:10
If we are drying plants off farm, what do we need to do for legal documentation? (ie report location, post license its site at GPS at DATCP or something more)

Sending a notice to the email all locations; growing, processing, drying, everything, we should have the coordinates for all of those locations.

12:40
Can you harvest before you receive test results? I’m going to assume this means that you have sent in, it’s been tested and then can you harvest before you receive the results back saying you’re clear?

You can. The only thing you cannot do is you cannot move it from the property. If for some reason you thought you needed to do it, you need to contact us and we’ll have to try and talk our way through it.

13:08
When do you think you might have a more complete summary of planted acres?

When people would submit their planting reports. We need the planting reports.

13:30
What opportunities are there for breeding sterile females to avoid pollination concerns?

There’s always some opportunity. Breeding sterile females to avoid pollination. Male sterility exists in lots of other plants. That has been a very useful breeding tool for the past century. That’s that’s just something we need to discover still. If there’s any native male sterility that exists or if there’s a way to somehow genetically manipulate the plant either by using some advanced technologies such as CRISPR or some natural variation that occurs to create steriles. But I would say it’s possible. It doesn’t exist yet but it’s possible.

14:28
What other plants can potentially pollinate CBD hemp? We are receiving conflicting reports regarding wild hemp, giant ragweed and a wide assortment of other blooming weeds and are a bit concerned.

Wild hemp can pollinate. That’s the same species, it can pollinate your CBD hemp. I do not know of any other species that will pollinate your hemp.

15:00
What precautions are you making not to cross-pollinate on your grain plots with CBD fields?

Of the economic research, the grain research being the Arlington and Chippewa Falls and we don’t have our CBD plots there. Shelby has her CBD plots in other locations. A geographic barrier, that’s it. We don’t know what is being grown around there. For the most part we know that area pretty well and haven’t seen any nearby CBD farms. I would assume if you know you live close to a large University Research Station, you might want to get in touch with them to see what’s going on. The onus is on the farmer this year for that. Yeah and that’s across the board, the onus is on the farmer to figure out what’s being growing around them. There is no ruling that allows for different growers to grow in different places. Communication.

16:04
Is there a public list of processors that growers can contact about their services?

Liz Binversie talked a little bit about that. That we have a list going on the Wisconsin hemp website as well as Google. But something that we’re trying to work on is that at field day will be discussing what other processors exist. They’re out there. My first suggestion would be go to the Wisconsin hemp website.

16:35
Will the course be online? I assume we’re talking about the hemp course at UW.

Not the first year that it’s offered. The goal is to eventually put it online but for the first year it’s going to be an in-class course.

16:52
After submitting our 30-day harvest notification, can we harvest only harvest only our crop, no transfer to processors? So I assume it’s asking can we harvest after submitting our 30-day harvest notification, before the 30-day window expires and DATCP has not sampled the crop, after the 30 day when window expires and DATCP still has not sampled the crop, where after DATCP has sampled the crop before we received are fit for commerce certificates.

You can harvest the crop. We need to sample it. We sample it when it’s growing. After we have sampled it you can harvest it, you just cannot take it from the property until you received your fit for commerce certificate.

17:42
Do we have to harvest our crop within a certain amount of time after we’ve received that fit for commerce certificate?

Ideally you should harvest within 10 days of when you receive the fit for commerce certificate. This just applies to getting your crop harvested before the THC content gets too high. It can be tested anywhere further downstream and processors before they buy it may have it tested. They can be tested anywhere along the line and so you just really want it to continue through the marketing stream and be able to profit from it.

18:20
Can we transport plant material from one location to another that are both registered under the same growers license without a fit for commerce certificate?

You should have the fit for commerce certificate. You cannot take the plant material from the property it’s growing on without the fit for commerce certificate.

18:48
Can we grow on a residentially zoned property outside of a residence? (ie a garage, out building, or greenhouse)

There is a field grown hemp, there’s greenhouse grown hemp, there’s indoor grown hemp. Depending on your zoning laws you may be able to grow at a residence. You cannot grow in a residence. Attached garages are considered part of the residence. That was discussed earlier in the in the April 18th webinar, a lot of the planting and growing considerations. That’s right so that’s been on our website before the licensing period for this year, before the licensing and registration period that there is no residential growing in your house, in your home. There is no growing there. Yes. Also, you need a minimum of 15 plants so that we have enough material for testing at the time of testing.

20:03
I would like to see a private use grow license? For example, two plants. Is this something coming or possible in the future?

I do not know if there’s going to be any private use grow licenses. We follow federal regulations and federal laws and we are waiting for the federal government to give us guidelines based on the 2018 farm bill legislation. We will see what happens with that. I know there are some states who have some private use allowances. Currently in Wisconsin we do not. We’ll just have to wait and see what comes with that.

20:48
I think all of us farmers are concerned about testing because it can literally ruin our whole crop. Do you anticipate that the average grower using reputable seed will have much to worry about? Also, to my knowledge, the emergency rule that regulates the hemp industry in Wisconsin does not mention deep carving or altering the hemp in any way prior to testing for THC. Is this a concern or do you expect anyone to challenge the results of the tests based on that?

I don’t know if anyone will challenge the results. We have a good foundation for what we’re doing and so the way that we’re doing things we will continue to do them. I would say if you have concerns about your crop potentially being too hot, that you take some samples and take them to a private lab. Last year we have one variety that failed across the board until we prohibited that variety. There were a few other varieties that failed in some situations and you know so you just have to be aware that there’s not a guarantee. One of the things, the more plant material that we take when we come to sample, the lower the THC content may be overall depending on the crop. There will be a few hot plants in every crop and so the more plant material we take the more it will be representative of the crop. For folks who have larger plots that’s easier to do. People sometimes complain they don’t want us to take a lot of plant material but it’s actually to your benefit.

22:36
There’s a question here about estimated dates and times for harvesting and we’re going to talk about that later in the webinar so I’m going to skip that question.

22:47
For the bus tour, is the bus handicap-accessible? That will be to you Rodrigo I assume.

Yes. When you’re doing the RSVP there is an option so if you need any assistance please let us know ahead of time because we want to be able to accommodate everyone’s needs.

23:29
Is a notice required if taking a sample to a private lab to be tested before the initial DATCP test?

No. You do not need that.

23:40
Why do you need so much material for compliance testing? Doesn’t HPLC require an extremely small amount of material?

We’re taking a representative sample of the crop, whatever the crop is. If you have only a dozen plants, the representative sample is going to be a dozen plant tops. So that’s going to be from a dozen plants. If you have 30 acres, a representative sample will be fewer plants across the 30 acres. We have to take a representative sample of the crop and if the crop is uniform then we take you know just a representative sample of the plants that are there. If there’s a lot of variability in the plants, then we need to get some of each of the different plants that look variable, look different.

24:40
How soon until you offer remediation plan options for hemp that fails? I know DATCP compliance testing, in other words if it fails is there a non-destruction option?

At this time there is not a non-destruction option. We will wait to see what we will get from the federal government on under the 2018 farm bill. Our program will have to be in compliance with their guidelines. They will be giving us guidelines on a number of things including whether or not there’s opportunities for remediation.

25:15
How much of the top of each plants gets cut off from each sample? One inch or more?

Two inches. We take two inches from the tops of each plant.

25:39
If the industrial hemp is to help small farmers, why is the fee for over 30 acres only $5 per acre? It should be $500 per acre. This will support small farmers. Their fee thought process.

I personally did not set the fees. The people who set the fees looked at all the other states across the country and made the most reasonable decisions possible based on the fees. Wisconsin’s fees are actually lower than many other states. We will be looking at the fee structure again when we’re doing new legislation. Once the 2018 farm bill guidelines come out and also there is Senate Bill 188, which is going to be the new legislation that will help our program to align with the 2018 farm bill, then we’ll be writing new rules and will be considering fees at that time. But for now the fees are what they are.

27:02
When will DATCP be updating the accepted seed variety list?

We’ll probably do that before the licensing for next year.

 

CBD Session Q&A

 

42:54
Do agronomists have any recommendations for moisture meters? We can use grain moisture but are there specialized flower moisture meters for CBD hemp?

I do not know the answer to that. I do not test by moisture, I usually have done it by sight. Specific to CBD, I don’t know. I’m not aware of any moisture meter for CBD. There is a moisture meter specific for grain but it is manufactured in Canada. For the life of me I can’t remember the name now. There is a moisture meter for hemp grain that’s being used for official grain purposes up in Canada. One thought I had about CBD was possibly, they have these hay test moisture meters so something like that it’s possible. I’ve heard anecdotally that if the CBD crop is dry if you’re able to snap the branches as opposed to just letting them thin, that would be an indication of this dry. Yeah you’re looking for I think an 8 to 10 percent moisture content is ideal and that is a test that’s frequently used. Any branch that’s kind of larger than pinky size if you can readily snap is indicative it’s dry enough.

44:27
We have a lot of kids help us on the farm with hay or rock picking, etc. do the workers have to be 18 years of age to handle hemp?

No, there is no requirement or age limits on handling hemp.

44:53
What has to be done for state testing a hemp compliant plant strain kept in a vegetative state? I think it’s bringing back to our conversation actually before the webinar. Ones that are kept as mother plants and used only for vegetative cloning, it’s not best practice to let them flower. It can cause hermaphroditism in future genetics. Yes, all this makes sense. So what is the state’s position on how to test or establish regulation on a hemp compliant strains that are allowed to flower finished crop? Will the state of Wisconsin prefer licensed hemp growers to manage/document the production of the entire completed crop female hemp plants back into the vegetative growing stage and then flowering and creating a second crop ten to twelve weeks later at the same plants to be tested twice within the second crop to date? I think it’s just to talk about the mother plants.

We do need to test the mother plants but we don’t need to test all the mother plants. So you could keep some in a vegetative state, we need some to go to more maturity so that we can actually give them an adequate THC test. Then the clones that are coming from that same crop can be used for planting, can be sold, can be moved. It all kind of goes back to if you want to move crop from the property it has to be tested. We recognize that people want to grow clones and they want to sell them and they need to keep things in a vegetative state in order to do that. If you can take like some subset of those plants and have those go to maturity, we can test those as the representative of the crop and then we can give you that fit for commerce certificate that then you can use for those clones.

46:56
Can we sell seedlings to other licensed growers who may not have a space to start seeds?

Yes you can grow seedlings to other licensed growers. We like to see that represented on your planting form and there’s a there’s a transfer column where you may transfer plants in, you might be purchasing seedlings or you’re transferring plants out where you’re selling seedlings.

47:29
Can I sell hemp flowers such as pre-rolls?

Once a crop has been tested, you can do whatever you want with that crop and so yes that would be correct.

47:45
Wondering if we will have clear legislation to protect us from the fact that THCA degrades into THC over time?

I’m not sure exactly where that question is going. I think that you know the THC content can be kind of a moving target and so you want to have a good test result for your crop and then and move it off to processing. I don’t know that there’s a hundred-percent guarantee. I’m not sure that I’m really answering your question adequately.

48:31
What measures is DATCP taking to protect consumers from residual toxins from remaining soils? What notice is being given to producers about risks of tainting batches during processing and how will a consumer in Wisconsin buying a Wisconsin product know of there are dangerous toxins in their products?

That’s not something that is up to the purview of the Department of Ag. No, we don’t do that kind of testing. A testing would be done downstream somewhere from growing. That’s one of the issues, not issues but one of the potential issues in this whole industry is that those regulatory procedures are not in place and that a lot of these processors, etc. are not being tested and so you need to be pretty consciousness as a consumer about where you’re getting your product from.

49:33
After crop has been inspected by DATCP and issued a fit for commerce certificate, can growers bring their harvest to an off farm drying facility for drying?

Yes. Yes, once you get the fit for commerce certificate you can move it to wherever you want to move it to.

49:54
Has cannabis aphid been discovered in Wisconsin yet?

That I don’t know, I have not heard of cases of cannabis aphid.

50:07
Are there pre-emptive sprays that growers can use for prevent mildews and molds?

Unknown on that. David Smith will be there and he will provide some information.

50:31
Is there list of any oils that can be used to remove pests? Any preventive measures before?

I will say that there are lists of acceptable oils and sprays on, it’s through federal regulation but that list is up on the Wisconsin hemp website and available at the DATCP website as well. That will list out each oil, what it is and what it’s used for. Oils and soaps and also a lot of recommendations say once the plant begins to flower you no longer want to use those. Some of the late maturing, the late season molds that you’re going to see, it becomes more difficult and more of a cultural practice of keeping airflow and removing that part of the plant that’s contaminated because once that flowers there you want to put minimal stuff on your plant.

51:29
Can growers stagger their harvest over several days or even weeks once it has been inspected and approved for harvest?

Well, if you’re going to have very different harvesting times you might want to have multiple testing times because the THC content continues to go up. Let’s say we come out and we test and you’re good to go and you harvest some early that is going to also probably be good. As the THC content continues to go up some of the later harvest might get past that point three percent THC and you might lose out somewhere in selling it to a processor if they have it tested, they might not buy it because of the THC content being too high.

52:18
Is there a risk of flowers falling off during harvest?

I’ve never heard of that. It’s pretty much on there. Yeah, I would say there is a small risk if you have to dry of plants and they dry quickly that those trichomes can break off and become brittle in which case you will lose your cannabinoids. That might be more the consideration is drying too fast and having those trichomes fall off your flowers.

52:49
Do you have resources for planning or building adequate drying chambers or sheds for smaller scale farmers growing only a couple hundred plants?

I think you know kind of your general shed building, hoop houses, some people are using like bare hoop houses, high tunnels. There are people building large drying facilities or lease so those will be available if they’re not already but finding those connections is kind of the thing right now. That’s the hurdle.

53:28
What is a good method to fix nutrient lockout with plants outdoors in a field?

Nutrient lockout, a lot of the time is occurring because your soil is too wet. Not growing in clay soils and making sure that your soil is well aerated is probably the thing that you’re going to do and also making sure that your roots aren’t bound when they’re planted. High clay soils, very very high organic soil – I mean that’s going to cause the most nutrient lockout. Aerated, loamy, sandy soils.

54:15
What is the latest time of year CBD hemp can be harvested?

That’s going to depend on its developmental stages, its dryness and then obviously if you have sent in your paperwork to DATCP in an appropriate and timely manner. And snow. Right, also frost. That’s your cutoff window, when you’re when you’re hitting frost but before that those are the indications.

54:42
Any suggestions for a consultant to help on indoor greenhouse operation, standard operating procedures?

I’m not doing indoor protection myself but the UW website again. It’s a good link, without us promoting a specific one. I would like to say yeah, go to that.

55:08
Does the greenhouse need to have a growing permit to grow from seed till transplanting into the fields?

Yeah. Well you need a grower a license and you need that location registered. We need to have those coordinates for that so if you are growing. If you plant you need to have those locations registered.

55:32
We heard that processors have the ability to dilute the THC percentage. Is that accurate?

Yes. Yeah with those isolates you can begin to make whatever concentrations you so desire.

55:48
If we have to cull plants before harvest or prune leaves, can we compost this on-site, feed to chickens, or are there other ways to destroy and dispose of the plants?

I will say that if you’re pulling male plants that there are instances of, especially depending on how late you’re pulling that male plant that could actually still be mature pollen in that sack, even if it’s not been released. I do not recommend dumping that plant or composting it close to your fields. In terms of feeding to animals, I know you the grain is not legal to feed to animals. I’m not sure about composting and feeding. I mean I’m not sure if you’re going to be feeding the chicken that’s probably going to be grain. Right. Even you know, we were talking about remediation earlier, even if you were trying to use like hemp that you couldn’t sell as animal bedding that’s not even allowed yet because the animals might eat it. For now you just kind of have to keep everything away from the animals. Maybe composting and returning it to the soil would be acceptable. Sure.

57:03
Is there somewhere to send plant material for petiole testing and if so do they have recommendations for nutrient levels?

Again, I would say the Wisconsin hemp website has all those lists of different people and I know of several different labs that are doing that and they are on that website.

57:24
If you have a plot that is covered side by side by multiple hoop houses for early flower, aka light deprivation, with the same strain can this be tested with one tests?

Say this again. If you have a plot that is covered by multiple hoop houses, so it’s more than one field. If they’re separated, if they’re separate like distinct greenhouses, distinct hoop houses, those are separate testing locations.