A Letter From Wendy Mosher, HFC Vice President.

Hempseed Meal for Laying Hens. Such a technical and specific title. I thought it may be enlightening to fill in the story around how this came to be.  Animal nutrition has always been near and dear to my heart – I firmly believe that even if you are a vegetarian,  the health of our animals contributes to our health.  That coupled with the incredible nutrition of hemp grain was enough for a group of hemp industry stakeholders to maintain the passion to bridle the seven-year journey ahead.

Years ago, in 2017, my then-Colorado state representative Jeni Arndt (who is now my town’s mayor!) together with Senator Donovan co-sponsored SB17-109 – the purpose of which was to convene a review of the feasibility of hemp in animal feed, under the auspices of our Agriculture Commissioner.  For roughly four months, I was lucky to be able to participate and learn from representatives across the feed world: veterinarians, CSU nutrition experts, various state Department of Ag representatives, Cattleman’s association,  AAFCO representatives, hemp industry stakeholders, and of course, the FDA Center for Veterinary Medicine, whose role is to approve feed applications.  The resulting report compiled from the think tank acknowledged the potential value and recommended that the industry lead the efforts to pursue approval. A fellow member of the stakeholder group Hunter Buffington and I met to discuss the next steps, and in early 2018, the Hemp Feed Coalition was born.

As is usual with any new organization, we spent the year of 2018 storming, norming, and defining our path.  Hunter led the newly created 501(C)3 as Executive Director in the early days, and together we contemplated: Were we purely an educational service for the industry, or did we need to write and submit applications? Should we conduct research in our private companies, or rely on universities? How can we get researchers to pay attention? If so what species, do we target the most valuable feed market first, or build on existing research to make the process faster? We were a ragtag group of believers, and none of us had the rounded expertise to know how to evaluate the research landscape, write the application, and conduct relevant clinical studies to fill in data holes, much less understand the regulatory steps and process.  But a little passion can go a long way; we expanded our stakeholder group to include esteemed leaders in the hemp industry,  we listened and learned from expert advisors in each of these areas, identified qualified researchers, and gave much of our own company’s capital, time, and sweat equity to push to what we hope is an imminent finish line. 

The organization determined the best approach would be efficient, and practical: to submit an application. Because of existing, published data and market potential, we decided to narrow efforts to pursue approval for hemp seed meal for laying hens. A feed formulator and trial partner was identified, and a feed trial commenced. Hempseed meal samples were prepped and analyzed, and an Ingredient definition was submitted. The organization continued to grow, and IND HEMP’s CEO, Morgan Tweet undertook the role of Executive Director, I vacated a steering committee role to assume the role of Vice President of the Board, and Andrew Bish from Bish Enterprises assumed the role of President. 

As evidenced by the timeline above, the approval process has been long and tedious, though importantly has been informative for HFC’s subsequent submissions (We’ve identified areas to make it more efficient!).  Reasons for this abound: The FDA-CVM is granted a 180-day turn-around time for each submission and subsequent response, creating a regulatory process that can span years. It is not uncommon to need clarifying information and each time the “180-day clock” is restarted.  FDA-CVM’s office is woefully understaffed – comprised of a small group of scientists who are managing hundreds of feed apps simultaneously and take seriously their charge to maintain feed safety. In addition, the Hemp Seed Meal for Laying Hens application was not perfect upon first submission, there was a learning curve, and we were submitting a never-before-seen ingredient. Even the most skilled cohort will have a longer time when applying for a completely novel ingredient.  At the time of the application, the assays for testing hemp and its cannabinoids were being refined.  Finally, regulators, in general, were suspicious of hemp and preferred to stand in the no-risk, “yeah but” lane.  HFC consistently advocates to be held to the same standards as other ingredients.

We are hopeful that hempseed meal for laying hens will be approved by the FDA-CVM and AAFCO in early 2024. This momentous achievement will broaden market opportunities and economic growth for rural businesses, hemp producers, livestock producers, feed mills, and more. The nutritional value of hemp seed will certainly speak for itself through improvements in animal health and in turn, the nutrition we receive from our livestock.

A big thank you to the key partners that have championed this hemp feed application; it truly takes an expert village, and we are grateful for their collaboration. This application required dollars, research, analysis, and stamina to communicate with regulators and get them the answers they needed. The HFC Board Members provided a large piece of that needed expertise. In addition, I’d like to acknowledge the following groups – Our friends at Wenger Feeds formulated the laying hen feed and conducted both feed trials. The amazing folks at IND HEMP sponsored the GAP Assessment for literature review, provided ingredient samples, coordinated application responses and communication with regulators, as well as provided marketing and fundraising support. Healthy Oilseeds provided ingredient samples and supported state grant initiatives that enabled HFC to conduct further ingredient analysis. Eurofins completed diligent work on method validation and sample analysis that was essential for this application to satisfy FDA’s requirements. Lastly, I’m proud of the New West Genetics team, who as founding members of HFC have contributed to its direction, regulatory responses, and direct marketing support from our fearless social media director.

The outcomes of this challenging process will lead not only to the approval of hempseed meal for laying hens but also a much more efficient process for the approval of other nutritious hemp seed ingredients across species and animal groups. HFC has learned much and has already begun work for the next species.  I am proud of the work we do at HFC and invite you to join us – become a champion for the industry!  

To become a member and learn more, visit Hemp Feed Coalition.