The Hemp Feed Coalition proudly shared the success of our application for Hemp Seed Meal for Laying Hens as an AAFCO Tentative Feed Definition. Although there remains one more critical vote in August, the major hurdles have been cleared first with FDA-CVM, then the Ingredient Definition Committee, and lastly the AAFCO Board approval this past week.
Unfortunately, some in the industry have tried to distort the reality of this accomplishment to a false narrative and it has prompted HFC to respond.
For clarification, HFC submitted the original application for hemp seed meal defined as “the product obtained by grinding or milling the cake, which remains after most of the oil is removed from the seeds of Cannabis sativa L. by a mechanical extraction process.” HFC along with a full steering committee of hemp seed processors collaborated to pen the original manufacturing definition that is required for the submission almost three years ago. In that definition, nothing outside of Good Manufacturing Practices and traditional seed cleaning equipment were called out to mitigate contaminate risk and ensure the cannabinoid thresholds were met.
Again, nowhere in the application were proprietary or specific varieties called out, burdensome seed cleaning technology deployed, or dehulled hemp seeds utilized.
Although HFC advocated for higher thresholds of cannabinoids in the original application, we cannot refute the evidence that was presented in the application, specifically when it came to the meal utilized in the chicken feed study. Through our review of several different meal samples and then the analysis of commercial hemp-enriched chicken feed, we proved that processors within the US have shown that they can and have met the recommended threshold of 2ppm for Total THC and 20ppm Total CBD. If anything, this is an instance where we were graded on the measuring stick we provided.
We recognize there may be concerns around the sensitivity of testing methods and encourage groups like Ag Policy Solutions to stay focused on their work with ASTM to help bring reasonable methods and standards to the industry. There are labs across the country that can test to the levels of detection and quantification FDA is requesting. It may not be what we want in the long term, but it is achievable today.
This is a critical baseline for the industry to build off and we implore all who have doubts to recognize the opportunity at hand. We heard repeatedly from regulators both within AAFCO and FDA-CVM that this definition can be amended with increased levels of cannabinoids should we deem it necessary and have data to support it in the future. If you would like to work with HFC to coalesce data to that end, we are happy to collaborate and help coordinate an FDA-level feed study for analysis.
Our goal is to continue to open markets, but we lead with safety and science first and foremost. We hope individuals recognize the leadership HFC continues to display in this arena and support others in their passions for alternative and necessary missions. If we’ve learned anything over the years it is clear our industry struggles with cohesion, and we are eager to see that change soon.
Check out the Tentative Definition here: Applications – Hemp Feed Coalition