Humboldt County’s Agricultural Commissioner Talks Cannabis Control

Humboldt County initiated the Humboldt Proof of Origin Pilot Program in August 2016, which combines a secure Proof of Origin stamp with anti-counterfeiting measures and an information management and sharing platform to securely identify, track and trace medical cannabis products that originate in Humboldt County. SICPA sat down with Humboldt’s Agricultural Commissioner, Jeff Dolf, to get his thoughts on the pilot.

What are the goals of the pilot?

The primary goal of the pilot is to make sure the county’s program is consistent with state requirements for track and trace. Aside from state regulations, the other thing we want to address in our cannabis control solution is the principles outlined in the Cole Memo, which shifts priorities away from strict enforcement of federal cannabis laws and gives states more leeway in the case of “jurisdictions that have enacted laws legalizing marijuana in some form and that have also implemented strong and effective regulatory and enforcement systems to control the cultivation, distribution, sale and possession of marijuana.” This pilot demonstrates that we are meeting these stipulations.

What made you decide to partner with SICPA on this effort? How does SICPA’s solution meet your needs?

It became apparent early on in this effort that the system SICPA offers provides other aspects, in addition to track and trace, that are important to the county. Humboldt County is unique in terms of the scale and scope of the medical cannabis industry here. The integrity of the Humboldt name is important—“Humboldt” means something in the cannabis world. The SICPA approach to track and trace offered us a way to safeguard the integrity of the Humboldt County artisanal brand, which in turn incentivizes industry to come into compliance along with our program.

SICPA’s ability to offer consumer engagement is important, too; having the QR code and Proof of Origin website and app allows patients to learn more about the quality of a product and lets them engage with the producers themselves.

Lastly, the batch and lot approach was very appealing. The grower community has been outspoken about not following plant tagging because it’s labor intensive and does not prevent diversion out of or injection into the cannabis supply chain. The fact that SICPA’s solution can begin tracking and tracing at the batch and lot level, and does not require starting at the individual plant level, was preferred by the industry, and we know it’s credible because of SICPA’s long history of providing these services in other industries including for all cigarettes distributed in California.

How has SICPA helped you shape this program?

SICPA has helped shape the program by sharing their expertise in safeguarding brand and product integrity as well as their experience and knowledge doing track and trace. For the county, it’s been really important throughout the pilot process to learn from SICPA’s experience and about the principles of applying track and trace methodologies to this industry so that we can be prepared for the scale of what is coming as more of the industry comes into compliance. We are still very young in our development of this process, but we are much further than we were when we started.

You launched the pilot on August 1. Tell us about what it was like to prepare for the launch? How did SICPA help you get ready?

SICPA has been engaged leading up to and after the launch by providing support and training not only to county staff, but also to all pilot participants. SICPA was really supportive in answering questions and helping to alleviate any trepidation that we had going into this endeavor. They have offered outstanding customer support and the pilot participants have been very outspoken in their appreciation of SICPA’s efforts.

Now that the pilot has launched, do you have any preliminary thoughts on how it’s progressing?

The pilot is going well. We’ve inspected all the cultivators that are participating and have found only a few discrepancies related to production declarations. There was one instance where a producer had suffered crop loss and was obviously not going to have the same level of crop that he had estimated in the system, so we worked with him to amend his production declaration to reflect that loss. In this particular case, the cultivator had photographs of his plants that showed they clearly died due to some illness. Things happen in agriculture—we are subject to forces of the environment. SICPA’s system allows cultivators to record explanations for any change to their production declaration. This particular case uncovered the need to add functionality to the system that allows cultivators to attach photographs to their explanations and we are now engaging with SICPA to define this feature.

Many states, including California, use similar track and trace programs to ensure proper collection of excise tax revenue. Do you believe this program could effectively handle a tax component? If so, how do you envision SICPA’s solution will help that process?

We have Measure S, our county’s excise tax for medical cannabis, on the November ballot, so we will see what happens. If the measure passes, we believe SICPA’s track and trace program can provide us with another way to assess whether a medical cannabis licensee is paying the right amount of tax to the county. The tax will be will be based on cultivation area, so the production declaration in SICPA’s system will give us another way of looking at that.