My next proposition may seem outlandish, and I offer it for discussion: Centralized Processing. I have come to believe that it could provide the balance between a hyper-regulated California business environment and the small farms of rural California.
Cannabis flowers are delicate; drying and curing should be maintained on-farm. I envision a box-truck that pulls up at the farm. The farmer loads sealed, labeled containers (appropriate packaging for storage that the co-op buys in bulk) of cured, unprocessed medicine. In a perfect world, the co-op is capitalized to pay farmers out for a portion of their harvest right away to cover operating costs.
It will take time to establish trust; the initial build-out needs to include locked storage for individual farms with the key held by farmers in a dark, temperature controlled facility. One issue with the current system is storage of cannabis is difficult on a farm-by-farm basis, in part because farmers have to hide their product. The co-operative could help by providing storage and developing packaging to store larger volumes of raw product.
Farmers could then contract with the co-op for processing (or could use processing rooms for their own staff); decisions could be made about the projected marketplace for the product, which would determine what quality of trimming/processing would be required. Tracking product into appropriate markets will enable farmers to access the niche that best fits their production style.
Establishing secure storage and stable business contracts with expected deadlines will enable the co-op to manage trimming to meet demand. This way, the harvest can be processed as needed. With normalized communications and ordering processes, co-ops could meet the needs of customers with the different types of medicine produced by the different farms. Co-op procedures could be set to trim up X number of units/farm as they come in so that the work gets done in an equitable timeline.
Using The Cluster Effect to Win in Rural California
We need to create business zones that foster the Cluster Effect in our rural communities. Successful implementation of the MMRSA guidelines will happen if processing, custody transfer for taxation and testing occur in one location. Creating transport steps between them will yield an undue cost burden that will keep producers from seeking legitimacy.
Farms who want to self-process retain that ability and would bring finished units to the Coop for testing by the independent lab on the premises. Locating all of the services that will be required to have finished products ready for retail in one complex of independent businesses will address public safety concerns, shorten the supply chain, while avoiding onerous costs and overregulation.
Locating these clusters in farming communities will create stable jobs and businesses that support the decentralized system that exists. Balancing traditional planning interests with the needs of the emerging industry, we should locate cannabis processing and raw plant manufacturing in rural areas where production is located and impacts to residential centers are minimized.
The legislature and regulators are concerned with tracking and quality control. Centralized processing encourages trace-ability and tax payment because of placement upstream from retail outlets, without putting undue burden on farmers.
Cannabis farmers have been denied the ability to keep records by a Prohibition reality that used records as incrimination to prosecute and imprison us. In seeking to create a compliant, functional system, we must first honor this legacy of Prohibition by seeking workable solutions. To create a sea-change of ability from farmers, systemic support is essential.
Centralized processing locations create the appropriate balance between regulatory need and undue burden on producers, holding a space where chain of custody transfer and testing can occur. Raw (cured) product being brought in could be identified by Batch/Lot and tracking/tracing could begin from there.
Encouraging farmer-owned co-operatives creates mechanisms for internal qualitative controls; the strength of the brand is as strong as its members. Co-operative frameworks provide opportunities to translate Best Management Practices onto the unique farms of the cannabis industry. Standards of Practice and appropriate quality assessment/quality control procedure enable tracking of product into appropriate markets.
This pathway will enable the creation of legitimate distribution channels which will serve to continue the rollback of Prohibition detriments to the environment, to communities and to the overall economic productivity of this country. The shift is happening; we must guide it with discussion and practice, seeking the way forward.
I offer this for discussion, not as a definitive. Looking forward to hearing thoughts from the community☺