California Moves Towards Licensed Organic Cannabis: The OCal Program

The California Department of Food and Agriculture (CDFA) published proposed regulation to form an organic cannabis certification program. The following summarizes

The CALIFORNIA CODE OF REGULATIONS: OCAL PROGRAM. Leaving out packaging, record keeping, track and trace and other legal maintenance, we will pinpoint the organic agricultural content summarized in 10 sections. On terminology, OCal is the term of usage for this program not Organic, referencing it is “prohibited from selling, labeling, or referring...products as organic,” defined in Article 2 Section 10103. These are the 10 sections that define the organic agricultural character of the OCal certification program: 

1. Article 2 Applicability: Section 10105. Allowed and prohibited substances and methods in OCal production. 
2. Article 3. General Section 10200. General. OCal Cultivation and Distribution Requirements.
3. Section 10201. OCal cultivation and distribution system plans. 
4. Section 10202. Land Requirements. 
5. Section 10203. Soil fertility and crop nutrient management practice standard. 
6. Section 10204. Seeds and planting stock practice standard. 
7. Section 10205. Crop rotation practice standard. 
8. Section 10206. Crop pest, weed, and disease management practice. 
9. Section 10208. Facility pest management practice standard. 
10. Section 10209. Commingling and contact with prohibited substance prevention practice. 

1. For Article 2, section 10105 Allowed and prohibited substances and methods in OCal production, references the National List of Allowed synthetic substances and ingredients, 7 C. F. R. section 205.601 and non-synthetic substances and ingredients in section 7 C.F.R. 205.602. The lists are too tedious and long to list. 

2. For Article 3. General Section 10200. General. OCal Cultivation and Distribution Requirements; Section 10200, states cultivators need to, “improve the natural resources of the operation, including soil, water, wetlands, woodlands, and wildlife, and respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.” 

3. Section 10201. OCal cultivation and distribution system plans. Focused on eliminating commingling of OCal and non-OCal products. To improve the natural resources of the operation, including soil, water, wetlands, woodlands, and wildlife, promoting ecological balance, and conserving biodiversity. Also to document OCal seeds usage.  

4. Section 10202. Land Requirements states no prohibited substances for three years, distinct boundaries, onsite signage of OCal and non-OCal.

5. Section 10203. Soil Fertility and Crop Nutrient Management Practice Standard. Growers must improve the soil not erode it, manage nutrients and fertility through a variety of means; rotation, use animal materials for soil improvement incorporated into the soil 120 days prior to harvest, compost plant and animal materials produced through a process that establishes an initial C:N ratio of between 25:1 and 40:1, as well as a list of synthetic substances The National List of Allowed and Prohibited Substances 7 C.F.R. section 205.601, 7 C.F.R. section 205.602. The cultivator shall not use animal materials that contain synthetic substances included in the National List of Allowed and Prohibited Substances 7 C.F.R. section 205.601; nor use sewage sludge for crops, or burn crops to dispose of them.  

6. Section 10204. Seeds and planting stock practice standard. A cultivator shall use its own OCal grown cannabis seeds or a certified nursery licensed. Except, Non-OCal grown untreated seeds may be used to produce OCal cannabis when OCal grown seeds are not commercially available; or treated seeds can be used with a substance the National List of Allowed and Prohibited Substances. 

7. Section 10205. Crop rotation practice standard. A cultivator shall implement a crop rotation, to improve soil organic matter, pest and nutrient management, and control erosion. 

8. Section 10206. Crop pest, weed, and disease management practice standard. A cultivator shall use management practices to prevent crop pests, weeds, and diseases, by crop rotation and soil and crop nutrient management practices. Also, sanitation measures to remove disease vectors, weed seeds, and habitat for pest organisms; Cultural practices that enhance crop health, including selection of plant species and varieties with regard to suitability to site-specific conditions and resistance to prevalent pests, weeds, and diseases. Control diseases through non-synthetic inputs, and synthetic substances found in The National List of Allowed and Prohibited Substances C.F.R. section 205.601. 

9. Section 10208. Facility pest management practice standard. Pest prevention practices at a Removal of pest habitat, food sources, and breeding areas; using non synthetic substances or synthetic substances consistent with The National List of Allowed and Prohibited Substances 7 C.F.R. section 205.601 through 205.602. 

10. Section 10209. Commingling and contact with prohibited substance prevention practice standard. A cultivator or distributor shall implement measures necessary to prevent the commingling of OCal and non-OCal cannabis. This includes packaging materials, storage containers, all containers or reusable bags. Any materials, bags or containers with synthetic pesticides cannot be used or OCal represented.

The points of action included in cultivation requirements section 10200, cultivation system plans section 10201, soil fertility and crop nutrient management section 10203, become the foundation for organic and regenerative agriculture. Such organic farms produce the highest quality products with the highest medicinal value for the market as well as cool the planet and balance our ecology. It is a win all around; our health and the health of the planet. Consumer support for organic farmers should develop, without big name distributor brands who overcharge transportation, marketing and sales. Cleaner, leaner business systems that tie organic OCal cannabis farms with customers through cutting edge software is possible and needed. Ideally, this will be done by equity cannabis businesses, in the efforts of overcoming the damages done by the war on drugs. The alliance between OCal cannabis farms and equity cannabis businesses could be powerful in transforming the players of the California Cannabis industry.