Gourmet-Hemp-Foods_Director-Eric-Welsh-DOD-Hemp-Policy.pdf - Joe Domino, Co-CEO, Gourmet Hemp Foods

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Awaken the World to the Benefits of Hemp Joe Domino, Co-CEO, Gourmet Hemp Foods LLC 11533 Busy Street Suite 168 North Chesterfield 23236 Office of the Under Secretary of Defense for Personnel and Readiness Operational Readiness and Safety ATTN: Eric Welsh, Director, Drug Testing and Policy 4000 Defense Pentagon, Suite 1E532 Washington, DC 20301-4000 Dear Director Welsh, I received your contact information after reaching to Mr. Eric Hollins' office with the United States Marine Corps Command in order to satisfy my inquiry concerning the 'HEMP AND DOD POLICY' disseminated by your office: DEFENSE OFFICE OF DRUG DEMAND REDUCTION PROGRAM. First off, a quick back-story. My company produces gourmet sauces with hulled hemp seeds and hemp seed oil and DeCA HQ abruptly halted our application to supply the Army Commissary because of policy directives coming from your office. Subsequently, representative at DeCA referred me to the office of 'Operation of Supplement Safety' and I have included my correspondence with them. OPSS shared the following link which redirected me to each Military Branch's respective policies concerning the consumption of hemp-derived products. https://www.opss.org/article/hemp-and-dod-policy Here's my issues: If your office makes the final call on policy-making on these hemp- related matters, then why does each branch of the military have contradictory policies from one to another? Below, I've copied and pasted each policy statement by the four Military Branches concerning hemp. After reviewing each statement, it’s self-evident that there’s a mitigation problem between your office and the respective military branches which must be clarified. I've bulleted the main issues that need to be addressed. 1|Page 1) Can you please define the ambiguous term 'Hemp Oil' used by the Army 2) If the Coast Guard is under the impression that hemp ingredients that are FDA approved and regulated are fine for their servicemen, and the Coast Guard is abiding by the identical orders give to the other three branches, then shouldn't this be the policy adhered by all four branches of the U.S. Military? 3) I see a lot of concern over ‘Hemp Oil,' but no mention of Hemp Seed Protein which, also, has an FDA GRAS Notice. In conclusion, I am seeking a letter from your office ( DEFENSE OFFICE OF DRUG DEMAND REDUCTION PROGRAM ) clarifying your position concerning: Hemp Seed Derived Products Regulated & Approved by the FDA. ARMED FORCES POLICIES CONCERNING HEMP: 1) Air Force: There is no mention of Hemp Seeds or its' distinction as a completely independent from either CBD or THC. This definition is seemingly overbroad. ‘ The use of products containing or derived from ‘hemp,’ as defined in Public Law 115- 334, Agriculture Improvement Act of 2018, may interfere with the Air Force Drug Testing Program. In order to ensure military readiness and the reliability and integrity of the Drug Testing Program, the knowing ingestion (orally, intravenously, through smoking/vaporization, or through other means) of products containing or products derived from hemp is prohibited.’ 2) Army: The term 'Hemp Oil' is a very misleading term because it denotes two entirely distinct hemp-derived products. One product being hemp seed oil, which is cold- pressed vegetable oil (being very similar to flax seed oil) and is a regulated and approved FDA food additive being sold in grocery stores nationwide. And then there's ‘hemp extract’, which comes, primarily, from the botanical biomass and processed with a solvent that concentrates the 'Cannabinoids.' Which of these two by-products is the Army referring to when they use the term ‘Hemp oil’? Please advise. ' In addition, this regulation prohibits Soldiers from using Hemp or products containing Hemp oil. It also prohibits using the following substances for the purpose of inducing excitement, intoxication, or stupefaction of the central nervous system. This provision is not intended to prohibit the otherwise lawful use of alcoholic beverages’ 3) Navy / Marines: Same as the Airforce’s policy, there is no mention of hemp seeds or their distinction from CBD or THC. This definition is seemingly overbroad. Effective immediately: a. Sailors and Marines are prohibited from knowingly using products made or derived from hemp (as defined in 7 U.S.C. 1639o), including cannabidiol (CBD), regardless of the products THC concentration, claimed or actual, and regardless of whether such product may lawfully be bought, sold, and used under 2|Page the law applicable to civilians. Use means to inject, ingest, inhale, or otherwise introduce into the human body. Use includes the knowing use of hemp products designed to penetrate through the skin layer, including but not limited to transdermal patches. 4) Coast Gaurd: The below statement is contradictory: how can you bar people from consuming hemp seed oil, and in the same sentence, declare that hemp seed ingredients are fine if they are regulated by the FDA? Hulled seeds, hemp seed oil & hemp seed protein all have GRAS notices: https://www.fda.gov/food/cfsan-constituent- updates/fda-responds-three-gras-notices-hemp-seed-derived-ingredients-use-human- food ' The Coast Guard does not tolerate the intentional use of illegal drugs, illicit chemical analogues, or prescription drug misuse. This includes ingestion of hemp oil or products made with hemp seed oil; however, does not include food items regulated and approved by the Federal Drug Administration (FDA) that contain hemp ingredients.’ __ Lastly, if hemp seed derived products were, in fact, intended to be banned by your office, can you please follow-up with all the relevant research which declares how/why hemp seeds impair the 'readiness’ of our troops? I have found one National Institute of Health (NIH) peer-reviewed study that should put that theory to bed. Its’ conclusions are quoted below. EVALUATING THE IMPACT OF HEMP FOOD CONSUMPTION ON WORKPLACE DRUG TESTS 2001 Nov-Dec;25 | Leson G, Pless P, Grotenhermen F, Kalant H, ElSohly MA. ' In the present study, daily ingestion of up to 0.6 mg of THC by 15 subjects did not produce confirmed positive urine THC results at the 10- or 15-ng/mL GC-MS cutoffs. Currently practiced seed cleaning methods appear to be successful in limiting THC concentrations in hemp oil and hulled seeds to 5 ]Jg/g and 2 lJg/g, respectively. At these THC residue levels, ingestion of 0.6 mg/day via hemp foods requires ingestion of unrealistically high amounts of such products. Thus, adopting THC limits for hemp oil and seeds at the above levels and practicing routine GC-MS confirmation of urine specimens screening positive appear to minimize the risk of producing confirmed positive urine tests from hemp food consumption. Use of a single immunoassay in this study limits its conclusiveness relative to screening tests, but because all specimens were confirmed by GC-MS, conclusions regarding the production of confirmed positive results remain valid. 3|Page Sincerely, Joe Domino Gourmet Hemp Food Co-CEO GLOSSARY: 7 U.S.C. 1639o: Definition of Hemp: ( https://www.law.cornell.edu/uscode/text/7/1639o ) The term “hemp” means the plant Cannabis sativa L. and any part of that plant, including the seeds thereof and all derivatives, extracts, cannabinoids, isomers, acids, salts, and salts of isomers, whether growing or not, with a delta-9 tetrahydrocannabinol concentration of not more than 0.3 percent on a dry weight basis. 4|Page 5|Page