How is this legal?

The Agricultural Improvement Act of 2018, commonly known as the 2018 Farm Bill, significantly transformed the legal landscape for hemp in the United States.

—Here’s an in-depth look at its provisions, state implementations, the legality of THCA flower, Ohio’s regulations, and ongoing legislative developments:

 

• 2018 Farm Bill and Hemp Legalization

 

The 2018 Farm Bill removed hemp from the federal list of controlled substances, effectively legalizing its cultivation and production nationwide. Hemp is defined as the plant Cannabis sativa L. and any part of that plant, including seeds, derivatives, extracts, cannabinoids, isomers, acids, salts, and salts of isomers, with a delta-9 tetrahydrocannabinol (THC) concentration of not more than 0.3% on a dry weight basis.

 

• State Implementation of Hemp Programs

 

Following the federal legalization, states were authorized to develop their own hemp cultivation and production plans, subject to approval by the U.S. Department of Agriculture (USDA). These state plans had to include procedures for tracking land used for hemp production, testing THC levels, and disposing of non-compliant plants. Some states continued operating under the pilot programs established by the 2014 Farm Bill, while others developed new programs in line with the 2018 provisions.

 

• Legality of “THCA Flower”, or Type 1 Hemp

 

Tetrahydrocannabinolic acid (THCA) is a non-intoxicating cannabinoid found in raw cannabis plants. When heated, THCA decarboxylates into delta-9 THC, the psychoactive component associated with marijuana. The 2018 Farm Bill’s definition of hemp is based solely on delta-9 THC content, not accounting for THCA levels. This has led to interpretations that THCA-rich hemp flower is legal, provided the delta-9 THC content does not exceed 0.3% on a dry weight basis. However, this interpretation is contentious, and some legal experts caution against assuming THCA flower is universally legal, as state regulations may vary.

 

• Ohio’s Hemp Regulations and Importation

 

In Ohio, hemp and hemp products compliant with the 2018 Farm Bill are legal. The Ohio Department of Agriculture oversees the state’s hemp program, ensuring products meet safety and compliance standards. Individuals and businesses do not need a license to sell hemp or hemp products, including CBD oil, but such products must adhere to Ohio’s food safety standards and be inspected accordingly.

 

• Proposed Legislative Changes

 

Federal Level:

 

As of 2024, Congress is considering amendments to the 2018 Farm Bill to address ambiguities and loopholes, particularly concerning intoxicating hemp-derived products. The rise of products containing psychoactive cannabinoids, such as delta-8 THC, has prompted discussions on stricter regulations to prevent unintended consequences of hemp legalization.

 

Ohio State Level:

 

In Ohio, legislation has been introduced to regulate or ban intoxicating hemp products. For instance, Senate Bill 326, introduced by State Senator Steve Huffman, aims to define and prohibit “intoxicating hemp products,” setting specific THC limits per serving and package. This bill reflects growing concerns about the availability of psychoactive hemp-derived products in the market.

 

Conclusion

 

The 2018 Farm Bill’s legalization of hemp has led to a complex regulatory environment, with variations at both federal and state levels. While hemp and certain derivatives are legal under federal law, products like THCA flower occupy a gray area subject to interpretation and state-specific regulations. In Ohio, compliant hemp products can be imported and sold, but ongoing legislative efforts may impact the legality of certain items, especially those with intoxicating effect's.

 

 

OUR LETTER TO THE OHIO STATE LEGISLATURE (SB 326): 

Hello, 
My name is Peter LaFontaine. I own The Fountain Cannabis Company LLC, a local delivery hemp based online store. I wanted to reach out concerning SB 326 and its purpose to ban intoxicating hemp. As a daily cannabis user since December 2012, over the years I have become extremely educated in cannabis as a plant species. Currently we have the 2018 Hemp Farm Bill by Congress which states that all hemp is cannabis that is 0.3% or less Delta-9 THC. I wanted to point out that Congress wrote the bill using inaccurate language surrounding the cannabis plant and the different types of genetics particular strains dominant in certain cannabinoids can have. To make a measurement to determine if a strain is “Hemp”, or what I see Congress is attempting to do is see if a strain is dominant in CBD with minimal THC. Using the language “Delta-9 THC”, rather than “Total THC” has caused what people call a “loophole” around cannabis. We need to regulate cannabis as is and stop putting these political terminologies to the plant that can make it federal legal or federally illegal. I believe that the Ohio State House needs to place its focus on banning alternative cannabinoids such as Delta-8 THC. As a hemp based business, we do not sell any type of alternative cannabinoids including delta-8 THC, THC-P, delta-10 THC, HHC, THC-O, HHCP, Delta-6a10a THC, HHC-O, and more emerging new ones coming out as time continues without any type of regulation. The Ohio State House needs to put protections on naturally occurring cannabinoids such as CBD, CBG, CBN, delta-9 THC, THCa, THCv, CBC, CBT, along with other minor cannabinoids. These are cannabinoids that the cannabis plant with all the variations of genetics may contain. People might try to say delta-8 THC is natural, but the forms being sold are “semi-synthetic” versions of this cannabinoid. The cannabis plant produces delta-8 THC in negligible amounts that are so minuscule it will have absolutely no effect on you. Companies run an chemical isomerization process on CBD or delta-9 THC to make delta-8 THC. My company does not view this safe and is one of the few companies that only focus on naturally occurring cannabinoids in our products. 

Hemp is cannabis. Marijuana is cannabis. Cannabis that gets a user high is high in THCa, the precursor to delta-9 THC. (THCa % • 0.877+ active Delta-9 THC= Total THC). Due to the current way the federal bill is written, we carry flower rich in THCa but yet compliant because the active Delta-9 THC levels that the plant started to already produce converting from THCa is 0.3% or less. This is poor wording on the part of Congress. The legal equation that needs to be implemented by Congress is the following to make a determination if a cannabis strain is “hemp”. THCa % (• 0.877) + “active” delta-9 THC (this is THCa that has been exposed to heat (ex. The sun) and converted to active delta-9 THC)= TOTAL THC. For cannabis to be deemed as hemp, it should be <1% TOTAL THC. As long as Congress Is only focusing on the delta-9 THC that has been activated most likely by the sun, then we will never get an actual hemp industry with a focus on CBD and CBG strains. 
Non-psychoactive strains that are shown to have health benefits.

The FDA has Epidiolex (CBD) approved for medical use, making more CBD flower accessible is something the federal government can start on and Ohio can be the leading example in this. In dispensaries ran by the state, you do not have any CBD dominant strains. They only focus on strains high in THCa. This is really shameful because as a medical program, they should have lab tested CBD flower available for patients. This can even potentially reduce patients driving after using flower that is THCa dominant. Whenever I drive, I use CBD flower with almost no THCa. It does not get you high but it reduces a lot of symptoms I have from autism. As a person with three jobs, including my company, I need to be clear minded most of the time and need a form of cannabis that is non-psychoactive. We need regulation for a hemp industry to thrive with access to CBD flower. I believe the day limits patients receive will deter patients from buying CBD flower from the dispensary when they can get it online or at a local smoke shop. 

Our key goals: 

• To leave edibles containing <0.3% THC per dry weight legal and accessible. 

• Continue to allow the import of federally compliant products such as flower including those dominant in THCa unless Congress says otherwise. 

• Redefine hemp under state law to be cannabis that it <1% TOTAL THC. This will distinguish psychoactive cannabis (marijuana) from non-psychoactive cannabis (hemp).

• Create separate licensing process for people who want to grow hemp as the state of Ohio defines it. Strains with Total THC <1%. These are strains that will not get a user high like flower dominant in THCa would. Make Hemp processing licensing more accessible by lowering pricing for licensing. 

• Ban alternative cannabinoids (semi synthetic and synthetic cannabinoids derived from hemp) 

•Create a separate market for hemp flower, and other hemp products to create dispensaries that carry CBD dominant products only, or merge this market with the current cannabis control with lower licensing costs than those for psychoactive cannabis plants. 

Thank you for you time, 

Peter LaFontaine www.thefountaincannabiscompany.com/
The Fountain Cannabis Company LLC 


 

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OUR SECOND LETTER TO THE OHIO STATE LEGISLATURE (SB 326):


Hello members of the committee,

 

Peter LaFontaine, on behalf of The Fountain Cannabis Company LLC in Batavia, Ohio. As a local delivery hemp vendor, I wanted to give my second input after reviewing the inputs of the proponents and those opposing the bill from the last several meetings held. I am finding inputs from parties that have nothing to gain if the bill fails BUT big financial gain if the bill does pass, meanwhile others get to keep their financial security if the bill fails and MUCH to lose if the bill passes. We have to have support for our small businesses and as long as the Ohio Cannabis Control is aligning with the interests of the few parties monopolizing the state's cannabis industry then there cannot be any compromise without acknowledging this fact. I wanted to bring forward a means of compromise based on facts and science and not from what we think is going on from what you hear on social media. We need to acknowledge that this issue is much bigger than a state level issue with poor wording on the part of Congress with the 2018 Hemp Farm Bill. As someone who believes heavily in cannabis, I also believe that there needs to be safeguards put in place to prevent these products from getting in the hands of people under the age of 21. I do have plans to reach out to Congress on the type of language they need to use revolving around cannabis and the science behind it. We need to be very careful of any special interests behind SB 326 and its true intent. There is currently a war between the “hemp” and “marijuana” industries throughout the country. This is all due to the poor language used in the 2018 Hemp Farm Bill when it comes to cannabis. I can lay out many reasons this bill should not pass or be amended. One example of the damage this bill can cause is removing the access to CBD dominant strains and products. The state of Ohio has a medical program, which now’s accessible for recreational purposes, but as a medical program the one thing all these companies have failed to do is make available CBD dominant strains and products. This is all due to financial reasons, incentives, and the way the day allowance system is structured within the program. Passing this bill won't even put a guarantee to a segment of cannabis users, especially for medical reasons, that they will have more access to CBD dominant products and strains. We need to make a hemp industry in the state of Ohio that is safe and based on natural components of the plant. Where I break off with many other companies such as mines is that a ban or regulation of “alternative” cannabinoids needs to be done for the safety of the community. Scientists are ahead of the game when it comes to studying natural cannabinoids, but not these semi-synthetic and synthetic cannabinoids such as Delta-8 THC, HHC, THC-P, and so on. We have companies creating new cannabinoids by slightly modifying the natural ones to create ones they can call hemp-derived. As a society we have an idea of what long term use of natural cannabinoids directly from the plant may cause, but not these new invented ones. 

My company as an example focuses only on naturally occurring cannabinoids such as THCa (THC), CBDa (CBD), CBGa (CBG), CBN, THCV, CBC, and CBT. We do not involve ourselves with Delta-8 THC, HHC, THC-P, and more recently created ones. You have ones such as THC-P that are actually much more potent than the naturally occurring delta-9 THC. After reviewing the proponents of the bill which included large cannabis corporations and regulatory bodies advocating for enhanced oversight in response to public health concerns related to unregulated products entering the market. They argue that comprehensive regulation is essential for protecting consumers from potentially harmful substances. The bill disproportionately favors large corporations at the expense of small farmers, producers and business owners. We need to increase consumer education, not change existing standards, and stop overlooking the economic viability needed by these hemp businesses owners. If there is concern about a particular cannabinoid on the market it needs to be isolated and addressed individually as a compound. In this case, it seems to lead to alternative cannabinoids which are separate from naturally occurring cannabinoids. It is essential to understand the scientific principles and factual information relevant to the language you choose when drafting a bill, as this knowledge is crucial for effective legislation. Until the science of cannabis is clarified in a more clear manner to lawmakers I have to oppose this bill as it currently is.

 

Thank you for your time,

 

Peter Anthony LaFontaine (Owner)

The Fountain Cannabis Company LLC

239-316-8648 (cell)

thefountaincannabiscompany@gmail.com

 

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SB 56 SUBMITTED TESTIMONY (02/24/25)


Members of the Senate General Government Committee, Thank you for

the opportunity to speak before you today.

I am here to speak to you as an opponent to SB 56, a regression on Issue

2, which passed with a majority of Ohioan's wanting legal cannabis . We

cannot speak about SB 56 without addressing the flaw in our federal

governments position on the legality of cannabis. As a society, we are

suppose to move forward rather than backwards with our policy.

SB 56 talks about a consolidation of the Cannabis Control Program.

Medical patients need to be prioritized over recreational users with

separate rules in place and not be placed into the same basket especially

in terms of consuming in public a vape. We still as a society feed off false

narratives and data regarding cannabis. The medical program needs to be

treated with more respect for its values. SB 56 undermines the voters of

Ohio. Overriding laws on a micro level is outrageous and this approach to

discreetly overriding laws needs to be reviewed by an Ethics committee.

This bill is prepared to throw people into jail for consuming in public,

something more Ohioans do than you think. Or do you know? If so, this

would touch on a major subject here in the United States called

Recidivism and the profiting off private prisons and jails. The re-

incarcerating of individuals including for petty crimes. One example of this

is of a particular county in the state of Florida, that when I lived there,

would incarcerate individuals for open container which would be a $100

fine, or as an alternative a 1 day in jail sentence. For federal funding they

would target the homeless who couldn’t pay the fine. With SB 56 we have

an underlying social issue that seems to be like a cancer and won’t go

away. Having history of being incarcerated 15 years ago, I used that time

to reflect on many things but also educate myself in some law, history,

geopolitics. When cannabis improved my life slowly I started to attend

college more frequent than before after gaining easier access to cannabis.

I eventually received my Associates of Applied Science in Audio/Video

Production Technology. I have plans to return to school for an Ed.D in

Urban Leadership later down the future with education in cannabis that

would benefit me internationally in places like Canada as well.

Reducing home cultivation limits without sufficient scientific knowledge on

how the genetics of the cannabis plant works, which was demonstrated in

his speech speaking on how many joints a plant makes, is blatant

legislative arrogance. People in the cannabis community seems to always

deal with people who have the Dunning-Kruger Effect. Using informationthey learned from the 1900s from bias sources running rampant at that

time. Regulatory overreach with cannabis, under reach when it comes to

guns. What stuns me is I live in a society where people are eager to handle

weapons of war, but would half of them be even prepared to be in such a

scenario. People need to appreciate the level of peace we are able to keep

in our democracy. So if we are speaking about public safety, hypocrisy is

right there. Cannabis is not brought into schools to commit mass murder.

What do you think is?…

When it comes to setting limits on THC, lets not fool ourselves. As

someone who owns a hemp company, I know very well that any individual

could purchase 99% THCa isolate, decarboxylate it to active THC and use

it at incredibly high levels. You will create a black market. A new one at

that.

Prohibiting cannabis sharing is a personal attack. You are trying to

effectively isolate cannabis users on an island from being able to socialize

with other people and do the same things people do when they drink, but

safer. You allow the sharing of a cancer causing chemical, alcohol,

meanwhile you prohibit the transfer of a plant between two responsible

adults. I do not want to even get into the poor legislation around

caregiving for patients by growing for them, making products for them,

and so on.

Removing social equity and jobs programs is another example of how

there is an agenda by someone linked to one of you we have in this office

today representing us. An agenda to make money off incarcerating

individuals. Money off the recidivism rate in this country. And who else

better to target than people who use cannabis. Targeting a minority soon

to be majority in the future. You know what countries have governments

that target minorities? Iran, Russia, Syria (including history with the new

administration), Sudan, and the list goes on. Why do we want to be like

any of them? Why do we have certain members of office with ambitions to

have their own security of power at the expense of others.

So as I come before you today, I want to let it be known that we should all

firmly oppose this bill, SB 56. I also want to briefly address SB 326 in

connection with public safety. There needs to be a compromise on

products containing “alternative” (aka synthetic) cannabinoids derived

from hemp for the purpose of public safety but protections for naturallyoccurring cannabinoids such as THCa, CBD, CBN, CBG, and so on. There

are an array of minor cannabinoids documented.

Thank you for your time,

 

Peter A. LaFontaine, owner

The Fountain Cannabis Company LLC