As Tentative definition for hempseed meal Moves forward, APS Constituents Have Concerns (Title Update April 4, 2024)

As Tentative definition for hempseed meal Moves forward, APS Constituents Have Concerns
By: Hunter Buffington, APS Director

The partners at APS have been dedicated to the fruition of hemp as an animal feed since our engagement with the original submission at the Hemp Feed Coalition. While we are happy to see the recent tentative definition return from the FDA-CVM after nearly four years of waiting. We feel it is necessary to address the current definition and its impact on our industry. Without reasonable limits that are attainable by the regulators, or achievable by farmers and processors who need secondary markets like animal feed, the definition becomes a pathway for a few and not a viable market. 

In conversations with other associations and agencies, cautionary statements have been shared that the current tentative definition is not economically feasible; requiring solvent washing or dehulling.

The proposed definition does not require dehulling nor do the limits proposed by the FDA-DVM align with any reported safety concerns, OR their own established limits in the accepted GRAS notice for hemp seed and its by-products to be consumed by humans.

The goal of this blog is to introduce this conversation over the next couple of weeks and include the perspectives of other subject matter experts, farmers and market leaders, with the request from our industry to revise the definition to its original submission limits of 10ppm THC and not action limit for CBD.

The definition and the rationale for this change are introduced below and I look forward to an ongoing dialogue and work that will open animal feed markets to hemp rather than reduce the volume of compliant supply and increase the cost for those eager to feed hemp to amounts that are unsustainable for the feed industry.

New Tentative Definition T71.5 Hempseed Seed Meal, Mechanically Extracted
T71.5 Hemp Seed Meal, Mechanical Extracted is the product obtained by grinding or milling the cake, which remains after most of the oil is removed from the seeds of Cannabis sativa L. by a mechanical extraction process. The ingredient must be labeled with guarantees for minimum crude protein and maximum crude fat on an as-fed basis. The meal shall contain no more than 20 ppm of total cannabidiol (Total CBD = CBD + (CBDA x 0.877)) and no more than 2 ppm of total tetrahydrocannabinol (Total THC = delta-9-THC + (THCA x 0.877)). It is used in diets of laying hens as a source of protein and fat at an inclusion of no more than 20% of the diet.
 
1.       The original submission was sent to the FDA-CVM from the AAFCO Oilseed Ingredients investigator after their initial review had a 10ppm limit for THC and no limit for CBD.

2.       The basis for the proposed limits were the FDA GRAS notice for whole hempseed oil.

3.       The analytical capabilities at the time of submission required an LC/MS/MS and could not be achieved with a GC-FID method. (There is work to validate a GC-FID method for hempseed meal to 10ppm by ASTM right now)

4.       There is no jurisdiction that has a limit for CBD in hempseed meal.

5.       The US Pharmacopeia defines hempseed meal with less than 10ppm THC, and less than 75ppm.

6.       The proposed limit of 20ppm CBD is less than the acceptable amounts of lead and arsenic in animal feed.

7.       The proposed 2ppm THC limit is the same amount of Mercury allowed in animal feed. Only cadmium is lower.

8.       There is no scientific research that these very low limits have any toxicity or affect animal or human health negatively. (compliant hemp is allowed 3000 ppm ∆9 THC, and there is no limit on CBD)

9.       To prevent cannabinoid contamination in hemp seed by products (FDA recognizes the seeds do not naturally produce cannabinoids) the seeds would have to  
a.       be cleaned three times before processing
b.       be dehulled

10.   Farmers and seed processors cannot afford the margins to clean or dehull grade B seed – which is ideal for the animal feed market needs for supply volumes and cost.

11.   Crushing hempseed hearts are marketed as high value protein powder that is most often for human consumption and will not support the development of a hemp grain supply chain economically.

The above ten bullet points will be discussed further in three upcoming blogs posts by my team, trusted researchers, processors and feed formulators. I hope that you will engage us with your questions.

The goal of the series is to address these issues, before the final approval of this definition by AAFCO in August and before these limits are imposed on the hemp industry.