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schizoidcel · 20 days

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## BOOTHILL x READER ★

🤍 ﹒ HEADCANONS ! ! . .

－ notes ̽ ۪⠀written before his release + gn reader huhu. yall i swear ill get to the lcb requests but im brainrotting too fucking much right now boothill is colonizing my mind so enjoy these thoughts i had and will throw into the tags

︶︶︶︶︶︶︶︶︶༉‧₊˚.

He's a little spoon and NOBODY can convince me otherwise period.

We know damn well hes touch starved. So ofcourse he'd wanna be nuzzled up inbetween your chest and chin

Will teach you how to ride a horse. He definitely has a favourite (his name is Sebastian 🌚🌚)

Very protective over him though. You will not ride on that horse until you are months into the relationship

He gave you another horse to practice riding on and an extra horse incase the other "knocks your socks off" ... Whatever that means

You named them Yee and Haw and he was so conflicted with his emotions that he considered getting a routine check up on his body

Will tease you if you completely fuck up immediately.

He grabs your hands to gesture on things you should be wary about while being on the back of a horse, knowing it'll mess your brain up and lead you to not pay attention to a single thing coming out of his mouth

On the other hand if you're able to handle it in a short amount of time, he'll start flirting with you

"I'm doing it, Boo!" "Nice work, honeybunch. Think ya can manage ridin' somethin' else?" "Dude"

It's one or the other. You will not escape the Boothill down bad programm

Boothill also acts like a himbo to mess around with you.

On another note, you called him Bootyhill once and he's still shook up. Whether /pos or /neg is up to interpretation

While we're on the topic of nick/pet names, he calls you things you've never heard of before .

Or even if you did, they're things you expected never to be called 😭

What the fuck is a doodlebug Boothill

Type of man to get flustered when you flirt back. He just starts bugging out

Will play it cool though, but the faint blue on his cheeks says otherwise

Also a fan of headpats. No, he's not ashamed. No, he will not tell you.

Expanding on the no shame, Boothill takes it to the extreme

No filter, no mask, no nothing. Touchy EVERYWHERE you go

Even if he can't really feel it, he just feels more at ease when you both are near eachother or touch one another. Man wants to protect his partner, after all

It dosen't matter if you're able to protect yourself, the gesture just makes him feel more comfortable and calm

Also has a hair pulling kink woah. Let's keep it sfw everybody

Forehead kisses ❤️ or just kisses anywhere on his head in general. Kiss behind his ears and he will overheat

He let's you play with his hair<3 It's one of his favourite passtimes with you

Braid it, tie it in a ponytail, give him buns, pigtails, curl them, decorate them with hairpins, clip bows in his strands it don't matter PLAY WITH HIS HAIR ⁉️

He relaxes SO MUCH it's insane. Genuinely just one finger goes into that hair of his and he melts

This plays into the little spoon factor

You'd tease him about it but he takes pride in it 😭

Has a weird obsession with biting. If you complain that it hurts he goes "What, want me to smooch the pain away?" and he does this fuckass face :3 while you're just staring at him dead in the eye (you say yes btw)

If you're ticklish, he's hell for you

Tickles you in the most random times possible.

And you know it's even WORSE with those cold ass metalic hands

You're cuddling? The sides of your torso are not safe. You're currently occupied with an activity involving your hands? Your armpits are not safe either. He's laying on your bare stomache face down? He starts blowing raspberries.

You know damn well he uses the feathers of his hat 😭

Sticks it up your nose to make you sneeze too. Usually to wake you up or some shit

You could have the most volcano eruption alert level 5 sneeze and he'd still say "Aww, ya sneeze like a kitten!"

One last note this man is a whiney loser bottom not sorry

the word ill is in boothill for a reason the way im laying in bed all sweaty ANYway 🌚😵😵😵😵

ૢ་༘࿐ thank you for reading ! Ⳋ᧙

#boothill x reader #bruh #i feel so insane #and normal #normaling #ok wer e done. im out. goodbye hsr community thisll be my only contribution #proof reading and looking at the eidolon i used for the header why nobody draw him with those glasses yet🧐🧐

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fakerealm · 1 year

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Tree was originally a Weaver from the Index until a prescript led him to joining LCB. Unfortunately he isn't used to doing more than managing looms of fate so everyone thinks he's a little bit weird, especially when he just starts talking to the air. His ears are body augmentations he got to be more alert and aware of his surroundings.

#limbus company #oc #what classic literature book is he based off of warrior cats. hes based off of tree from warrior cats. hope this helps.

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southamericanvalve · 7 months

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Thermal Safety Valve Manufacturer in Peru

South American Valve is an emerging Thermal safety valve manufacturer in Peru .It is also known as Thermal relief valve. It is a safety device employed in liquid piping and pipeline systems to protect the equipment and system. These valves are an essential safety feature in various industrial processes and systems where elevated temperatures can lead to the buildup of pressure and pose safety hazards.

South American Valve is the best Thermal safety valve manufacturer in Peru. They work in conjunction with other safety devices, such as pressure relief valves, temperature sensors, and control systems, to ensure the safe operation of equipment and processes.

Parts

Body

Seat

Spring

Temperature-Sensitive Element

Lifting Mechanism

Disc

Bonnet

Adjustment Screw

Types

Spring-loaded thermal safety valve

Pilot-operated thermal safety valve

Bellow thermal safety valve

Advantages

Automatic Operation

Temperature Sensing

Reliable Pressure Relief

Versatility

Safety Assurance

Maintenance Alerts

Application

Steam Boilers

Pressure Vessels

Oil and Gas Industry

Power Generation

Chemical Processing

Water Heaters

Industries which use them

Oil industries

Gas industries

Chemical industries

Power plant

Water plant

Aerospace

Petrochemical industries

Description

Body material: Cast iron, cast steel (WCB, WCC, LCC, LCB, WC6, WC9), Ductile iron, carbon steel, stainless steel (SS316, SS304, CF8).

Class: 150 – 2500, PN10-PN450

Size: ½” – 40”

Ends: Socket weld butt weld, flanged, threaded.

Operation: Hand Wheel, Gear operated, Electric Actuated, and Pneumatic Actuated.

Visit us : https://www.southamericanvalve.com/product-category/thermal-safety-valve/

#valves #southamericanvalve #Thernalsafetyvalve #safetyvalve

0 notes

supremekalmllc · 4 years

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New Post has been published on https://supremekalm.com/washington-cannabis-who-is-a-true-party-of-interest-underthe-new-rule/

Washington Cannabis: Who is a True Party of Interest Under the New Rule?

At long last, the Washington State Liquor and Cannabis Board (“LCB”) has finished revising its “True Party of Interest” rule (TPI). This process started way back in August of 2018 and after many revisions and multiple legislative changes. The LCB approved the new rule on September 2, 2020 and they will go into effect on October 3, 2020.

I wrote about the draft rules in detail here and if you are unfamiliar with TPIs generally, I recommend reading that post first as it outlines the changes have made it into this final version of the TPI rule. This post will focus instead on my main takeaways from the new rule.

Who is a TPI?

The new TPI rule does not change the basic premise that any individual who owns a marijuana business is considered a TPI. The new TPI rule states that the following individuals will be considered a TPI with regards to the corresponding entity:

Entity True Party(ies) of Interest Sole proprietor Sole proprietor General partnership All partners Limited partnership, limited liability partnership, or limited liability limited partnership -All general partners

-All limited partners

Limited liability company (LLC) -All LLC members

-All LLC managers

Privately held corporation -All corporate officers and directors (or persons with equivalent title)

-All stockholders

Multilevel ownership structures All persons and entities that make up the ownership structure Any entity(ies) or person(s) with a right to receive revenue, gross profit, or net profit, or exercising control over a licensed business -Any entity(ies) or person(s) with a right to receive some or all of the revenue, gross profit, or net profit from the licensed business during any full or partial calendar or fiscal year

-Any entity(ies) or person(s) who exercise(s) control over the licensed business

Nonprofit corporations All individuals and entities having membership rights in accordance with the provisions of the articles of incorporation or bylaws

Each TPI must qualify to own a marijuana license, which means they must not have a disqualifying criminal history and must be residents of the State of Washington. Under the new rule, this is still pretty restrictive. For example, if a corporation holds a marijuana license, it must ensure that all shareholders are approved as TPIs even if they hold only a small fraction of the total shares in the company. However, there is one big change with regard to spouses.

In the above table, youâll see that the LCB considers those âwith a right to receive revenue, gross profit, or net profit, or exercising control over a licensed businessâ to be TPIs. This is not new as the LCB has long maintained that revenue sharing and control create TPI relationships even if an individual or entity is not an owner of a licensed business. The new rule, however, defines some of these terms:

âControlâ means the power to independently order, or direct the management, managers, or policies of a licensed business.

âGross profitâ means sales minus the cost of goods sold.

âNet profitâ means profits minus all other expenses of the business.

âRevenueâ means the income generated from the sale of goods and services associated with the main operations of business before any costs or expenses are deducted.

Of these new definitions, the âcontrolâ term is probably the most informative. Now we know that control turns on the ability to independently order or direct a licensed business.

Who is not a TPI?

The biggest change to the TPI rule has to do with spouses. In the past, any person married to a TPI was considered a TPI themselves. That means that if you married the owner of a marijuana business in Washington, you would be subjected to the very non-romantic process of being vetted by the LCB. Not exactly the most romantic way to start a life together.

The inclusion of spouses in the original definition of TPI lead to some absolutely ridiculous scenarios. For one, if you were operating a marijuana business and your romantic partner did not qualify to own a marijuana license (e.g., they had a disqualifying criminal record or were not residents of the state of Washington) you would be forced to choose between marrying your partner and staying on a license. The LCB literally put a restraint on marriage. Thankfully, this arbitrary restriction is no more.

But, there is a little more to the story, as you can see from the following provision in the new rule:

A married couple may not be a true party of interest in more than five retail marijuana licenses, more than three producer licenses, or more than three processor licenses. A married couple may not be a true party of interest in a marijuana retailer license and a marijuana producer license or a marijuana retailer license and a marijuana processor license.

Washington law and LCB regulation prohibit vertical integration. This means that a retailer cannot have any financial interest in a producer/processor license, and vice versa. Although spouses no longer need to be vetted as TPIs simply due to the fact of marriage, a married couple cannot hold an interest in a retailer and producer/processor license. In addition, Washingtonâs licensing caps are imputed to married couples as well. An individual can only hold up to five retail licenses or three producer/processor licenses. A married couple cannot exceed either limit.

In addition, the new rule creates a non-exhaustive list of individuals that are not considered TPIs, including the following:

Financial Institutions

Individuals receiving a bonus or commission âso long as the commission does not exceed ten percent of their sales in any given bonus or commission period.â

Brokers (âA person or entity contracting with the licensee(s) to receive a commission for the sale of the business or real property.â)

Consultants

Service Providers (e.g., branding or staffing companies)

Landlords and lessors

Option holders

I want to elaborate on the last two categories. First, letâs look and landlords and lessors. Here is the relevant exemption language:

A person or entity receiving payment for rent on a fixed basis under a lease or rental agreement. Notwithstanding, if there is common ownership interest between the applicant or licensee, and the entity that owns the real property, the board may investigate all funds associated with the landlord to determine if a financier relationship exists. The board may also investigate a landlord in situations where a rental payment has been waived or deferred.

This codifies a long-standing policy where the LCB treats any overlap in ownership between a landlord and licensed marijuana business as creating a TPI or financier relationship. In the past, we have complained about this policy on this blog because the LCB failed to provide any warning to the industry as to who would be considered a financier or TPI. At least now the LCB has put the industry on alert.

Turning now to option holders. The new rule states that the definition of TPI does not include:

a person with an option to purchase the applied for or licensed business, so long as no money has been paid to the licensee under an option contract or agreement for the purchase or sale of the licensed business, or a business that is applying for a license.

It appears that the LCB is now prohibiting any time of option agreement where consideration is paid. At least that is how I read this definition. The LCB has long allowed for option agreements so this leaves option holders who have paid a fee to hold the option in a challenging position.

Bottom Line.

The new TPI rule does change who is and who is not considered a TPI but, I think many in the industry were hoping that this new version of TPI rule would go further. At least I know that I did. Weâll continue to monitor how this new rule plays out. We anticipate that it will be challenged early and often.

The post Washington Cannabis: Who is a True Party of Interest Under the New Rule? appeared first on Harris Bricken.

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charlesmichel234 · 4 years

Link

Signs and signage are used extensively at almost all types of places, properties and spaces. These help in making the onlookers or people visiting some specific place or space alert or aware about certain things. Written information as well as some symbols may be used in the form of signs and signage.

#Hiring Sign Makers

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sittiannee · 5 years

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LCB acquires thirteenth <b>warehouse</b> site

London City Bond (LCB) has acquired a new 162,000 sqft warehouse in West Thurrock, having also opened two sites in Burton upon Trent and Leeds ... from Google Alert - warehouse https://ift.tt/2Mj6qIF

#IFTTT #Google Alert - warehouse

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icindesenolmiyanherseyinaq · 5 years

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Plans for wine <b>warehouse</b> in Drakelow Tunnels rejected

PLANS to turn a former top secret underground military complex into a wine storage facility have been refused by the council. London City Bond (LCB) ... from Google Alert - warehouse storage https://ift.tt/2M3tqv1

#IFTTT #Google Alert - warehouse storage

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klykcielewe · 1 month

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ALERT LCB

Uwaga! W najbliższy czwartek (21.03) urodziny redaktorki! Aldona Gutorska, redaktor naczelna Wieścii z Kłykciów Lewych kończy 49 lat. Przygotuj się na ewentualne podtopienia i przerwy w dostawie prądu. Każdy jest zaproszony na sobotnią imprezę w redakcji. Bez wyjątku. Obecność i prezent obowiązkowe.

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fyuris · 6 years

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Orthopediatrics (KIDS) vs. Amedica (AMDA) Financial Survey

Its products include RESPONSE Spinal Deformity System, PediNail Intramedullary Nail System, PediLoc Plating Systems, ACL Reconstruction System, Locking Cannulated Blade (LCB) plate system, Locking Proximal Femur (LPF) plate system, PediFlex Flexible Nailing System, PediFrag, PediLoc ... from Google Alert - lumbar spine http://ift.tt/2FSoYfs

#IFTTT #Google Alert - lumbar spine

0 notes

garrrrrrrrrrrrrrrrrrrrrrr · 6 years

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Orthopediatrics (KIDS) vs. Amedica (AMDA) Financial Survey

#IFTTT #Google Alert - Spinal

0 notes

forensiceyes · 4 years

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Washington Cannabis: Who is a True Party of Interest Under the New Rule?

Who is a TPI?

EntityTrue Party(ies) of InterestSole proprietorSole proprietorGeneral partnershipAll partnersLimited partnership, limited liability partnership, or limited liability limited partnership-All general partners

-All limited partners

Limited liability company (LLC)-All LLC members

-All LLC managers

Privately held corporation-All corporate officers and directors (or persons with equivalent title)

-All stockholders

Multilevel ownership structuresAll persons and entities that make up the ownership structureAny entity(ies) or person(s) with a right to receive revenue, gross profit, or net profit, or exercising control over a licensed business-Any entity(ies) or person(s) with a right to receive some or all of the revenue, gross profit, or net profit from the licensed business during any full or partial calendar or fiscal year

-Any entity(ies) or person(s) who exercise(s) control over the licensed business

Nonprofit corporationsAll individuals and entities having membership rights in accordance with the provisions of the articles of incorporation or bylaws

In the above table, you’ll see that the LCB considers those “with a right to receive revenue, gross profit, or net profit, or exercising control over a licensed business” to be TPIs. This is not new as the LCB has long maintained that revenue sharing and control create TPI relationships even if an individual or entity is not an owner of a licensed business. The new rule, however, defines some of these terms:

“Control” means the power to independently order, or direct the management, managers, or policies of a licensed business.

“Gross profit” means sales minus the cost of goods sold.

“Net profit” means profits minus all other expenses of the business.

“Revenue” means the income generated from the sale of goods and services associated with the main operations of business before any costs or expenses are deducted.

Of these new definitions, the “control” term is probably the most informative. Now we know that control turns on the ability to independently order or direct a licensed business.

Who is not a TPI?

But, there is a little more to the story, as you can see from the following provision in the new rule:

Washington law and LCB regulation prohibit vertical integration. This means that a retailer cannot have any financial interest in a producer/processor license, and vice versa. Although spouses no longer need to be vetted as TPIs simply due to the fact of marriage, a married couple cannot hold an interest in a retailer and producer/processor license. In addition, Washington’s licensing caps are imputed to married couples as well. An individual can only hold up to five retail licenses or three producer/processor licenses. A married couple cannot exceed either limit.

In addition, the new rule creates a non-exhaustive list of individuals that are not considered TPIs, including the following:

Financial Institutions

Individuals receiving a bonus or commission “so long as the commission does not exceed ten percent of their sales in any given bonus or commission period.”

Brokers (“A person or entity contracting with the licensee(s) to receive a commission for the sale of the business or real property.”)

Consultants

Service Providers (e.g., branding or staffing companies)

Landlords and lessors

Option holders

I want to elaborate on the last two categories. First, let’s look and landlords and lessors. Here is the relevant exemption language:

Turning now to option holders. The new rule states that the definition of TPI does not include:

Bottom Line.

The new TPI rule does change who is and who is not considered a TPI but, I think many in the industry were hoping that this new version of TPI rule would go further. At least I know that I did. We’ll continue to monitor how this new rule plays out. We anticipate that it will be challenged early and often.

The post Washington Cannabis: Who is a True Party of Interest Under the New Rule? appeared first on Harris Bricken.

Washington Cannabis: Who is a True Party of Interest Under the New Rule? posted first on http://ronenkurzfeld.blogspot.com

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growlegalweed-blog · 5 years

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Legal Weed Resources

Check out... https://legalweed.gq/420/washington-wslcb-publish-their-2019-cannabis-topics-trends-alerts/

Washington: WSLCB Publish Their 2019 Cannabis Topics & Trends Alerts

Here’s the Table of Contents

Winter Edition 2019 – Cannabis

Topics

Board Approves Jan. 1, 2020 Effective Date for All Marijuana Products, Packaging and Labeling

Moving?

Assigning Applications by Region – Update

Did You Know…

Trending Now: Use of Personal Funds and Ownership Changes

Pesticide Disclosures

Observations from the Field: Discounting Product Between Processors an Retailers

Paying Your Excise Tax

Legislative Session and the Licensing Process

2019 Legislative Session – Agency Proposed Legislation

Leaf Data Systems Update

Full Newsletter

https://data.lcb.wa.gov/stories/s/Topics-and-Trends-Marijuana-Winter-2018/tdtm-4fyz/

Board Approves Jan. 1, 2020 Effective Date for All Marijuana Products, Packaging and Labeling

On January 9, 2019 the Board approved a motion to make the effective date for all marijuana product, packaging and labeling requirements Jan 1, 2020. You can read more about product packaging and labeling requirements on the Understanding Board Interim Policies for Packaging and Labeling section of the LCB website. On this page, you’ll find the previously announced Board Interim Policies, approved colors and shapes, links to the recent webinar and accompanying PowerPoint, and other useful information.

Moving?

You cannot move your marijuana business without prior approval from the WSLCB. Your license is tied to your location. If you move without prior approval, the WSLCB may discontinue your license.

As soon as you know you plan to move to a new location, apply for a change of location through Business Licensing Services, here.

Assigning Applications by Region – Update

In October, the Licensing Division began assigning applications by region. We made this change to improve consistency and communication between Licensing and Enforcement and to provide better customer service for licensees and applicants. So far the feedback from licensees has been positive.

Did You Know…

Fire Marshal approval is required any time your extraction method requires the use of a closed-loop system or ethanol. When processing an application to add these extraction types, your Licensing Specialist will ask for a copy of the Fire Marshal approval. If you plan to use ethanol in the extraction process, a Class 2 permit from the WSLCB is also required which allows you to purchase ethanol. You can find the application for a Class 2 permit here.

WSLCB approval is required before you add any new extraction type. To start the process, submit an application to alter your operating plan.

Trending Now: Use of Personal Funds

On December 12, 2018, the WSLCB passed Board Interim Policy (BIP) 06-2018 which allows marijuana licensees to spend personal funds on their marijuana business prior to the Board vetting the funds. Some key factors to note:

Funds can only be used once the WSLCB receives an Additional Funding Application.

The policy only applies to approved owners who are investing their own personal money into the business.

Licensing will investigate the source of the additional funds.

If the source of funds is questionable, unverifiable, or determined by the WSLCB to be gained in a manner which is in violation of law, the WSLCB will conduct further investigation regarding the funds.

Ownership Changes

You must receive approval from the WSLCB before you make any changes to your license ownership, ( WAC 314-55-120) including the addition or removal of any true party of interest (as defined in WAC 314-55-035). If you want to make changes to your licensed entity, submit a Change in Governing People application. Until that application is processed and approved, we will not approve any other changes to your business. Failure to report changes in ownership could lead to an enforcement investigation.

Pesticide Disclosures

As of January 1, 2019, marijuana retailers must provide all consumers, for as long as the products are for sale, a statement that discloses all pesticides applied to the marijuana plants and growing medium during production of the useable marijuana or the base marijuana used to create the concentrate or the extract added to infused products. This information must be available to the consumer in the store prior to purchase, and may be provided by means of a web address, QR code, or hard copy inside the store. The marijuana producer/processor may include this required information on the marijuana package, but it remains the responsibility of the marijuana retailer to ensure the information is available to the consumer prior to the marijuana product sale.

Additionally, upon request of the retail customer, a marijuana retailer must disclose the name of the certified lab that conducted and the results of the required quality assurance tests for any marijuana or marijuana products the customer is purchasing or considering purchasing. There is no provision in rule for referring the consumer to “look it up themselves” at a remote location or website, and the information must be provided in the store upon request.

WSLCB Enforcement officers will begin working with marijuana retailers to educate staff, check for violations, and take appropriate action to gain compliance. You can review this recent rule change on the agency website.

Please contact your WSLCB Enforcement Officer if you have any questions about implementation and enforcement of this important public safety rule.

Observations from the Field: Discounting Product Between Processors and Retailers.

It has come to our attention that processors are offering volume discounts to retailers on marijuana product. Licensees should be aware that this activity is not allowed. WAC 315-55-018 prohibits discounts between the manufacturing and retailer tiers and WAC 314-55-017prohibits processors from requiring the purchase of other products as a condition of a transaction. In the case of volume discounting, requiring retailers to purchase a specific amount of product in order to receive a discount directly conflicts with the WACs. Price on product should be sold uniformly across the industry regardless of the amount purchased or how much money is spent.

Paying Your Excise Tax

WAC 314-55-089 requires Marijuana Retail licenses to self-report their monthly marijuana product sales to the LCB using either the paper form (Retailers Sales and Excise Tax) or by using the point of sale system monthly summary report. Licenses are to report both the calculated tax amount and the amount of additional collected tax. When remitting the marijuana excise tax to the LCB, the greater of the collected vs. calculated is to be paid. The collected marijuana excise tax may be paid by check, cashier’s check, money order or electronic funds transfer.

Waiver

Licenses may apply for a payment waiver if they are able to show good cause by demonstrating they are:

In the process of getting a bank account

Have lost their bank

The bank has denied their application

Some other reason why they are unable to get money orders or a bank account.

Payment Methods

Payments other than electronic funds, may be in person or by mail. When mailing a payment, the post mark date must be on or before the tax due date.

Payments made by electronics fund transfer are considered received the date they are entered into Payment Station.

Payments made in person, by electronic funds transfer or mail post marked or received after the tax due date will be assessed a two percent late payment penalty

Legislative Session and the Licensing Process

The 2019 legislative session began January 14 and runs through April 28, 2019. During that time our licensing specialists get an increase in calls from stakeholders about how proposed legislation impacts their business. It’s important to remember that a bill is just an idea and non-binding until it passes. A bill does not become law until it passes both the House and the Senate and is signed by the Governor.

The WSLCB cannot make changes to its process based on proposed legislation. Only after a bill has become law and effective (date found in the legislation) will the changes be incorporated. At the conclusion of each legislative session agency staff compile fact sheets about all of the bills that passed which affect our licensees and operations. These sheets contain a bill summary, how to apply (if applicable), who to contact for questions, and can be found on the LCB website.

2019 Legislative Session Agency Proposed Legislation

Following is a brief synopsis of the bills LCB has requested that impact marijuana licensees:

Systems Modernization Project Account

The expiration date of the Licensing and Enforcement System Modernization Project Account is revised from June 30, 2019 to September 1, 2023.

This will not cost licensees any money. It simply allows the funds to be spent on the purpose for which the fees were collected in the first place – modernizing our legacy computer and record keeping systems – after July 1, 2019.

Otherwise, the $1.2 million in currently available funds would be transferred to the state general fund

Budtender Permit

Modeled on the training required for employees who serve alcohol for on-premises consumption, this permit would be required for cannabis retail store employees who sell or service marijuana products for the public.

The training program would be developed by the LCB and would be good for two years.

Uniform Enforcement Authority

This bill would give LCB enforcement officers the same authority to enforce state laws for cannabis, tobacco and vapor products that they currently have for alcohol law enforcement.

Note: these are the bills the agency has requested and does not reflect other proposed legislation that may affect the industry.

Leaf Data Systems Update

The next software release for Leaf Data Systems is coming soon! Release 1.37.5 will include a variety of workflow improvements, especially related to waste reporting, inventory type attributes, lab results, inventory transfers, and the ability to adjust previously entered sales data. General improvements will include numeric standardization that will standardize decimal values pertaining to weights and the replacement of drop-down menus with “type-ahead” search fields for batches, inventories and inventory types.

It’s anticipated that the release will be launched in March. Prior to release, licensees will be notified, in plain language, details of each of the changes in 1.37.5. Updated training materials will be made available at the same time.

Two additional software releases will follow, bringing Leaf Data Systems to full functionality.

For technical support with Leaf Data Systems:

Call 888-420-5813

Email [email protected] (link sends e-mail)

For questions about your license:

Call 360-664-1600

Email [email protected] (link sends e-mail)

Visit lcb.wa.gov

For questions about taxes:

Call 360-664-1789

Email [email protected] (link sends e-mail)

Visit lcb.wa.gov

For Traceability compliance questions:

Call 360-664-1614

Email [email protected](link sends e-mail)

#&amp #2019 #Alerts #Cannabis #Publish #Their #topics #Trends #Washington #WSLCB

0 notes

gigglesndimples · 6 years

Text

Freedom Leaf Interview: BiotrackTHC’s Patrick Vo

Seed-to-sale tracking is in the news. MJ Freeway has had numerous calamitous hacks to its systems. But MJ Freeway’s chief competitor, BioTrackTHC, which operates in seven states and Puerto Rico, has not. Credit goes to the Fort Lauderdale-based company’s CEO Patrick Vo and his team of software engineers. He received degrees from the University of Arizona and Indiana University before beginning his corporate career at Price Waterhouse Coopers. After moving to Colorado in 2011, Vo dove into the marijuana industry, and soon was hired by BioTrackTHC. This interview was conducted in March.

On Mar. 8, BioTrack announced it was merging with Helix TCS. Why the merger and why with Helix?

Both companies provide ancillary support products and services to the cannabis licensees, and the shareholders and management of both companies believe that the merger will position both teams to excel. Both organizations will remain distinct business units, and leadership will not change for either team. However, we plan to rationalize common business functions and have each team leverage the knowledge, operational and economic resources of the other to create even more value to the customers that rely on us. All in all, we’re very excited for the potential this merger holds for both companies and look forward to what the future holds.

Where you born and raised?

I was born in Muncie, Indiana. I’m a child of Vietnamese immigrants. That starting point shaped who I am. Woven through all of my choices is the idea that I’m “one of the lucky ones.” There are millions of others who were left behind [during and after the Vietnam War] and didn’t make it out. The greatest tragedy of my life would be to waste it by achieving mediocrity.

What led you to enter the marijuana industry?

I was a nerd when I was younger. Cannabis was something the cool kids did in school, so it was not a part of my growing up. That changed when I moved to Colorado and started working with a physician who provided medical recommendations for cannabis patients. I saw firsthand the positive impact cannabis has on patients with all sorts of conditions. I knew then that cannabis was where I wanted to be.

A few months later, I met BioTrack founders Steven Siegel and Brian McClintock and was shown their software. It was just the two of them at the time. I told them: “You created the best cannabis software that no one’s heard of. Let me help you build a company around it.”

The company initially developed prescription-drug monitoring software for the state of Florida in 2009. How did that turn into BioTrackTHC?

The company was founded to develop technology that would prevent medicine from being diverted for non-medical use. The first target was the prescription-opioid epidemic. Around 2009-2010, Colorado cannabis licensees approached us and asked if we could pivot our software for cannabis workflows. With the prescription-drug monitoring software as a foundation, we began designing cannabis-plant and inventory tracking systems based on direct input from cultivators and dispensaries.

VO: “A large-scale crackdown on the cannabis industry would be political suicide.”

How does BioTrackTHC’s seed-to-sale tracking work?

We have two seed-to-sale tracking systems: One is for businesses and the other is for governments to use. Every seed, clone and plant is issued and assigned a unique identifier. That identifier, the associated inventory record, carries information, such as the licensee that has custody of the plant, the plant/strain name, the date it was planted, its growth stage, which employee has interacted with it and so on. Once a plant is harvested, each category of plant material [flower, stems] is assigned its own unique identifier that’s a “child” of the preceding “parent” identifier. The assigning of unique identifiers and connecting new “child” inventory with its “parent” inventory creates a lineage chain from plant to plant material to consumable products. The system can tell any unique identifier’s characteristics and quantity, trace it all the way back to the plant from which it came and follow it to where it and any of its derivative products end up, whether it’s still in inventory, destroyed or sold.

The government version captures all inventory activity throughout an entire state. Not only do the government regulators have visibility over what an individual business reports, they can see products move from one licensee to another, lab-test results and [have] controls in place to prevent malicious and unintentional breaking of the law.

Patrick Vo at a dispensary

What are the advantages and disadvantages of using RFID chips?

In industries where products move through an assembly line and conveyor belts, RFID [Radio Frequency Identification] chips provide an advantage over barcodes by reading through certain lightweight materials and boxes. The theory in our industry is that an RFID reader should be able to scan a tag or a group of tags from a farther distance than reading the tag number with your eyes or using a traditional barcode scanner, thereby decreasing the time it takes to undergo an auditor inspection. However, the RFID was not designed for that application. RFID waves can’t pass through items with high water content. Indoor lights and metal can cause interference with signal reading. Densely lining up tags together may cause “shadowing” where the first tag prevents the tags behind it from being readable. An indoor room with water-filled plants that are densely arranged and surrounded by lights and metal is pretty much the worst environment for this technology.

Many of our customers operate in states that require RFID to tag plants and inventory. The feedback from essentially all of them is that RFID tags are not practical. They’re also for one-time use and cost nearly 50 cents each. In large quantities, this can have a major impact on revenues as well as the environment. To me, their only advantage is the appearance of being high-tech.

Self-reporting is basically an honor system. How do you respond to that concern?

Our platform requires that other parties input data where appropriate, removing many of the potential conflicts that arise from self-reporting. For example, state-recognized laboratories, not the licensees themselves, are responsible for inputting a product’s quality-assurance results, such as potency, microbial screening and pesticide residue, into the government’s system of record. When a licensee ships wholesale product to another licensee, our platform doesn’t automatically assign product custody to the receiving licensee. The product is categorized as “in transit” until the receiving licensee acknowledges in the system whether they’ve taken custody and the product quantity they’re accepting. Any unaccepted product goes back to the sending licensee, and any discrepancies between what was shipped and what was accounted for upon receipt, or that the shipment never made it to the destination, are reflected in one of the system’s many red-flag reports, so the state agency can be alerted and take appropriate action.

VO: “We’re all frustrated with MJ Freeway’s situation. When one team suffers, we all suffer.”

One of your competitors, MJ Freeway, has suffered a number of serious issues. Washington State recently delayed its transition from BioTrackTHC to MJ Freeway’s Leaf Data, leaving the state without a working tracking system. How did that happen?

The original launch date was Nov. 1, and it was delayed until Jan. 1. Then, the system launch was delayed again until Feb. 1. On Feb. 8, the Washington State Liquor and Cannabis Board (LCB) reported that an intruder had gained unauthorized access to the Leaf Data system on Feb. 3, less than 100 hours after the system launched. Transportation route information for wholesale deliveries from Feb. 1-4, as well as transportation vehicle VINs [vehicle identification numbers], license-plate numbers, and vehicle types were downloaded. Though Washington State makes most government data available for public records requests, detailed cannabis transportation information is typically redacted, since knowing which vehicles are transporting tens of thousands of dollars’ worth of product and exactly what routes they’re taking leaves them vulnerable to carjacking and theft.

Prior to the expiration of our contract, Washington State offered us an extension. We didn’t say “no,” but we just couldn’t say “yes” until the security concerns that came to our attention were satisfactorily resolved. We couldn’t risk the security of our own systems and our livelihoods being commingled with MJ Freeway’s system, and so the contract expired.

What led to the delay and subsequent security breach?

With only days until the expected decommissioning of the BioTrack government system, Washington State announced that MJ Freeway’s system would not make the Nov. 1 launch date, and that all licensees would have to report their plant and inventory quantities and activities via manual spreadsheets, something that everyone involved with the industry knew would be devastatingly costly. To make sure that the Washington cannabis industry could survive the “manual spreadsheet era,” we practically cloned our Washington traceability software system overnight and deployed it as a private-sector system, independent of MJ Freeway and the state. Licensees and the majority of our point-of-sale competitors agreed that our Unified Cannabis System (UCS) was the best path forward for the industry. For a small monthly fee to cover the hosting costs of the UCS, nearly all licensees in the state were able to continue reporting to our private UCS system, which then coordinated the chain of custody transfer data between licensees and generated over a million individual spreadsheet files that were automatically submitted to the LCB. It’s not an exaggeration to say that the UCS upheld the Washington industry and automated the reporting for more than 1,600 licensees from Nov. 1 until MJ Freeway’s system finally launched on Feb. 1.

Is MJ Freeway the only company operating in this space that’s been hacked? Why do you suppose that is?

We’re all frustrated with MJ Freeway’s situation. Though we all compete with each other for business, we’re ultimately fighting together to build trust, confidence, credibility and professionalism for the entire industry. When one team suffers, we all suffer.

Patrick Vo speaks at an event.

What is BioTrackTHC doing to make sure that the data you’re processing and storing remains secure?

Because the core of what we do is data—business management data, compliance data, patient/consumer data—system security has always been a top priority. BioTrack utilizes physical cryptographic security keys as well as passwords for multi-factor authentication into critical systems. This means guessing or stealing an employee’s username and password is not enough to gain access. The unique security key must be inserted in the computer’s USB port to successfully log in. Google deployed the same security keys to more than 50,000 Google employees and found they’re incredibly effective.

BioTrack also utilizes a technology that implements the Zero Trust architecture spearheaded by Google. It piggybacks on the security keys using a chained authentication system. Every developer log-in attempt is individually managed and independently tracked. Each log-in is limited in scope and valid for one-time use, and because there are no shared keys or shared developer environments, the ability for a would-be attacker to gain access to the system is dramatically reduced. And even in the highly unlikely event attackers gained access to one system, they couldn’t access other systems.

VO: “Assigning unique identifiers and connecting new ‘child’ inventory with its ‘parent’ inventory creates a lineage chain from plant to plant material to consumable products.”

When seeking state contracts, how does BioTrackTHC stand out from the competition?

Providing business software is one of the greatest values we bring to the table. Building solutions that are informed by how licensed businesses actually operate and incorporating those real-world processes and workflows into an informed government platform sets up both the government and the industry to succeed. With so many new states coming online and the continued growth of the industry, we’ve seen both the good and the bad and can therefore help different governments navigate this new terrain more effectively.

Patrick Vo at his desk

BioTrackTHC is currently operating in Arkansas, Delaware, Hawaii, Illinois, New Mexico, New York, North Dakota and Puerto Rico. What are the different regulations challenges from state to state?

Every state’s cannabis program, and the rules and regulations surrounding it, is unique. Though there are similarities and overlap, they’re all individualized to some extent. Since we’ve developed both a government-grade system and a business-grade system, we possess a robust and diverse array of turnkey software features and workflow options to build a system that can meet the vast majority of a new state’s needs right out of the box. Our team of experienced government-product managers is responsible for understanding all of the relevant cannabis regulations in their assigned states, for monitoring changes to those regulations and for managing the design modifications to the software to meet the needs of those regulatory changes.

An interesting example is Hawaii. The islands of Hawaii are separated by federal waters and federal air space, so though medical cannabis is allowed to move from production facilities to dispensary facilities on the same island, transport to other islands is not allowed. As an added control to make sure that licensees don’t intentionally or unintentionally violate the law, we wrote some code to constrain transportation so that the destination facility must reside on the same island as the originating facility.

A much more complex example is Washington state as it relates to Native American tribes. The tribes within Washington State may operate their own producer, processor and retail facilities that can also participate with the non-tribal Washington cannabis industry. Cannabis inventory can freely move between tribal licensees and non-tribal licensees, but the treatment of cannabis excise taxes creates some interesting dynamics. Tribal retail dispensaries may sell both tribal-grown products and non-tribal products. These tribal retailers are still required to retrieve cannabis excise taxes from the end-consumers in order to not have an unfair advantage over non-tribal retailers. However, those excise taxes are remitted to the tribal government and not to the Washington government because the Washington government has no authority over tribal businesses.

Non-tribal retail dispensaries may sell tribal-grown products in addition to non-tribal products and they too must retrieve cannabis excise taxes for both. However, the Washington government must separately track the excise taxes collected from the sale of tribal products so that the state can remit that portion of the taxes to the tribes.

How’s the medical-marijuana program in Puerto Rico doing?

It was originally supposed to get off the ground right around when Hurricane Maria hit the island in September. However, the cannabis businesses showed some real grit and was integral to restoring the island back to normalcy. Although much of the island is still in need of support and many people are still in horrible situations, there has been a collective push from the industry and the island as a whole to get cannabis businesses up and running because that means jobs, wages and tax revenue that could go towards post-storm recovery. In addition to the overall economic value that the businesses generate, many of the cannabis business owners and staff personally stepped in to help. It’s been truly inspiring to see how strong the Puerto Rican community is in the face of adversity.

Do you have any concerns about the legal cannabis industry grinding to a halt because of federal intervention?

I’m not very concerned at this point. Popular support for the legal cannabis industry is too large for federal law enforcement to shut it down. [Attorney General] Jeff Sessions and the U.S. Attorneys have to know that a large-scale crackdown on the cannabis industry would be political suicide.

How would you react if a U.S. Attorney showed up at your door one morning with a warrant?

I would say, “Sir, we’re a software company. We don’t sell seeds.” I would attempt to have a respectful and constructive conversation with the U.S. Attorney. Whether he or she is for or against cannabis, society’s acceptance of it is a foregone conclusion. Not everyone is pro-cannabis, but not everyone is pro-alcohol or pro-tobacco either. Even if you don’t agree with the movement, everyone can support technologies that strengthen public safety through facilitating transparency and accountability. If the U.S. Attorney continued to pursue the warrant, then so be it. We’re a part of this industry and will continue to stand up for it.

This article appears in Freedom Leaf 32. If you enjoyed this article, subscribe to the magazine today!

MJ Freeway’s Seed-to-Sale Dilemma

Seed-to-Sale Tracking: How It Works

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