March , 20 9 

Mr. Andrew Hatch 

Chief, Program Services Branch 

Marketing Order and Agreement Division, Specialty Crops Program 

Agricultural Marketing Service, United States Department of Agriculture 

 400 Independence Ave. SW 

Washington, D.C. 20250 

Dear Mr. Hatch: 

On behalf of the American Veterinary Medical Association (AVMA) and our member veterinarians, we 

thank you for the opportunity to provide comments as the U.S. Department of Agriculture (USDA) 

prepares to implement the Agriculture Improvement Act of 20 8 and engage in rulemaking to regulate 

hemp production. 

The AVMA appreciates USDA’s outreach to stakeholders as the Agricultural Marketing Service works to 

develop and implement a nationwide program for overseeing the production of hemp. Amongst the 

diverse hemp products that may result from such programs, veterinarians have an interest in the 

production and uses of cannabinoid products. We receive countless reports from our members 

indicating that animal owners are actively purchasing these products and administering them to their 

pets and horses to treat medical conditions in the absence of veterinary consultation. We are also aware 

of several research institutions with both completed and ongoing investigations into the potential 

therapeutic benefits of cannabinoids for animals. Indeed, with the Food and Drug Administration’s 

stated awareness of growing public interest in cannabis and cannabis-derived products, and intent to 

gather stakeholder input regarding these products, their safety, and potential pathways for an efficient 

regulatory framework, there is much to indicate that cannabis and cannabis-derived compounds and 

products will continue to be of interest to the veterinary community, our patients, and our clients. 

To help ensure the quality of such products, AVMA encourages the USDA to consider how standards for 

production of hemp (and hemp-derived products) will ultimately support the efforts of the Food and 

Drug Administration (FDA) to establish a regulatory pathway that preserves the opportunity for some 

products to be brought to market as pharmaceuticals, while allowing others to potentially be brought to 

market as food additives. The regulatory structure required to address both routes to market is likely to 

be complex. Given this anticipated complexity, it is imperative that guidance from USDA be carefully 

developed and clearly communicated. As there is potential for a multitude of state programs to rely on 

the parameters set forth by USDA, the future ability of the federal government to effectively regulate 

these products as pharmaceuticals, food additives, or in other forms will depend on uniform sampling 

and testing during production. 

Therefore, we encourage USDA to establish a uniform standard, acceptable sampling and testing 

methods, and acceptable processing methods, with respect to all aspects of hemp production, but 

particularly regarding determination of the concentration of delta-9-tetrahydrocannabinol (THC) within 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

hemp plants, seeds, and their derivatives. An accurate way to determine THC content in varying types of 

product (e.g., plant, seeds, derivatives) is required to ensure the commodity produced, marketed, and 

sold meets the legal definition of “hemp” in the Agriculture Improvement Act of 20 8. We recognize 

that accurately determining whether a plant and its derivatives meet the definition of “hemp” can be 

challenging because, depending on which portion or part of a plant or derivative is sampled, and what 

analytical method is used, varying THC concentrations may result. Uniform standards for field sampling 

and testing of THC content are needed so that producers and their customers may have confidence they 

are meeting requirements set by the Act for this commodity. 

Because the AVMA is a scientific organization that relies on evidenced-based medicine, we support 

further research on cannabis-derived products as therapeutics, so that FDA approval of such products 

may be obtained. Such approval provides the assurance we need that products made available for use in 

veterinary patients are efficacious and safe. Ultimately, we hope that the collaborative efforts of the 

USDA and FDA with respect to hemp and its products will result in improved health and wellbeing for 

our patients. 

Thank you again for the opportunity to provide feedback on the proposed revisions. We appreciate your 

consideration of our concerns and requests and look forward to continued collaboration with the USDA 

and FDA. If you have further questions or would like more information, please contact Dr. Gail Golab, 

Chief Veterinary Officer, at 847-285-66 8 or via e-mail to ggolab@avma.org; Dr. Dharati Szymanski, 

Assistant Director, Division of Animal and Public Health, at (847) 285-6742 or via e-mail to 

dszymanski@avma.org; or Dr. Lauren Stump at (202) 289-32 or via email to lstump@avma.org. 

Sincerely, 

Janet D. Donlin, DVM, CAE 

Executive Vice President 

DS/LS/GCG/ML