CCRS 2022-01-09 - 6 Day Pre-Launch Report

In about six calendar days the Washington State Liquor and Cannabis Board will launch an update CCRS platform. The notable changes in this update are two fold:

• The Product Category and Type information has been scrambled.
• A tedious web-form process (w/captcha) is being replaced by a CSV upload.

There are a couple of other bumps we've identified along the way.

CCRS History

In December 2021 the LCB announced they would replace their real-time track-and-trace system powered by LeafData (MJ Freeway) with a internally-designed system with CSV file uploads as the "API". It was deployed on an aggressive time-schedule with little feedback from the industry. Many licensees complained, all of the software integrators provided feedback on better ways to do things. It was largely ignored by the LCB. OpenTHC has continue to be critical of the CCRS technology, while at the same time being a large proponent of the choice the Agency made to own their technology stack.

Product Classification Changes

These changes seem minor but in reality they are not. Most of the options for intermediate bulk products have been move into retail-unit type products. Wide paths of software across dozens of vendors and thousands of licensees have just been scrambled. Everyone in the industry depends on these classifications -- and those classifications are tied to specific regulations. These (unnecessary) changes will lead to large scale confusion on regulatory product classification.

A second confounding factor on these changes is that an external working group of software vendors (WCIA) has their specifications built on top of legacy LeafData behaviours and early CCRS specifications. This means that going forward from January 9th -- this deviation will widen.

The possibilities for product mis-classification are huge and the causes are two-fold:

• a) the LCB is changing the meaning of critical, regulatory terms.
• b) the WCIA work-around, which was using those terms will now break-away.

The end result is that licensees (and their software vendors) will have to chase down these terminology inconsistencies on a case by case basis -- for 100s of products across 1000s of inventory items.

And of course, with the changed -- and now no-longer valid choices for bulk material -- what should they be classified as? There is an open issue with the LCB #56

Manifest CSV Files

Since the CCRS changes were announced we've uploaded over 80 attempts and have only had success twice. Issues with these uploads are failing other vendors as well #54

Today (2023-01-03) we uploaded 42. Of the 42 uploaded -- only five (5) generated any kind of error at all -- this means that 37 were just completely lost. The LCB did send a notice that "due to a configuration issue during our deployment, which we have corrected and noted for future deployments" those emails were not deliverd -- and told us they should be delivered now -- but no messages ever arrived.

Sometimes the system reports that a Manifest has been partially accepted -- when it has not been accepted at all #58

There were other minor isues involving field name inconsistencies #46 and #53

The Phone number fields are limited to 14 characters -- which causes problems if one tries to include an extension #55

Notably, the CCRS Manifest file was NOT allowing all valid characters in the email addresses which was causing some failure. The LCB has since fixed their system to accept a broader range of valid emails.

Other Issues

We've uploaded Product information which was accepted, then uploaded Inventory linked to that product. However the system is reporting an Invalid Product. #57

At one point our connected licensee list in the TEST environment was somehow corrupted and showed licensee that we were NOT authorized for (IR68951). This caused lots of confusion on uploads, and is related to #15 Integrator License Page missing License ID from 2021-09-21. The LCB claims the licensee had removed them but it had not been fully processed -- which doesn't make sense -- licensees are not signing in to the TEST environment and changing these settings -- especially when they are active clients on LIVE.

Ideas Fixes

Well, not to beat this dead horse too much but -- we'd love the LCB to move back to a real-time, full transactional, JSON based API. It's what they had before with both BioTrack and LeafData, it's what Metrc does (and it's what our own compliance engine does too).