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Tuesday 23 April 2019

Cannabis Testing Labs

 
 
A testing lab is an essential piece in the regulatory framework that brings legalized cannabis from the farm to the medical or recreational consumer. It is essential for all licensed cannabis businesses to test their products to ensure compliance. Testing labs test for amounts of various cannabis compounds, primarily the delta9-tetrahydrocannabinol(THC) and cannabidiol (CBD) content, in each product. Labs test to ensure that the amounts of these compounds as specified on their packaging are in line with what is in the actual product. More importantly, labs test to ensure that the amount of pesticides and chemical fertilizers used for growing the plant are within safety levels. Testing also looks to detect contamination from metallic pollutants that have made their way into the product. Testing checks to see if plants are free of mold, yeast and bacteria. Cannabis, in places where it is legalized, probably undergoes more stringent testing than most of the food and water we consume.

In the US, before retail outlets and dispensaries are issued licenses to start operations, they need to ensure that their products are tested and that these reports are validated by the cannabis regulatory authorities. For this reason, test labs need to be up and running earlier than retail outlets and dispensaries to test the product upstream in its business cycle. There have been issues where test labs are not consistent with each other and don't have common testing standards. It has also been reported that extensive testing has resulted in increased production costs as well as excessive rejection of product, all of which have increased the price that the end consumer has to pay. However many consumers of legal cannabis cite the fact that the product has been quality tested as one of the positives of the legal cannabis industry. 
 
What is probably the sweet spot in terms of the right amount of testing is that the safety testing for cannabis should be no more and no less than that for any consumable and perishable farm produce. The norms to be followed should equal that for any produce which is grown for human consumption and the testing bodies, product quality and safety testing methods must be similar to any other agricultural produce. Anything less than this in terms of testing will put consumers at risk. Anything more than this will lead to increased costs for both producer and consumer. It will also be unjust discrimination against the plant and mean unnecessary hurdles in the path to its normalization in society. More stringent testing norms for only the cannabis plant will create an opening for the exploitation of the cannabis grower, as well as a means for entities who stand to gain through making life harder for the cannabis grower, such as competing growers and industries. It will be an additional burden on the small farmer who is struggling to emerge from the years of cannabis stigmatization.

Recent reports of substandard accessories causing health issues have come to light. This is especially with regard to vapor cartridges used in vaporizers many of which are now duplicates closely resembling original brands and products. The EVALI epidemic among users of vaporizers  with contaminated cartridges indicates the kind of challenges that cannabis regulation faces and the need to extend testing to cannabis accessories and not just limit it to the actual plant.

Organizations such as the US FDA maintain a tight regulation of cannabis usage in food, beverages and wellness products, specifically the usage of the compounds cannabidiol (CBD) and delta9-tetrahydrocannabinol (THC). There has been much debate about the limits that such organizations place on the amount of these compounds in different products. As a better understanding of the benefits of these compounds emerges, one expects to see less stringent norms regarding them from these bodies.

While work on establishing testing labs and uniform standards to measure the various compounds in a cannabis product is essential, there is a vital need to do away with the 0.3% THC limit that decides whether a cannabis plant is a narcotic or not. This 0.3%THC limit is a completely arbitrary, unscientific limit that has been imposed on the plant. This determines whether a plant will live or die. In most places, cannabis plants with THC above the 0.3% limit are destroyed as illegal. In a lot of cases, even plants with THC less than 0.3% are destroyed because the authorities do not have the wherewithal to test a plant for its THC levels, or because the authorities are just ignorant or do not care either way. This is the root of discrimination against the plant world wide, akin to the segregation of a human because of the amount of melanin in his or her skin. Doing away with this discriminatory limit will not only ease the working of numerous standards organizations and testing labs, law enforcement and cultivators, it will go a long way in saving the millions of cannabis plants that are killed each year as a result of this, besides the hundreds of thousands of humans who are imprisoned or killed because of it. 
 
Already many countries are starting to adopt a less stringent 1% or 2% THC limit to differentiate between industrial and narcotic cannabis. Even this, according to me, is unreasonable. THC is one of the most medicinal and beneficial compounds in the cannabis plant. Irrespective of the amount of THC in a plant, it can be used for whatever purpose one desires - be it industrialmedical or recreational. Numerous studies have shown that THC cannot be equated to alcohol in terms of the damage it causes to the individual. Despite the harms of alcohol, we still find in retail outlets, alcoholic drinks with the percentage of alcohol as high as 80%. No naturally growing variety of cannabis will produce THC at levels higher than 30% is my thinking. Most naturally growing varieties will have THC in the range of 5% to 10%, in naturally well balanced proportions to the other cannabis compounds present in the plant. It is the artificial methods used to grow cannabis, specifically to raise levels of THC, that has resulted in cannabis with THC levels higher than 30%. If regulation on THC levels must be done, it should be by targeting these growers of hybrid or doctored varieties of cannabis, not the growers of natural varieties of cannabis. The amount of resources to uphold this completely illogical 0.3% limit on THC, and the number of cannabis plants that get destroyed as a result of it, and the number of persons who get into legal trouble as a result of it is more tragic than comical.  

Related articles

The following set of articles related to the subject are taken from various media. Words in italics are the thoughts of yours truly at the time of reading the article.  
 
'This also is a good opportunity to consider the ramifications of laboratories that draw conclusions on THC concentration in marijuana samples where the only available reference materials are < 0.3%.

The NIST report is a great start to the federal understanding of challenges facing the cannabis testing laboratories, including – but certainly not limited to – a shortage of standard test methodologies, appropriate calibration (including calibration curves) programs and reference materials.'

https://mjbizdaily.com/us-agencies-getting-serious-about-cannabis-testing-challenges/


'NIST already guides standardized testing and measurement in other industries, such as dietary supplements and food safety. “We work already in this space with regulators, product manufacturers, farmers, on the forensic side as well as in other areas,” NIST research chemist Brent Wilson told Marijuana Moment in a recent interview. “We had the interaction with them already, and we knew that they needed us to get involved to help improve the analytical testing [of cannabis] that’s being done in the community.”'

https://www.marijuanamoment.net/federal-science-agency-issues-first-report-on-thc-and-cbd-variability-in-cannabis-laboratory-testing-results/

 
'Since hemp and marijuana are indistinguishable without a chemical analysis, these cases represent a dramatic departure from traditional seized drug cases. Being able to determine whether the amount of THC in a sample is higher than 0.3% — the legal amount for hemp — brings with it a razor-thin margin of error. So the question becomes, how can we perform quantitative THC testing in the most efficient manner?

From day one of legalized industrial hemp production, we’ve relied on an outside vendor to do the testing. While this is time-consuming and expensive, the needs of the judicial system have exceeded our capabilities.

We now are close to implementing a test in our lab to determine if the THC concentration in a sample is above or below 1%. It is not the 0.3% legal threshold, but we feel that testing to this level is a reasonable first step toward distinguishing hemp and marijuana, as there is little to no market for illicit marijuana with less than 1% THC.'

https://nij.ojp.gov/topics/articles/efficient-casework-policy-address-emerging-challenges-seized-drugs#about-author--0


'"Unregulated illicit market cannabis products, like products in an unregulated marketplace, are of variable quality and may put some consumers at risk," Armentano said. "These incidents linked to the use of unregulated, illicit market vapor cartridges reinforce the need for greater market regulation, standardization, and oversight — principles which NORML has consistently called for in the cannabis space. Consumers must also be aware that not all products are created equal; quality control testing is critical and only exists in the legally regulated marketplace."'
https://norml.org/news/2019/08/29/hospitalizations-linked-to-use-of-unregulated-vapor-cartridges


'“These data reveal a predominant use of prefilled THC cartridges sold through informal and unregulated markets, although the origin of these products further back in the production and distribution chain is unknown,” the report states.

The report goes on to say that it’s unclear if the cause of the illness is THC or “a substance associated with prefilled THC cartridges, such as a cutting agent or adulterant.”'
https://mjbizdaily.com/cdc-reports-majority-of-patients-sickened-in-vape-epidemic-used-marijuana-vaporizer-devices-many-from-illicit-market


'CannaSafe also tested 10 of the unregulated cartridges for pesticides. All 10 tested positive.

The products all contained myclobutanil, a fungicide that can transform into hydrogen cyanide when burned.'
https://www.nbcnews.com/health/vaping/tests-show-bootleg-marijuana-vapes-tainted-hydrogen-cyanide-n1059356


'Massachusetts regulators on Thursday issued final licenses to two marijuana-testing laboratories, paving the way for the launch of the Bay State’s much-delayed recreational cannabis program.

Rec sales are expected to begin within weeks. The market had been scheduled to launch July 1.'
https://mjbizdaily.com/massachusetts-oks-two-cannabis-testing-labs-clearing-way-for-adult-use-sales/


'From July 1 through Nov. 30, labs tested 23,864 batches of various products, and 3,373 failed. The test results through November showed that about 90 percent of buds are cleared for sale, suggesting a mostly clean market for growers.

The biggest reason for failure is improper claims on labels, such as overestimating a product’s potency, which blocked over 2,100 products from sale. The California Growers Association, an industry group, is among those concerned the state is forcing growers and manufacturers to hit too tiny a target when gauging levels of THC.

Pesticides, meanwhile, accounted for over 700 rejections in various products.'
https://apnews.com/b45648b55ec84f4ea3a43439f0d4b7e5


'Ohio regulators awarded the state’s first certificate of operation to a laboratory to test medical cannabis, clearing the last obstacle to medical marijuana sales.'
https://mjbizdaily.com/ohio-regulators-approve-medical-marijuana-lab/


'A new round of regulations in California will cause laboratory testing fees to increase more than 40%-55% for some of the state’s licensed cannabis cultivators as well as makers of concentrates and infused products, according to industry experts.'
https://mjbizdaily.com/california-marijuana-phase-3-testing-costs/


'California’s infused product makers and testing labs are breathing a sigh of relief now that state regulators have sought to clarify rules governing THC potency for edibles and beverages, a move that is expected to result in fewer products failing lab tests.'
https://mjbizdaily.com/california-regulators-clarify-rules-around-thc-limits-in-edibles/


'Hawaii News Now reports that Honolulu-based Steep Hill Hawaii is rejecting 20%-30% of the marijuana that comes through its doors.

Michael Covington, chief operations officer for Steep Hill Hawaii, told the news outlet that 95% of the failed cannabis is testing positive for “biological organisms,” including mold, yeast and bacteria.'
https://mjbizdaily.com/hawaii-lab-rejects-more-than-20-of-medical-marijuana-tested/


'Reliable cannabis laboratory testing is an attainable goal. In the absence of federal regulations in the United States for the foreseeable future, it will be incumbent on state regulators to implement universal testing standards for cannabis laboratories.'


'Flowers from Ohio's first mature plants will be dried and ready for sale in early November. But when that marijuana is sold depends on when the first testing lab and dispensaries open.

As of today, none of the five state-licensed testing labs are operating and none of the 56 licensed dispensaries have opened their doors. No patients have been registered for the program, but the Ohio Board of Pharmacy says the patient and caregiver registry can be turned on as soon as Ohio’s market nears operation.

The state’s first testing lab could open at Hocking Technical College in early November, and dispensaries could be ready in December, state regulators told the Ohio Medical Marijuana Advisory Board on Thursday.'
https://www.cincinnati.com/story/news/2018/10/04/first-medical-marijuana-harvested-ohio/1523310002/


'Testing has been especially tough on cannabis-infused cookies, candies and tinctures: About one-third have been blocked from store shelves'
https://mjbizdaily.com/nearly-a-fifth-of-california-marijuana-products-failing-testing-standards/



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