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Why do cultivators of state-legal cannabis test their product? The question may sound naïve but, as we’ll see, it is worth asking.
Here are some answers:
First, they may test to monitor how changes in their growing practices (nutrition, lighting, pesticide use, others) may affect potency or other qualities of the product. On the specific issue of pesticide use: since marijuana possession, etc., has been criminal for a long time, and remains criminal at the federal level, there has been little botanical research on the interaction of various pesticides with the plant. Thus, there are no experts, and the industry will have to try to figure this out, going forward. Sample testing will be part of that process.
As a metric of the complexity of the work to be done, consider that Oregon presently tests for 59 pesticide analytes, along with 45 solvents, and their action levels.
Second, growers want to monitor the genetics, improving some of their strains through selective breeding, abandoning other strains, and in general controlling for quality. In a recent email exchange, Anthony Smith, Ph.D., founder of Kenevir Research, said that in-house testing is “only of value where the costs of having the measuring technology are outweighed by the value of the information” for product development, quality assurance, lean manufacturing systems or the like.
Smith’s advanced understanding of cannabis testing has made him an asset to the industry. Oregon Gov. Kate Brown recently appointed him to the state’s Task Force on Researching the Medicinal and Public Health Properties of Cannabis. Signal Bay (OTC:SGBY), a leading provider of expert, analytical, and operating services to the medical marijuana industry, brought Smith on as an advisor to the company because of his expertise in cannabis testing and genetics. By late 2015, Signal Bay and Kenevir entered into a strategic relationship by means of an MOU.
Monitoring strains over time does not apply especially well to the do-it-yourselfers in their basements, individuals who generally have short time horizons, but it is certainly a concern of major growing operations.
A marijuana plant produces no less than 70 different active compounds. Of these, two are the most important, tetrahydrocannabinol and cannabidiol, aka THC and CBD. A particular patient receiving medical marijuana may be interested in knowing the THC/CBD ratio contained in a strain, which in turn affects such things as the severity of the “high”; therefore, of course, the health care provider, the dispensary, etc., are all very interested as well. In general, CBD is not psychoactive itself, and the more of it relative to THC in a particular strain the lesser the subjective “high” experienced.
There is also CBN, which is often confused with CBD. CBN is psychoactive, though not as intensely so as THC, and its presence tends to lessen the anxiety-producing consequences that high levels of THC can arouse, an important trait for many end users.
Grading the Outcome of the Buds
The third important consideration for growers who may and do test is: it helps them decide on the best moment for harvest. For growers, it is critical not to cut down plants that have not reached their peak THC production yet. It is also important not to wait too long. As a writer in High Times said two years ago, either mistake can be very costly “when it comes to grading the outcome of your buds.”
As that language indicates, the use of testing to decide on harvest times runs naturally into the next item on our list, its use to inform buyers about potency.
So, fourth, growers may and do test to tell their buyers about the potency of what they are selling. Smith and others contacted for this article have cautioned that the market for in-house testing will likely remain limited, because it doesn’t suffice for this fourth purpose, nor will it suffice for the fifth, to which we’ll come in a moment.
“As long as there are buyers and sellers,” Smith said, “there will be a strong need for contracted, independent, ‘third-party’ analytical testing.” Sellers, at any level on the chain, who want their product tested in a way that will satisfy the potential buyers at that level about its quality, composition, etc., will want it tested in a rigorous way by validated laboratory processes, not by the sort of mobile “meters” that have made their appearance on the market of late, Smith and others believe.
Finally, the fifth reason on our list: growers will test, or contract out for testing, simply because legislation or regulations require that they do so. Many states take much of the decision making out of the cultivators’ hands. Lori Glauser, president and COO of Signal Bay, pointed out in a recent email that Nevada, Oregon, and Massachusetts now mandate testing by an independent, accredited lab prior to wholesale or retail sale of the product (as flower, concentrate, or edible), and Signal Bay expects the same will be true in the future of California and other states. In Connecticut, a medical-marijuana only state, there are only four authorized cultivators, and they must have their product tested by one of only two authorized labs.
Those five points don’t necessarily make up a complete list, but they certainly suffice to indicate that testing is an important matter for growers.
Down the Supply Chain
Moving down the supply chain: what about the dispensaries?
There is an analogous range of reasons why they might test.
- To employ this knowledge for leverage in pricing discussions with the growers;
- To provide real-time potency information to customers (with the caveat mentioned above about whether they consider that entirely advisable);
- To develop trust with those customers, perhaps including a “budtender” relationship in which the dispensers may suggest products appropriate to desired affects or symptoms.
- Finally, they too test when and because legislation or regulation requires it.
Discussions with dispensaries in the state of Connecticut told a discouraging story from the point of view of the marketers of testing equipment who might seek them as customers. Tom Nicholas, the CEO of a state-licensed medical marijuana dispensary, said in a brief interview that the dispensaries “can’t open the safety sealed packaging that we receive from the producers, therefore, no need for in-house labs.”
Likewise, Laurie Zrenda, the principal of Thames Valley Relief, in New London, Connecticut, said, “The growers are the ones with the relationships with the labs. I am only a dispensary and I don’t have any contact with the labs.”
Still, as noted above, satisfaction of the regulatory requirements is only one of the reasons for testing. Manufacturers of testing equipment are betting that they will be able to persuade cultivators and the other parties involved to do their own testing side-by-side with whatever laboratory testing continues to be required.
The Sources of Bias
Testing for all parties along the supply chain, and for the benefit of regulators too, requires an understanding of the sources of bias.
The obvious bias is that, typically, the cultivator, dispensary, or whatever institution wants the testing done will have obvious incentives to get a “good” result, a higher reading for THC and CBD in particular. These incentives are of course present for any in-house form of testing, but they can be passed along to a lab as well, either subtly or blatantly.
A related weakness, then, is that it is easy to increase the sample results for THC or CBD. This may require nothing more than that someone in a lab shake the bag of marijuana until the trichomes collect at the bottom. Trichomes are those tiny crystalline hairs that typically cover the buds. So once they’re at the bottom, the tester can smear a bud in them and voila! High numbers!
Jason Lupoi, the director of scientific applications at Sage Analytics, explained an even easier fix. “You can artificially increase the potency results just by drying off the sample,” because potency is measured as a ratio of the pertinent chemicals to the total mass of that sample. As the amount of H2O in that mass decreases, the mass of the psychoactive molecules is unaffected, so the ratio improves.
According to another point of view, however, drying off the sample isn’t a bug—it’s a feature. Smith said that accredited labs will employ “validated extraction procedures” to produce consistently dried out samples for their testing. So there may be some disagreement even over what counts as a bias.
Another point about bias becomes clear if one sets human incentives and carelessness aside and thinks only about the lab machinery. There is no uniform source or standardization for the lab equipment. Indeed, some critics see the lab industry as a “Wild West” in which every gun-slinger declares himself sheriff. That vision has thrilled television viewers for generations, but should not entice cannabis users.
Controversies continue. State-legal marijuana remains an infant industry, one still living under the cloud of Schedule I, so neither regulatory nor informal market standards for testing have anything settled about them.
In the words of Glauser, of Signal Bay, “There are tremendous incentives for growers to show high potency results and acceptable pesticide content. And those incentives can be passed along to non-accredited labs with a wink and a nudge. We’ve even heard stories of growers paying labs a little extra for more favorable results. Third party, accredited labs are absolutely necessary to ensure accuracy and eliminate bias.”
In Part II of this discussion, we will look at testing more explicitly from the point of view of the regulators, as well as from that of the ultimate consumers, the recreational consumers and/or patients and caretakers. We will have a good deal more to say, in that context, about pesticides and other possible contaminants. We will have something to say, also, about the reasons Signal Bay has recently acquired a cannabis testing lab in Bend, Oregon, and announced plans to open a lab in California, “in the heart of the Emerald Triangle,” in the near future.