Oregon Growers Analytical

Eugene's first and only premier cannabis testing facility; providing the best possible analytical testing services to the Oregon cannabis industry. Trust Your Bud™

[oganalytical]

Don't forget! Tonight is our monthly #FREEevent, Cannabis Science Pub 6-9pm at @cozmicpresents; feat. Jeremy Plumb from @farmapdx and Dr. Ken Walker from Oregon Optimal Health talking about the #endocannabinoid system, as well as #CBD success stories from Cham MacKenzie at @tjs.organic.gardens. Join us for a relaxing evening of pizza and beer while we learn more about the science of cannabis! https://www.facebook.com/events/747726785350107/

[oganalytical]

The Complicated Reality of Pesticide Analysis

There is a common thought circulating that a GC is the most appropriate instrument for pesticide screening on cannabis. While this is a great start to a more in-depth conversation about consumer safety screening, it gives an incomplete picture which can lead to detrimental health impacts if left unclarified.  

We must begin with the goals of a pesticide screen. The obvious goal is to determine whether or not trace levels of pesticides are present in a particular commodity. Furthermore, the analysis must be performed in such as manner as to protect against false negatives (i.e. reporting that pesticides are not present when one or more actually is) and false positives (i.e. reporting that a pesticide is present when it actually isn’t). Protecting against false negatives is important since the primary purpose of the test is to protect consumers from unknown and unwanted exposure to toxic compounds. Protecting against false positive is important since it prevents producers from being subject to erroneous data that jeopardizes sale of valuable commodities.

The reality is that screening for pesticides is actually quite complicated. There are thousands of pesticides and there is no such thing as a single simple test that can detect all of them. In addition, tolerances are actually quite low so the methods that are used must be very sensitive. The low level of detection therefore requires that the testing procedure can accurately identify a pesticide despite typically very high levels of background compounds that come from the commodity itself.

Because of the reality that pesticides are allowed for use in agriculture, but consumers must be protected from undesired exposure, various regulatory agencies such as the FDA, EPA, USDA, and various universities have spent a great deal of time and money developing appropriate testing methods. A validated testing method has not yet been published for the determination of trace levels of pesticides in cannabis. However, a method known as the AOAC 2007.01 method has been developed and validated for thousands of agricultural products. It seems reasonable that this method is an appropriate starting point for the determination of pesticides in cannabis.

The AOAC 2007.01 method involves using an organic solvent to extract pesticides from the sample. This crude extract is then subject to various well-established steps to remove plant co-extractives such as chlorophyll, plant fatty acids, and plant waxes. It is important to remove these compounds since they interfere with the downstream detection methods.  The cleaned extract is then analyzed using both gas-chromatographic (GC) and liquid-chromatographic (LC) separation followed by mass-spectrometric detection. It is important to realize that both GC and LC are necessary because neither technique is capable of chromatographing and detecting all pesticides. For instance, most carbamates and fungicides cannot be chromatographed on a GC because they breakdown in the heated inlet. In contrast, although theoretically all pesticides can be chromatographed using LC, some types of compounds (e.g. organochlorines) cannot be detected using LC technologies.  Equally important is the realization that GCs and LCs can be configured to use different types of detectors. It has been universally realized that the only detectors capable of conferring the accuracy of identification of pesticides are mass-spectrometers. Mass-spectrometers allow one to identify low levels of pesticides even in very complex extracts that are typical of agricultural products. This is very important in minimizing false positive and false negative results.

We must also understand that nearly all products that are put into our bodies are already screened in established testing labs scattered across the country to ensure that inappropriate pesticides are not present and that those that are present are below accepted levels.  Because of the risks associated with false positive and false negative results, these labs are subject to strict oversight by organizations such as the EPA and FDA. An important part of this oversight is that these labs must be accredited by independent accrediting agencies. This accreditation involves on-sight inspections of the facilities to ensure that the labs are following appropriate procedures and have an appropriate quality control system in place. Unfortunately, cannabis testing labs in Oregon are not currently subject to any oversight to ensure that they are using appropriate methods and that their reported values are correct.  

Until we have an audit system in place to ensure the validity of a lab’s ability to perform consumer safety screening for cannabis, the burden is on consumers to ensure their products have been screened appropriately.

Authors: Rodger Voelker, PhD, Lab Director at OG Analytical and Bethany Sherman, Executive Director at OG Analytical

[oganalytical]

So encouraging to see the good people at @oregonsconstantgardener helping local #cannabis growers to be responsible #pesticide applicators. Thanks and keep up the good work!! #TrustYourBud

[oganalytical]

You can run but you can't hide, #abamectin #azadirachtin #acequinocyl. Scariest #halloweed ever with these 3 joining the party. Be expecting a possible sharp increase in pesticide failures in the near future. #trustyourbud

[oganalytical]

Another mind-blowing #bho #shatter from @nextlevelwellness541 testing at 88% #totalthc (99% #thca!) For all you doubters out there: the falcon tubes pictured show this sample's (lack of) plant waxes compared to other #concentrates. #nofilter #labshots #trustyourbud @acrossintl #aifam

[oganalytical]

Can you name that #cannabinoid? Have a Happy #FourthofJuly :) #labshots #moleculemascot #TrustYourBud

[oganalytical]

Now available at @nextlevelwellness541 ! This #PinkKush is one of the cleanest concentrates we've seen, testing at 82.5% total #THC! Get yours today!

[oganalytical]

Brand new #CannabidiolicAcid #CBDA Standard from @RestekCorporation! #WhatWeveBeenWaitingFor

[oganalytical]

Alright! @brightsidepdx is the Feature Co-op in this month's @dopemagazine !! Also featuring @wizkaliko :)

[oganalytical]

Who's Really Taking the Initiative?

Spring is here! and with it some fun in the sun, a 4/20 Easter, and fresh ballot initiatives. Ballot initiatives? That's right, ballot initiatives!

Having been put to shame in the last legislative cycle by both our neighbor to the North and self-titled upstart 'Bongistan' to the East, the cannabis community in Oregon is now eager to show all the other states what progressive marijuana reform really looks like. While it may seem strange that signature gatherers are already out in force for this, remember: in Oregon, a bi-polar state whose cannabis use has historically outpaced the national average by about 40%, everything is politics.

Many of us, in our quest to see full legalization happen in our lifetime, are eager to support legislation that will realize this, "...and damn the cost!" some say. But with multiple ballot measures competing for the same voter demographic the situation can become complicated. For a good example of this just look at California's recent ballot initiative debacle from 2012. None of those measures could come to fruition due to the others, and California continues to be a patchwork of municipal and county regulations.

If you aren't already clear on the details of what's happening this fall, let us bring you up to speed; two Adult-Use legalization initiatives are trying to make their way onto the State ballot this November: notably Initiatives 21 & 22 (The Oregon Cannabis Tax Act) (OCTA), promoted by Paul Stanford of The Cannabis and Hemp Foundation (an effort which Oregon voters previously rejected in 2012 at 43% of the vote); also, the Control, Regulation, and Taxation of Marijuana and Industrial Hemp Act (CRTMIHA) coming from New Approach Oregon's Anthony Johnson.

In an initial comparison of the basic details: the CRTMIHA is 34 pages long, with 86 sections of new regulation amending existing drug laws to exempt marijuana, and designates the Oregon Liquor Control Commission (OLCC) as the agency to tax and regulate marijuana production and sales; the OCTA is 4 pages long, creates a new Oregon Revised Statutes chapter (ORS 474), outlining the responsibilities of a newly-created Oregon Cannabis Commission as the agency to tax and regulate cannabis cultivation and sales. Both include provisions for Industrial Hemp. Neither affect the Oregon Medical Marijuana Act (OMMA).

There is simply too much text to sufficiently examine the CRTMIHA in a single blog post, so instead we will look at those aspects which most differentiate it from the OCTA.

State Sales vs. Private Sales

Anyone who can drink alcohol in the State of Oregon is aware of the OLCC, who, in addition to putting the fear of God into lenient bartenders and convenience store clerks everywhere, sell all their products to contracted liquor stores at a set price. So while the OLCC has decades of regulatory experience, we have to question the wisdom of CRTMIHA assigning this task to them. The alcohol and cannabis markets may have some similarities, but we are very different industries with very different needs! We believe the OCTA approach of a new Commission (to be chosen by the Governor), hopefully made up of responsible industry leaders, would better serve our industry.

Vertical Integration vs. Corporate Cannabis

The fear of many Oregonians in the cannabis community is "the Marlboro-ization of Marijuana," and this is a legitimate concern. Small-scale "Mom & Pop Shop" grow operations are the norm here in Oregon, who much like their Emerald Triangle counterparts are not equipped politically or financially to maintain their place in the coming "green rush." So while the OCTA allows "the cultivation and possession of up to 24 cannabis plants and 24 ounces for personal, non-commercial use" (ORS 474.065(3)), The CRTMIHA calls for the OLCC to process 4 separate types of license: Production, Processor, Wholesale, and Retail (Sections 19-22), and limits private grows to 4 marijuana plants and 8 ounces of personal possession. Furthermore, Section 24 of the CRTMIHA states that a person may hold one or more licenses in any category. It is clear to see that the OCTA promotes vertical integration for homegrown cannabis while the CRTMIHA will create barriers of entry for existing growers, while simultaneously opening the door for out-of-state corporate interests.

The Future of Concentrates

Section 6 of the CRTMIHA sets the allowable "non-commercial" amounts for the "making, processing, keeping, and storage, of homemade marijuana products" at: (a) 8oz of flower, (b) 16oz of Solid, and (c) 72oz of liquid. These weight amounts defy logic (i.e. many concentrates come in liquid form) so we appealed to the Definitions for clarification ...which gave none. Section 57 of the CRTMIHA, copied here in full, goes even further: "Homemade marijuana extracts prohibited. No person may produce, process, keep, or store homemade marijuana extracts." Again we searched Definitions for language to differentiate "extract" from "concentrate" and found none. Our conclusion? With cannabis extract and concentrate products on the rise in both the medical and recreational markets, the CRTMIHA does not appear to be well-structured as a forward-thinking policy.

"Is Not of Good Repute or Moral Character"

The last point we will take up today is Section 29 in the CRTMIHA which covers under what grounds the OLCC can refuse to issue a license. While many of the stated reasons are perfectly reasonable a few stand out as being potentially difficult to qualify, let alone quantify. For example: Section 29 (b)(B) "is in the habit of using alcoholic beverages [...] to excess;" Section 29 (b)(E) "has maintained an insanitary establishment;" Section 29 (b)(F) "is not of good repute or moral character;" Section 29 (b)(I) Is not possessed of or has not demonstrated financial responsibility sufficient to adequately meet the requirements of the business proposed to be licensed." These all seem like good points to consider when describing what sort of person you don't want dating your daughter, but writing into law that an agency can deny license to a person solely based on its interpretation of that individual's moral character or financial solvency is simply too much.

We here at Oregon Growers Analytical are big supporters of vertical integration for the 'boutique' grower and concentrate producer. We want to see local businesses succeed in building a respectable brand that contributes to the quality of our industry. In any emerging market there are always shady agendas and unscrupulous operators playing the field, so as the petitions start flying this Summer please strive to educate yourself about what you are signing and more importantly what you intend to vote on. Not all Initiatives are created equal, and the devil is definitely in the details.

[oganalytical]

[oganalytical]

That's right, if you're up this late you're just looking at #nugporn...

[oganalytical]

Aaron Smith of @NCIAorg talks about the future of #marijuana businesses in #Oregon at last night's social

[oganalytical]

...@tdazzl and @WizKaliko talkin' shop at last night's #Cannabis industry social. Great meeting you guys!

[oganalytical]

random sidewalk #derp

[oganalytical]

High on the Agenda

As a facility focused on what we can understand about cannabis from scientific testing, sometimes we can lose track of what may be going on behind the scenes as more regulations are developed for our industry. With so much happening in the daily development of our national attitude towards cannabis it's easy to get hung up on agendas, our own or others'.

Some people in our community are more concerned with fame and influence, or with protecting their own business interests in this emerging market. With so many agendas at stake, much like a political battle, things can turn negative and ugly very fast. Bad attitudes make for great news but poor reputations; these people know it, and spend their time obfuscating what motivates them.

Situations like this are easy to post about, and there are a lot of negative influences to pick on. But at the risk of setting you up for disappointment we're going to go in the opposite direction today, and focus on some of those individuals whose agendas are more in-line with the big picture; people brave enough to truly focus on marijuana policy rather than furthering their own ambitions in the industry:

1. Dan Riffle - Marijuana Policy Project

From debating Kevin Sabet and his reefer madness posse, to recently circulating a petition for the President to fire D.E.A. Administrator, Michele Leonhart, Dan Riffle has been a warrior for change in terms of shaping message and media for the MPP. As Deputy Director of Government Relations, Mr. Riffle has appeared on CNN and Washington Journal, among other shows, to discuss federal marijuana policy, and has been involved in legalization efforts from Michigan to Maryland to New Mexico.

In spite of not being a recreational or medical user of cannabis (He has said as much on social media), Dan Riffle is not afraid to go toe-to-toe with the D.E.A. in the political arena, or take vocal prohibitionists to task in the twittersphere; he has stated many times that federal prohibition is just bad policy, regardless of who smokes and who doesn't. His Twitter feed is a no-holds-barred smack-down of witty truths aimed at the unreasonable; something we've experienced first hand...

So while Mr. Riffle's efforts in marijuana legalization are highly visible, he himself has not been. Many people in this country who can now use marijuana with less fear of government reprisal owe it to Dan Riffle. So, Dan, we wanted to give you this shout out: Keep up the good work, Sir, and we hope that someday the One Hitters get to take the D.E.A. to task on the softball field as well!

2. Sam Chapman - New Economy Consulting

Who helps write State marijuana legislation, or what happens when the State's marijuana regulations are poorly crafted? Enter Sam Chapman, marijuana policy activist and full time political lobbyist at the State Capitol. Sam worked with Goeff Sugerman to write House Bill 3460, a bill recently passed in Oregon that establishes licensing and regulation for Medical Marijuana Facilities (dispensaries).

Sam Chapman founded the Students for Sensible Drug Policy (SSDP) chapter at the U of O while he was a student there. For many years since Mr. Chapman has been actively engaged in seeking out the opinions of canna-business professionals so that he can have a better understanding of how to shape marijuana policy at the State level. When the Oregon Health Authority recently released their latest draft of the rules for Oregon dispensaries, Sam was quick to take up the task of addressing some potential flaws in the draft, and as I write this is lobbying to protect safe access for Oregon medicinal marijuana patients.

We think that because of his inclusive, big-picture view and calm determinism, Sam Chapman will succeed in working behind the scenes to influence marijuana law and provide all of us in this industry with a New Economy that is fair, and right, and based on sensible policy. We thank you, Sam, for giving a voice to so many of us in the industry who don't have one.

3. Chris Goldstein - Freedom is Green

With a website focused on East Coast Cannabis in particular and national marijuana culture in general, Chris Goldstein applies his journalistic skills to cover stories about the science, justice, and business of cannabis. Mr. Goldstein is also a member of the TeaPot Party, founded in 2010 by artist and legalization advocate, Willy Nelson; he was most recently infamous for his arrest at last years Smoke Down Prohibition for smoking a joint next to the Liberty Bell.

Many of us are too afraid or unwilling to get involved in prohibition repeal at the level of street protest, but this esteemed member of the Fourth Estate has repeatedly risked arrest and criminal charges to further the message that our country's marijuana laws need to change. Beginning his career as a marijuana reform advocate hosting the Active Voice Radio show in New Mexico (where he was a radio personality for ten years), he has since been involved with NORML and spokesman for the Coalition for Medical Marijuana in New Jersey.

So for your tireless participation in, and coverage of, in-the-trenches cannabis activism in places such as Philly and Jersey, we want to give you props and encourage others to approach marijuana reform with as much fearlessness as you have. And thank you very much for the Sensible Science section on the website, which we find especially informative!

[oganalytical]

Our ad for #ReeferMadness in this week’s @eugeneweekly. Hope to see you there!