The Blind Spot in Denver’s Pesticide Recalls [Updated]

On Friday, Denver’s 19th recall of cannabis, extracts, or cannabis-infused products occurred. The Denver Post – which has done a valuable public service with its very informative reporting on the matter – is maintaining a running list of all the recalls.

An individual perusing the above list might notice that the recalls consist primarily of cannabis extractions and infused products. In fact, only 4 of the 19 recalls have included actual cannabis plant material – or the flowers that people typically smoke – in its raw, unprocessed form. Regarding the 15 recalls that consist of edibles, concentrates, and other infused products, the Denver Department of Environmental Health’s (DEH) notices will generally consist of language to the effect of, “[Marijuana Infused Product Manufacturer] is recalling marijuana-infused products that were derived from potentially contaminated plant material purchased from [Cultivation Facility].”

This is all well and good, and many have expressed the sentiment that the recalls mean that Colorado’s regulated system is working as it should by identifying quality control issues and removing contaminated products from circulation. This is true, but only to an extent. The whole truth is that Denver’s pesticide recalls have a very big blind spot.

Continue reading “The Blind Spot in Denver’s Pesticide Recalls [Updated]”

Who’s Watching the Watchmen?

At the 2015 Marijuana Business Conference and Expo, held last year in Las Vegas, keynote speaker and longtime consumer advocate Ralph Nader provided words of warning to the cannabis industry.

“Proper regulation is the best aspirin you could ever have, other than marijuana,” Nader said, to a ripple of laughter. “We’ve got to have standards of inspection, for, say, pesticides, for fungus, for rot. We have to have standards of advertising and truth, so we don’t get hit with lawsuits.”

The lawsuits Nader presciently predicted have already arrived. More importantly for the purposes of this discussion, however, are Nader’s comments on testing labs. Marijuana Business Daily reports that Nader stressed the importance of testing labs being independent from the companies that they were testing so as to limit the possibilities for corruption.

While not allowing the same business to own the means of production and the means to approve the product produced as safe for consumption is a no-brainer, the tougher question is: How can cannabis testing labs – which are privately-owned entities in each state that they exist – truly be independent if they are beholden to the ultimate goal of generating profit from their activities? Keep in mind that legal cannabis systems in every state are functioning without the federal standards and regulations to which other agricultural and manufacturing enterprises are subject. That means that these private labs are, for the most part, the primary guardian of public health and safety for the tens of millions of medical patients and adult consumers who can obtain cannabis legally in states from California to Connecticut. Nader commented on the privatization of services meant to serve the public good – rather than shareholders or owners – and alluded to the Volkswagon emissions scandal:

“Why do you think [the Volkswagon scandal] happened? It’s because under federal law, they allowed private labs to do the testing,” Nader said. “Watch out for control of these labs by your industry. That’s when the problems are going to start.”

It turns out that Nader was right again.

Continue reading “Who’s Watching the Watchmen?”

Recent Publications: “8 Solutions to Common Cultivation Challenges,” in CBT and “Our Land, Our Choice,” in High Times

While I have unfortunately not been posting here as much as I would like, part of the reason is that I have been engaged to write for some industry publications.

The first to be published was a column, “8 Solutions to Common Cultivation Challenges,” in Cannabis Business Times. I would highly recommend subscribing to receive their new magazine – which is free – as there is a great deal of high-quality content throughout its pages. The magazine is issued bi-monthly, and “Growing Pains” – the overall title of the column authored by myself and my colleague, Nic Easley, will appear in each issue over the next year. Look out for the next issue, which features part one of a two-part essay providing guidance on scaling up  a cultivation operation.

Additionally, Nic and I were also engaged to write an essay for High Times magazine. Featured in the February 2016 issue, “Our Land, Our Choice” examines the complex legal hurdles facing Native American Tribes, some of whom have begun to lay the foundation for a new tribal cannabis industry, bringing a promise of economic development to reservations hit hard by unemployment and poverty. The magazine is available on newsstands or via the link above.

Thanks very much to Cannabis Business Times and High Times, it is an honor to have my work featured in such industry-leading publications.


When is One Harvest More than Five?

Once you step outside. Read on, and I’ll explain…

While perusing an article discussing the energy-intensive nature of indoor cannabis cultivation, I came across a quote expressing a sentiment that I hear all too often in the industry.

“Growing indoors is pretty energy inefficient, but in most places in the U.S. you can only get one or two seasons outdoors, so there’s really not much of a choice,” said David DeGraff, chief executive officer of The Grow School in Denver.

As noted, the sentiment that indoor cultivation can out-yield farming cannabis outdoors is pervasive. I would also argue that it is misguided, based more on the fact that most growers entire experience consists of cultivating inside under lamps, rather than direct, evidence-based comparisons. Fortunately, now that more reliable data on cannabis cultivation is being gathered and analyzed, we have the opportunity to debunk such myths and push cannabis farming forward in a more intelligent, responsible manner.

Continue reading “When is One Harvest More than Five?”

Cannabis Safety Institute Publishes Important White Paper, “Pesticide Use on Cannabis”

Last month, the Cannabis Safety Institute published an important paper, “Pesticide Use on Cannabis.” I encourage everyone interested in the issue to read the full text, which includes sensible recommendations for regulating pesticide use in cannabis cultivation and processing, as well as for lab testing and effectively enforcing said regulations.

The paper was authored by Dr. Rodger Voelker and Dr. Mowgli Holmes and provides one of the first truly scientific approaches to analyzing the cannabis industry’s pesticide problem using actual data gathered within Oregon’s legal cannabis system. Dr. Voelker is the Lab Director at OG Analytical, an independent testing lab serving the cannabis industry in Oregon, and has been refreshingly outspoken regarding the need for proper standards in cannabis cultivation, processing, and testing, the entirety of which is performed by for-profit laboratories that are not subject to any universal standards.

The final takeaway from this paper: “It is the opinion of the Cannabis Safety Institute that for the time being states should adopt policies restricting pesticide use on Cannabis to those products that are listed as minimal risk under FIFRA Section 25(b); have broad and non-exclusive language on their labels; and, in addition, are considered acceptable for use in organic practice.”

Visit the Cannabis Safety Institute’s site, linked above, to read additional White Papers and links to other studies regarding cannabis and consumer safety.

Denver Dispensary Cited for Illegal Pesticide Use Still Lists Illegal Pesticides on Product Label

Those of you who read my previous essay, “Pesticide Use in Colorado’s Cannabis Industry: Assessment and Ramifications,” should be familiar with the dispensary Natural Remedies, located in downtown Denver. The grow operation associated with Natural Remedies, ironically named Organic Greens, was one of eleven cited this past spring for illegal pesticide use. The owner of the company, Andrew Boyens, even went so far as to challenge in a court of law the city’s right to enforce long-established pesticide regulations. Even though chemical pesticides were admittedly used, Boyens and his attorney asserted that the cannabis produced in the Organic Greens facility was safe, according to reports from 9NEWS of Denver. While certain pesticides may in fact be safe to use on cannabis, no research on the subject has been performed; thus it simply cannot be stated with certainty what is safe and what is not. You can read more about the details of the case here and here.

Yesterday, a friend patronized Natural Remedies; against my advice, I should add. However, this gave me the opportunity to peruse the label attached to the 1.75 grams of cannabis flower that was purchased.

Continue reading “Denver Dispensary Cited for Illegal Pesticide Use Still Lists Illegal Pesticides on Product Label”

Investigative Report by The Oregonian Reveals Pesticide Residues in Cannabis Extracts

Extracts, or concentrates, are the result of various processes that involve using a solvent or some other means to remove desired chemical compounds – such as THC, CBD, and terpenes – from raw cannabis plant material. Old-fashioned hashish is a concentrate, but newer processes employ petroleum products – butane, most commonly – as well as super or sub-critical carbon dioxide to separate the cannabinoids and terpenes contained in cannabis from the plant material itself. The outcome is referred to in the industry as wax, shatter, or crumble and is generally a substance of golden-brown color that varies in consistency from a resinous oil to something like, well, wax (see photo below). They can be extremely potent, with THC levels of about 70-90% (for context, the most potent cannabis flower tests at just over 30% THC, though anything over 20% is considered quite potent), and are increasingly popular in legal and illegal cannabis markets.


The resulting product is smoked via a process referred to as “dabbing,” which involves heating a metal bowl with a torch and applying a small scoop of the concentrate to the red-hot metal, then inhaling the resulting smoke. This CNBC report provides further context.

Unfortunately for those that enjoy dabbing, an investigative report by The Oregonian found recently that even concentrates that passed state-mandated testing standards contained pesticide residues. Reporters secret-shopped legal medical cannabis dispensaries in Oregon, purchasing 10 extracted products that were then sent to two independent labs for testing. Of the 10 samples, 8 tested positive for residues of 14 different pesticides, only one of which is approved for use in organic production. 6 of the pesticides discovered are classified as possible or probable carcinogens.

Continue reading “Investigative Report by The Oregonian Reveals Pesticide Residues in Cannabis Extracts”