Introduction & Statement of Purpose

Welcome to Cannabis Candor. My name is Adam Koh. Currently, I am a consultant specializing in cannabis cultivation and facility management for Comprehensive Cannabis Consulting, a Colorado-based company providing services nationwide. Previously, I managed a medical cannabis cultivation facility in Denver that, at the time of my departure, contained just fewer than 350 lights devoted to flowering plants, which translated into the charge of overseeing the care of 2,500-3,000 total plants at any one time. However, this site is not meant to be a platform for professional advertisement and I will comment further on my employment only when it is absolutely inextricable from the topic under discussion. Rather, this is an outlet for my personal thoughts on the state of the legal cannabis industry, particularly those surrounding responsible cultivation practices and the ever-evolving regulations of this new field. It should be noted that, when I speak of the cannabis industry generally, I am also including hemp, a member of the cannabis species that is non-psychoactive and grown for seed and fiber. When I refer to individual crops, cannabis will be the term used to indicate the female plants that produce flowers, which are then dried, processed, and consumed by smoking or ingestion for medical or recreational purposes.

Much of the press and other readily available forms of media that portray the developing world of legal cannabis do so in a sensationalistic and superficial manner. I will seek to redress that approach with measured, thoughtful considerations of relevant issues that I do not believe are being voiced adequately or appropriately by other outlets. While I will necessarily take a critical tone at times – perhaps frequently, if I’m being totally honest – I am not attempting to create division or defame any individual, organization, or institution. Instead, by calling attention to issues that I believe require additional contemplation or an alternate approach, I hope to drive productive discussion and move toward intelligent solutions that benefit everyone involved with this exciting and important field. Consequently, I welcome civil and well-considered comments and questions, and will do my utmost to engage with anyone who also desires to converse constructively about the legal cannabis industry.

While the cannabis industry has received a great amount of attention in recent years, I believe that certain significant issues and considerations have been overlooked, or even swept under the rug, to the detriment of those working in the field, the patients and consumers who use its products, and even that section of the public that may not consider themselves affected in any way by the experiments underway currently in Colorado, Washington, and elsewhere. Coverage of cannabis is framed most frequently in the following terms: Its promising medical benefits; the potential ramifications to individuals and society of legalized use and abuse; the revenue generated by and for individuals, businesses, and governments; the banking issue; and the perspective that legal cannabis provides on drug policy in this country generally, among other important topics.

Significantly, the vast majority of the conversation around legal cannabis is focused on issues that arise from the point of sale onward, while the specifics of the production of the crop itself remain largely shrouded behind the scenes. This is not surprising considering the overarching structures of our high capitalist society, in which the general populace is largely divorced from the production of the commodities that it consumes. As such, an unfortunate lacuna in these discussions is that legal cannabis and hemp present a brilliant opportunity to illuminate contemporary approaches to agriculture overall, and have a unique chance to serve as an example of responsible, sustainable cultivation practices.

The manner in which plants grown for human consumption are treated is an issue of paramount importance that has gained increasing attention in recent years. Sections of markets and, in some cases, entire grocery stores devoted to organic produce are now commonplace. Local farmers’ markets, community-supported agriculture (CSA), and farm-to-table restaurants are more prevalent and enjoy wider participation and patronage than they did just a decade ago. Revulsion for monolithic agri-tech companies such as Monsanto is a fashionable stance. Numerous academics and others have been calling attention to the wide-ranging perils of our reliance on synthetic fertilizers and pesticides, as well as the fact that these methods can be less effective and more costly – in a multitude of ways – than organic ones. However, for all the articles, documentaries, books, and discussion that tout the benefits of such viewpoints, ventures, and approaches, organically produced agricultural commodities account for just over 4% of all food sales in this country. Additionally, less than 1% of all crop and pastureland in the US was being farmed organically as of 2011.

There are myriad reasons for these small slivers, of course, but one simple explanation is that it is difficult and takes many years to change the practices of a colossal industry such as agriculture, which has had available to it synthetic fertilizers since the early twentieth century and synthetic pesticides since World War II, not to mention the entrenched financial interests of those influential people and corporations that profit from traditional industrial agricultural methods. Enter cannabis, which has never before in the history of this country been cultivated on a commercial scale comparable to what is happening currently, to speak nothing of what is about to happen imminently. For this unassuming reason, the opportunity to which I referred above presents itself.

Agriculture in this country – whether organic or not – is subjected to an incredible amount of regulation aimed at ensuring that the produce that makes it to market is safe for human consumption and that the practices involved in bringing that produce to market are not overly detrimental to people or the environment. Whether these regulations are sound and successful is another, lengthy conversation. However, the central point for our purposes is that, due to the previous prohibition of cannabis and hemp, these crops were never subjected to the research upon which the regulations and rules governing the cultivation of all other agricultural commodities are based.

The conundrum presented by this lack of research manifests itself most clearly and immediately in the realm of pesticide use. The use of pesticides in the cultivation of cannabis particularly is an important, controversial issue that is just starting to make its way into the public eye. I say cannabis particularly due to the fact that, unlike hemp, cannabis is grown exclusively for human consumption. I will in a subsequent post explore this problem in much greater depth. At this time, however, it will suffice to explain that every pesticide registered with the Environmental Protection Agency specifies the crop(s) on which it can be used, how much can be applied, where (outdoors, greenhouse, home garden), and when, in addition to safety and environmental considerations and protocols. This information is listed on the label, which serves as a legal document instructing the applicator on the manner in which the pesticide is to be used; any application outside the bounds defined by pesticide label directions is illegal. No research has been done on the reaction of cannabis to pesticides, or on the plant’s retention of residues or metabolites. Indeed, the commercial cultivation of cannabis is so new that there are at this point no widely agreed-upon best practices for growing this crop. As such, crucial information contained customarily on pesticide labels, such as where the crop is usually grown, which in turn governs to some extent the manner in which the pesticide is to be used, is not yet able to be determined completely or with certainty. All this to say: No pesticides currently registered with the EPA are labeled for use on cannabis (or hemp, for that matter). Therefore, no pesticides can be applied legally to cannabis or hemp.

Based on the grumblings I heard from other attendees – nearly all of whom are commercial cannabis growers – at a recent work group on this subject at the state Department of Agriculture, some, if not many, in the cannabis industry in Colorado view this as a catastrophe and fear that, if they cannot employ synthetic pesticides, then their crops will succumb completely to bugs, molds, and mildews, ruining businesses and those associated with them. While it may be challenging to cultivate without all the tools available to the rest of the field, I will again stress that I believe this “restriction” should be viewed – and seized – as an opportunity. Whereas acceptance by traditional farmers of organic cultivation methods for food crops faced (and faces) the daunting task of working against an established, elephantine system, which employs methods that are in some ways more expedient to execute than sustainable organic practices, the legal cannabis industry has no such obstacle to overcome.

Those currently cultivating cannabis and hemp legally should embrace the challenge presented to them by the lack of research and uncertain regulatory status of those crops by raising their plants in the most safe, sustainable, and responsible ways available to us. We owe this to the consumers (many of whom are already severely ill and have come to cannabis for relief), the environment, and also ourselves; for the use of poisonous substances in agricultural production can create toxic work environments that are detrimental to the health of employees, as well as those with whom they come in contact. In my opinion, there is no reason not to pursue the most responsible path forward other than the desire to make as much money as possible, as quickly as possible. Undoubtedly, some are driven primarily by greed and will tread that avenue accordingly. However, while the manner in which the cannabis industry is portrayed in the media focuses heavily on its potential profitability, that cannot be the one and only factor driving the industry. If so, it will either fail or tarnish itself irrevocably. Boom towns have become ghost towns many times throughout history – Colorado can look to its own past for numerous examples of this – and a public health crisis brought on by irresponsible cultivation would be an effective way to lead the currently thriving cannabis industry down the same course, or at the very least provide potent ammunition to its detractors. This field is already viewed with great skepticism and prejudice; hence those of us in it must hold ourselves to a higher standard if legal cannabis is to gain widespread, long-term acceptance and success. Indeed, if we can set the bar highly and manage to elevate ourselves enough to clear it, we can change the perception of cannabis in general and call attention to the benefits and possibilities of organic, sustainable farming practices to the enrichment of society overall. That is one of the great opportunities to which these remarkable plants have opened my eyes, and one that I hope to share with others.