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The “wild, wild west” ideology sums up the Oregon climate for cannabis lab regulations and procedures. HB 3460 went into effect March 3rd 2014, which set the regulations for medicinal marijuana dispensaries to legally operate within Oregon. Unfortunately, test labs were completely left out of the bill. Tom Burns who represents the Oregon Health Authority (OHA), wants nothing to do with the burden of regulating cannabis test labs. Ultimately, Oregon test labs have been left to regulate themselves, which has potentially serious ethical consequences to consider.
I had the opportunity to sit down with analytical chemist Ric Cuchetto, from Chemhistory located in Portland, Oregon. He has over 20 years of experience in testing for pesticides and other harmful materials. Cuchetto’s credentials include: establishing analytical techniques for hazardous waste incinerators for correct permitting, and provided technical trainings for equipment such as triple-quad mass spectrometers (LC-MS-MS). I wanted to educate the Oregon cannabis community with Cuchetto’s knowledge on how to find legitimate labs by asking the right questions, in order to sort through the duds.
The first point Cuchetto brought to my attention when shopping for a test lab, is finding out who exactly is performing the testing. Cuchetto recommends that analytical chemists are best suited for testing cannabis. The competency of the individual testing cannabis products is more important than the equipment being used itself. Analytical chemists ideally should be running these tests because they can understand and navigate the complex matrix of cannabis. Cuchetto recommends a chemist with a strong background in flavor and fragrance, or pesticide residues in food. Transparency is key when running a lab and it all starts with who is performing these duties on a daily basis to ensure patients are receiving safe medicine.
The second most important thing when considering what lab to test with is understanding the equipment they use to test cannabis products. Detecting pesticides at 100 parts per billion or 0.1 parts per million (as stated in HB 3460) will be difficult to do by any other method except liquid chromatography-tandem mass spectrometry (LC-MS/MS). Cannabis has the most greasy, oily and complex matrix to test in all of agriculture -including hops, cannabis’s closest analog. LC-MS/MS allows the lab professional to remove noise and interference to isolate the cannabinoid compounds found in the matrix.
Labs commonly use “flame ionization detectors” instead of the LC-MS/MS, but Cuchetto explains that you have virtually no chance of seeing all of the compounds found in a respectable HB 3460 pesticide test. Do not test with labs who use obsolete equipment. FID’s only allow people to view the total amounts of cannabinoids, not the ratios between THC A and CBD A. Unfortunately, HB 3460 has no mention on testing the acids of cannabis which causes more confusion amongst the community.
The third question to ask is what procedures and guidelines they follow as a lab. Chemhistory is working toward ISO certification, who develop international lab testing standards. Chemhistory also bases it’s practices off of the American Herbal Pharmacopeia, for guidance in cannabis testing. Because there has never been a legal cannabis industry, testing is an entirely new frontier. This unfortunately allows unqualified people to create their own testing standards which is entirely unethical when providing medicine for sick patients. Certain companies sell testing machinery with a two or three day training session before people are “certified” to operate the machinery. This means that anyone off the street with enough money can essentially buy a test lab without any of the credentials a lab tech should embody. Cuchetto and myself advise you to ask the tough questions in order to see if qualified professionals are actually running the show.
Accurate representative sampling is another unsolved issue among Oregon labs. Cuchetto recommends all batch and representative sampling be performed by a trained professionals with statistically valid, randomly selected, sampling procedures. Chemists should not be testing the terminal buds on cannabis plants (aka the tip-top of a cola) as the only representative sample for a batch size of say, five pounds. Random sampling must be enforced in order to produce accurate numbers that reflect the batch in its entirety. Concentrates on the other hand are homogenous, because there is no “cola” to hand pick when testing. Edibles are slightly more tricky when trying to give the most accurate representative sample according to Cuchetto, because the cannabis isn’t always homogenized throughout the product.
The fifth thing to consider when trying to find a test lab is reporting, numbers and turn-around time. Chemhistory guarantees 72-hour turn around time, in order allow 48 hours to incubate mold and mildew tests which is an HB 3460 requirement. A certificate of analysis and additional expert opinions regarding your samples should be provided after every test. If the turnaround times seem almost too good to be true, then they probably are.
Overall, the most important questions to ask are: who is operating the lab equipment and why they are qualified, and what equipment is being used in the first place. At this point in time, those who use LC-MS/MS machines are some of the of the most qualified labs, especially when it comes to pesticide testing. GC-MSD machines work well for testing cannabis in terms of terpenes and cannabinoids, but it doesn’t effectively test all pesticides. Random and representative sampling is another major issue. Labs should be sampling batches randomly themselves, not primarily testing the top cola of a plant. This action does not accurately represent the batch as a whole.
Regulating test labs is vital to the health of Oregon’s OMMP community because vulnerable patients must be receiving clean, pesticide/mold-free cannabis. Until all Oregon labs are operating under the same procedures, finding the best test lab will be difficult. I hope this article will at least let people know where to start from the chemist’s point of view.
Photo Credit: The US Food and Drug Administration under public domain via Wikimedia Commons