Thats a very good question. In terms of legislation I think Nevada has the best testing requirements, because they essentially require everything on the flower, and then scale it back for extracts and edibles, which is reasonable. Massachusetts has essentially the same system, but Terpene testing is optional, which I think is a very bad idea because terpenes define the quality of both medical and recreational cannabis. Its like having the wine industry not label the alcohol by volume or producers of aspirin not labeling how many milligrams are in each pill. California is currently implementing a system modeled on Massachusetts and Nevada, with optional terpene testing but requiring it if it will be used in labeling or advertisement in any way, which in the California market means everyone will be getting terpene testing. California also is changing the micro testing so as to not cause beneficial bacteria and harmless mold spores to cause a batch to fail, and is instead tracking harmful or dangerous strains of mold specifically.
In theory, Nevada is the best, but in practice Massachusetts is the best because their administrative and enforcement abilities are far better than Nevada. California may be my favorite, but its all still theoretical because its not going to be implemented until 2018. We shall see. Colorado, on the other hand, is very lax, but I expect testing regulation reforms in the next 5 years.
What kind of tests do you run for your bacteria? I’m familiar with some of the good ol’ Gram staining and some of the simpler methods of identification, but what about the more complicated tests?
Hi Marco! I met you at Cannmed in April and you gave me an amazing packet of information related to cannabinoids and the enzymes that break them down . Thank you!
This is a topic that is very dear to my heart. I spent many hours working with top chemical instrument manufacturers such as Waters Corporation and Perkin Elmer developing methods for the detection of pesticides in cannabis flower. Although we’ve been testing for pesticides in foods for many decades, cannabis presented many challenges that were not found in tomatoes and cabbage. What we’ve all concluded is that testing of pesticides in cannabis can be done with the same safety and speed as in the food industry, but growers will have to accept the higher cost, which is a challenge in a post black market community.
When cannabis testing started, and we were back at Steep Hill doing Cannabinoids and Terpenes in 2011, it was 50$ a test. We had two employees in the lab, a $15,000 GC-FID, and very little regulatory or quality control standards. Now, when we test for pesticides, we need a $250,000 LC-GC-MS/MS. Not only is it more expensive, but each sample costs a lot more to run, and the chemist you have to hire to run this instrument costs a significant amount more than a college graduate you can get to run a GC-FID. In the food industry, a pesticide test will look for 300-400 common pesticides, take about 2 weeks turn around, and cost about $2,000 per sample. Right now, the cannabis industry is still in place where its expecting $50 tests for everything, and pesticide testing is just not able to be provided that cheaply.
A problem i’m seeing in California is that many labs are buying used $30,000 instruments to do pesticide testing, and basically what happens is their results can’t actually detect the pesticides they are reporting. This is because of a lack of regulatory oversight requiring labs to prove through method validation that their methods can detect pesticides down the astronomically low levels mandated by regulators, often double digit ppb (10-99 parts per billion). So there is a false sense of confidence right now in California where people are submitting their stuff for pesticides, paying $50, and getting a result that says its clean, but often this is not true. Sometimes pesticides show up when an extractor sends their input to a different lab, and then the cultivator and extractor get into a squabble about which lab’s performed the analysis correctly, both often arguing in favor of their own financial interest.
So its a long road ahead for pesticides. Similar issues of cost exist for heavy metals testing too, which is in the lower part per billion as well for regulatory requirements.
In Nevada where we were legally looking for TYM (total yeast and mold), TAC (total aerobic bacteria), and ECC (coliform bacteria) we had three growth mediums. Agar for the mold, and petrifilm from 3M for TAC and ECC. These medium were selective for the class of microbe, so a colony either formed or didn’t, allowing the analyst to simply count the colonies. Now if the client wanted to know which species were on their plant (a special request for further analysis) we would transfer the colonies from the growth medium to a microscope slide and stain it there. Mold got lactophenol blue, and bacteria got crystal violet (the gram stain you referenced). This allowed our analysts to identify the family, genus, or species of microbes found on the cannabis sample. This was performed rarely and wasn’t legally required, but was ratehr a courtesy to help our clients solve some of their micro problems at their facility.
Thank you for taking the time to share your vast knowledge with us @marco! We’re at time for the AMA, but if you do have a few extra minutes for the remaining questions (whether right now or later on) that would be greatly appreciated. Looking forward to seeing your future research and influence on the cannabis testing industry.
I have not had an opportunity to perform studies on plant physiology outside metal testing for nutrient purposes (seeing if the absorption of Nitrogen, Phosphorus and Potassium are quantitatively as expected by the grower). I do know that in indoor grow operations, the transpiration of the cannabis plant is sufficient to provide the humidity the plants need to thrive. We saw many stubborn growers in Nevada who read on a Google search that 60% relative humidity was ideal for the cannabis plant and then used a humidifier to maintain that humidity. Of course they’re facility was quickly overrun with mold. Well watered plants will transpire an enormous amount, and will keep themselves moist while keeping the walls, studs, ceiling tiles where mold thrives more dry. We’ve also seen greenhouses in the desert which use swamp coolers, also leads to mold outbreaks. Generally I advise growers to water their plants to sufficiency and then monitor the grow rooms humidity. Sometimes, just watering the plants could cause a relative humidity that is too high, and may need to be coupled with a dehumidifier depending on the climate. Definitely a good idea for indoor grow areas in humid places like San Francisco. Outdoor, of course, being in touch with nature, has much fewer problems. Wind keeps the humidity down and sun kills many microbes.
Its been my absolute pleasure. If people have other questions down the road they are welcome to lay them here and I will check in and post a reply when I’m available
Your most welcome. I believe you may be referencing this image from our Cannabinoids Route of Administration Article. I’ve included the picture you are referencing here so that others can view it.
That’s it! I shared this with the pharmacists at the hospital where I work. It provided them with information that they were never taught, never studied and was a huge eye opener for them.
I’m in the safety/security discipline of the cannabis community but always enjoy learning all I can about other disciplines as well. It is great to find such a well versed individual as a networking partner. Thanks Nicholas for the resource.