I think that we need to start changing the terminology around the hazards associated with cannabis from food safety hazards to product safety hazards. These hazards have not only been associated with harmful effects for those that ingest cannabis infused products, but also for those that consume the cannabis products in other ways such as inhalation (vaping or smoking). So, when we refer to these hazards as food safety hazards, the immediate thought is edibles, which misleads cultivators, manufacturers and consumers to have a false sense of security around the safety of products that are consumed in other ways.
By standardizing and documenting safety procedures, manufacturers mitigate the risk of cannabis-specific concerns
There are several product safety hazards that have been associated with cannabis. These hazards can become a public health problem if not controlled as they could harm the consumer, regardless of the method of consumption.
Let’s take a look at the different types of hazards associated cannabis:
Biological Hazards refer to those microorganisms that can cause illness to the consumer of a product that contain them. They are not visible to the naked eye and are very dangerous when their metabolic by-products (toxins) are ingested or their spores are inhaled. The symptoms for illnesses caused by these microorganisms will vary. Consumers may experience gastrointestinal discomfort (vomiting, diarrhea), headaches, fever and other symptoms. The ingestion of these pathogens, allergens or their by-products may lead to death, if the illness is not treated on time or if the consumer of the product is immunocompromised. In addition, the inhalation of mold spores when smoking cannabis products, can lead to lung disease and death. Some of the biological hazards associated with cannabis are: Salmonella sp., E. coli, Clostridium botulinum, Aspergillus sp. and Penicillium sp.
Chemical Hazards refer to those chemicals that can be present in the plant or finished product due to human applications (pesticides), operational processes (extraction solvents and cleaning chemicals), soil properties (heavy metals), environmental contamination (radiological chemicals) or as a result of occurring naturally (mycotoxins and allergens). Consuming high concentrations of cleaning chemicals in a product can lead to a wide range of symptoms from mild rash, burning sensation in the oral-respiratory system, gastrointestinal discomfort or death. In addition, long term exposure to chemicals such as pesticides, heavy metals, radiological contaminants and mycotoxins may lead to the development of cancers.
Physical Hazards refer to those foreign materials that may be present in the plant or finished product. Foreign materials such as rocks, plastics or metals can cause harm to the consumer by chipping teeth or laceration of the mouth membranes (lips, inner cheeks, tong, esophagus, etc.) In the worst-case scenario, physical hazards may lead to choking, which can cause death due to asphyxiation.
These hazards can be prevented, eliminated or reduced to an acceptable level when foundational programs (Good Agricultural/Cultivation Practices, Good Manufacturing Practices, Allergen Management Program, Pest Control, etc.) are combined with a Food [Product] Safety Plan. These lead to a Food [Product] Safety Management System that is designed to keep consumers safe, regardless of the method of consumption.
Cannabis that contains more than 0.3% THC is not eligible for USDA organic certification, due to the crop’s Schedule I status. While some hemp farmers are currently on the path to obtain a USDA organic certification, the rest of the cannabis industry is left without that ability.
Growers, producers, manufacturers and dispensaries that utilize the same practices as the national organic program should be able to use that to their advantage in their marketing. Ian Rice, CEO of Envirocann, wants to help cannabis companies tap into that potential with what he likes to call, “comparable to organic.”
Ian Rice, CEO of Envirocann & co-founder of SC Labs
Rice co-founded SC Laboratories in 2010, one of the first cannabis testing labs in the world, and helped develop the cannabis industry’s first testing standards. In 2016, Rice and his partners at SC Labs launched Envirocann, a third-party certification organization, focused on the quality assurance and quality control of cannabis products. Through on-site inspections and lab testing, Envirocann verifies and subsequently certifies that best practices are used to grow and process cannabis, while confirming environmental sustainability and regulatory compliance.
“Our backyard in Santa Cruz and the central coast is the birthplace of the organic movement,” says Rice. California Certified Organic Farms (CCOF), founded in Santa Cruz more than 40 years ago, was one of the first organizations in the early 1990s that helped write the national organic program.
“What we came to realize in the lab testing space and as the cannabis market grew, was that a lot of cannabis companies were making the organic claims on their products,” says Rice. “At the time, only one or two organizations in the cannabis space were making an attempt to qualify best practices or create an organic-type feel of confidence among consumers.” What Rice saw in their lab was not cannabis that could be considered organic: “We saw products being labeled as organic, or with certain claims of best practices, that were regularly failing tests and testing positive for banned chemicals. That really didn’t sit well with us.”
Coastal Sun Farms, Enviroganic-certified
At the time, there was no real pathway to certify cannabis products and qualify best practices. “We met with a few people at the CCOF that were very encouraging for us to adopt the national organic program’s standards for cannabis. We followed their lead in how to adopt the standards and apply a certification, building a vehicle intended to certify cannabis producers.”
Because of their background in lab testing they added the requirement for every crop that gets certified to undergo a site inspection, sampling, as well as a pesticide residue test to confirm no pesticides were used at all during the production cycle. One of their clients is Coastal Sun Farms, a greenhouse and outdoor cannabis producer. “They grow incredible products at a high-level, commercial scale at the Enviroganic standard,” says Rice. “They have been able to prove that organic cannabis is economically viable.”
The Envirocann certification goes a bit beyond the USDA’s organic program in helping their clients with downstream supply chain risk management tools (SCRM). “Because of the rigorous testing of products to get certified and go to market, we are getting way ahead of supply chain or production issues,” says Rice. “That includes greater oversight and transparency, not just for marketing the final product.”
A good example of using SCRM to a client’s advantage is in the extraction business. A common scenario recently in the cannabis market involves flower or trim passing the pesticide tests at the lab. But when that flower makes it down the supply chain to a manufacturer, the extraction process concentrates chemical levels along with cannabinoid levels that might have previously been acceptable for flower. “I’ve witnessed millions and millions of dollars evaporate because flower passed, but the concentrated final product did not,” says Rice. “We’ve introduced a tool to get ahead of that decision-making process, looking beyond just a pass/fail. With our partner labs, we look at the chromatograms in greater detail beyond regulatory requirements, which gives us information on trace levels of chemicals we may be looking for. It’s a really rigorous audit on these sites and it’s all for the benefit of our clients.”
Envirocann has also recently added a processing certification for the manufacturing sector and a retail certification for dispensaries. That retail certification is intended to provide consumers with transparency, truth in labeling and legitimate education. The retail certification includes an assessment and audit of their management plan, which goes into details like procurement and budtender education, as well as basic considerations like energy usage and waste management.
Fog City Farms, Envirocann-certified
While Envirocann has essentially adopted the USDA’s organic program’s set of standards for what qualifies organic producers, which they call “Enviroganic,” they also certify more conventional producers with their “Envirocann” certification. “While these producers might not be considered organic farmers, they use conventional methods of production that are responsible and deserve recognition,” says Rice. “A great example for that tier would be Fog City Farms: They are growing indoor with LED lighting and have multiple levels in their indoor environment to optimize efficiency and minimize their impact with waste and energy usage, including overall considerations for sustainability in their business.”
Looking to the future, Ian Rice is using the term “comparable to organic” very intentionally, preparing for California’s roll out of their own organic cannabis program. The California Department of Food and Agriculture (CDFA) is launching the “OCal Comparable-to-Organic Cannabis Program.” Envirocann is obviously using the same language as the CDFA. That’s because Envirocann aims to be one of the verifying agents under the CDFA’s new program. That program will begin on January 1, 2021.
Before you begin any large-scale cultivation project, you must necessarily consider the four factors highlighted below, among many others, to ensure your cultivation is successful. Failure to do so will cost you greatly in both time and money, and ultimately could lead to failure. While the four areas highlighted below may be the most important considerations to address, you should hire a cultivation advisor to determine the numerous other considerations you must deal with before you begin.
1. Genetics
Genetics will play a huge role in your cultivation plan, as they can ultimately make or break the success of your business. Access to quality, verified genetics will greatly affect your profits. All cannabis genetics grow differently and may require different conditions and nutrients. Further, consumers in today’s regulated market have greater awareness; they are much more knowledgeable about genetics and able to discern between quality cannabis versus commercially produced cannabis.
Market trends will dictate whether or not you’ll ultimately be able to sell your harvest at market rate. You need to project out at least one year in advance the genetics you will be growing. But often it is impossible to predict what consumers will be purchasing a year in advance so this part of your cultivation plan should be well thought out. Further compounding this difficulty is the fact that it may take six months to ramp up production of any given variety.
Genetics that are popular now may still be popular next year, but that also means there will be more competition for shelf space, as more competitors will also likely be growing these same genetics. Therefore, don’t rely on only one trendy variety as the bulk of your selection for the year, no matter how popular it is at the moment. Producing a single variety as the bulk of your crop is always risky, unless you have a contract with a sales outlet, in advance, for a set quantity of that one particular variety. Diversity in your genetics is beneficial, when chosen correctly.
Making proprietary genetics from your own seed collection can give you a big advantage in today’s competitive market. Having a variety with a distinct, unique and desirable smell, taste, effect or cannabinoid profile will allow you to distinguish your brand amongst others. Entire brands have been built off of a single variety: Cookies and Lemontree are two examples of companies that have done this. All it takes is one really good variety to attract a lot of attention to your brand. Having your own breeding project on site will allow you to look for and identify varieties that work for you and your business model, and ultimately will help to distinguish your brand apart from others.
Only buy seeds from reputable breeders! Any new varieties that you are going to be cultivating should be tested out at least three times, on a small scale, before being moved into a full production model. If you are growing from seed there is always the potential for your crop to get pollinated by male plants or hermaphrodites that went unnoticed, and therefore, they could be a potential risk to your entire harvest. Treat them accordingly, i.e. by cultivating them on a small scale in a separate, enclosed area.
Buying clones from a commercial nursery can be risky. Genetics are passed from one grower to another haphazardly, and names are changed far too easily. This can create a lot of confusion as to what variety you are actually purchasing and whether you are getting the best version of the genetics. Just because a clone is called “sour diesel” doesn’t mean you’re actually getting the real, authentic sour diesel. And to further complicate things, the same clone grown in different environments can produce a noticeable difference in flavor, smell and effect depending on your cultivation method. Always try your best to verify the authenticity of the genetics you purchase. Ask about the history and origin of the particular genetics you are purchasing. Better yet, ask for pictures, physical samples, and most importantly, certificates of analysis from a laboratory, indicating the potency. In many states anything under 20% THC is going to be hard to sell, while anything over 30% will easily sell and command the highest price. It’s a good idea to have a laboratory test the terpene profile in order to verify a variety is actually what the seller purports it to be.
Knowing the source of your genetics is imperative. It will help ensure that you actually have the variety that you were intending to grow, and therefore, allow you to achieve your intended results. Knowing what varieties you are going to cultivate, before you grow them, will also give you a better idea of the ideal growing conditions for that specific variety, as well as what nutrients will be required to achieve optimum output.
2. Automated Watering Systems
Installing an automated watering system, during build out, will by far be the most cost-effective use of your money, and will save you the most amount of time in labor. An automated watering system, commonly referred to as a “drip system” or “drip irrigation,” is necessary regardless of whether you are cultivating indoors or outdoors; it will allow you to water multiple different areas at once, or only water a few specific areas of the garden at one time. Hand watering a 22,000 square-foot cultivation site will take one person eight hours every single day, on average, to maintain. However, a properly designed drip system can water an entire large-scale garden in a couple of hours, without any employees, record all the relevant data and notify you if there is a problem. This enables you more time to spend closely inspecting the plants to ensure there are no bugs or other problems present, and that your plants are healthy and thriving. This attention to detail is necessary if you want to have consistent success.
Larger scale cultivation requires bigger and more expensive equipment.
Automated watering systems not only save a great deal of time but also eliminate the possibility of human error, like over watering, which can kill an entire crop quickly. There aresoil moisture sensors that can be placed in the soil to regulate the supply of water to the plants in a precise manner. Without an extremely skilled, experienced work force, damage to plants due to over watering is very common. A drip system will reduce the threat of human error by ensuring delivery of precisely the correct amount of water and nutrients to each plant every single time they are watered.
Not all drip systems are created equally. There are different types of automated watering systems. Designing the right drip system for your cultivation site(s) can be complicated. Make sure you do your research, or better yet, work with a cultivation advisor who has experience with automated irrigation systems in conjunction with a licensed plumber, to ensure you are installing the best system for your particular set up.
Adding a fertilizer injector to your drip system can further increase the efficiency of your operation and save you money on nutrients by using only what you need and ensuring correct application. Again, automating this process will save you time and money, and reduce the threat of human error.
3. Nutrients
The types of nutrients you use and the amount of nutrients you use, are going to directly affect the quality of your cannabis flower. Conventional agriculture and Dutch hydroponic cannabis cultivation have always used salt-based fertilizers. However, they can be toxic for the plant in high amounts. While cheap and easy to use, salt- based nutrients are made in big factories using chemical processes to manufacture. They are not good for the environment, and overall, they produce an inferior product. The highest quality cannabis, is grown with organic living soil. Although seemingly contrary to popular knowledge, when done properly, cultivating in organic living soil is more cost effective than using powdered or liquid salt-based fertilizers.
Yield and quality depend on the skills of the cultivator, more than the method they are using. Having healthy plants from the start, will always yield better results, no matter what way they were grown. In my 20 years of experience I have seen plants grown in balanced living soil yield just as much as plants grown with synthetic nutrients. Further, the quality is not comparable.
Controlling your clone supply can ensure they are healthy
Always remember, it is the quality of your flower that will determine the price it is sold for, not the yield. Even if you produce more overall weight of chemically grown cannabis, if nobody wants to purchase that product, then you are going to yield far less profit than another company growing in the same amount of space using organic practices that yield a higher quality product.
The difference in quality between plants grown in balanced living soil versus any other method of cultivation is undeniable. It is really easy to post a pretty picture of a flower on Instagram but that picture doesn’t tell you anything about what went into producing it. When flower is produced using chemical nutrients, it is likely going to be harsh and not enjoyable to smoke. Lesson learned: don’t judge a bud by an Instagram photo! There is a stark difference between cannabis grown using synthetic nutrients versus cannabis grown in living soil. Once you’ve experienced the difference you will never want to consume cannabis that is grown any other way.
4. Plant Propagation
Having the ability to propagate your own clones, from mother plants that you have cultivated, can save you a staggering amount of money. In some states, having a cultivation license allows you to produce your own clones for your cultivation, while having a nursery permit will allow you to sell clones for commercial sales to other companies. The average price of a wholesale clone is around eight dollars. If you require 5000 plants for every harvest, that’s a $40,000 expense you must bear, every grow cycle. This can obviously add up quickly. And as previously mentioned there’s the risk of purchasing inferior genetics or unhealthy plants, both of which greatly affect your profit margins.
On the other hand, the cost of materials and labor to produce a healthy clone can be as low as one dollar when using advanced cloning techniques. Controlling your clone supply can ensure they are healthy and allow you to know exactly what you are growing each time. Further, it doesn’t take a lot of space to propagate your own cuttings. In a 400 square-foot space one could produce between 5,000 to 10,000 clones per month, all of which could be maintained by one person depending on your situation.
And last but definitely not least, the most important thing you can do to ensure the success of your cultivation, is hire an experienced knowledgeable grower who is passionate about cannabis. The success of your company depends on it. You need someone with the knowledge, experience, and skills to make your cultivation dreams a reality. You need someone who can plan your build-out and cultivation to ensure success from the start. And you need someone with the skills to handle the multitude of inevitable problems that will arise in a cost effective and efficient way.
These are just some of the many considerations you must account for when planning a large scale grow in the regulated market. An experienced cultivation advisor can help you with these, and many other considerations you will need to contend with before you begin your grow. Creating a well thought out plan at the outset can end up saving you thousands, if not hundreds of thousands of dollars down the road.
HMS Great Britain has now set forth from its European home port for another intriguing and very British escapade on the high seas.
So far the jury is out.
It could be the beginning of the next British Golden Age, Spanish Armada and all that. Or could it could end up (more likely) somewhere up the Khyber Pass (a sordid misadventure of British Imperialism that did not go well in the 19th century with global implications still reverberating to this day). For Netflix fans of The Crown, think “Suez Crisis” as a more recent and apt analogy. Starting with as much as a 6.7% reduction in domestic GDP already on the horizon.
Snarky historical analogies and nostalgia aside, how will Brexit influence and shape a global cannabis industry, starting at home?
The UK Is Not Actually in Regulatory Free Fall
The first thing to realize is that most of the puffery around Brexit was that with the exception of labor conditions, there is little free choice in the world of trade anymore. The players who get export and import licenses, for anything, have to conform to basic equivalency rules, no matter what they are called.
This applies to cannabis in a big way. No matter how the UK market develops domestically in other words, and that is a separate discussion.
Currently, shamefully, the domestic medical guidelines for prescription of cannabis exclude chronic pain patients and a few other obvious groups. The NHS medical market in other words, is a monopoly, set up by the current and previous governments, mainly serving GW Pharmaceutical patients who qualify for Sativex and Epidiolex. Not to mention company shareholders.
Everyone else, including those for whom these drugs do not work well, or work less well than other alternatives, are left in an international trade negotiation in their living rooms as they and or their children suffer.
The import barriers for cannabis – both from Europe and from Canada are absolutely in the room and in a very personal way for the British right now.
How they actually define cannabis, will also clarify. This will be driven now by the UK’s biggest import partners – namely Europe, the United States and Canada (although South Africa and Australia of course, will always be in the picture).
Which regulatory scheme the UK adapts, including for cannabis and of both the THC and CBD variety (not to mention other cannabinoids), in other words, will at minimum have to be broadly equivalent with all of the above. Not the other way around. No matter how much the Food Standards Agency (FSA) wants to fuss and fiddle with “Novel Food.” That alone is a canard.
Cannabis is a plant. It is time to start acting like that. And it is no more “novel” than tomatoes in many, easy-to-understand environments, including commercial ones. Not to mention will increasingly be regulated like commercial food crops – even if those crops are then also bound for dual purpose medical use.
The regulators will eventually get there – but not without a lot of tortuous twists and turns.
A “New” Market? Not So Much…
There is a lot of consultant palaver and baloney in the room right now. There is no more a new market in the UK as there was in Germany (or Canada or Colorado). Local producers are already organizing, and on the hemp front. The big ones are hip to regulations and are getting certified to enter it. Everyone else is being left on the dangerous sharp end of police raids, even with prior local approvals.
That said, foreign producers are of course looking at the UK right now, and in a big way. The lock GW Pharmaceuticals has on the domestic market will not hold long. European producers are absolutely in the room (starting with Tilray in Portugal and Alcaliber in Spain). Not to mention what is going on in other places right now, even if of less well-known corporate branding.
Every big Canadian company is already in the room in the UK, and many Americans are now beginning to show up in the market.
However, for the most part, such ventures are doomed outside of conference sponsorships until the regulatory questions are answered if not met.
And that includes federal certifications that are easy to find – there is no one single authority that handles cannabis internationally. And there never will be. Supply chains are already global.
A Perfect Export Market
One of the biggest, so far widely discussed questions is who in Europe will start exporting to the UK (forget Holland for the moment). Not to mention producers in Spain, Greece, Poland if not Macedonia. That conversation is also on the table now. For the first time, so is Germany, and on the medical side.
Pharmaceutical producers in particular who meet international pharma standards may be the best hope yet – although right now policy makers are still looking at cars rather than cannabis to help keep Germany’s trade export quota where it feels “comfortable” domestically.
Image credit: Flickr
That too will change. And fairly quickly. See Greece, if not South Africa.
The political roil of branding and politics afoot in Germany right now makes this new kind of export market idea as a part of economic development, an inevitability.
Not to mention, at least for the present, a reverse trade in regulated British CBD products – if producers are smart about regulations – throughout the continent right now.
Of all countries, outside Switzerland, the UK has the ability to develop a broad and intriguing market in the EU – but only if they are compliant with regulations in Europe.
And this is where the policy makers in Parliament and 10 Downing Street have already misjudged if not broadly misled, not in a regulatory environment of their own, but in fact in a diplomatic “room” where the rules are already set via international standards and certifications, not to mention treaties.
It is obviously not just at conferences but now on the ground in Germany and across Europe that Americans are heading to the industry here. And it is not just the “new” cultivation guys at Demecan in Berlin (currently hiring), or in Guernsey, but in truth, throughout the industry.
Wish you were here? Here is the broad skinny to actually getting (and keeping) a job in the industry in Europe.
Get A Job Before You Come
By far, the easiest and safest way to come to a new country, like Germany (or the UK for that matter) is to have pre-arranged employment. That is also beginning to happen, as large companies set up grow and manufacturing facilities throughout Europe. That said, these are hard to come by (there are many Germans and other natives vying for the same jobs). However so far, certain kinds of experience in the U.S. (or Canada) beats anything that has gotten going here so far from the cultivation side and many other aspects of the biz.
But – and this is a big one – you have to have the kind of experience that counts. Regulated industry participation is a must on your CV if this is your preferred route of travel. Pharmacists in particular, could have a fascinating career path here not open in the United States at all yet. So will doctors – but that certification has to be earned here to practice.
It is also far easier to deal with the paperwork that is required than it used to be ironically – in that there are new qualifications being set out for the same in both the UK and Germany at the moment. Understanding them, however is another matter, and interpretation at the immigration office is not something you want to sign yourself up for. In any language.
Member states of the EU, pre-Brexit
However, immigration law is just the beginning on the regulation front. Regulations across the cannabis industry are also changing fast – and not just under the heading “cannabis.”
Nothing, really is “easy” about being an expat. You have to want to do this.
There are now starting to be numerous European job postings in the industry on Linked In. It is a great place to start. Having B1 Deutsch (third level, very hard to pass, intensive German language certification) is usually a must for employment (not to mention getting around in the country).
Disclosure: This journalist failed A1 German in Germany (introductory level) twice. Starting from scratch is not recommended, because the rest of your class (usually with previous German training) will kick your butt in numbers bingo by the end of the first week. Learning – including punctuation and spelling 50 new vocabulary words a week is pretty standard. And that is before the grammar. All taught in German too! Four hours a day, five days a week.
Yes, your class will laugh at you, even if they think you are otherwise cool as a North American.
It also helps if you have taken at least one German language course (as in college semester level) before you come. Otherwise you will hit unbelievably intimidating compound words that take up a great deal of space on a page and four different tenses that even native Germans do not really understand by the end of the second week (and it is mind-blowing). You learn to appreciate Mark Twain’s humour about the dratted language very quickly, not to mention that the umlaut is really the only thing you have any freedom of expression with.
Be prepared to sign up for language courses when you land with the local VHS (Volkshochschule) – which is sort of like German community college for anything you want to take classes in. It is also the cheapest deal on language courses around. The private ones are pricey.
That said, master the lingo, even passably, and Germans are super pleased about the same. No matter how badly you mangle the language, they are just happy to hear you try.
Student Visas and the Educational Path
By far, the easiest path to starting your journey overseas, is luck. The second one however, is actually one way to go if you are prepared to work yourself to the bone, and do it while learning German intensively. Plus get a university level or graduate degree along the way.
If Cannabis Europe is your dream job and vocation, you will make it happen. Just don’t expect it to be easy, or just like anywhere else.Go first as a language student. That gets you two years, fairly easily, as long as you have €8k in your bank account at all times, and do not work at a German job. That is verboten. However, as an American, particularly in Germany, you still have the right to come here and learn.
There is also about to be a fairly ground-breaking immigration law that comes into effect as of March in Germany that allows highly skilled foreigners to earn their way to citizenship. There is a list of requirements that go along with this, of course. The path to being able to stay includes getting a higher German degree or special German training. Expect pretty much the same thing from post-Brexit Britain too – just in the same language.
You also have to have health insurance and a lot of other things taken care of. It is not a sudden move or jump. For all the amazing things that come with this, also be prepared to think about looking in the mirror at least a few times and thinking “am I stupid, what on earth have I done?”
Then there is location. A Kreuzburg address may impress the folks back home, but those are not cheap these days, and extremely hard to come by. Rent, in general, and not just in Berlin, is beginning to be a real issue in every German city. Finding an accommodation that you can afford in “starting out” circumstances – is not easy right now anywhere.
But it’s not just about rent or the buzz you might have heard. Don’t just put Berlin on the map (or even Munich, also a growing professional scene). Both cities are far from the center of the cannabis scene in Europe, much less Germany although there is a lot going on all the time there. Dortmund, and the Ruhrgebeit in the former “Rust Belt” of Germany are much cheaper, full of students, and popping with cannabis reform all over. Cologne is also a very interesting city right now. So are Bremen and Stuttgart.
The Differences Are Large Besides the Language
No matter what you think you can expect, the only thing you can rely on is that just about everything will not be the same. Yes, German beer fests and bratwurst are comfortingly familiar to be accepted easily. But when it comes to really immersing yourself in a country well enough to think of it as “home”, let alone understanding the vagaries of this business in particular? Just about everything is different. This ain’t Kansas, (or Colorado, for that matter) Dorothy.
Bottom line? If Cannabis Europe is your dream job and vocation, you will make it happen. Just don’t expect it to be easy, or just like anywhere else.
According to a press release published last week, the U.S. Hemp Authority (USHA) announced that FoodChain ID, a global leader in food safety, testing and sustainability, is now the exclusive certifying body for the USHA certification seal.
FoodChain ID’s claim to fame is their widely-recognized Non-GMO Project Verification labeling standard, but they also offer services in the food, beverage and ingredient industries, including the entire food supply chain, as well as being a leader in USDA Organic certifications.
The effort to provide quality standards and guidance for best practices in the hemp and CBD markets is led by a coalition of organizations with the same goal: to legitimize the industry and gain consumer trust. The effort is funded by the U.S. Hemp Roundtable and joined by the Hemp Industries Association, the U.S. Hemp Authority, testing laboratories, agronomists, quality assessors and other industry-leading firms.
In order for a hemp company to get the certified seal, they must prove that they can meet strict standards, pass an independent third-party audit as well as enter a licensing agreement. The certification seal is an attempt to provide some legitimacy to the ever-changing hemp and CBD markets in the United States.
Marielle Weintraub, president of the U.S. Hemp Authority, says that through the program’s independent, third-party lab testing, the certification seal provides consumers with truth in labeling and transparency. “The U.S. Hemp Authority Certification Program is our industry’s initiative to provide high standards, best practices, and self-regulation, giving consumers an easy way to identify hemp-derived products that can be trusted,” says Weintraub. “We are striving for ingredient transparency and truth in labeling.”
Just some of the many CBD products on the market today.
According to Weintraub, the standards and best practices for the program are routinely updated and improved. There will be a public session where they discuss those standards and update industry stakeholders on their progress at the Natural Products Expo West on March 2nd.
Mark Dabroski, senior vice president, commercial services at FoodChain ID, says that hemp products are becoming increasingly common in the food, beverage and health and wellness markets. “Hemp seed oil and protein markets have been increasing exponentially over the last decade,” says Dabroski. “With the category’s expected growth at a 46% CAGR to reach $2.8B by 2023, the need for self-regulation and transparency are critical.”
“As consumers increasingly demand to know what is in the foods and products they buy, our suite of testing and verification services helps meet this demand,” says Dabroski.
From seed-to-sale, overseeing processing and extraction as well as navigating a dense web of complicated regulations, cannabis businesses have unique inventory management needs.
Unfortunately, there is no magical, one-size-fits-all inventory solution that is perfect for all cannabis companies. That is why cannabis businesses must take time to properly evaluate and identify an inventory system that is effective for their specific needs and requirements.
Inventory management plays a crucial role in maintaining productive and compliant day-to-day operations — and when seeking investment — as it has a direct impact on a business’s bottom line. Because of the regulatory and legal complexities in the industry, using an incomplete, rudimentary or outdated inventory system can lead to serious financial discrepancies guaranteed to cause headaches for accounting professionals and business leaders.
The right system also can give businesses actionable data to respond to changing market conditions, business needs and growth opportunities as they arise quickly. This visibility is a necessary aspect of ensuring your cannabis businesses can achieve long-term, sustainable growth.
Here are some guidelines to keep in mind when shopping for an inventory management system:
Use the Cloud
First, be sure your company is using cloud-based accounting software. This will instantly simplify both your accounting and inventory processes. Cloud-based solutions ensure company financial and inventory records are up to date and accurate.
Do Not Rely on Your Accounting Software
A plant tagged with a barcode and date for tracking
Your accounting software may provide native functionality for inventory tracking — but do not use it. Such native inventory functions are not robust or complex enough to properly maintain the complicated inventories of cannabis businesses. For instance, your business might be cultivating numerous plants across several sites, tracking plant movement and processing, or packaging it internally. You may be selling your products at other dispensaries or supplying other dispensaries’ products at your counter. Simply put: Cannabis businesses need more sophisticated solutions to track sales, monitor supplies, oversee shipments and remain informed on where products originate from and how frequently to re-order. Native functionalities too often do not provide such robust features.
Look for Direct Integration
That said, business owners want to ensure their inventory system directly and seamlessly integrates with their cloud accounting software. You should not have to input or upload information when setting up inventory software manually. In today’s world, the two systems should automatically and easily share information with each other. Each system’s website will often say whether it can integrate with various accounting platforms, but it never hurts to do some additional research. For example, both Fishbowl and Trade Gecko can be directly integrated with Xero. Some systems even offer a demo environment to let business owners experience what the integration will look like.
Explore Invoicing Capabilities
Some inventory management systems include invoicing capabilities, which can simplify the invoicing process – or even automate it. Such functionality reduces the risk of error when transferring data between programs. A consolidated system that automatically links inventory and invoicing allows business leaders to update invoices easily, mark orders as paid or unpaid, filled or unfilled, all while keeping a close eye on inventory. Some inventory solutions even offer dynamic reporting that displays real-time sales reports and fulfillment processes – making it easier than ever to work with vendors, identify and eliminate unnecessary costs and control cash flow.
Do Not Just Sign Up with the First System You Find
Choosing an inventory management system requires plenty of thought, and no two solutions look exactly alike. So, do not rush into a commitment just to get it over with and move on. Instead, spend enough time learning about various systems and their options to guide a confident purchasing decision. Going with the wrong system and having to switch later not only wastes time and money, but it can undo many of the efficiencies you worked to implement.
Consult an Accounting or Business System Expert
Working with accounting and business systems experts will provide insights related to your short- and long-term business goals. Such experts can help business owners understand exactly how their specific inventory ought to be tracked to avoid serious discrepancies or non-compliance. In addition, a strong accounting professional can act as an invaluable resource and partner when it comes to selecting and personalizing an inventory management system and identifying inaccuracies or inefficiencies. A good tax pro also can serve as a point person between the cannabis business and the software developer to address initial customization and setup or any issues that may arise.
Running a cannabis business requires an investment of time and money from the very start. The good news: You do not have to spend an arm and a leg on your inventory management system to find something that works. Some solutions marry affordability with efficiencies — but be sure to explore several options to find the right fit, keeping in mind the guidelines laid out above. Remember: Cost does play an important role, but the system’s capabilities are more vital to positioning your cannabusiness for sustainable, long-term growth and compliance.
There is a strange, if yet so far undetected, regulatory hum in the air right now in Europe that will begin to increasingly occupy those who are in the certified industry here or looking to get in.
And no, it’s not imminent “recreational,” although it will also have vast impact on the same.
A little understood regulatory structure (so far at least within the cannabis industry) called EU-BIO is now firmly in the room.
What that is and how it will impact the industry is already starting to show up in a few places (see the new announcement by the Swiss that their recreational trial will be organic). This is of course before any dates have even been decided upon for said trial (although others have been set up in the country for about a year).
Beyond this, there are vast implications for every part of the industry, THC or CBD, medical or “lifestyle” focused.
What is EU BIO?
All food in the European Union is regulated on a “federal” level much like in the United States. The difference in Europe however, is that every European “state” or country (like Germany, Spain or Holland) also then has their own regulatory structure which is also equal to the federal standards of the U.S. – including via treaty on both the pharmaceutical and “consumer” side. In general, as a result, regulations, including in all things cannabis space related, are much stricter in Europe.
What this also means, generally, is that all food, cosmetic and human-use lebensmittel (to use the German word for everyday consumer goods like food, cosmetics and lifestyle products) must pass through regulatory agencies that are very much like the USDA and FDA in every country and on a regional European level before being approved on a national sovereign one. Where those are, and who handles what, however, is a patchwork of agencies across the continent. There is no homogenization, in other words, for an organic producer looking for the right agency to get certification from in Germany and Austria.
The European Union’s logo that identifies organic goods.
The distinctive green logo that is omnipresent in particularly German grocery stores also comes with a few high standards of its own. Namely that the logo must appear on all pre-packaged EU food products claiming to be organic within the EU and all member states as well as all imports. Even more importantly, the logo cannot be placed on “transition” projects – namely those which are hoping to fulfil the regulatory standards but are not there yet.
To complicate matters even further, of course all product that ends up as EU GMP must begin life as an organic product. Forget pesticides – radiated product is a hot topic right now as well as its certification in the German medical market.
And that also means, by definition, that all cannabis production in Europe as well as products hoping to be sold via relatively normal channels, must also meet these certifications.
The only other option of course, is what is called “Novel Food.” And even here, thanks to changes in EU BIO on the table for the next couple of years, those who hope to gain access via this kind of labelling, still need to pay attention to organic production. No matter where you are. Or what you want to sell.
Are All “Organics” Made Equal?
Just as in the medical industry and GMP, the strictures of “certified organic” are supposed to be fairly straightforward, but are interpreted by different countries and regions.
Member states of the EU, pre-Brexit
Generally speaking, however, national or even regional “organics” are not exactly the same. For example, Canadian “organic” is not the same as EU-BIO, starting with the fact that the plants in question are not necessarily of European origin (see the same logic here as behind Novel Food). In other words, there is no automatic equality, starting with the source of the seed. But there are also other issues in the room including processing.
That said, being organic is going to be the watchword of the industry. And in this, a bit surprisingly, the US will also have a lasting impact. Why? Because many countries want to export to the US (far from cannabis) and are required to adopt similar agricultural standards (see Latin America for starters).
Bottom line: it is better to be “green”, through and through, no matter where you are, or where you are from, in the global industry going forward. By the end of 2021, certified organic supply, at every level of the industry, won’t be a “choice” anymore.
There are obvious upsides and downsides to cannabis regulation. Gone are the days when it was a free for all, for outlaws growing in California’s hills, under the limited protections California’s medical cannabis laws provided. While there is no longer the threat of arrest and incarceration, for the most part, there are also a lot of hoops to jump through, and new rules and standards to contend with. This article highlights three areas in which your cultivation plan must necessarily change due to the new regulations.
1. Integrated Pest Management (IPM) is limited
In the new regulated market, products that were once widely used are now no longer allowed. Prior to regulation, in the days of Prop 215, you could spray your plants with just about anything, since there was no testing mandated for the products that were being sold. However, people unfortunately got sick and experienced negative reactions, with products like Eagle 20, which contains mycobutinol, and Avid, which contains bifenthrin. Accordingly, under new regulations there are thankfully much more stringent standards dictating what pesticides can be used. It’s ironic that for most of the “medical marijuana” era in California there were no mandatory testing requirements for the THC content of your cannabis, let alone testing for toxins, including pesticides, molds or heavy metals.
You need to have a very thorough pest management plan to make sure your bug populations are always in check. Given that there are a small number of allowable products for pest control in the regulated market, this can be tricky. You need to be extremely familiar with what is and isn’t allowed in today’s regulations. You must also make sure that someone who is certified to apply pesticides is applying them.
Photo: Michelle Tribe, Flickr
As a word of caution, there have been instances where approved pesticides were found to have old unused chemicals (that are not approved for use) from the manufacturing process in them. They may have only occurred in very small amounts, but they are harmful to humans and there is no lawful way to dispose of them.
Further, the presence of these harmful chemicals can cause your finished product to fail when undergoing mandated testing.
Rather than using risky chemicals, the best solution for (early detected) control of pests is the use of beneficial insects. Although they may not be the best solution for an infestation, predator bugs like Neoseiulus Californicus can efficiently control small populations of spider mites while ladybugs are good to limit aphids. Strategic planning of your IPM is one of the best ways to keep pest levels in check.
2. Plant size and plant count matter more than ever
Despite widespread legalization in the past few years for both the medical and recreational markets in the United States, the black market is still rampant and most cannabis is still being produced illegally in the US and internationally.
Maximizing plant canopy space is essential to a profitable business in today’s market
Generally speaking, in the black market, the less plants you have the better, as high plant counts lead to longer sentences of incarceration. With the passage of prop 215 in 1996, many growers, especially outdoor, started growing their plants as big as they possibly could because most limitations were based on plant counts. Some outdoor growers were able to cultivate plants that yielded over 10 pounds per plant. These days regulations are based on canopy measurements, meaning you can grow as many plants as you want within a defined, limited square footage area. This is where “light deprivation,” a method used to force plants into flowering, becomes favorable as it allows 2-4 harvests per year instead of just one. It is a much more intensive way of growing when you have tens of thousands of plants. While it is easier to plant, cultivate and harvest a larger number of smaller plants, it also requires a much more detailed level of planning and organization.
In order to achieve 4 harvests per year, you must have a well thought out cultivation plan and an all-star staff, but if you are able to accomplish this, you can increase your revenue significantly. Maximizing plant canopy space is essential to a profitable business in today’s market, and to do that will require more detailed planning, better organization and proper crop management.
3. How you grow and what equipment you use
With regulation comes liability for defects or injury. It is essential that all equipment used is approved for its intended use. Traditionally, cannabis was cultivated in secrecy in the black market. This led to many unsafe grow rooms being built by people who did not have the proper skills to be undertaking projects such as converting a garage into a grow room or handling the electrical and plumbing running into them. Accordingly, there were many instances of damages to property or injuries to people because of this. Now that counties and states permit cannabis cultivation facilities, the infrastructure and labor that is done must meet regulated building codes and general safety requirements. It is therefore imperative to know the codes and regulations and hire a professional that does, to ensure you meet the standards in order to avoid potential liability.
Larger scale cultivation requires bigger and more expensive equipment. Cultivation facilities are more likely to have sophisticated equipment, such as chiller systems, that are designed to control the grow room environment. While very efficient, some are not intended to be used specifically for cannabis cultivation, and can therefore be difficult to control and maintain. They perform very specific functions, and when not properly tuned to your conditions, can malfunction by prioritizing dehumidification over cooling. This can be a real challenge in warmer climates when temperatures rise, requiring cooling, but also necessitate removal of moisture from the cultivation space.
Larger scale cultivation requires bigger and more expensive equipment.
On the other hand, there is new technology that can make a huge difference in the success of your cultivation. I recently worked with two different companies that specialize in root zone heating systems. One manufactured equipment for root zone heating and cooling of 10k sq ft raised beds that had never been used in California previously. The other company specialized in root zone heating using radiant floor heat. They both worked as intended to maintain a constant root zone temperature, which increased plant health, and ultimately increased yield.
Many counties require data collection from your cultivation, requiring you to track the amount of water and nutrients used. Therefore, another useful tool you can use to increase efficiency, is data collection software that will allow you to collect different information about the amount of water and nutrients used, as well as specific information about the conditions in your grow medium. You can also record and display temperature and humidity readings in your grow room, in real time remotely through Wi-Fi, that you can then access from your phone or computer from anywhere in the world. This can be a useful tool when documenting information that your county, state or investors may require from you. Further, the ability to collect and analyze data will allow you to identify areas of inefficiency in order to correct and optimize your grow room’s potential. While you can achieve these same goals with simple in-line water meters, keeping track of nutrients and pesticides is not as easy. Data collection in the most basic form, using a pen and paper, can be an inaccurate and an inefficient use of time, and can easily be misplaced or ruined. Therefore, simple data software collection programs are the best solution to make the process simple and hassle free.
While it is nice to have state of the art equipment, if it does not work properly, or cannot be easily maintained, it will not be worth it in the long run and you will never see a return on your investment. Innovation comes with a price; using equipment that is cutting edge can be risky, but on the flip side, when done properly it can give you a big advantage over your competitors.
In switching from the black market to the regulated market, these three areas have proven to be the biggest areas of change and have presented the biggest challenges. It is important you consider these necessary changes, and make a solid plan before you begin your cultivation. This is where a cultivation consultant can help.
As cannabis markets continue to gain traction, inconsistent and largely unpredictable markets have left recreational consumers in an informational fog. Try as the industry may, or may not to inform consumers, the lack of knowledge was evident when an established Colorado hash company opened a second operation in California. Expecting high demand for their solventless concentrates, the demand for their solvent-based counterparts came as a surprise. Initially hoping to eliminate solvent extracts from their product line-up, the company was forced to devote about half their overall production to solvent extracts, until information spreads and attitudes start to change. Over the past year several companies have joined the solventless side of history, but consumer understanding remains largely stagnant. For those immediately overwhelmed by terminology, cannabis extracts, concentrates or hash are all interchangeable terms describing concentrated cannabis. Under these umbrella terms, two distinct categories emerge depending upon whether chemical solvents were or were not used to extract the hash. Hence: solvent or solventless. A brief overview of cannabis concentrates will help consumers to understand the evolution away from solvent extractions and toward a superior solventless future.
Science and economics merge when considering all the possible uses of concentrated compounds to final product formulations
Before regulated cannabis markets, cannabis extracts had long been in use. These old-world methods of cannabis extraction use very basic solventless techniques to create more potent, concentrated forms of cannabis. Dry sifting is easily the oldest form of cannabis extraction and a prime example of one solventless technique. Something as simple as shaking dried cannabis over metal screens and collecting the residue underneath creates a solventless product called keif. Dark brown bubble-hash, made popular decades ago, is another ancient technique using only ice and water to perform extractions without chemical solvents. After decades of stagnant and limited old-world methods, changes in legislation allowed cannabis sciences to flourish. These old-world hash methods were quickly forgotten, replaced by the astonishing progress of modern solvent extractions.
Tetrahydrocannabinol (THC), just one of hundreds of cannabinoids found in cannabis.
The emergence of solvent extracts revolutionized cannabis around 2011, creating new categories of cannabis products that exploded onto the scene. Not only did solvent extracts produce the most potent and cleanest forms of hash ever seen at this point, it also created new possibilities for hash-oil vape cartridges and cannabis extract infused edibles. These solvent extracts use butane, propane, or other hydrocarbon solvents to extract, or “blast” cannabinoids from the plant. By running solvents through cannabis and then purging or removing leftover, residual solvents, a super-potent, premium hash product is achieved. Regulated markets require testing to ensure only a safe level, if any, of the solvent used in the extraction process remains in the final product. This technology ushered in the first wave of concentrates to medical and recreational markets under the descriptive titles of wax, shatter and crumble. While these effective and affordable products can still be found today, far superior products have largely replaced wax and shatter. Distillation techniques can further purify and isolate THC-a, while removing harmful residual solvents. For a time, Solvent-free was used to describe this ultra-purified distillate, but the needless term has fallen out of use. Solvent-free is still a solvent extraction using chemical solvents, don’t be fooled. Distillation and CO2 extractions have fallen into general disfavor as they destroy the flavorful terpenes and valuable cannabinoids, that when present create an “entourage effect.” This “entourage effect” happens when the medicinal and recreational properties are most effective, pronounced, and impactful due to a full range of terpenes and cannabinoids being present in the final product. With companies manually reintroducing terpenes to their final extracts, it’s an attempt to restore what was lost during solvent extraction processes. Many brands claim to use cannabis derived or food-grade terpenes to infuse or reintroduce terpenes into their purified hash oils. While this adds flavor and taste, especially to distillate cartridges, it’s far from an ideal solution. Armed with this new information, the informed consumer looks for a full profile of terpenes and cannabinoids in their hash.
THC-A crumble, terpene-rich vape oil, THC sap (from left to right).
With terpene preservation a new priority, all aspects of hash making were reevaluated. By using fresh-frozen cannabis flower, solvent extractions quickly reached new heights. Using the same techniques as prior solvent extractions, the cannabis plant is frozen immediately upon harvesting, rather than trimming and drying the crop as usual. Freezing the plant preserves valuable terpenes helping to create a new category for hydrocarbon extracts under the general label of live resins. This live resin, containing vastly greater profiles of terpenes and cannabinoids than earlier waxes, shatters or crumbles is sold as live-resin sauce, sugar, badder, frosting, diamonds and more. Many versions of live resin re-use previous terms that describe consistencies. These live resin solvent extracts outperform the wax, crumble and shatters of old, and are priced accordingly. Some of the best solvent extracts available today use butane to extract hash oil, which forms THC-a crystals and diamonds seen in live resin sauces. Having learned the value of terpenes and cannabinoids, early efforts to purify THC were clearly misled. The industry defining use of fresh-frozen cannabis flowers greatly improved the quality of all extracts having realized the psychoactive effects are largely dependent on the various profiles of cannabinoids and terpenes. Pure THC-a crystals and isolates are easily achieved with solvent extractions but, produce inferior effects both medicinally and recreationally. Discovering the “entourage effect” as described earlier, these elements of cannabis allowed old-world solventless techniques to be re-inspired and reinvigorated with the benefit of healthy genetics and a hearty understanding of past mistakes.
Having gone full circle, solventless techniques are again at the forefront of the cannabis industry, having attained near perfection for our current understanding of cannabis anatomy.
The increasingly finer mesh works to separate and extract microscopic trichomes
Using the lessons and tendencies of prior extractions, the solventless method, in all its final forms, begin with the same initial process to make ice-water hash oil. Often referred to as solventless hash oil (SHO), fresh-frozen flowers are submerged in ice and water, soaked and agitated before the water is filtered through mesh screens. As these mesh screens are measured by microns, the increasingly finer mesh works to separate and extract microscopic trichomes that break free from the cannabis plant. The 120- and 90-micron mesh screens usually collect pristine trichome heads. After scraping the remaining material from the screens, its sieved onto trays where the hash can dry using modern techniques of sublimation. The results are beyond phenomenal and are sure to shock even life-long cannabis consumers. This technique isolates only the most potent and psychoactive parts of the plant, to produce white to clear solventless ice water hash. When done with precision 6-star ice water hash is formed. The hash can be sold and consumed as is or undergo additional solventless techniques to produce hash-rosin. Not to be confused with live-resins, rosin uses pressure and slight heat to squeeze ice-water hash, into hash-rosin. Some companies have elected to whip their rosins into a solventless badder or allow their hash rosins to undergo a cold cure process that creates textures and varieties like hash rosin sauce. Regardless of the final solventless product, they all begin as ice water extractions. These simple, natural methods of extraction are quickly being adopted by companies known for live resin. As solventless extracts are safer, cleaner and superior in quality to solvent chemical extractions, the race is on as the industry shifts toward a solventless future.
While I’d be happy to never see another solvent extract again, without the miraculous breakthroughs and advances in all aspects of cannabis manufacturing and production we may have not yet arrived where we are today. When using solvents to extract, the trichomes, which contain the full spectrum of terpenes and cannabinoids, are dissolved by the solvent, which is then evaporated off, leaving behind dissolved trichomes. In solventless hash, these trichomes remain whole and are never dissolved or broken down. Instead they are broken free by agitation in ice and water, separating the trichome heads from their less-active stems. These valuable trichomes heads contain everything pertinent and are never destroyed, dissolved or melted like solvent-extractions are forced to do. The benefit of keeping the heads of these trichomes whole results in a far superior product expressing the full profile of terpenes and cannabinoids the way mother nature intended. This natural profile of trichomes lends itself directly to the entourage effect that solvent extracts were found to be missing.
Extraction techniques are not equal and depend upon whether quality or mass production is the aim. Solvent extracts have quickly begun to represent the old-guard of mass-produced cannabis concentrates, with the solventless new-guard focusing on quality, small batch, hash-rosin excellence.
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