The CannaGrow Conference & Expo, held in San Diego on May 7th and 8th, educated attendees on the science of cannabis cultivation. The conference brought subject matter experts from around the country to discuss cannabis breeding and genetics, soil science and cultivation facility design.
Discussions at the conference delved deep into the science behind growing while providing some expert advice. Drew Plebani, chief executive officer of Commercial Cultivator, Inc., gave a comprehensive review of soil ecology and how understanding soil fertility is crucial to successfully growing consistent cannabis. “Soil fertility is measured by laboratories in terms of soil minerals, plant-available nutrients, percent of organic materials, pH levels and most importantly the balance of the soil’s chemical makeup,” says Plebani. “There is no silver bullet in soil ecology; increasing your soil fertility comes down to understanding the composition of soil with analytical testing.” Plebani went on to add that soil systems for cannabis need to be slightly fungal-dominant in developing an endomycorrhizal system, which is optimal for cannabis plant growth.
Plebani notes that growth and viability are reliant on maximum root mass.
Tom Lauerman, colloquially known as Farmer Tom and founder of Farmer Tom Organics, kicked off the conference with an introduction to cultivation techniques. Lauerman also delved into his experience working with federal agencies in conducting the first ever health hazard evaluation (HHE) for cannabis with the National Institute for Occupational Safety and Health (NIOSH). Through the HHE program, NIOSH responds to requests for evaluations of workplace health hazards, which are then enforced by the Occupational Safety & Health Administration (OSHA). Lauerman worked with those federal agencies, allowing them to tour his cultivation facilities to perform an HHE for cannabis processing worker safety. “I was honored to introduce those federal agencies to cannabis and I think this is a great step toward normalizing cannabis by getting the federal government involved on the ground level,” says Lauerman. Through the presentation, Lauerman emphasized the importance of working with NIOSH and OSHA to show federal agencies how the cannabis production industry emerged from the black market, branding itself with a sense of legitimacy.
Attendees flocked to Jacques and his team after the presentation to meet them.
Adam Jacques, award-winning cultivator and owner of Grower’s Guild Gardens, discussed his success in breeding CBD-dominant strains and producing customized whole-plant extractions for specific patients’ needs. “I find higher percentages of CBD in plants harvested slightly earlier than you would for a high-THC strain,” says Jacques. “Using closed-loop carbon dioxide extraction equipment, we can use multiple strains to homogenize an oil dialed in for each patient’s specific needs.” As a huge proponent of the Entourage Effect, Jacques stressed the importance of full plant extraction using fractionation with carbon dioxide. He also stressed the importance of analytical testing at every step during processing.
Hildenbrand discussing some of the lesser-known terpenoids yet to be studied.
Zacariah Hildenbrand, Ph.D., chief scientific officer at C4 Laboratories, provided the 30,000-foot view of the science behind compounds in cannabis, their interactions and his research. With the help of their DEA license, he started the C4 Cannabinomics Collaborative, where they are working with Dr. Kevin Schug at the University of Texas-Arlington to screen various cannabis strains to discover new molecules and characterize their structure. “Secondarily, we are using gene expression profiles and analysis to understand the human physiological response and the mechanism through which they elicit that response,” says Hildenbrand. “As this research evolves, we should look to epigenetics and understanding how genes are expressed.” His collaborative effort uses Shimadzu’s Vacuum Ultraviolet Spectroscopy (VUV), and they use the only VUV instrument in an academic laboratory in the United States. “Pharmaceuticals are supposed to be a targeted therapy and that is where we need to go with cannabis,” says Hildenbrand. Him and his team at C4 Laboratories want to work on the discovery of new terpenes and analyze their potential benefits, which could be significant research for cannabis medicine.
Other important topics at the conference included facility design and optimization regarding efficient technologies such as LED lighting and integrated pest management.
With the news of Pennsylvania’s medical cannabis legalization measure passing, lawmakers are clamoring for strict regulatory oversight in the form of traceability to prevent diversion and misuse. State Senator Daylin Leach (D- Montgomery/Delaware) introduced the bill and believes it will have the most intensive protections for safety in the country. “Our goal was to create a system that helps as many patients as possible, as soon as possible and as safely as possible,” says Steve Hoenstine, spokesperson for State Senator Leach. “The seed-to-sale tracking system and the bill’s other protections do just that.”
At the recent Cannabis Labs Conference, Cody Stiffler, vice president of government affairs at BioTrackTHC, discussed why traceability is so important. Stiffler previously served as the chief executive officer of the American Medical Management Association, where he fought the Florida prescription drug abuse epidemic. “We originally started tracking prescription medications and methamphetamine precursors to combat the prescription drug abuse and meth epidemic in Florida,” says Stiffler. He focused on providing accountability and traceability, making sure every prescription was legitimate and keeping drugs off the black market. Implementing tracking protocols allowed for the accountability of pharmacists, physicians and patients.
Cody Stiffler presenting at the Cannabis Labs Conference
The primary goals of a traceability system, according to Stiffler, are to prevent diversion and promote public safety. “We want to advance the cannabis industry with respect to traceability and regulatory compliance by integrating laboratory testing with traceability,” says Stiffler. “Our software helps get safe products to patients and consumers in a responsible manner.”
Stiffler’s role at BioTrackTHC is to provide industry insights to states looking to legalize cannabis and support them with identifying the best practices that meet requirements in their state. Traceability is commonly defined as the ability to verify history, location and application of a product from source to distribution. BioTrackTHC’s tracking software covers everything from seed to sale, involving regulatory bodies in oversight. In the beginning of cultivation, each plant is assigned a bar code or sixteen-digit identifier. According to Stiffler, Colorado’s system uses radio-frequency identification (RFID) tags while Washington’s system gives the business a choice because the software can work with any type of identifier, whether it is a barcode, QR code or RFID tag. “Our system generates those numbers and prevents diversion with a closed loop system,” says Stiffler.
A plant tagged with a barcode and date for tracking
Washington, Illinois, New York, New Mexico and Hawaii are the five states that use BioTrackTHC’s software. “If the state wants to see the chain-of-custody, they can go back in the system and see every touch point and the full life cycle of the product in real time,” says Stiffler. “Our system also incorporates lab testing to ensure no product reaches shelves unless test values are associated with it.”
A flowchart showing tracking from seed to sale.
For many states, problems lie not in diversion, but inversion, where black market growers bring their products into the legal market. “A lot of people growing black market product are inverting it into the regulated market,” notes Stiffler. This kind of black market activity can flood the legal market with un-tested cannabis.
Product recalls are examples of when traceability software can be very useful. Pesticides, microbiological contaminants, heavy metals and other contaminants are at issue. Stiffler invokes an example from a company in Washington making THC-infused drinks. “Because of an issue in the manufacturing process, the bottles were exploding in refrigerators and on shelves,” says Stiffler. “Because the product’s lineage was completely tracked, we could isolate all of the products in that specific batch from that specific manufacturer and then forward trace to every retailer that had it in inventory,” he adds. “Whenever someone who did not get the recall notice would attempt to scan that barcode at point of sale, a message appeared noting its recall status and that it is not for sale.” The software’s financial data analytics can provide real time visibility for profit margins or losses resulting from recalls.
According to Stiffler, these kinds of protections in place give law enforcement and government agencies piece of mind that they are helping to prevent diversion and promote public safety. Traceability software is one of the very important safeguards protecting food safety and product safety.
HARRISBURG, PA– On Wednesday, the Pennsylvania Legislature approved a bill to legalize medical cannabis. Pennsylvania will be the 24th state to legalize cannabis in the United States. The House voted 149-46, passing bill SB3 and sending it to Governor Tom Wolf, who signed the bill into law on Sunday.
The bill, with a list of seventeen qualifying conditions, will allow for certifying physicians by the Pennsylvania Department of Health and licensing growers and dispensaries. The bill also requires standards for traceability in regulatory oversight, establishing criminal penalties for diversion or falsification of identification cards issued to caregivers and patients.
House Majority Leader Rep. Dave Reed
House Majority Leader, Rep. Dave Reed (R-Indiana), believes the bill allows for robust regulatory oversight. “[…] I am confident Senate Bill 3 provides all the necessary protections to prevent the abuse of medical cannabis, including its unavailability in leaf form,” says Reed. “This new health care program will be closely monitored and if there are found to be weaknesses in the law down the road, we can certainly make any necessary revisions.”
The measure’s prohibiting the distribution of cannabis in dry flower form follows New York’s policy of only allowing patients to use it in forms other than smoking, such as vaporizing or consuming orally in capsules.
Tom Santanna, director of government relations at the Pennsylvania Medical Cannabis Society, is confident the PA Department of Health is the right organization to regulate medical cannabis. “An important part of the regulatory process includes providing for the safety of cannabis via laboratory testing, and it is our feeling that the PA Department of Health is the correct agency for that task,” says Santanna. “The legislation gives the Department of Health the authority to create standards for safety and it is our goal as an organization to work with them to make sure the proper safeguards are in place.”
State Senator Daylin Leach introduced the bill.
The passing of this legislation will undoubtedly encourage more doctors to consider recommending cannabis as a treatment option in Pennsylvania. Dr. David Casarett, professor of medicine at the Perelman School of Medicine, University of Pennsylvania, believes this could help a number of his patients. “When it becomes legal in Pennsylvania, I will certainly discuss it as an option for some of my patients,” says Casarett. “If it is legal, then at least I will know my patients are getting it from a safe and reliable source, without supporting the illegal drug trade and organized crime.”
State Senator Daylin Leach (D- Montgomery/Delaware) introduced the bill and has introduced medical cannabis legislation in every session since 2009. Steve Hoenstine, spokesperson for State Senator Leach, believes the measure will have the most intensive protections for safety in the country. “Our goal was to create a system that helps as many patients as possible, as soon as possible and as safely as possible,” says Hoenstine. “The seed-to-sale tracking system and the bill’s other protections do just that.” State Senator Leach will deliver the keynote speech at the Innovation in the Cannabis Industry; Technology, Medical & Investment Conference in Philadelphia on April 30.
It is expected to take up to two years to begin the implementation of regulations and allow retailers to open their doors to patients.
In a letter sent to lawmakers last week, the Drug Enforcement Agency (DEA) announced plans to make a decision on rescheduling cannabis by mid-2016. The announcement could represent the culmination of a shift in the federal government’s attitude toward cannabis legalization.
Currently, cannabis is a Schedule I narcotic, meaning the government views it as lacking medical benefits and have a high potential for abuse. The rescheduling of cannabis has the potential to open the floodgates for research, including much needed clinical trials.
Derek Peterson, chief executive officer at Terra Tech, a cannabis-focused agriculture company, believes this bodes well for the growth potential of the cannabis industry. “From the perspective of quality and safety standards, I find it unlikely that rescheduling it would negatively impact the degree to which cannabis is examined,” says Peterson. “It’s unnecessarily high position on the DEA drug schedule does nothing but limit the industry’s potential for growth, stall any meaningful pharmaceutical testing and increase law enforcement’s ability to prosecute non-violent drug offenders,” adds Peterson.
The rescheduling could also potentially allow for the prescribing of cannabis for patients. Stephen Goldner, founder of Pinnacle Labs and president of Regulatory Affairs Associates, is hopeful this will lead to a greater shift in public attitude towards cannabis. “The DEA’s announcement is a clear message to all States and possibly even to United Nations policy makers: even the DEA is willing to reconsider cannabis,” says Goldner. “Since the DEA is reconsidering cannabis, state politicians and local police departments can also be flexible and move away from prohibition, towards the regulation of cannabis.”
The rescheduling of cannabis could have a tremendous impact on the growth of the cannabis industry, including more clinical trials, medical research and physician participation. It could also open the door for more federal agency involvement, as the Schedule I status inhibits any EPA research on cannabis pesticide use or FDA guidance on food and drug good manufacturing practices. When reached for comment, the FDA’s press office said they could not speculate on any involvement in the matter.
I have been working with the chemical analysis side of the cannabis industry for about six years, and I have seen tremendous scientific growth on the part of cannabis labs over that time. Based on conversations with labs and the presentations and forums held at cannabis analytical conferences, I have seen the cannabis analytical industry move from asking, “how do we do this analysis?” to asking “how do we do this analysis right?” This change of focus represents a milestone in the cannabis industry; it means the industry is growing up. Growing up is not always easy, and that is being reflected now in a new focus on understanding and addressing key issues such as pesticides in cannabis products, and asking important questions about how regulation of cannabis labs will occur.
While sometimes painful, growth is always good. To support this evolution, we are now focusing on the contribution that laboratories make to the safety of the cannabis consumer through the generation of quality data. Much of this focus has been on ensuring scientifically sound data through regulation. But Restek is neither a regulatory nor an accrediting body. Restek is dedicated to helping analytical chemists in all industries and regulatory environments produce scientifically sound data through education, technical support and expert advice regarding instrumentation and supplies. I have the privilege of supporting the cannabis analytical testing industry with this goal in mind, which is why I decided to write a regular column detailing simple ways analytical laboratories can improve the quality of their chromatographic data right now, in ways that are easy to implement and are cost effective.
Anyone with an instrument can perform chromatographic analysis and generate data. Even though results are generated, these results may not be valid. At the cannabis industry’s current state, no burden of proof is placed on the analytical laboratory regarding the validity of its results, and there are few gatekeepers between those results and the consumer who is making decisions based on them. Even though some chromatographic instruments are super fancy and expensive, the fact is that every chromatographic instrument – regardless of whether it costs ten thousand or a million dollars – is designed to spit out a number. It is up to the chemist to ensure that number is valid.
In the first couple of paragraphs of this article, I used terms to describe ‘good’ data like ‘scientifically-sound’ or ‘quality’, but at the end of the day, the definition of ‘good’ data is valid data. If you take the literal meaning, valid data is justifiable, logically correct data. Many of the laboratories I have had the pleasure of working with over the years are genuinely dedicated to the production of valid results, but they also need to minimize costs in order to remain competitive. The good news is that laboratories can generate valid scientific results without breaking the bank.
In each of my future articles, I will focus on one aspect of valid data generation, such as calibration and internal standards, explore it in practical detail and go over how that aspect can be applied to common cannabis analyses. The techniques I will be writing about are applied in many other industries, both regulated and non-regulated, so regardless of where the regulations in your state end up, you can already have a head start on the analytical portion of compliance. That means you have more time to focus on the inevitable paperwork portion of regulatory compliance – lucky you! Stay tuned for my next column on instrument calibration, which is the foundation for producing quality data. I think it will be the start of a really good series and I am looking forward to writing it.
In the first part of this series, I presented some issues with perpetual harvest models for cultivation with respect to inefficiencies in technology and environmental monitoring. I made the case for compartmentalizing cultivation facilities to not only increase energy efficiency, but also to mitigate contamination and control risks for pest incursions. In the second part of this series, I will elaborate on how compartmentalizing your facility can help you stay compliant with pesticide use regulations and promote worker safety.
Problems with Pesticide Use and Worker Safety Regulations
Where there are pests there are pesticides, whether they are low-toxicity materials derived from natural sources or chemical products that are illegal to use on cannabis. Even in the case of growers that are following current pesticide guidelines and using only products approved by their state department of agriculture, perpetual harvest models present issues in ensuring that the workplace is safe for employees and compliant with pesticide use regulations.
One obvious difficulty is the impossibility of containing drift from pesticides applied as foliar sprays. At this point, due to the lack of research performed on pesticides and cannabis, there are currently no defined pre-harvest intervals (PHI), even for products allowed for use on cannabis. A pesticide’s PHI is the number of days that must pass between the time of the last application of a pesticide and when the crop is cut for harvest. While no official, research-based PHIs have been outlined for pesticide use on cannabis, most conscientious cultivators refrain from spraying their crops with anything once flowers have emerged, as the resinous, sticky buds and their many crevices would presumably retain a great amount of any material applied to them. However, flowers do not generally emerge fully until the third week of the flowering process, and many growers apply preventative applications in the first two weeks of flower. In a perpetual harvest facility, what is to stop drift from applications made early in flower from contacting plants close to harvest? One could simply not spray in flower at all, but eliminating early-flower preventative treatments could increase the chances of a pest incursion, which, as discussed above, can be seemingly intractable in this type of facility.
It is important to consider the restricted entry interval (REI) when dealing with pesticide use. The REI of a pesticide is the period of time after an area is treated during which restrictions on entry are in effect to protect people from exposure to hazardous levels of pesticide residues. Most of the products and materials approved for use on cannabis in Colorado have no REI or a relatively short one. At the time I left my former facility, the longest REI for any product in use was twelve hours (for Evergreen Pyrethrum Concentrate), though most had REIs of four hours or less. This issue could be avoided in a perpetual harvest facility by simply always scheduling pesticide applications at the end of the workday; if a product is sprayed at 6 PM, for example, then the treated area should be safe for entry by the following morning when employees arrive. However, what is to be done if a pest incursion is discovered in the middle of the day and an immediate treatment is necessary to prevent its spread? Would the management or ownership of such a facility be willing to clear out the entire perpetual harvest area for 4-12 hours, potentially leaving other tasks unperformed or incomplete, so that a few plants could be sprayed? Even if operators went to such lengths to observe REIs properly, instances such as the hypothetical described above would create massive interruptions in daily workflows and scheduled tasks that are highly undesirable in a well-managed commercial setting. Compartmentalization allows for essential tasks in a single room that might need an emergency treatment to be completed in a timely manner, and cordoned off after the pesticide application to observe the REI.
A final point concerning this topic is that perpetual harvest facility designs make it difficult to observe certain requirements of the Worker Protection Standard (WPS). WPS is administered by the EPA (but is enforced by the Colorado Department of Agriculture (CDA) in that state) and consists of training intended to reduce the risk of pesticide poisoning and injury among agricultural workers and pesticide handlers. WPS training is required for all agricultural workers and pesticide handlers, including those in the legal cannabis industry. One requirement of WPS is that employers provide decontamination supplies for their employees in case of accidental pesticide exposure or poisoning. Sandra McDonald is a pesticide safety expert and owner of Mountain West PEST, which provides WPS and other training to farmers of all crops in Colorado. She states that decontamination supplies cannot be stored in areas that are to be or have been treated by pesticides (such as perpetual harvest rooms, for the purposes of this discussion), as the applications could possibly contaminate the decontamination supplies with pesticide residues, making them useless or even dangerous.
So, in a perpetual harvest facility, where does one store decontamination materials? Again, while there are solutions to this question, they are not ideal. The materials would of course have to be located outside the perpetual harvest room, the entirety of which is a “treated area” at one time or another. But, in facilities the size of the ones under discussion, it could be difficult for an employee who has been exposed to pesticides to reach an eyewash station if he or she has to navigate the expansive perpetual harvest room, as well as a doorway or two, in order to gain access to safety supplies located somewhere that pesticide contamination is not a risk. McDonald notes that most of the products approved for use on cannabis by the CDA would not require immediate decontamination. However, as not to downplay the very real risks posed by some approved products, she also points out that first aid statements on the labels of such pesticides recommend at least 15-20 minutes of continuous rinsing in the case of a worker getting pesticides in his or her eyes, and treatment that takes place sooner rather than later is obviously preferable. Additionally, there are some approved materials with high pH levels that could be immediately damaging if a worker splashed them in his or her eyes.
The issues raised by perpetual harvest designs in respect to pesticide use and worker safety are amplified greatly if businesses operating perpetual harvest facilities employ or have employed chemical pesticides that are illegal for use on cannabis. Unfortunately, the illegal application of restricted-use pesticides has revealed itself to be widespread, as examples from Colorado and Washington illustrate. One of the most commonly used illegal products, Eagle 20EW, carries with it a 24 hour REI. This means that to properly observe this safety measure, employees would be required to keep clear of the treated area for a full day, which I find unlikely to be enforced considering the daily requirements of a cultivation facility. Drift again poses a problem, but a much more serious one compared to the products on the CDA’s approved list.
Recommendations
It should be obvious by now that, when considering facility or site design, compartmentalization is desirable and necessary. This goes for greenhouse and outdoor production, as well as indoor. In fact, some outdoor farmers in the Emerald Triangle area of northern California work multiple, separate parcels to hedge against the threat of crop loss wiping out their entire year’s efforts. Though the discussion above focused mostly on flowering plants; propagation, vegetative, and mother areas should be separate as well, as they effectively contain all future harvests and are therefore of paramount importance.
The appropriate amount of compartmentalization will vary depending on the operation. In most agricultural businesses, some amount of loss is expected and incorporated into plans and budgets. In terms of areas for flowering plants, they should be compartmentalized to an extent that, should a severe infestation or systems failure occur, the loss of expected revenue from one or more rooms or areas will not cripple the business. Such loss should not happen often in a well-run, well-equipped facility. However, I have seen the drastic damage that russet mites can cause, in addition to experiencing the dread that permeates an entirely darkened warehouse after a transformer explosion, and would advise that cash flow projections take into account the possible loss of a harvest or two from a single room per year, just to be safe.
In cannabis farming, as in all agriculture, we must plan for the worst and hope for the best. Compartmentalization is a fundamental and effective safeguard against small pest incursions becoming widespread infestations, while allowing for grow areas to be fully sterilized and decontaminated after a harvest without completely interrupting all operations. It also allows for the observance of REIs, PHIs (even self-imposed ones), and certain WPS guidelines much more easily than perpetual harvest models. Finally, while costing more up front, ongoing operational expenses can be lessened, with a greater return on the energy that is used. While the benefits of wide-open spaces are frequently touted in a variety of contexts, cannabis cultivation is one where being boxed in is preferable to ensure that your employees, plants, and investment are protected.
When newspapers and television run a cannabis story, it is frequently accompanied by photos or video of vast, cavernous warehouses filled with veritable oceans of plants. Photos used to illustrate stories in the New York Times and Denver Post serve to illustrate this point.
This type of facility design is sometimes referred to in the cannabis industry as a “perpetual harvest” model. This is because plants are harvested piecemeal – one row at a time, for example – with new plants ready to flower replacing the recently harvested ones. In this model, flowering plants of various ages occupy the same space and the room is never completely harvested and empty, hence the “perpetual” moniker. This is in contrast to more compartmentalized facility designs, in which flowering plants are segregated in smaller groups in various rooms, which are then harvested completely before the room is cleaned and new plants ready to flower replace the previous ones.
The perpetual harvest setup appears impressive and lends itself well to portraying the volume of production being achieved in large facilities. This is likely why I have seen such models, or similar ones, copied in other states. Prospective entrants to the industry have also approached my firm with such designs in mind for their cultivation facilities. However, we generally advise against the perpetual harvest facility model, as this type of design imposes serious difficulties upon operators. Problems arise primarily in the areas of pest and contamination mitigation, ability to properly observe pesticide use and worker safety guidelines, and inefficiencies in lighting and HVAC usage. The problems noted are linked to the perpetual harvest design and can be mitigated with increased compartmentalization. Before getting to my recommendations, however, lets run down the issues created by the perpetual harvest model.
In many photos I see of perpetual harvest facilities, the ceilings are extremely high, as are the light fixtures in most cases. This is likely the result of one of the main perceived advantages of such spaces, which is that they require minimal construction prior to getting up and running. There are no walls to be put up or ceilings lowered, and the lack of compartmentalization makes running wires and ducting much easier.
However, whatever capital was saved in initial construction will likely be burned up by increased ongoing operational costs. High ceilings such as those in the above photos mean more cubic footage that climate control systems must cool or heat. Additionally, due to the great height of the light fixtures, plants are not getting the most bang for their buck, so to speak, compared to designs that allow lights to be lowered appropriately to provide optimal intensity and spectrum. Double-Ended High Pressure Sodium (DE HPS) lamps are probably the most common type of lighting in use for flowering by commercial cannabis cultivators today, and they are ideally situated about four feet above the canopy when running at full capacity.
For businesses aiming for a no-frills production model with minimal attention to the light management needs of individual cannabis cultivars (or strains, as they are commonly referred to), then this consideration may be moot. However, those operations attempting to produce the highest-quality flower and plant material know the value of proper light management, as well as the fact that some cultivars respond differently than others to intense light. Indeed, I have observed cultivars that produce more when light intensity was decreased, while others thrived under intense light that would have seriously damaged others. This makes the one-size-fits-all approach to light management I’ve seen in most perpetual harvest designs generally detrimental to the quality of the final product, in addition to using the same amount of energy, or more, to achieve that lower quality result.
Difficulties in Pest and Contamination Mitigation
Such a design makes it easy for a small pest incursion to become a full-blown infestation. Because plants about to be harvested are sharing space with plants just beginning their flowering process, this means that both current and future harvests will be affected, or even lost entirely if the pest problem is severe. Having plant groups of different ages share the same space is generally unadvisable. This is because older plants, particularly those close to harvest, are weaker and more susceptible to pests by virtue of the fact that their life cycles are nearing an end. On the other hand, a more compartmentalized facility design provides physical barriers that can contain mites and mildew spores to some extent, limiting the damage done by individual pest incursions.
One of the essential tasks in an indoor cultivation operation is sterilizing just-harvested spaces to ensure that the subsequent run gets off to a clean start. This task could conceivably be performed in a perpetual harvest model; say, for example, trays, trellis frames, and other equipment are scrubbed after a row has been cut down and removed for drying or processing. However, due to the fact that there are always other plants in the room, it seems impossible for any plant group to get an assuredly clean start, as other plants may be harboring bugs, mold spores, or viruses, despite not showing signs or symptoms. The presence of plants also eliminates the possibility of using cleaning agents such as bleach, which gives off harmful fumes, but is sometimes necessary to completely sterilize an area that might have previously experienced some amount of powdery mildew or botrytis.
In Part II of this series, I will discuss some problems with pesticide use and worker safety regulations as well as provide recommendations for compartmentalization in cultivation facilities. Stay tuned for Part II of A Case for Compartmentalization: Problems with “Perpetual Harvest” Models in Cultivation, coming out next week.
The Oregon Health Authority (OHA) recently implemented a set of temporary rules effective through June 28th of this year with the goal to establish a set of regulations for cannabis testing by October 1st. An investigation by The Oregonian highlighted some of the previous problems with cannabis testing in the state.
The most impactful rule changes include The NELAC Institute (TNI) mandatory standards for laboratories that the Oregon Environmental Laboratory Accreditation Program (ORELAP) will use to accredit labs. Initial rules in the Oregon medical cannabis program, HB 3460 from 2013, did not specify accreditation rules for cannabis testing.
The OG Analytical laboratory in Eugene, Oregon is working to comply with new regulations, including new sample collection rules
ORELAP currently performs accreditation for lab testing under the Clean Air Act, Clean Water Act, Resource Conservation and Recovery Act and the Safe Drinking Water Act. The new cannabis testing rules will give ORELAP the authority to accredit and regulate cannabis labs in the state of Oregon.
Rodger Voelker, Ph.D., laboratory director of OG Analytical in Eugene, OR, believes these rules are monumental in establishing legitimacy in cannabis testing. “These new rules have major repercussions mainly because they require not only getting accreditation, but maintaining it with very strict requirements,” says Voelker. “That also includes procedural guidelines that very carefully outline the quality of laboratory practices and establishes a set of criteria for method validation.”
Rodger Voelker, lab director at OG Analytical laboratory
Voelker notes that two of the biggest changes are in quality control and data management. “The documentation they require is very thorough and strict with the idea that any aspect of an analysis can be replicated,” adds Voelker. “This is a real win for us in my opinion because now we have an agency that can issue the appropriate credentials as well as have the authority to make punitive measures.”
The timeline for implementation with temporary rules allows state regulators to work with laboratories to perform accreditation and bring laboratories up to speed. According to Shannon Swantek, ORELAP compliance specialist, products that dispensaries sell in medical and recreational markets are required to be tested under the new rules and in the analyte lists by an ORELAP accredited laboratory, starting on October 1st.
Swantek’s job is to accredit cannabis labs to the TNI standards, which is essentially very similar to ISO 17025, just with more prescriptive measures and the ability to pair with state agencies to enforce rules after accreditation. “The timeline for accreditation is dependent on how ready the lab is and how compliant they are to the TNI standard already,” says Swantek. “The culture had gotten so fraudulent that the legislature felt Oregon needed some serious, more strict rules in place.”
Labs need very expensive instruments to perform all of the testing required by OHA
One of the biggest changes coming to Oregon cannabis testing is the new sampling requirement. “An accredited laboratory employee must take the sample because sampling is where a lack of training or outright fraud is skewing results, which occurs when a grower brings in a sample not representative of the batch,” adds Swantek. Sample preparation methods will also be required to be more robust to meet the action limits of pesticide testing in particular, helping to identify lower levels like parts-per-billion, according to Swantek.
Reports were also lacking key information in the past. The new rules will require more information such as the procedure used, the analyst carrying it out, dilution factors and any other information you need to theoretically reproduce the result. This will result in more accurate labels on products.
Many are concerned that the new lab testing requirements will raise the price of testing too much. In reality, those current prices are not realistic for accurate data, which points to the rampant fraud that ORELAP is trying to eradicate. “The old rules were written in such an ambiguous way that the prices were set by laboratories without a proper quality program or even without proper instrumentation,” says Swantek.
OG Analytical had to close its doors briefly to meet accreditation
The accreditation process will require particularly robust quality control systems in labs. “Accreditation to the TNI Standard means that lab quality systems will require a documentation system, training procedures, record keeping, personnel requirements, organization details, proof of no conflicts of interest and corrective actions if noncompliant,” adds Swantek. “We single out each method or procedure, look at their raw data and proficiency testing and determine if they are meeting the technical requirements.”
According to Voelker, other industries have learned to adjust their costs with stringent lab testing rules. “I get that no one wants to pay more for lab testing, but the reality is that joining the world of commodities comes with additional costs to ensure consumer safety,” says Voelker. These rule changes will undoubtedly bring more consistency to Oregon’s cannabis industry with accurate lab testing and help the OHA shed more light on issues surrounding consumer safety.
New Frontier, a financial data analysis firm, recently released a report that caused a media frenzy over the cannabis industry’s alarmingly high energy bill. The Washington Post published an article with the headline “The Surprisingly Huge Energy Footprint of the Booming Marijuana Industry.” Denver news publication, Westword, posted an article with the headline “Legal Marijuana Used Over $6 Billion in Energy Last Year, Report Says.” There are dozens of articles published suggesting the legal cannabis industry’s energy consumption has a $6 billion price tag, which is misleading.
What’s the problem? The $6 billion figure that New Frontier cites comes from a 2012 research study that estimates the energy footprint for legal and illicit markets. That means the $6 billion estimate includes the legal cannabis industry and the black market’s energy footprint. To put it in perspective, the size of the entire legal cannabis industry in the United States was less than that in 2014 at $4.6 billion, according to the ArcView Group.
The projected energy demand for growing in the Northwest through 2035, from the New Frontier report.
According to Giadha Aguirre DeCarcer, founder and chief executive officer of New Frontier, only including the legal market would significantly reduce the size of this estimate. “Dr. Mills’ study looked to assess the total energy use associated with marijuana in the US, not just that of the nascent legal marijuana industry; including this holistic view is an important growth determinant for the legal market as the U.S. transitions from a predominantly illicit production environment,” says Decarcer.
Dr. Evan Mills, energy analyst at the Department of Energy and member of the UN Intergovernmental Panel on Climate Change, conducted the 2012 research study and is a senior advisor on the New Frontier report.
Brett Roper, founder and chief operating officer at Medicine Man Technologies, believes those numbers still need to be adjusted. “Dr. Mills’ study is based on pre-2011 data and sources that date back as far as 2003,” says Roper. “The study provides figures that are, quite frankly, outdated based upon changes in the industry related to cultivation and production efficiency.” The study focuses on cultivation increments of sixteen square feet consuming 13,000 KW per year that, according to Roper, is not reflective of current indoor cultivation technology and energy consumption metrics.
A back-end view of Medicine Man Technologies’ indoor production facility
According to Roper, today’s efficiencies, scalable cultivation operations and new technology could explain the overestimate from five years ago. “We are a Tier III operator that produced approximately 5,100 (+/-) pounds of dried cured flower in 2015 and have a total power bill of approximately $420,000 for the year,” he says. Note that the company had roughly $18 million in revenue in 2015. “Using this metric we have a total energy billing of approximately $83 per pound grown.” According to Roper, they cultivate completely indoors with HPS lights that are not particularly energy-efficient, so this estimate is relatively conservative.
Medicine Man Technologies’ approximately 40,000 sq. ft. cultivation facility.
Dr. Mills’ research cites much higher numbers for the cost of energy per pound of finished product than Roper’s findings. “From the perspective of a producer, the national-average annual energy costs are approximately $5500 per module or $2500 per kilogram [roughly 2.2 pounds] of finished product,” says Dr. Mills. That would suggest the average cost of energy for indoor growing to be above $1,000 per pound, roughly half the current average wholesale price. These numbers would mean that cannabis growers, on average, lose roughly 50% of their total revenue to their energy bill. Medicine Man Technologies’ energy usage is less than 3% of their total revenue.
Xcel, a Colorado utility, showing the rise in electricity demand for cultivation.
The New Frontier report does provide caveats on the use of Dr. Mills’ research. “While this analysis was conducted before many of the recent advancements in cultivation technologies, it highlights the significant energy-related environmental impact of marijuana production, and makes the issue of energy efficiency not just one of competitive advantage but also one of environmental sustainability.”
New Frontier’s CEO, DeCarcer, stresses that their report is intended to serve as a starting point to a much broader exploration of energy use in cannabis. “We are already in the process of establishing a partnership through which New Frontier will ingest real time energy-use data from cultivators across different legal markets for analysis in our next report,” says DeCarcer. “Our goal is to build on the work done by Dr. Mills and others in order to ensure that we are providing the most accurate representation of where the industry currently is, and where it is headed.”
Regardless of the discrepancies, this kind of discourse is great for prompting innovation and getting people to think about the environment. It is very important to examine the energy footprint of cannabis cultivation as it raises questions regarding energy efficiency, which would help the industry’s long-term environmental sustainability.
Walking into one of the grow rooms on Adam Jacques’ farm outside of Eugene, Oregon, you will find dozens of cannabis plants and a whiteboard on the wall with the note “Do it for Frank” across the top. This is a reminder of why Jacques and his team are growing medical marijuana: To help people.
Above some notes is their daily inspiration: “Do it for Frank”
Frank Leeds, one of Jacques’ cannabis patients, lost his battle with cancer in early January.
A view of the grow room where they have 48 plants in flowering..
Jacques was working with Frank for the past five years to develop “Frank’s Gift,” a high-cannabidiol (CBD) strain with a slew of potential medical benefits. Deeply saddened by the loss of his patient and close friend, Jacques continues to run his grow operation, Grower’s Guild Gardens, where he and his wife, Debra, work to get high-quality, safe medicine to their patients.
Adam Jacques looking over his plants in their vegetative stage.
On their farm, strain testing is currently underway for the upcoming changes in the recreational program in Oregon. “With the way the medical laws are now, I have 48 plants for my patients, including multiple high-CBD genetics, and any excess flower will be sold to recreational dispensaries to cover our overhead costs,” says Jacques. When the Oregon Liquor Control Commission (OLCC) grants them their recreational grow license, he will take some of those trial strains to an outdoor crop estimated to be in the thousands of plants on his 42-acre farm.
Presenting at the Dispensary Next Conference a few weeks ago, Jacques said to a crowded room of industry professionals: “The biggest reward is helping people.” Jacques and his team’s work exemplifies the good that smaller grow operations can do for the industry.
This plant is roughly four weeks from harvest, currently in the flowering stage.
Jacques’ recent work has taken him to help Leni Young, a four-year-old girl originally from Alabama who suffers from debilitating seizures. Her parents became medical refugees when she was not selected for an Alabama study involving cannabis oil. As a result, the Young’s took their daughter to Eugene, where with the help of Jacques and his team, they could get her customized cannabis oil with high doses of CBD and tetrahydrocannabinolic acid (THC-A) that could help treat her seizures.
Left to right: Wayne Young with his daughter, Leni Young, and son, Thomas Young, alongside Debra Jacques.
The cannabis oil that Jacques created has brought Young’s seizures down from multiple occurring every day to just one every six weeks. “One-strain solutions like ‘Charlotte’s Web’ are no longer the answer for treating medical conditions,” says Jacques. “We create something custom designed for individual patients, and it is working.” CBD and THC-A, the main active ingredients in Leni’s medicine, are two of the non-psychoactive compounds in cannabis believed to have extraordinary medical benefits.
Jacques inspecting some of the different strains they are testing for the recreational program.
Less than three weeks ago, a bill was introduced to the Alabama legislature that would decriminalize the possession of and allow patients to get high-CBD oil. The bill is called “Leni’s Law.”
Jacques’ goal in the long term is to get clinical trials with peer-reviewed studies to connect the dots between his patients, cannabis and evidence-based medicine. “I am working with a laboratory in Arizona and a doctor from Israel to perform a peer-reviewed study,” he adds. “Getting peer-reviewed will allow me to provide legitimate scientific evidence for my claims and get the knowledge into the hands of my patients.”
Looking into the immediate future, Jacques is wary of different regulations coming to Oregon. “Once you go recreational with your business, you lose the ability to provide any sort of a medical recommendation,” says Jacques. “I do not want to see the recreational program and the desire for profits push out our ability to help patients.”
Jacques and his team represent the idea that embodies the cannabis legalization movement, which is to help people get the medicine they need. “The money is not really important any more,” says Jacques.
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