Tag Archives: PPM

June 15, 2023

Building An Integrated Pest Management Plan – Part 4

By Phil Gibson

This is the fourth in a series of articles designed to introduce an integrated pest management framework for cannabis cultivation facilities. To see Part One, an overview of the plan and pest identification, click here. For Part Two, on pest monitoring and record keeping, click here. For Part Three, on preventative measures, click here. Part Five comes out next week on how to build a framework for control actions and how to monitor them. More to come!

This is Part 4: Direct Control Options

Even when the best methods are implemented and precautions are taken to protect your infrastructure, determined pests can penetrate your perimeter. Before you see crawling, hopping or flying insects, or sickly-looking plants, be sure to implement your physical protection (positive pressure airflow sealed facilities) and personal hygiene methods (shoe baths, sticky mats, & air shower entrances) to protect your crops. Equip your employees with personal protection equipment (PPE) proper gloves, masks and clothing as discussed in our last chapter, preventative measures.

When things do break-out beyond your acceptable thresholds, Direct Control Options include non-chemical microbial biofungicides, microbial bioinsecticides and direct chemical control options. Lots of big scary words there, all of which are toxic even under safe application methods and when used at recommended concentrations levels. This means training in their use and protective clothing is required. Careful application of these control options is necessary so you exterminate your pests and not your people! This seems obvious, but do not just “wing it.”

These chemical elements can be applied in diluted concentration levels, manual wipe-down application, concentrated flush frequencies, or root drench applications, foliar spray mist applications, HVAC aerial diffusions and aerial knock-down sprays. You may even choose to remove badly infected plants and destroy them completely.

Use experts when you are planning for these tools. All of these methods require handling and safety precautions. Proper breathing filters, eye & skin protection, as well as disposable gowns/hazmat suits should be used when applications are performed and until the applications have dissipated to safe levels. Be careful not to co-mingle removed plant materials. Gloves become transport and infection spreaders after use.

Please also be sure to review your harvest testing requirements and what treatments are safe for your consumers and within legal limits. No one wants to have their harvest rejected due to pesticide contamination.

Figure 2: Municipal Water Treatment, RAIR Cannabis, Michigan

Clean-up after application may be required depending on the bioinsecticide or chemical that is used. Again, always ensure the safety of your employees and take precautions.

Start the application of your control options with your site map, room assignments and scout monitoring teams. Where does air flow into and within the facility? When your scouting team count logs go beyond your acceptable thresholds, here are some options for you.

Let’s begin with cleaning your irrigation and nutrient water sources. For a walk-through tutorial for incoming water treatment, humidity recovery and nutrient water recycling, please review the video tour of Water Treatment at RAIR Cannabis to see how an expert has done it.

From the IPM Planning Guide standpoint, peroxide and acid sterilizers can be used to clear irrigation water, for surface wipe-downs or as direct plant applications. We will cover those first. Caustic sterilizers require PPE for cleaning. Forgive my image here, we were just using water.

Concentrated Cleaners for Surfaces & Irrigation Sources (Hydrogen Peroxide & Sanitizers)

Plant interacting interfaces, i.e. surfaces, benches, walls, floors, trays, utensils, clippers, etc. should be sterilized with every use. Methods can include direct wipe-down or scrub, concentrated or diluted sprays or room vaporizers. A good example of hydrogen peroxide (H2O2) liquid would be a food grade sanitizer with 3-35% H2O2 content. Use acceptable diluted versions of these cleaners as appropriate.

Figure 3: Cleaning & Scrubbing, Where’s the PPE?

A commercial example would be Zerotol 2.0 with 27% H2O2 & their proprietary acid mix. Alternatively, you can use direct hydrogen peroxide generators from commercial sources to generate your H2O2 at various concentrations. More detailed examples are included in the complete Integrated Pest Management Guide (link at the end of this article). Establish your procedures for sterilizing your rooms and tools before you introduce plants, and describe what is to be done after every harvest and room turn. Track the cleaning materials used for your operational records. You will find this useful to track operational cost over time.

Sanitizing Acids for Surfaces & Irrigation Sources

Similar to hydrogen peroxide, hypochlorous acid (HOCl) comes in many commercial forms and can also be generated onsite using purchased generators. Commercial mix examples are UC Roots, Watermax and Athena Cleanse. They come in 0.028% to 15% concentrations. Self-generators range in output from highly precise 0.01% to 1% concentrations with more examples in the guide.

Treatment Tools

OK, so enough on cleaning preparation. Here are some tools that can be used to fight back against a pest intrusion:

Non-Chemical Microbial Biofungicide for Pathogens in Soil or Fertigation Water

Microbial fungicides are available to clear nutrient irrigation systems by minimizing pathogens and improving plant resistance to infections. Some fungicide versions target root pathogens by attacking the diseases directly. Others control or suppress common water carried challenges like pythium, rhizoctonia, phytophthora, fusarium and others. Brand names include Botanicare, Bonide, BioWorks, Actinovate, Mycostop and many more. Details covered in the guide.

Non-Chemical Microbial Bioinsecticides for Larval Stages

These biological tools attack the organisms or insects at a physical or mechanical way by breaking down the pest’s nervous system, biochemistry, or structural integrity (exoskeletons, etc.). These are engineered or living organisms (bugs to attack bugs) that are developed as targeted attacks for specific pests. Brand names are BioCeres, Botanigard, Venerate, Bio Solutions and others.

Minimal Risk Chemical Pesticides for Airborne Critters

Figure 3: Example Fungus Gnat Infestation – Royal Queen Seeds blog

Regularly approved for used in most locales, essential oils, natural acids (like citric acid) and insecticidal soap are commonly available in every hydroponic store. These work very well as safe spray “knock-down” insecticides for crawling or flying pests. Commercial examples use a proprietary mix of various oils, citric acids or isopropyl alcohol to do their task (examples in guide). Insecticidal soaps and fungicides for surface cleaning perform a similar purpose and typically use potassium salts or fatty acid mixtures.

Biochemical Pesticides

These tools are used to inhibit insect or fungal growth to acceptable levels. The multifaceted and commonly used neem oil comes in many commercial versions and is a naturally occurring pesticide extracted from the leaves and seeds of the neem tree. Example brand names are Bonide, Monterey, Triact and others. They range in concentrations from 0.9% to 70% concentrations. These oils suffocate living organisms or eliminate moisture to kill insects, spores or fungus at their initiation and throughout their lifespan.

Another option here are Azadirachtins. These act as insect growth regulators and disrupt the bugs natural evolution. Brand names are AzaGuard, AzaMax and others in the guide.

In summary, this week

We summarized some of the many pest control options available for water treatment, soil borne, intermediate or flying pests. We also covered various concentrations for these pesticide and sterilizer options. If you are not familiar with dilution ratios, %, PPM terms and how to apply the correct level of pesticide, you may find our plant science test kitchen blog on this topic of use here.

Chemical access and use should be restricted to employees familiar with their authorized application. PPE is very important to protect any employee that will come in contact with materials, liquids or vapors for chemical resources (gloves, boots, respirators, Tyvek (or equivalent protective wear) suits and eye protection or goggles.

For more detail on each of these treatments, you can see examples for your integrated pest management procedures in our complete white paper for Integrated Pest Management Recommendations, download the document here.

In our next chapter, Pest Population Control Actions, we will review control thresholds and example plans for a range of problems from biofilm build up to white flies and more. Our final chapter after that will suggest an emergency response framework and how to address pest outbreaks. See you next week.

January 9, 2020

The Power of Prevention: Pathogen Monitoring in Cannabis Cultivation and Processing Facilities

By Nathan Libbey

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As the cannabis market matures and the value chain becomes modernized, it’s important to address product safety in a comprehensive way. In other areas of manufacturing, Hazard Analysis & Critical Control Points (HACCP) has been the standard for reducing hazards both for employees and for the products themselves. A Critical Control Point (CCP) is any spot from conception to consumption where a loss of control can potentially result in risk (Unnevehr, 1996). In the food realm, HACCP has been used to drive quality enhancements since the 1980s (Cichy, 1982).

In a nutshell, HACCP seeks to help identify where a problem may enter a product or environment and how that problem may be addressed before it escalates. In cannabis, these hazards include many of the same problems that food products have: specifically molds, yeasts, and pathogenic bacteria (Listeria, E. coli, etc.). While the current industry standard is to test products at the end stage for these contaminants, this late-stage pass/fail regimen leads to huge lots of destroyed product and a risk for consumer distrust (Yamashiro, 2019). HACCP, therefore, should be applied at every stage of the production process.

Pathogen Environmental Monitoring (PEM) is a tool that can be used to identify CCPs in a cannabis cultivation or processing facility. The main goal of a PEM program is to find a contaminant before it reaches a surface that touches the product or the product itself. PEM is conducted using a pre-moistened swab or a sponge to collect a sample from the cannabis environment. The swab can then be sent to a lab for microbial testing. Keys to an effective PEM are:

1. Start with a broad stroke – When the FDA comes to a facility suspected of producing pathogen-laced food products, they conduct what is known as a Swab-a-thon. A Swab-a-thon is a top to bottom collection of samples, usually totaling 100 or more. Similarly, preemptively swabbing should be the first step in any PEM—swab everything to see what exists as a baseline.

2. Map your scene – identify on a map of your facility the following:

Cannabis contact surfaces (CCS) (belts, clippers, tables, etc)
Non-cannabis contact surfaces (Non-CCS) (floors, lighting, drains, etc)
Flow of air and people (where do air and people enter and where do they go?

Identifying the above zones will help deepen your understanding of where contaminants may come into contact with cannabis and how they may migrate from a Non-CCS to a CCS.

3. Plan and execute:

Based on the results of mapping, and Swab-a-thon, identify where and when you will be collecting samples on a consistent and repeatable basis. Emphasis should be placed on areas that are deemed a risk based on 1) and 2). Samples should be collected at random in all zones to ensure comprehensive screening.

4. Remediate and modify:

If you get a positive result during PEM, don’t panic—pathogens are ubiquitous.
Remediate any trouble spots with deep cleaning, remediation devices or other protocols.
Re-test areas that were positive for pathogens to ensure remediation is successful.
Revisit and modify the plan at least once a year and each time a new piece of equipment is added or production flow is otherwise changed.

The steps above are a good starting point for a grower or processor to begin a PEM. Remember that this is not a one-size-fits-all approach to safety; each facility has its own unique set of hazards and control points.

Comprehensive guides for PEM can be found at the links below, many of the concepts can be applied to cannabis production.

https://affifoodsafety.org/lcp/advanced-search/

http://www.centerforproducesafety.org/amass/documents/document/263/Listeria%20Guidance%20UFPA%202013.pdf

Cichy, R. (1982). HACCP as a quality assurance tool in a commissary food-service system. International Journal of Hospitality Management, 1(2), 103-106.

Unnevehr, L., & Jensen, H. (1996). HACCP as a Regulatory Innovation to Improve Food Safety in the Meat Industry. American Journal of Agricultural Economics, 78(3), 764-769.

Yamashiro, C, & Baca, Y. (2019). Prevent high-value cannabis crop loss with innovative environmental monitoring tool.

December 15, 2016

The Nerd Perspective

Pesticide Detection in Cannabis: Lab Challenges and Why Less Isn’t Always More

By Amanda Rigdon

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Almost as soon as cannabis became recreationally legal, the public started to ask questions about the safety of products being offered by dispensaries – especially in terms of pesticide contamination. As we can see from the multiple recalls of product there is a big problem with pesticides in cannabis that could pose a danger to consumers. While The Nerd Perspective is grounded firmly in science and fact, the purpose of this column is to share my insights into the cannabis industry based on my years of experience with multiple regulated industries with the goal of helping the cannabis industry mature using lessons learned from other established markets. In this article, we’ll take a look at some unique challenges facing cannabis testing labs, what they’re doing to respond to the challenges, and how that can affect the cannabis industry as a whole.

The Big Challenge

Over the past several years, laboratories have quickly ‘grown up’ in terms of technology and expertise, improving their methods for pesticide detection to improve data quality and lower detection limits, which ultimately ensures a safer product by improving identification of contaminated product. But even though cannabis laboratories are maturing, they’re maturing in an environment far different than labs from regulated industry, like food laboratories. Food safety testing laboratories have been governmentally regulated and funded from almost the very beginning, allowing them some financial breathing room to set up their operation, and ensuring they won’t be penalized for failing samples. In contrast, testing fees for cannabis labs are paid for by growers and producers – many of whom are just starting their own business and short of cash. This creates fierce competition between cannabis laboratories in terms of testing cost and turnaround time. One similarity that the cannabis industry shares with the food industry is consumer and regulatory demand for safe product. This demand requires laboratories to invest in instrumentation and personnel to ensure generation of quality data. In short, the two major demands placed on cannabis laboratories are low cost and scientific excellence. As a chemist with years of experience, scientific excellence isn’t cheap, thus cannabis laboratories are stuck between a rock and a hard place and are feeling the squeeze.

Responding to the Challenge

One way for high-quality laboratories to win business is to tout their investment in technology and the sophistication of their methods; they’re selling their science, a practice I stand behind completely. However, due to the fierce competition between labs, some laboratories have oversold their science by using terms like ‘lethal’ or ‘toxic’ juxtaposed with vague statements regarding the discovery of pesticides in cannabis using the highly technical methods that they offer. This juxtaposition can then be reinforced by overstating the importance of ultra-low detection levels outside of any regulatory context. For example, a claim stating that detecting pesticides at the parts per trillion level (ppt) will better ensure consumer safety than methods run by other labs that only detect pesticides at concentrations at parts per billion (ppb) concentrations is a potentially dangerous claim in that it could cause future problems for the cannabis industry as a whole. In short, while accurately identifying contaminated samples versus clean samples is indeed a good thing, sometimes less isn’t more, bringing us to the second half of the title of this article.

Less isn’t always more…

In my last article, I illustrated the concept of the trace concentrations laboratories detect, finishing up with putting the concept of ppb into perspective. I wasn’t even going to try to illustrate parts per trillion. Parts per trillion is one thousand times less concentrated than parts per billion. To put ppt into perspective, we can’t work with water like I did in my previous article; we have to channel Neil deGrasse Tyson.

The Milky Way galaxy contains about 100 billion stars, and our sun is one of them. Our lonely sun, in the vastness of our galaxy, where light itself takes 100,000 years to traverse, represents a concentration of 10 ppt. On the surface, detecting galactically-low levels of contaminants sounds wonderful. Pesticides are indeed lethal chemicals, and their byproducts are often lethal or carcinogenic as well. From the consumer perspective, we want everything we put in our bodies free of harmful chemicals. Looking at consumer products from The Nerd Perspective, however, the previous sentence changes quite a bit. To be clear, nobody – nerds included – wants food or medicine that will poison them. But let’s explore the gap between ‘poison’ and ‘reality’, and why that gap matters.

In reality, according to a study conducted by the FDA in 2011, roughly 37.5% of the food we consume every day – including meat, fish, and grains – is contaminated with pesticides. Is that a good thing? No, of course it isn’t. It’s not ideal to put anything into our bodies that has been contaminated with the byproducts of human habitation. However, the FDA, EPA, and other governmental agencies have worked for decades on toxicological, ecological, and environmental studies devoted to determining what levels of these toxic chemicals actually have the potential to cause harm to humans. Rather than discuss whether or not any level is acceptable, let’s take it on principle that we won’t drop over dead from a lethal dose of pesticides after eating a salad and instead take a look at the levels the FDA deem ‘acceptable’ for food products. In their 2011 study, the FDA states that “Tolerance levels generally range from 0.1 to 50 parts per million (ppm). Residues present at 0.01 ppm and above are usually measurable; however, for individual pesticides, this limit may range from 0.005 to 1 ppm.” Putting those terms into parts per trillion means that most tolerable levels range from 100,000 to 50,000,000 ppt and the lower limit of ‘usually measurable’ is 10,000 ppt. For the food we eat and feed to our children, levels in parts per trillion are not even discussed because they’re not relevant.

A specific example of this is arsenic. Everyone knows arsenic is very toxic. However, trace levels of arsenic naturally occur in the environment, and until 2004, arsenic was widely used to protect pressure-treated wood from termite damage. Because of the use of arsenic on wood and other arsenic containing pesticides, much of our soil and water now contains some arsenic, which ends up in apples and other produce. These apples get turned into juice, which is freely given to toddlers everywhere. Why, then, has there not an infant mortality catastrophe? Because even though the arsenic was there (and still is), it wasn’t present at levels that were harmful. In 2013, the FDA published draft guidance stating that the permissible level of arsenic in apple juice was 10 parts per billion (ppb) – 10,000 parts per trillion. None of us would think twice about offering apple juice to our child, and we don’t have to…because the dose makes the poison.

How Does This Relate to the Cannabis Industry?

The concept of permissible exposure levels (a.k.a. maximum residue limits) is an important concept that’s understood by laboratories, but is not always considered by the public and the regulators tasked with ensuring cannabis consumer safety. As scientists, it is our job not to misrepresent the impact of our methods or the danger of cannabis contaminants. We cannot understate the danger of these toxins, nor should we overstate their danger. In overstating the danger of these toxins, we indirectly pressure regulators to establish ridiculously low limits for contaminants. Lower limits always require the use of newer testing technologies, higher levels of technical expertise, and more complicated methods. All of this translates to increased testing costs – costs that are then passed on to growers, producers, and consumers. I don’t envy the regulators in the cannabis industry. Like the labs in the cannabis industry, they’re also stuck between a rock and a hard place: stuck between consumers demanding a safe product and producers demanding low-cost testing. As scientists, let’s help them out by focusing our discussion on the real consumer safety issues that are present in this market.

*average of domestic food (39.5% contaminated) and imported food (35.5% contaminated)

November 30, 2016

Steep Hill, ACCL Find Pesticides in Over 50% of Cannabis Samples

By Aaron G. Biros

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On Election Day, voters in California passed Proposition 64, establishing a recreational cannabis market and regulatory environment. While the state won’t issue the first licenses under the new regulatory scheme until 2018, the medical cannabis industry is already well established.

Steep Hill Labs, Inc., based in Berkeley, California, found in October that 84.3% of samples submitted tested positive for pesticide residue, according to a press release. The announcement came before Election Day, but is particularly eye opening given the massive new market created overnight by Prop 64.

Particularly concerning is their detection of Myclobutanil, which was found in more than 65% of samples submitted to the lab. According to the press release, when Myclobutanil is heated (i.e. smoked or vaporized), it is converted to Hydrogen Cyanide, which is extraordinarily toxic to humans and can be fatal in higher doses.

Reggie Gaudino, Ph.D., vice president of scientific operations and director of genetics at Steep Hill Laboratories. (photo credit: Preston Gannaway) — Reggie Gaudino, Ph.D. (photo credit: Preston Gannaway)

According to Reggie Gaudino, Ph.D., vice president of science, genetics and intellectual property at Steep Hill, their more recent study shows they detected pesticides in roughly 70% of the samples they received and 50% of those contained Myclobutanil. Gaudino says that up to a third of those samples would have failed under Oregon’s regulatory standards.

If a lab test were failed, it would contain pesticides at or higher than the required action level. Oregon’s action level, or the measured amount of pesticides in a product that the OHA deems potentially dangerous, for Myclobutanil is 0.2 parts-per-million (PPM). Steep Hill’s instrumentation has a method detection limit down to the parts-per-trillion (PPT) level, which is a more precise and smaller amount than Oregon’s action level.

“Those in the cannabis community who feel that all cannabis is safe are not correct given this data – smoking a joint of pesticide-contaminated cannabis could potentially expose the body to lethal chemicals,” says Jmichaele Keller, president and chief executive officer of Steep Hill. “As a community, we need to address this issue immediately and not wait until 2018.”

Potentially harmful pesticides, and specifically Myclobutanil, have been detected in Colorado and Washington’s recreational markets on a number of occasions, proving this is a widespread issue. Steep Hill’s release suggests that California regulators take a look at Oregon’s pesticide regulations for guidance when developing the regulatory framework.

What’s even more troubling is that not all laboratories have or had the capability of detecting pesticides at sufficiently low levels and because of this, other labs had significantly lower rates of pesticide detection, suggesting possible inconsistencies in testing methods, instrumentation, sample preparation or other variations. During a 30-day period in late September and early October, Steep Hill found, using publicly available data, or data from contracted testing, that other labs were only reporting between 3% and 21% pesticide detection.

Examination of cannabis prior to testing- credit Steep Hill Labs, Inc.

It is important to note that those samples were not identical and there could be a great degree in variation on the quality of samples sent to different laboratories, so it is not an entirely accurate comparison. Steep Hill does however detect pesticides down to the parts-per-trillion level, whereas many common methods for detecting pesticides look at the parts-per-billion level.

Reggie Gaudino says the Association of Commercial Cannabis Laboratories (ACCL) is using this data to work with Steep Hill and a number of other labs to address these issues. “As a member of the ACCL, and after discussion with ACCL, we have agreed that all future discussion of this issue should not include laboratory names, as this is about educating the industry in general, and making sure all members of the ACCL are developing the best possible methods for detecting pesticides,” says Gaudino. “The ACCL has responded to this data, by inquiring on a larger, industry-wide basis, which represents a better picture of the issue, rather than only in California’s still-technically unregulated market.” The important message is this is a major issue that needs addressing urgently. “As such, the troubling issue remains, across the larger ACCL membership, there is still detection of pesticides in at least 50% of the cannabis being tested.”

According to Jeffrey Raber, Ph.D., president of the ACCL, the industry is experiencing a pesticide problem, but it is very difficult to quantify. “It is fair to say that around 50% of the cannabis being tested contains pesticides, but we really don’t know that exact number until a much more comprehensive statistical analysis is performed,” says Raber. “We agree this is a big problem and that it needs to be addressed, but we are not sure just how big of a problem it really is.” With so much variation in labs in a state where not everyone is required to test products, it is very difficult to pin down how consistent lab results are and how contaminated the cannabis really is. “If all of the labs had the same methodology, samples and shared statistical analyses for a real study then we can look at it closely but it seems we are a ways off from that. I can say confidently however that this is a pretty significant problem that needs addressing.”

Still, Steep Hill detecting pesticides in a majority of their samples and some labs finding as little as 3% should raise some eyebrows. “Unfortunately, our recent study discovered that 84.3% of the samples assessed by our triple quadrupole mass spectrometer contained pesticides,” says Keller. “As of today, this tainted product could be sold in most dispensaries throughout the state of California without any way of informing the patients about the risks of pesticide exposure.”

These findings could mean potentially enormous health risks for medical and recreational cannabis consumers alike, unless regulators, labs and growers take quick action to address the problem.

October 27, 2016

Oregon Issues Health Alert for Contaminated Cannabis

By Aaron G. Biros

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According to Jonathan Modie, spokesman for the Oregon Health Authority (OHA), on Friday, October 21^st, the OHA issued a ‘health alert’ regarding cannabis products sold from a McMinnville dispensary that were possibly tainted with extremely high levels of Spinosad, an insecticide commonly used to combat mites and other pests. “My understanding is that two medical patients purchased the cannabis products whom we had contact info for, but most of the purchasers were recreational customers,” says Modie. “Because it is not required to get contact info for recreational customers, we issued the health alert to get the word out as quickly as possible because we didn’t know who bought the product.” The OHA is urging consumers who purchased cannabis from New Leaf CannaCenter in McMinnville to check the labels and see if they purchased potentially dangerous cannabis, and to either return the cannabis to the dispensary or dispose of it appropriately.

The action level, the measured amount of pesticides in a product that the OHA deems potentially dangerous, for Spinosad is 0.2 parts-per-million (PPM). The two batches in question are the strains Dr. Jack (batch number G6J0051-02) and Marion Berry (batch number G6J0051-01), which were tested to contain approximately 42 PPM and 22 PPM respectively, much higher than the OHA’s action level.

While this is the first health alert issued in Oregon in connection with potentially contaminated cannabis, Modie says he expects there will be more health alerts in the future. “Unfortunately the product was inappropriately transferred from the grower to the dispensary and from the dispensary to customers, so we are working to get the word out to dispensaries, growers and processors about the testing rules to prevent this from happening in the future,” says Modie. “We want to make it clear that any grower, processor or dispensary that does not follow the testing requirements or fail to label, store or retain batches that fail a test will be subject to enforcement actions such as fines, penalties, suspension or revocation of their license.” The OHA has a list of pesticide analytes and their action levels on their website.

“We are advising recreational and medical users alike to read the product labels closely; the labels must have the license or registrant number, the packaging or distributor license number, the name of the strain and the universal symbol,” says Modie. “We are also suggesting consumers request a copy of pesticide test results from the dispensary.” It is unclear at this time if all of the cannabis products in question have been properly disposed of, but OHA was informed that New Leaf has pulled all products in question off of the shelf.