Oregon Cannabis Guide 2016
MY ROOMMATE Emily Weatherford is the Ms. Frizzle of weed science—she’s a chemist at Portland’s Green Leaf Lab (greenleaflab.org), which tests cannabis before it’s legally allowed to be sold at dispensaries. From my very basic understanding of the weed business, legalization labs have been scrambling to get accredited by ORELAP (Oregon Environmental Laboratory Accreditation Program) before the October deadline. The accreditation process is happening as you read this, but Green Leaf was one of the first in the state to receive its official certification and OLCC marijuana testing license.
I recently sat down with Emily and her boss, Green Leaf’s Chief Science Officer Eric Wendt, to talk about weed science and the accreditation process in layman’s terms.
MERCURY: What’s the position of a lab in the food chain of consumer weed?
WEATHERFORD: We work with anyone from growers, to people who extract cannabis to make concentrates, to people who make cannabis products like edibles, but we also sometimes work with dispensaries as well. Anyone who would like to sell their weed legally in Oregon has to have it tested by an accredited lab. We’re in the flow of things right before [products] can go to the dispensary, but we work with just about every single source of cannabis.
What specifically are you testing it for?
WEATHERFORD: We’re testing for potency for the cannabinoids, so letting people know what kind of dosage they’re going to get, and we’re checking for pesticides.
WENDT: The required testing depends on the product type. The new rules break up products into three different categories: useable marijuana, concentrates or extracts, and cannabinoid products—[these] are ancillary, down the road-type products, whether it’s topicals, creams, edibles, anything that has an extract or concentrate product added to it to medicate it in some way.
For flower material, useable marijuana, if it’s going to the store, in terms of cured flower, it needs to be tested for pesticides, potency, water activity, and moisture content. If it’s going to a processor, the testing requirements are less because it’s going to get tested again after it’s been extracted, processed, and turned into an oil or extract product. Extract products need to be tested for pesticides and residual solvents. People use solvents in the production of extracts, whether it’s a butane hash oil or a propane ethanol. One way or another, you extract cannabinoids using solvent because they’re fat soluble, so it strips them from a plant material. Then you have to go back and remove it so it’s a safe amount before people consume it. So you have to test for solvents and pesticides, and potency isn’t a required test, but most people will be opting in for that.
Edible products, or cannabinoid products, need to be tested for potency only to make sure they meet the limits in place and because they’ve already been tested for pesticides and solvents from the extract material that’s going into them, so they don’t need to be tested again after the fact.
What’s the precedent for cannabis testing labs in Oregon, specifically?
WEATHERFORD: Previously we had requirements that anything sold needed to be tested by a laboratory, but there wasn’t an accreditation system for the validity of that laboratory. So you could just have labs that were doing very minimalistic testing and producing results that hadn’t really been verified in any way, and that’s the regulation that’s happening with the [recreational] market opening up—assuring that every lab that’s putting out results can stand up to questioning of those results.
WENDT: There was no oversight by a regulatory agency. So, you could call yourself a laboratory and say you’re performing testing, but there was no authority by the state or by anybody private to confirm that what you were doing was legitimate or accurate or that you were even performing testing. There was nobody to say, like, your garage wasn’t your lab and you’re not testing your results. [With] the accreditation process, we—the cannabis labs—now fall under the same governing body as all the environmental labs in the state. So we have to go through the same rigorous inspection protocols, we’re held to the same standard, and that’s the TNI Standard, which is a global laboratory quality systems standard that’s in place. We have to meet the requirements of that standard in order to continue to operate.
In other states that legalized weed, like Colorado, was there precedent for what you’re doing?
WENDT: Colorado still doesn’t have an accreditation program, nor do they have official testing requirements—for example, they’re still not testing for pesticides. They don’t have protocols in place on how to sample products... [There] was a big problem in Colorado where they issued recalls for a lot of edibles because they weren’t testing the extract products for pesticides and they didn’t put two and two together that when you extract cannabinoids from flower you’re also extracting the pesticides along with them. No one was testing for it, and all the sudden there were products on the market that were recalled even though the requirements for testing pesticides weren’t in place.
Oregon has learned from those mistakes and tried to build on them. That’s why Oregon has both the most comprehensive pesticide testing requirements of any state, as well as residual solvent testing. We also developed specific sampling protocols for the different product types, which was a challenge in itself because no other agricultural commodity has the same price structure as cannabis nor are there issues with legality about crossing state borders.
WEATHERFORD: [Cannabis] falls in a gray area between agriculture and medicinal, so we get the strict rules of both overlapping in our market.
So... this is hugely uncharted territory.
WENDT: Yeah, particularly for science... The industry is evolving so fast that the OHA and the state of Oregon wanted to get in front of it and say, “Let’s make it as safe as we think we can right now,” and as more research and information comes out, we would have the possibility to maybe dial back the requirements.
WEATHERFORD: In academic research you often are referring to people in a similar field of study, and you can read their papers and their methods and you can call up other labs and talk to them about what they’re doing. When you’re working in a private industry like this, where there hasn’t been a lot of public research done, there isn’t an incentive for the science to be crowdsourced. So everyone’s developing their own methods and trying to figure out the best way to do it on their own as opposed to working as a scientific community.
WENDT: Because the first people to figure out a good method will have a competitive advantage in the marketplace. It’s also been a challenge because a lot of the large industry support you’d normally have from instrument manufacturers—big science companies—normally get out ahead of the regulations and say, “Hey, here’s how to test for all these things, here’s how to run it on our instruments” to encourage you to invest in their instrumentation because it’s a huge cost. You’re talking $400,000 to $500,000 for a piece of instrumentation. So in order to invest in something like that without proven methodology in place, it’s a big risk for businesses. But that’s kind of what the state threw out there and required of us—they didn’t generate a list and then prove that it was feasible.... They said, “Here’s the list we want to test for, we don’t know how to do it. Please figure it out.”
WEATHERFORD: Which, as a private lab, is a huge crunch for manpower, and we’re not paid for R&D [research and development], we’re paid for testing product.
WENDT: Our industry doesn’t have access to traditional banking, [so] you start having to [privately] invest in large instrumentation purchases.
WEATHERFORD: The nature of cannabis being so incredibly nonpolar and an incredibly difficult matrix to work with is constantly proving new challenges.
WENDT: It’s certainly a very complex agricultural product. You have all the fragrances you experience, the terpenes, the things that look like hydrocarbons, the cannabinoids themselves in high concentrations, just the chlorophyll material. It’s a far more complex plant than an apple.
WEATHERFORD: Then there’s also the difficulties of testing the many different matrixes we encounter, because if you think about it, when someone develops an HPLC [high pressure liquid chromatography, a technology used to quantify cannabinoid content in cannabis], no one says, “Let’s see what happens when we grind up a cookie and put it through this.”
WENDT: From a sample preparation aspect it’s especially challenging, because producers and extractors are doing their best to take cannabinoids from the plant, refine them, and infuse them back into edibles or other products. It’s then our job to effectively and accurately extract them back out again. Whether we know how much they added or not, we have to prove it. So if you were to go home and bake a batch of cookies and bring me a dozen of them and say, “Can you tell me exactly how much baking soda I added to these and how much is in each one,” that would be challenging. But that’s effectively what we’re doing.