“You can fool all the people some of the time, and some of the people all the time, but you cannot fool all the people all the time.” Abraham Lincoln
A common theme appears before us, “safety”. It is widely believed that regulatory safety requirements will make distributing, consuming or possessing Cannabis safer. Growers and consumers have typically held this role and have taken responsibility for Cannabis safety.
This article is mostly about medical safety. “Adult use” is outside the scope of this article. Although understanding the difference between “licensed medical Cannabis patients” and “recreational or adult-use” is important as they can have very different needs. Folks who consume Cannabis for the enjoyment of the plant have been safe for thousands of years. Using the plant as medicine has changed somewhat after learning the value of Cannabis for treating seizure disorders in children.
As more uses for the plant become apparent, standardization in compounding, dosing and testing will allow for more clinical trials and patient treatments. Some folks have undiagnosed conditions which seem to be driving the use of the plant. For example, before it was “discovered” that some strains were helpful in treating PTSD, Veterans were already consuming Cannabis to improve their lives. There are so many parallels between medicinal use and recreational use that it’s impossible to define who wants Cannabis vs. who needs Cannabis. Do you consume Cannabis for purely medicinal reasons? Yes! Do you consume Cannabis because it makes you feel better without the side-effects associated with other medicine? Yes! So where’s the line? What makes something as varied as the Cannabis plant medicinal vs. recreational? That’s where the term “Adult Use” comes in as it denotes a certain freedom for the individual to decide. That’s how alcohol, caffeine, glucose and other substances are used. They are all helpful, necessary and possibly harmful at the same time.
One overlooked but critical factor for patients is affordability. We hear over and over again that the price of Cannabis dictates the purchase decision. When the cost of Cannabis goes up to a certain number, chronic pain sufferers (90% of licensed patients in Hawaii) will turn to or back to pharmaceutical drugs to alleviate pain. We see this in thousands of counties across the US as the opioid epedemic grows. At one point during operation green harvest, patients began purchasing meth instead of Cannabis resulting in a meth and ice epidemic in Hawaii. Many families are still suffering from the extreme addiction and consequences caused by the jump in prices for Cannabis on the black market.
Some would like you to believe that controlling Cannabis will make Cannabis safer. This belief costs patients 10-75% more at the retail counter and the average consumer does not buy Cannabis for safety. However, it should be clear that some patients absolutely require safety through testing for contaminants. Medical professionals also need testing for standardized dosing regimes. But for thousands of years, Cannabis has been safe. Most consumers buy Cannabis based on strain, quality and price, not safety. Consumers in large part believe Cannabis is safe and this adds to the popularity of the plant.
Government involvement makes Cannabis less affordable. Regulations and taxes will continue to separate patients from medicine long after Cannabis is legal.
Testing laboratories aim to perform standardized testing on Cannabis. Send two samples from the same flower (bud) to different laboratories and you’ll get different test results.
It’s not that all Cannabis products do not need testing. Cheap, imported hemp oil products, which are currently legal, especially need testing. It should also be noted that as of the time of this writing, hemp-derived CBD oil originating in the US is illegal in all 50 states. Cannabis testing at the state level does not ensure safety. Cannabis testing across states is not standardized for patients and no one is testing CBD oil from China.
For example, a Cannabis patient visits their local dispensary. They find out their favorite dispensary is out of the strain they need. So they drive a little further to the next dispensary, crossing a state line to find the medicine they require. They are now buying Cannabis under the control of a different government. The Cannabis they just bought was tested under completely different rules. In Hawaii, Cannabis patients have been responsible for testing their own medicine for decades. Can the DOH show any harm from decades of self-testing?
Fact: The Cannabis you purchase from a dispensary has never been and never will be tested.
How Cannabis Testing Works in Hawaii and Most Other States
A small sample from a “batch” within a “lot” is set aside by the dispensary for testing. Perhaps relative to the rest of the lot but no one will ever know if it came from a plant that was simply set aside for testing. Higher THC products can be sold for more money. So contaminants aren’t the only concern for profit-seeking dispensaries. The aforementioned sample is then sent to a lab, tested and destroyed in compliance with the SOPs approved by the state. The test results are for the representative sample, not the product you purchase. You will never receive a gram of Cannabis that has been tested unless you are a lab technician with a DEA material handling permit responsible for destroying the sample.
So what’s the solution? Better laws? More state regulation?
If legislators or the DOH would like to help make Cannabis safer, they would have their own inspectors take the sample from the dispensary.
It’s impossible for laws or rules to change quickly enough to require testing of products that are changing every day and in combinations that change the composition or molecular structure of the test subject. Investors could require their cultivators to use new pesticides, herbicides, fungicides, insecticides and other new, untested amendments to avoid penalties. This is happening now in other states. Washington recently adopted emergency rules for example.
Next, take samples from the retail side of the operation from the same and different SKUs of batches and lots. Pulling random samples from store shelves just makes sense. Post-packaging must be considered. Bacteria, for example, is not limited to the greenhouse. So why is testing limited to what goes into the package at the greenhouse and possibly repackaged at the dispensary? Repackaging is not supposed to happen, btw.
Some government agencies responsible for things like consumer health, learned a long time ago that safety in certain food products is aided by pasteurization and irradiation, mostly milk and juice. However, the FDA is not certain whether irradiation works. However, certain food irradiation is approved for foods and food packaging that may or may not be labeled. Irradiation is also used for non-food applications, such as medical devices. We’re not advocating for irradiation of Cannabis, ever. But that is a standard practice for certain food items.
Packaging is a stumbling block for safe Cannabis. Even Sun grown, certified organic Cannabis doesn’t travel well. In other words, packaging in non-sterile environments allows the introduction of pathogens into the mix.
We do not recommend consuming pasteurized or irradiated Cannabis. We believe in Sun Grown, Organic Cannabis for medicine making. As crazy as it sounds governments approve of using of herbicides, insecticides, and pesticides for plant-derived medicine. It would seem many Hawaii State Lawmakers are perfectly happy to trust the quality of your child’s medicine to attorneys and investors.
What’s the solution?
Know your supplier. In the home markets of Hawaii and many other states, patients have already learned to avoid growers who poison for profit. Especially on Kauai, ground zero for gmo pesticide air drift. Patients can feel the harshness of Cannabis grown with chemicals. This is most dangerous for a certain number of patients who suffer from autoimmune diseases. Some patients can have extreme allergic reactions to Cannabis that is treated with or contains anything that is not natural or in agreement with their bodies.
No Panic, Grow Organic!
When you grow your own medicine or food, you have the best chance of creating something that is optimal for your condition and safe for consumption. The only way to know if the Cannabis you buy is safe is to try it yourself. No one can protect you from pathogens. When you get the safest Cannabis in the world and forget to wash your hands when you roll a joint, guess what, you just crossed the line of safety. Ever drop a joint on the floor?
For thousands of years Cannabis has been used as safe and effective medication. Only during prohibition has the question of safety or efficacy become relevant to patients.
“After deferring to the DEA, your release reads that, ‘FDA is the sole federal agency that approves drug products as safe and effective for intended indications.’ Why then has the FDA failed to respond to the 1999 Institute of Medicine (IOM) report which concluded that marijuana’s active components are potentially effective in treating pain, nausea, the anorexia of AIDS wasting, and other symptoms, and should be tested rigorously in clinical trials? Read More
The FDA has not approved marijuana as a safe and effective drug for any indication. Source
It should be noted that safety testing is not the only form of Cannabis testing. We highly recommend biological and genetic testing and research on Cannabis to be sure the genetics are preserved via open source licenses and the availability of more effective medicines are created for patients. Afterall, when there’s such a limited number of approved conditions, requiring dispensaries to grow strains which contain the types of medicine patients need should not be an afterthought. In deed, it’s still not a requirement. Anyone with 10 CBD plants of a particular strain helpful to a particular condition will be the source of medicine for the right patient.
Attention Decision-makers, the word “recently” is used in the Cannabis industry to denote weeks and months -not years as you may be accustomed.