Aug 18, 20215 min read

Lab Lessons and Lame Legislation: Failures in Regulating CA Cannabis Testing (BCC Fact Sheet)

Updated: Feb 28

Cannabis Testing in CA has Failed

Boy, do we ever know how to mess a good thing up before it even begins... Things are really messed up in the world of weed, as though a 1980's understanding of cannabis was used to create guidelines for California's cannabis testing today. 100 years from now we will acknowledge the progress made, but wish many of the mistakes and misdeeds baked into the legislation, were avoided in the efforts to regulate and legalize. The cannabis industry is being designed like any other business in corporate America, where corporations dictate laws and regulations.

Alcohol in the Hash?

I've received plenty of DM's over the last several months asking the same thing: "Should there be isopropyl alcohol in my solventless products?" and the answer is a resounding no! Why are these C.O.A.'s (Copy of Analysis) turning up with isopropyl alcohol in solventless products? An early blunder in legislation and testing is our answer.

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Little Faith in the Current Testing

The answer came to me while investigating some dirt fed my way a few months back, that I ultimately decided wasn't valid. A COA or copy of analysis showed ISO alcohol in a hash rosin product. What ensued however, was a two hour telephone call with the head of a major solventless brand and the head lab chemist. There was only one reason to include the lab in this phone call and it was to take the blame for the mistake. The isopropyl alcohol testing positive on C.O.A.'s for solventless products is the result of sloppy lab work and a failure to implement standardized testing minimums. Trace elements of alcohol were accounted for by the lab's use of disinfecting wipes or cleaning products. You would think a scientific testing facility would understand this and prevent such a simple mistake from happening, but get this. I was told, the chemists come from other fields and are learning how to test with different materials/consistencies as they go.

Common Sense too Common

Well, why not retest the sample and update the results? A lesson learned during the 710 Labs Gummy fiasco, trace elements and positive results can be retested, however the C.O.A. is not updated. Regardless of the reasons for false positives, and regardless of the results of re-testing, the original C.O.A. is the only one that remains on file both in dispensaries and online through the B.C.C. What looks like an effort to prevent manipulation after testing, has led to incorrect results shown to consumers. It took a good moment for this to fully sink in. This failure to inform consumers or update COA's on file is a problem created by legislation.

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The BCC Fact Sheet

While I expected to be searching for a needle in a haystack reading legislation and trying to find this in writing, I lucked out as the B.C.C. fact sheet made things pretty clear. "A licensed testing laboratory shall not amend any COA after issuance" and in case it wasn't clear, they repeated the line in the next column of their one-page fact sheet!

BCC regulatory information quotes. — Mentioning No Testing Changes Twice in the One Page Fact Sheet From the B.C.C.

I really thought this one would be difficult to spot, as most bureaucratic legislation tends to be. Contradiction to common sense isn't usually this blatant, but then again, what's more blatant than a century of plant Prohibition based on lies? (Maybe the acceptance of alcohol, despite it's poisonous reality). Anything that fails testing is "quarantined," but for positive results that remain under acceptable levels, retests are never seen by consumers. So, despite the lab's admission, taking responsibility for the false positive with retests to prove it, the COA's on file continue to show the contamination to consumers. Apparently, even false positives and lab error do not qualify as "remediation, necessary to supersede the original test results," however I'd hate to find out what these remediation tactics actually imply .*

Punished For Doing More

The amount of ISO alcohol contained within the test result was so minute that other labs across the state wouldn't have registered a result. I was pretty shocked to learn that there are no requirements or regulations for LOD or LOQ (or else they need to be significantly lowered). The LOD, or limit of detection, is how small or how little of a substance is required to show up on the test. This lab happened to be running advanced testing that shows far more than the BCC requires for legal sale. But instead of being rewarded for extensive testing with LOD/LOQ less then 0.10mg, it came back to bite him in the ass. Here's another facet of the Cannabis industry provoking quantity and profit over quality and understanding. When asked what the remedy was, hoping the product sells out and preventing it from happening on the next batch (despite it not being the hash makers fault or responsibility) was the only answer. His hands were tied with a clean, quality hash product, tainted by lab errors and legislation.

Failure to Standardize Lab Testing

Without regulations for the Limit of Detection, anything that tests over that limit, but under the limit of quantitation, simply reads <LOQ. It shows that some amount is present but not enough to show the exact numbers until it reaches the LOQ. When we are talking about trace amounts of terpenes or cannabinoids and in one gram products, trying to compare them without standardized levels of detection is impossible. In order to understand what we consume, standardized levels of detection seems like it would be the place to start. And people wonder why I pay the tests and their results absolutely no attention anymore. I won't even get into the projected range of error for each and every test.

To Top Off the Lunacy

Just to top the non-sense off, requesting to show only what was required by the BCC is no longer an option. Choose to only test what is necessary and those results can happen, but asking for more has a "no-going back" clause. Everything's incentivized against quality products and precision. "A COA must accurately reflect all testing, even if ... it was not required by BCC regulations." Screwed again for doing more. Yeah, its required to show all of the extensive original testing, just not any of the accurate retests to provide consumers with facts.

While these may seem like a few rare occasions, it builds on a long list of reasons to be wary of lab numbers and results. The reasons for skepticism just continue to grow...

*(UPDATE: REMEDIATION ARTICLE IS WRITTEN HERE)

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