This one almost wrote itself, yet the words are often hard to get started on a topic so groundbreaking, its unmentioned prior. We have written about and discussed the disastrous start to lab testing and regulation, with a lengthy list of complaints, however, this article will look at the legislation surrounding "remediation" practices to show everyone what the regulators saw fit for the new cannabis marketplace. Once again, it's far worse than imagined...
Remediating contaminated cannabis
A long list of unthinkable items have become the unfortunate realities of the new cannabis market. Adopting strategies from Big-Agriculture benefited the plant in a long list of ways during the last decade, but as we move into the next phase of modern retail cannabis, many of the methods shared with other agricultural fields come as major disappointments. Perhaps none are more revolting than remediating contaminated cannabis crops with the use of chemical solvents.
Contamination < Remediation
Adding to our long list of concerns and reasons to avoid solvent extractions completely, is their ability to hide contamination. Peer into the current-past of cannabis extraction and realize a rude awakening: We have probably been consuming contaminated crops... for years.
Any cannabis failing state laboratory testing as outlined in Article 5 of the DCC regulations, may employ a range of remediation methods according to Article 6. Article 6 § 15727 item A states, "A cannabis or cannabis product batch that has been additionally processed after failed testing must be retested and successfully pass all the analyses required under this chapter". Item B mentions that the "business involved in distribution shall arrange for remediation of a failed cannabis or cannabis product batch." You heard it here first, going all the way back to Color REMEDIATION Columns and our article on CRC.
This one puts new meaning into the idea of a corporate run, corporate owned, and corporate regulated industry, with little regard for quality or the consumer. Just so we're crystal clear, this says that cannabis that has failed testing and cannot be sold, can be "remediated" and then retested before it officially fails. With flower prices at a historic low and more cannabis than we know what to do with, the pettiness and greed required to squeeze every last cent out of rotting cannabis-biomass is absurd. Cannabis, meet capitalism, your new worst enemy.
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Cannabis, meet capitalism, your new worst enemy.
If said remediated batch fails testing after remediation, no worries, just try blasting it with butane again. Item D states, "A cannabis or cannabis product batch may only be remediated twice," only twice! "If the batch fails after the second remediation attempt and the second retesting," only then is it safe to call trash, trash. Truth truly is stranger than fiction.
Most likely a second failed test would lead to distillation, after the initial remediation attempt is made with butane. Basically any farmer whose flowers fail testing, can be fed along to BHO extraction and then retested. If it fails again, distillation will all but guarantee a poor product, but one that passes regulation, amazingly.
Reintroduction-Remediation
Much like distillate producers who pour terpenes back into distillate and think it's capable of an entourage effect, blasting contaminated cannabis with volatile solvents isn't an effective solution. It's not simply an issue of removing contaminants when those contaminates effect the plants ability to grow healthy and thrive, producing a limited potential of what the crop could be.
Bugs & Bags Tipped Their Hand
Some BHO makers tipped their hand on this one. If anyone remembers back in 2020, a close-up or macro shot of rosin bags were shown and next to the bag were bugs small enough to be pressed through the rosin bag and into the final product. It's just too bad that material of this quality would never be considered for solventless refinement (for a lengthy list of reasons both practical and regulated). With everything to lose, those partial to solvents were in desperation mode in the moment.
Wondering how anyone could see butane killing bugs as a positive aspect to BHO, rather than seeing the problem in the garden, the comparison fell flat. With no relation to solventless refinement, the post helped to reveal more about solvent extraction. It left an inkling that something really gross is going on in many BHO and distillate labs. Now we have the regulated proof.
Bulk Cannabis Biomass
It was no secret that moldy, mildew filled, pest-ridden, bulk-biomass is the usual victim of distillation, but to see it implied as a solution for contaminated crops, backs up everything said prior. Strangely enough, and despite a list of terms and definitions, the word remediation is neglected, allowing the process of remediation to be interpreted by other D.C.C measures. Measures like volatile solvent extraction, color remediation, and further distillation are implied (more on this as we make our way through extraction regulations in next weeks column).
Don't get me wrong, there will always be a space for distillates and BHO, but a proper place where consumers understand the utilitarian nature of remediation and solvent extraction to provide some form of THC to the indigent.
An Impersonal Industry
After solvent extraction became relatively organized and regulated in Colorado (circa 2014) consumers came to the realization that their wax or shatter maker is never the one growing the plant. A sense of camaraderie, a spiritual connection between grower and smoker was severed. An impersonal feeling arose with yet another middle man buying from someone else and creating a new area of industry with solvent extractions.
A White-Labeled Domain
While it's known and accepted most extractors and hash makers outsource their material, what wasn't understood was that this method applies to other areas of cannabis. For example: not only do extractors outsource their material, but so do most of the cannabis flower brands! This may come as a major surprise or none at all, depending on your knowledge of the situation. A specialty position of hash maker is understandable, but buying flower low to repackage and sell high sounds like... the black market. Just like big agriculture, the same farm and farmer often supply a long list of brands. Just the latest corporate-style bummer and disappointing reality of retail cannabis.
Wrap Up
We have reached and surpassed the limit of outside knowledge with cannabis being so incredibly unique from almost all other agricultural plants. Furthermore, the latest methods of solventless refinement require all new testing and research.
With no way to verify or confirm regulations are met (and no oversight), consumer's are at the mercy of a declining market, with too many players, and far too little competition until recently. Remain highly skeptical and avoid products capable of coming from this kind of a mess. The same message holds true from 2019-2022: go solventless or sink.
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Not to mention what is going on in the edible market. Fake (D8) THC gummies with Heroin and Fentanyl, marketed as 'Organic' and 'Made in USA' actually from (surprise): China. Currently being sold, untested, as a nutritional supplement. Same with Mushrooms. Sad.