Note: Shortly after I post this, I’m going to e-mail each of the labs certified for Cannabis testing under I-502 with a link to this blog. I will solicit their feedback, and am going to try to set up a “behind the scenes dialogue” with them in order to reduce the likelihood that some weird pattern I see in the numbers is due to a completely normal, expected artifact of how the testing and/or reporting of testing results is conducted.
I do not want to be doing a disservice to either the lab testing sector or to individual players within that sector. I am not an expert in testing for moisture or foreign material or bugs & germs or fungi & molds or residual solvent or cannabinoid levels (I guess, truthfully, I have some experience with the last one). I am, however, reasonably adept at detecting odd patterns in data.
It seems only fair to give the Labs a chance to set me straight if I’m seeing things as bad that are really OK and explainable once one knows the inner secrets of the lab testing kingdom.
I’ve taken a close look at the lab results data for all tests that have occurred through August of this year, and will report some observations regarding moisture testing in this post.
I intend to publish my LAB RESULT work in a series of postings over the next couple of weeks, and feel that the time is ripe for such work, as we move into the final phases of both the LCB and DOH rule-making that will impact the industry, and the tests that will and/or will not be required of industry participants in the future.
I have been crystal clear for at least the past year that it is my firm belief that Proficient/Reproducible/Accurate/Good/Unbiased/Empirical (PRAGUE) lab testing is crucial to the health and development of the State-legal Cannabis industry.
It is an issue of “fair weights and measures”, and it is an issue of customer assurance that the “quality” of the product in the regulated market will be better known (and, hopefully, “better”) than that from the other channel of Cannabis acquisition (hereinafter referred to as “The Darkside”).
At its core, this is the ONLY advantage that the regulated market has over The Darkside (other than relative levels of legality and “Revenuer-focus”).
In the short term, costs of production will be higher in the regulated market. Tax rates are higher in the regulated market. One must show ID to get product in the regulated market. One must be entered in a database to get medical product in the regulated market. One must also subject oneself to being filmed in order to get product in the regulated market. One can’t even reliably SMELL the product in the regulated market before purchase.
Aside from a high level of assurance that retail store employees are not packing firearms during transactions, I see little advantage to the regulated market other than its labelling and quality assurance testing.
Hence, I worry more than I likely should about the importance of having PRAGUE labs and lab results servicing the needs of this industry and its consumers and patients.
To that end, it is my null hypothesis going into this work that the labs are all PRAGUE and the labs will all show similar patterns of results. Their results will reflect reality, and they will (when appropriate) follow the rules of statistical probability that tend to govern non-biased measurement systems.
Enough touchy-feely opinionated intro — on to the initial results of my investigation into lab results.
To answer the question posed in the title of this post, I’d be willing to bet that the regulated bud you are currently (or recently have been, or might soon be) smoking/vaping contains less than 15% moisture.
That’s an easy one to answer, because anything above 15% FAILS the test for moisture and hence, does not make it to market (unless it passes a re-test, I’d imagine).
It is also easy to answer, because the current RATE of tests failing the moisture test is less than .05%.
There is nothing wrong with that, but looking at the trend across the 15 months of testing (broken out into 5 consecutive 3-month “Quarters”), it’s fairly clear that the initial failure rate of 2-3% has rapidly and reliably declined.
On one hand, it looks very much as if Washington farmers are learning how to adequately dry their flower.
On the other hand … and this is the part where knowing EXACTLY what the testing protocols entail would be handy … there is an odd aspect to the overall distribution of reported moisture levels that I’ll get to in a moment.
Without knowing EXACTLY how this testing is done, I’m going to imagine that a grower (or processor, or producer/processor) pretty much dries their bud down to a level that makes sense to them (given their experience, and/or what “the books” say).
For the most part, this will result in bud that is somewhere around X% moisture (where “X” is a theoretical “ideal”, and values above and below X will tend to occur with less frequency the further one gets from “X”). Some will be a bit wetter and some will be a bit drier. A small number will be much drier and a small number will be much wetter.
The fact that being TOO wet (over 15% moisture) causes a failure would lead me to expect a biasing of the distribution of testing results to be BELOW 15% and, indeed, to avoid the 15% level (and above) like the plague that a failed test result should be viewed as being.
There will likely be some very low moistures and some very high ones, but not too many of either (I’d imagine very few people want completely dried flower and that no-one wants moldy goop drizzling out of their mylar package upon opening).
Before I looked at the data, I actually expected to see a fairly sparse distribution of results above about 13% … on the assumption that most cures were likely to be shooting for the 8-12% range of ultimate moisture (just a guess …the key point being that I assume most growers would shoot for a reading of at least a few points BELOW the 15% cut-off).
During the most recent quarter (June, July and August, there were 8,511 moisture tests reported in the State Traceability system. Only 4 of these were reported as exceeding 15.0% moisture content (for a failure rate of less than .05% (or less than 1 in every 2,000 tests resulting in a failure).
That’s a very small number, and not something that is generally amenable to powerful statistical examination around “expected rates of occurrence” and related concepts.
However, the symmetry (and density) of a distribution around an important threshold (like a 15% failure level) IS amenable to investigation using all kinds of tools (including my favorite of flipping a coin – but that is just because I like money so very much).
Here is a scatterplot of the moisture test results reported over the past 3 months:
The two things about this chart that I find the most interesting are the “spike” observed around 6% moisture, and the “cliff” that occurs at exactly 15.0% moisture.
The “spike” is suggestive of the “normal-like” curve that one might reasonable expect to see in an efficient system where there is, truly, an “optimal” moisture level that folks are shooting for.
Based on these data, I’d now guess that this “optimal” level is probably somewhere around 6-7% . I’m assuming it is a bit above 6%, as sensible growers would bias their results down a bit in order to avoid a “too-wet and failed” result.
The remaining question is why there appear to be so many moisture results coming in between (say) the 10-15% range, particularly when there are virtually none showing up ABOVE 15%.
This issue becomes more clear, when the distribution of values between 14.1% and 20% is summarized
Given that the grower DOES NOT KNOW the moisture level of the product before submitting it for testing, why would there be 91 observed values falling in the range of 14.91% – 15.0% moisture, but only 4 results with values over 15%? (update note from Jim: I have been challenged on this point by a grower I trust … namely that some growers DO, actually know their moisture levels before submitting samples … not sure if they know it down to 1/10% precision, but if this is true it tempers my concern a wee little bit).
It’s kind of like flipping a coin 95 times and getting a head (or passing the test) 91 times.
The chances of that happening if the coin was fair (i.e., if being below or above 15% were equally likely to occur when looking at values between the ranges of 14.91% and 20%), are really small (the proverbial “p” is less than .00000001).
In this example, the “coin” is clearly not fair. Noone wants results over 15%, and virtually no one is getting results over 15% any more. The “luck of the draw”, however, for those that are REALLY REALLY Close to 15% is very very very strongly favoring a passing grade for such samples. If each test REALLY were a coin toss and we believed the coin to be one that would normally come up “heads” 9 times out of 10 (90% of the time), we would STILL see 91 “heads” out of 95 flips only 2.18% of the time. …. Still a statistically unlikely pattern of results to see … even with a coin biased 90/10 in favor of seeing such biased results.
There should, IMRO (in my resulting opinion), be more bud testing at above 15.0% than is currently being reported.
I’m thinking about writing lyrics for a song to be titled “Where has all the wet bud gone? (sung to “Where have all the flowers gone?” … I’m glad Pete lived to see Legal Cannabis in the US of A)
The first verse would likely go something like:
“Where has all the wet bud gone?
No Doubt Oregon
Where has all the wet bud gone?
My personal belief – wet bud is out there. You are smoking it or have smoked it or, likely, will smoke it at some point in the future if nothing changes in how we hold growers accountable for their product and labs accountable for the results they report in exchange for being paid to run the quality assurance tests.
You just don’t KNOW that you are / have /may be smoking it.
I picked moisture to start with, as it seems pretty much innocuous. It is not like high THC levels driving price, no sirree. It’s pretty innocuous. Except that failed bud cannot be sold as flower.
It is also important to remember that moist bud coupled with extended shelf time and/or the right levels of heat WILL promote the growth of mold. Mold can hurt. Mold can kill. Mold is bad (except when on cheese or producing penicillin).
In the world that existed between June and August of this year, virtually no flower samples failed their moisture tests, yet the reported test results themselves almost cry out for there to have been more failures. When one sees no failures, one cannot help but wonder about the value of even conducting the tests (much like I feel about airport security protocols in the USA).
Everyone in this industry … or at least anyone wishing this industry to be all that it can be should stand up and take note of ANYTHING that compromises trust in the quality assurance results being reported for State-legal Cannabis in the regulated market.
If the regulated Cannabis market in Washington does not have meaningful PRAGUE Lab results, then it does not have a meaningful advantage over The Darkside.
I’d summarize the moisture results as being strike one against Washington’s State-legal Cannabis Lab Testing Industry. I’m not reporting lab-specific results here, but I AM looking closely at them and am accumulating a report-card for each test against which I am scoring the labs. When I have finished my analyses of all of the quality testing results, I’ll collate full report cards for the individual labs. I don’t know if I’ll publish those here — I guess that depends on what they look like.
While it is clearly good business practice to produce good results for one’s clients, the goal here is not a passing grade. THE GOAL HERE IS SAFE PRODUCT OF KNOWN QUALITY.
There is a downside to systematically under-reporting high moisture results, and that is having people (including patients) more likely to be inhaling or otherwise ingesting molds and mildews and related nasties.
Killing for profit is so un-Cannabis. If that is what is happening here, let’s see a stop to it now.
Then again, if I have missed something about how testing is done or if my logic is otherwise faulty, and these results are, actually PRAGUE, then my apologies in advance to the Labs.
If I got something wrong, please post comments on this posting to that effect. Let me know what I got wrong. If I buy it, I’ll re-do the analysis and report on the “correct” results.
If I did not get it wrong (or if I pig-headedly adhere to the belief that I did not get it wrong), then I hope you all look forward to the remaining posts in this series (and possible mainstream articles that flow from this work).
Over the next few weeks, I expect to be reporting on Foreign Matter, Residual Solvents, Microbial Screening (Bugs & Germs & Feces), and (my personal favorite) Potency. I’ll leave potency for last. I suspect that it will be hard to keep quiet about which lab is tied to which results when I get to potency.