PSA1 – Potency in the Regulated Market

PSA Announcement – For the Patients
June 22, 2016
Poem: The Grass is Always Greener
June 30, 2016
Show all

PSA1 – Potency in the Regulated Market

For my first Patient Service Announcement, my goal is to provide you with a vetted listing of some “High-THC” and some “High-CBD” flower options that were tested between January and April of this year in the Washington’s regulated Cannabis market.  This market (as discussed below) forces the consumer and patient to rely more upon what the label says about the bud to make informed purchase decisions than was necessary in the access points that are now all but gone.

In just over 5 days, the destructive creation of WA’s “newer and better-for-you” medical system will be complete and Washington’s Medical Cannabis Patients will finally be Protected by the State.  The State will be tinkering with this market for years, no doubt.  I sincerely hope that not too many of you suffer unduly (or die unduly) before they get it right.  I also hope that the hypocrisy of paying a 37% excise tax on your medicines does not take too much of a toll on you or on yours.

Late last year, I published a series of posts on HI-Blog that critically assessed the quality assurance test results and the potency test results being reported by our Cannabis testing labs.  Those 5 or 6 posts are all categorized on HI-Blog under “Compliance” and “Testing”.

By publishing the following lists of specific strains being brought to market by specific farmers that show high cannabinoid levels AND were tested by labs whose results I have no reason not to trust, I hope you are able to better evaluate some of the many, many, many quality offerings that the regulated stores have to choose amongst while stocking their shelves.

I intentionally withheld data produced by the “Friendly” labs from these lists.  I believe it would be unethical to include them on a listing intended for patients.  I also withheld data from labs that had performed too few tests for me to reliably characterize their level of Friendly-ness last fall. (added notes June 26: the 4 labs with data “too thin to tell” were: Phytalab, True Northwest, The Werc Shop and Dragon Analytical …. I have not yet made any judgement of them other than they likely need to have increased their testing volume since last summer.  I have, however, seen signs of inflationary potency reporting in at least one of the 3 that remain in business.   Phytalab is no longer serving this market in Washington.

Finally, I withheld data from the new labs that began operations after I had completed my lab assessment work last year, as I have not yet made a systematic effort to characterize their reported results.

I was torn whether to report high-cannabinoid product tested by the four new labs.  I’ve seen pretty obvious signs that one of the new labs may be having some early problems with their testing and/or reporting that is leading to a surprising number of very-high (but theoretically possible) cannabinoid levels.  As I have not yet performed a complete assessment of the new labs (nor have I quantified just how unlikely this pattern is by chance),  I opted to play “fair” and exclude data for all four of them.  My regrets to the new labs…. but the behavior of many of your peers has put me into a “you must earn my trust” mode for your market.  I appreciate the few interactions I have had with the newbies.

With those caveats, here are the lists, drawn from results reported by Laboratories that were originally classified as “PRAGUE” (a good thing) and excluding results reported by labs that were originally classified as “Friendly” (arguably not such a good thing).




In excluding results from the “Friendly” labs, I have, effectively, excluded brands with labels that imply “high THC – buy me” and/or “high CBD – buy me” but which have a higher-than-normal likelihood of doing so inaccurately  (in my opinion).  I do not believe it appropriate to point anyone in the direction of anything done by these labs.
Farms missing from these lists may well be producing high-cannabinoid product(s).  No blame is intended for or deserved by the farmers or processors using the Friendly labs.
No blame is intended for or deserved by the retailers carrying products tested by the Friendly labs, either.
Such farmers, processors, and retailers will simply not be highlighted or recommended to patients on this blog.   I do not, at this time, believe that product tested by these labs represents an appropriate choice for patients wishing to make informed product purchase decisions.
Should the labs be subject to robust quality assurance oversight in the future, I will re-evaluate my position.  Ultimately, we all benefit from having PRAGUE be the norm in Cannabis lab testing.  I hope we get there.  Soon.
You may all blame the behavior of the Friendly labs between June and August of last year for the “incompleteness” of these lists.  I know that I do.  Such behavior betrays the very spirit of legalization and undermines the primary advantage of a regulated market (product transparency on both product quality and potency).
Why knowing what you are buying is important.
Patients who wish to continue medicating with Cannabis or with Cannabis-infused products and/or extracts in Washington State are about to be re-criminalized or forced to source their product from regulated access points.  On the day the current market ends, these legal access points will be limited to regulated retail stores that either do or do not carry a Dept. of Health-sanctioned medical endorsement.  There is an “out” in which a small number of people can band together and grow a small number of plants …. But check out the rules before depending on this option.  I doubt there will be many of these operating in the near future.
Retail access points with valid medical endorsements will generally have staff with additional training relevant to Patients.  Those staff will not be allowed to discuss Cannabis as medicine in the context of specific medical complaints and/or specific expected outcomes.  This is because such things are regulated by the FDA  and the FDA takes their role as Pharma’s enforcement arm very seriously.
Welcome to a world where your budtenders – even those with training in the area (let alone those with years of relevant medical care-giving experience) are not allowed to speak in such terms within the regulated system.  “Medicine”, “cure”, “alternative-to-traditional-medicines-for-this-disorder” are examples of terms, phrases and sentiments that they cannot legally utter in the presence of patients searching for meds in regulated stores.
As a result, you will likely be  more dependent upon your own instincts and product experience in selecting those regulated products that might best meet your medical and/or other needs.
By all means, find budtenders that you trust.  Find vendors that you trust.  Find FARMERS that you trust.  When they have earned your trust, reward them with your business and – to the extent you can – your loyalty.
Until that trust has been earned, you are left with your instincts and experience.  You are also left with a world where your direct interaction with the “bud” is limited largely to being able to see it through a transparent barrier.   You MAY be able to smell a sample in a sniff jar, but you sure can’t touch it or interact with it as much as you may well have been able to way back when medical dispensaries were allowed to service Patient needs.
The good news (in case you have not yet ventured into a retail store) is that you are likely in for a pleasant surprise with the sheer number of different brands and products and strains and strengths and things that are available for purchase.  All with a fairly large degree of variability in pricing, in quality, and in suggested value.
Don’t get me wrong here.  You are very likely not going to find some of the specific products that have become a usual part of your medication regime.  You will find lots of options, however.  With any luck you will be lucky in replacing your meds in the stores … or perhaps one store …. perhaps one store half way across the State that is not allowed to deliver.  Perhaps.  I wish you luck.
The primary tool that the regulated system gives you to discriminate amongst this plethora of potential medicines is a regulated and well-defined label that is chock full of alleged facts about the stuff inside the package.
Many of the consumers in the retail “recreational” market appear to be using the Cannabinoid Potency information required to be on the product label as a significant factor in determining their purchase decisions.
For flower, trim, joints, cones and extracts, the Potency data take the form of reported percentage levels of CBD, THC, THCA and “Total” (which is now defined as totally decarboxylated THC – or — THCmax = THC +( 0.877*THCA).  Edibles (liquid and solid) report the milligrams of these cannabinoids that are present per dose and the number of individual doses contained in the package  (solid doses are all individually packaged).
When people evaluate a product’s “quality” as being dependent upon it’s “Cannabinoid potency”, they almost come across as being a bit confused.  Such thinking contributes to a naïve form of product purchase decision-making which seems to work for many people.  Eventually, they will learn.
It is almost ironic, then, that I am of the opinion that many (if not most) of the potency results being reported in the State today are likely not accurate reflections of reality.  Specifically, I believe them to be systematically over-reported by labs pandering to what naïve consumers demand.
Effectively, such consumers believe that, for “$13.00 per gram – out the door-all in with taxes and fees included”, it is better to get Everclear than it is to get Grey Goose.  More alcohol for the buck, you see.  Better ROI.
Except for the fact that alcohol testing standards (and product liability concerns) pretty much ensure that alcohol levels are reported accurately on the labels of alcohol products.
Due to the RELATIVELY  SAFE NATURE OF CANNABIS, there is no such virtuous cycle of liability-avoidance operating in the State-legal Cannabis Market (which makes the market dysfunctional … but that is another story).  If an inaccurate label leads to you ingesting too much (or too little) “THC” that is not likely to harm you to the same degree that mis-dosing alcohol can.  Unless, of course, you are driving, boating, flying or running with scissors after having medicated.
Personally, I like the idea of being able to dose my medibles with decent precision.  I might, that way, eventually learn how much I actually need to achieve certain desired results while avoiding potentially unpleasant over-dosing.
In that context, I hope that these lists of high-cannabinoid flower help you to find some products that fit the basic profile of what you need.
I produced these two lists to help you find quality WELL-TESTED product.
I hope this helps you identify producers that seem to be producing “potent” product (per the cannabinoid “potency” levels, at least).  While I don’t like to confuse potency with quality, anyone actually hitting numbers such as those listed in the tables is likely producing some very fine product on dimensions other than just cannabinoid levels.
I don’t have much data on terpenes to help here …. and you often will not either.
Perhaps, if thousands of you begin routinely asking retailers and farmers to provide terpene profile results on their products,  the market will respond.   That is one way to get folks to begin testing for terpenes.  Doing so would cost a bit more, but it would be a huge service towards educating patients and all consumers and, as such, a huge investment in the future health of this market and of us all.
I expect higher-end producers to begin voluntarily reporting terpene levels in the near future.  I, for one, plan to ask for which products a retailer has terpene information available.
Market demand is a huge force in shaping a market.  If patients decide to embrace this regulated market en masse, they will represent a big part of that demand.  YOU have a great deal of potential power.  Try to use it wisely and responsibly as we nurture this young market along.
The  labs that were behaving in a “Friendly” manner last Summer now represent a large proportion of the testing being done in the Washington market (although their share has shrunk noticeably over the past 4 months).  As a result, the lists I’ve provided to you today will be incomplete.
There will be lots of high-CBD products and high-THC products being produced and lots of stores stocking such products in abundance that will not be included on the lists I just provided.
There will be lots of farmers producing such products that will not be on these lists, either.
That is, simply, because through whatever market forces or decisions or fates or coincidences happened, they are either (as a farmer or processor) differentially using “Friendly” labs to produce their test results, or they are (as a retailer) differentially stocking products that were tested by “Friendly” labs on their shelves.
I regret that these lists represent a sampling of less than 25% of the flower being tested in the State.  They exclude a number of farmers that I truly believe to be good-to-great farmers producing good-to-great products.   I cannot, however, bring myself to reinforce what “the Friendlies” appear to have been doing.  Ignoring their results is the best thing for me to do.  It is the best thing for me to do, particularly, in a PATIENT Service Announcement.
Be safe. Be well.  Be happy.  Be medicated. Be regulated.
Most importantly, be well informed.
…and stay tuned for more PSAs at this site over the next few days.
Dr. Jim






  1. 42otto says:

    I would love to see that head cheese strain from emerald evolution tested by steep hill. 35%+ thc seems a little bit fishy.

    • Jim MacRae says:

      Otto — my regrets on taking so long to reply.
      I appreciate your skepticism, although mid-30s do seem to be achievable by some strains.
      As it turns out, you may well have been correct in this case for a different reason (other than your very good common sense)

      I believe that a few of the cannabinoid results in one (or both) of the tables in this article were inflated by an assumption in my code that has been shown to me to no longer be valid.

      One of the labs in the State that I trust and that I believe is doing a positive service to the industry (Analytical 360, in case that helps) has given me some specific feedback on lots I mentioned in this article’s tables. A360’s feedback allowed me to find the issue in my code(relating to an assumption that there would only be one record per business in the location table of the traceability database). Now, I’ve fixed the code and I’m kicking the tires of the new output hard before re-releasing. The nice thing is that only a very small number of records were impacted. The bad thing was, I was wrong.

      I truly thank you, other sceptics that reached out to me, and to the Lab that had both the awareness and decency to rapidly identify a problem in the information I created and then took the time to contact me and explain what they were seeing.

      I love constructive criticism — particularly when it is justified. Such criticism makes me better.
      That fact does not make me blush any less when I am shown to have been wrong, but I do appreciate it.

      A sincere thank-you


  2. google says:

    Thanks on your marvelous posting! I genuinely enjoyed reading it, you may be a great author.
    I will remember to bookmark your blog and definitely will come back
    from now on. I want to encourage one to continue your great work, have
    a nice afternoon!

Leave a Reply

Your email address will not be published. Required fields are marked *