On Friday, I suggested in an e-mail to the LCB that all product that has been tested by PEAK Analytics should be pulled from the shelves of Washington’s State-legal Cannabis Retail Access Points.
Almost 2 full working days (and a Seafair Weekend) later, I have heard nothing back from them and have seen no indication that they have instituted a product recall.
I do not want consumers (or Patients) to get unduly worried, but the bottom line is that any product that has been tested by PEAK was not adequately screened for two of the 5 classes of microbiological organisms (nasty bugs) that are required in order for a product to be ready for sale in the regulated system.
As I am quite certain this represents an acute public safety issue, I fired off that letter to the LCB as an “emergency”, using the best estimates of exposure risk I had available.
That letter summarizes my rationale for calling out the acute public health risk posed by PEAK-tested product currently for sale that the LCB seems to have missed.
I have spent much of the past 48 hours re-assessing my risk estimates using the new traceability data. I will be updating my estimates of risk and sending them to the authorities in the next day or two (and likely posting here on HI-Blog).
The good news is that my quick estimate that 10% of PEAK’s product likely should have failed (because their average QA failure rate is 10% lower than the rest of the industry) was too big (product can fail for many reasons). As the only problem the Auditor specifically dinged PEAK on was for two of their microbiological panels, it is the failure rate of those two panels that should be used in estimating how many people that consume PEAK’s product are likely being exposed to nasty bugs.
In the meanwhile, I would like to reiterate that you should ask to see the Certificate of Assessment pertaining to any products you plan to purchase from the regulated system. If the store cannot (or will not) supply that to you, you are (IMO) putting yourself at unnecessary risk buying from them, as you may be purchasing product that has not adequately passed QA testing and, hence, SHOULD NOT BE ON THE MARKET. If they can’t supply the COA, they likely don’t care too much about following rules that are intended to keep their consumers safe. That would lead me to suspect that they also don’t care too much about the safety of their consumers.
As one of my FB “friends” recently posted …. “I am a Patient, not a cash cow!”
If the store you are shopping at can supply a COA that corresponds to the product that you are considering, look at the lab that has done the testing. If it is PEAK Analytics, your are (IMO) putting yourself at unnecessary risk buying that product, as you would definitely be purchasing product that has not adequately passed QA testing and, hence, SHOULD NOT BE ON THE MARKET.
As it would appear that many stores are not yet able to produce COAs on demand (which is, by the way, against the rules and could easily result in punishment for the store), I have attached the following table for those of you who just can’t wait to purchase something in stores that can’t tell you who tested it.
While PEAK has done over 30% of all testing in the State over recent months, the proportion of product that they have tested falling into different product categories differs.
The following table shows you what percentage of the product tested in Washington during the first 5 months of this year (Jan-May) was tested by PEAK …. cut by product type.
In using this table, you are REALLY putting yourself at risk of buying PEAK product if you buy (lab unseen) product made from (or consisting of) lots of MJ-Mix, Kief, lots of Flower and (of particular note to Patients) Suppositories. The only nice news I can see in this is that, for those of you buying tinctures in this marketplace, PEAK had tested NONE of them during the first 5 months of this year.
Until I can get my list of outlier stores together (likely tonight) …. I hope you find this list of some assistance.
Again …. don’t freak out if you have bought and ingested PEAK-tested product. If you get sick, suggest to your doctor that you MAY have been exposed to Coliforms and/or Enterobacteriaceae.
If you really must purchase PEAK-tested product, I wish you luck. Life is, in many ways, a crapshoot.
How you choose to play your odds is on you.
Here’s the list of how much of each product type PEAK has tested this year.
Be safe. Peace, love and (non-PEAK-tested) dope.
What is interesting about the % of product types chart above is that the ones that Peak has a majority market share of are the product types that have higher chances of microbial failure.
I did not know that …. although that would explain some of the ratios I’ve been seeing (was trying to reconcile them with the admittedly incomplete information in the RG-Lee Audit report).
Thought you might be interested to know that I’ve also looked at the Potency data (mainly flower, but I’ve looked at all product types tested) for each of the first 5 months of 2017. I am increasingly curious to see what I get back regarding my RG-Lee public record request … as PEAK’s numbers look pretty darn consistently above average. Have also identified a lab or two that is also displaying higher-than-average Cannabinoid levels. I wanted to get that baseline done so I can do some apriori Ho stuff in anticipation of the data that will allow me to assess the migration of PEAK’s customers in August and September with a bit more power (and October, if they are still suspended).
Wanna bet the LCB, in a fit of desperation realizing that they are hurting people, arranges to have RJ-Lee quickly re-certify PEAK so that “it is no longer an issue”?
That would seem so Orwellianly appropriate for them.