I just sent the following e-mail off to the LCB Board members and some key Staff. If any of you know Governor Inslee’s e-mail, would you mind either forwarding it to me or forwarding the following on to him (his website does not list an e-mail contact).
The below, I believe, speaks for itself.
In the meanwhile, PLEASE, if you value your health, DO NOT BUY ANY PRODUCT THAT HAS BEEN TESTED BY PEAK (until such time as RJ-Lee says they are good to go, that is).
If I had any such product, I’d take it back for a return and refund. Of course, I do not have any such product. I guess that is the nice thing about knowing who tests with whom and where specific suppliers can be found. I’ll be posting a list of PEAK-heavy stores on HI-Blog this weekend.
e-mail to LCB follows:
Dearest Members of the Washington State Liquor and Cannabis Board:
According to recent media reports, your Agency received a report from RJ-Lee in the past two or three weeks which recommended that the Laboratory Certification for PEAK Analytics be temporarily suspended.
I would like to commend you on acting on their recommendation to stop PEAK’s dangerous output from continuing to compromise product being tested before finding it’s way into the retail marketplace..
I would also like to point out that your apparent failure to institute a state-wide recall of all PEAK-tested product currently on the shelves of Retail access points stands grossly in opposition to the Vision, Mission and Goals of the organization you lead.
While I am hopeful that you are simply waiting to gather more evidence of PEAK’s lack of proficiency before doing the right thing, I realize that your organization is not staffed with Scientists and it is possible that you do not realize that your willingness to allow Washington consumers (and Patients) to be exposed to nasty microbial organisms is highly likely to have already harmed and quite possibly will have already killed consumers of Washington’s State-legal Cannabis.
This note serves as an attempt to, respectfully, educate you about the safety ramifications of your apparent willingness to allow consumers of State-legal Washington Cannabis to continue to be exposed (in very large numbers) to known pathogens in the Cannabinoid-containing products you regulate. I would like to emphasize that these pathogens are not allowed above defined threshold levels in those very products.
To put it in a way that not being a Scientist should not compromise your ability to understand:
There are 5.2 million adults in Washington.
Approximately 1 million of them are shopping in Retail Access Points to get at least some of their Cannabis.
Over the past two weeks, approximately 750,000 of those consumers have likely purchased product from a Retail Access Point.
Given that PEAK Analytics accounts for approximately 30% of testing volume done in the market (expected current range is between 27% and 33%), that would suggest that at least 225,000 Washingtonians have likely purchase product tested by PEAK since you became aware of the deficiencies in their operations brought forward by RJ-Lee.
Now … in the audit report (and consistent with information I published in late March on HI-Blog at www.highintelligence.org) , it is clear that normal QA fail rates are around 12%.
PEAK was found to be failing less than 2% of the product they tested.
That leads to the fairly easy conclusion that somewhere around 10% of the product that PEAK has tested is quite likely (I would argue highly likely) to be contaminated with at least one of the many nasty microbes that RJ-Lee concluded PEAK’s slopping, non-compliant processes were unlikely to detect.
That results in a best-guess estimate (and, by the way, a pretty good estimate) that about 22,500 consumers of Washington State-legal Cannabis have been exposed to unacceptable and out-of-compliance levels of either “total Coliform” or EB (Enterobacteriaceae – which includes (but is not limited to) the disease-causing organisms known as Salmonella, Escherichia coli, Yersinia pestis, Klebsiella, Shigella, Proteus, Enterobacter, Serratia, and Citrobacter.
Although you are not Scientists (and you have none on Staff, as Staff are frequent to point out), you should know that these things are dangerous. They can harm people. They can kill people. If consumed by immuno-compromised or respiratorily-compromised Patients, they are even more likely to harm and/or kill.
By making the conscious decision to allow PEAK-tested product to remain on Washington’s Retail shelves, it follows that you have exposed approximately 22,500 Washingtonians to dangerous stuff that should not be in this otherwise relatively safe product. That is just in the past two weeks.
Some proportion of those people are highly likely to have been harmed by these products. Some may very well have died. Please note this is not hyperbole. Feel free to check out my credentials. Hyperbole is not a tool I frequently employ. Rest assured, I am not employing it here.
The harm and the ever-growing potential for death enabled by your failure to force a recall of PEAK-tested product currently on Retail shelves will continue and expand until such time as you yank that PEAK-tested stuff (ALL of it) from the shelves.
This is an opportunity for you to do the right thing, even though it is a difficult thing and an inconvenient thing.
It will not be easy on Retailers that stock PEAK-tested product (which is, basically, all of them). It will not be easy on Wholesalers that have been using PEAK for their testing. It most certainly will not be easy for those many stores that fail to follow your rules regarding having product COAs on site and available for customer inspection.
Know that failing to pull that product WILL harm and will very likely kill some of the consumers that rely on you and the good women and men of the WSLCB to ensure that the cannabinoids they ingest are, as defined by WAC and RCW, safe.
Every day that PEAK-tested product is available for sale represents thousands of instances in which further inaction on your part will result in harm to those you are charged with protecting.
Late in my career, I had the pleasure of working in a facility that had once housed Union Carbide’s Main Corporate Campus in Connecticut. Every time I sat in the executive conference rooms of that beautiful facility, I thought back to the decisions made by the Executives (and the Board) of that organization as they dealt with the unfolding tragedy in Bhopal, India and wondered what in heaven’s name was going through the minds of those people..
Union Carbide, of course, no longer exists as an independent world-leading organization.
The decisions you make regarding the issue I have attempted to articulate to you in this email will, I suspect, largely determine the legacy that you each carry forward after leaving your current Board positions. They may also determine the future of the WSLCB. I hope you choose wisely, and with the safety of Washington’s Cannabis consumers at the forefront.
This is an opportunity for you to do the right thing and to promote safety and health in this State.
It is also an opportunity for you to show your true colors.
Personally, I am hoping that those colors look more like a Seahawk than they do a vulture.
Dr. James MacRae (Scientist).
I’m the guy that was in the audience holding up his hand(s) for 15 minutes without being recognized during this week’s CAC meeting … At the time, I was going to correct one of Board Member Hauge’s false suppositions underlying the concerns he expressed regarding the existing plant canopy. Please know that I mentioned my concern to your chief examiner following the meeting. No doubt he has corrected you himself.)
Should you wish to discuss this, you have my number and e-mail address.
You may be interested in some of the things I plan to post over the next few days up on HI-Blog.
I do not know if the WSLCB monitors relevant traffic on Facebook, Twitter or Instagram regarding things relevant to your mandate. If not, you may want to task someone with that.
I suspect that discussions relevant to this issue it will be heating up on the internets significantly and soon.
Finally … if anyone knows a good e-mail for Gov. Inslee, please forward this on to him. His website does not include a contact e-mail.