S.H.I.T.B.A.G.S. – Be Wary of Deceptively-labelled Products in the I-502 / SSB-5052 Market

On Dec 11, the Washington State Liquor and Cannabis Board (WSLCB) announced the suspension of PRAXIS Laboratory in Centralia because they had been found “to have falsified testing data to provide high tetrahydrocannabinol (THC) potency results for more than 1200 samples of cannabis.”

Further, the WSLCB informed the public  that “During the investigation the lab owner attempted to destroy evidence of falsified data in an effort to obstruct LCB’s ability to conduct a complete investigation.”

For this egregious alleged behavior, the penalty bestowed upon PRAXIS is the immediate summary suspension of their certification for 180 days, during which time the WSLCB will seek the permanent revocatioin of their “marijuana laboratory certification” due to both fraud and the subsequent obstruction of the WSLCB investigation.

Importantly, moving forward, PRAXIS will “no longer be allowed to test cannabis for licensees in Washington.”

After largely ignoring the dysfunction that has come to permeate the cannabis lab testing industry they oversee for the better part of the last 6 years, the WSLCB has apparently changed it’s position and now no longer seems willing to tolerate or encourage (to use their words) “consumer deception”.

That is a good thing, but it’s a bit late coming and it – once again — comes with no apparent action on the part of the agency to assist consumers in identifying potentially mis-labelled product OR to have such product removed from the marketplace, re-tested and re-labelled.   Consumer deception is bad tomorrow — but it (once again) is OK today, per our regulators.  

There is no tax revenue benefit from inhibiting sales, I guess.

That’s their call — when an Agency refuses after 7 years of regulating a market to institute a single product recall — FOR ANY REASON WHATSOEVER — why would they do so just because a bunch of consumers can’t tell from the label how much intoxicating substances are in the intoxicants they are buying?  Nothing wrong with that, in the WSLCB’s view.  Close a lab.  Sell the affected product.  Collect some taxes.  Whitewash.  Rinse.  Repeat.

The WSLCB does not seem to mind medical cannabis Patients in Washington buying cannabis whose labels do not accurately reflect the amount of medicinal cannabinoids in the product.   Perhaps they would if they actually viewed cannabis as medicinal and if they could bring themselves to seeing medical cannabis Patients as something more than malingerers using a doctor to skirt laws that no longer completely apply.

At best, they are a confused Agency.

To cut what could be a very long diatribe short, I am absolutely sick of the WSLCB’s wanton and willful disregard for the safety of consumers that choose to participate in the markets they regulate and their apparent denial of the safety ramifications those decisions potentially have on ALL Washingtonians and not just consumers of regulated cannabis.

At the very least, the WSLCB could inform consumers as to which wholesalers (farms and/or processors) had product impacted or potentially impacted by PRAXIS’ alleged deception.

The WSLCB’s lack of action supporting public safety and public health is stunning.   No hot pink gummies are allowed (by George!), but let the idiot populace consume deceptively-labelled cannabis — just so long as it has it’s obligatory “21+ only” stickers in place —- and it’s combined 43.5% excise and sales tax cut for the state.

At the risk of being repetitive, I am sick of the WSLCB’s willful negligence regarding the safety of Washington’s cannabis consumers and for their chronic mis-regulation of the cannabis market.  My frustration is palpable — you may even feel it through my words.

Not being one to sit and stew (for long, anyway), I’ve decided to rectify this aspect of the WSLCB’s negligence.

It is my belief that consumers should know which wholesalers have recently been heavily engaged in using PRAXIS for their cannabis testing.    An informed consumers would  be more aware of whether or not product they are planning to purchase might have been sullied by PRAXIS’ alleged deception.

The following is a list of 46 wholesalers that, during the first 11 months of 2020, did “the bulk” of their testing with PRAXIS and/or did a large amount of testing with PRAXIS.   I make no statement or inference about these operators, other than to say that they are more likely than most to have product still on the market that was tested by PRAXIS and hence, might fall into that fuzzy product category of “Seemingly Have Intense THC Because Agency Governance Sucks” (S.H.I.T.B.A.G.S.).

Among all wholesalers, this group is the most likely to have had product impacted by PRAXIS’ deception.  I include every wholesaler who, during the first 11 months of 2020, tested at least 25 samples with PRAXIS, while at the same time having at least 33% of ALL of their samples tested by PRAXIS.

There are lots of reasons these wholesalers could have been using PRAXIS.  

The lab could have been close to their facility or convenient to their current sales delivery routes.   Their prices could have been better.   Their volume discounting could have been better.  They could have been a long-standing fan of Dustin Newman, PRAXIS’ owner  — perhaps even as far back as when he served as the Lab Director for Testing Tech in 2016 when it became the first lab to be suspended by the WSLCB.   They might have liked the services offered by the lab.   Maybe the appearance and/or personality of their staff.   I don’t know —- and I don’t really care at the moment.

The point is that their product was frequently being tested — or likely to have been tested —  by PRAXIS in the months leading up to the lab’s untimely closure.   The products of these wholesalers are, presumably, more at risk of being deceptively labeled with respect to it’s cannabinoid content, courtesy of PRAXIS’s alleged deception.

This list then, is intended to be a tool for consumers that care about such things and, importantly, for Patients whose well-being might well depend on such things.

It is also intended to serve as a reminder  to all licensees that – in spite of the chronic traceability problems brought to you all by LEAF and the WSLCB — many of your choices (such as the lab(s) you choose to use) are visible to interested parties, including at least one that has pretty much given up on the WSLCB as a relevant entity in assuring consumer safety and protection in this state’s regulated cannabis market.

Please share any questions you have using the comment section below this post.  

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Some statistics on the S.H.I.T.B.A.G.S. list:

There were 518 wholesalers that tested at least 1 sample in the state’s regulated cannabis market between Jan and Nov, 2020.   111 of them (21.4%) tested at least once with PRAXIS.

PRAXIS performed about 1 in 7 of the tests, statewide during this time (14.5% of the tests, statewide).

The 46 wholesalers listed above, while representing just 41.4% of PRAXIS’ regulated cannabis customers, account for over 90% of all tests done by PRAXIS in 2020.  All of PRAXIS’ big customers are on this list.

PRAXIS conducted over 70% of all the tests done by the 46 listed wholesalers during 2020.

The only other lab that seems differentially preferred by the “group” of 46 is Green Grower Labs, out of Spokane.   I’m not reading anything into that — but it was evident in the data.

The 65 other wholesalers who used PRAXIS but are not listed above tested either < 33% of their tests and/or fewer than 25 tests with PRAXIS.  They are not listed primarily because their volume of testing is low enough that various quality issues in the LEAF data system are more likely to have been expressed.  (I’d argue that doing 100% of 1 test is a bit different that doing 100% of 100 tests, regardless). 

If in doubt and you are thinking of shopping for regulated cannabis, just ask your retailer to see the CoA of the product you are interested in.  The lab that did the testing will be displayed on the CoA.   If the retailer can’t produce it, you should shop elsewhere (IMO).

Remember that eventually, PRAXIS-tested product will no longer be available for sale (unless their suspension is lifted).  The wholesalers that chose to use PRAXIS for their testing recently, however, likely will be.

I would like to acknowledge David Busby of OpenTHC.COM and his team, who have done a great deal of good work to make Washington’s seed-to-sale traceability data more accessible than ever. Check out Data :: OpenTHC if you are interested in seeing a bit deeper into the regulated cannabis market (for free). Some of the data I used to understand where consumers were most likely to find PRAXIS-tested product was derived using OpenTHC-developed resources.

14 comments

  1. If Praxis was giving higher numbers why did it have a reputation for giving lower potency results and higher micro failures than other i-502 labs? Has anyone had the items that supposedly had inflated results retested? For someone that thinks so little of the WSLCB you don’t seem to have any problem with accepting what they said about Praxis.

    1. I am unaware of the reputation of which you speak.

      Rest assured, Michael, I accept little that the WSLCB says without confirmation.
      That does not mean that I don’t pay attention to their litany of half truths.
      When they announce a consumer protection-related issue I do tend to take notice.
      Such announcements from them are very uncommon. You should read their press release on the topic.
      They seem very sure of themselves. Arrogance does tend to be an Agency characteristic, though.

      FYI – I have a public records request in for the very information you so insightfully speculate on in your comment.
      It may take them a long time to give me a responsive response. I have one equity-related request that is now three years old
      and for which I have now received almost 50 separate installments of their answer. I have no idea how many more years it will take them to
      complete their passive-aggressive response to the request.

      When they do, I’ll hopefully do something to help the “diverse” people that they discriminated against in rolling out the regulated cannabis market in WA.

    1. As I think you know, Shawn, I truly believe that Bad Agency Governance Sucks.

      In the case of PRAXIS, the WSLCB’s chronic lack of effective oversight of the lab industry has led to the current state of affairs in which an informed consumer would be hard pressed to trust many of the labels that currently adorn the packaging of regulated cannabis in the state of Washington.

      I do not, for a moment, think that is a laughing matter.

      Many people think that Some Having Intense THC —- or CBD for that matter —- is much less of a deal than when product that should have failed “safety” testing is marked as “safe” and sold at retail. Many folks perceive it to be much less of an issue when the alleged intensity of the product is deceptive than when the safety status of the product (the “quality” that QA testing is supposed to assure) is inaccurately represented. I disagree with that position and am, apparently, in the not unfamiliar position of being in the minority in holding that view.

      When Testing Technologies was closed down back in the day, I recall that their problems were widespread and pointed to not only a general lack of trustworthiness in their reported results, but also a lack of faith in whether or not they had even been doing some of the tests they reported results upon. Lots of finger-pointing in the ensuing investigation and public dialogue surrounding the closure apparently confused the LCB and all major parties were allowed to re-enter the lab testing industry after serving a not insignificant time-out. The owner re-opened after awhile (6 months, as I recall) and the lab director went off to work at True Northwest and, subsequently opened PRAXIS (small world amongst Friendlies, eh?).

      When PEAK was shuttered by the WSLCB, they had been found to have inadequacies in their lab protocols for testing some potentially harmful bacteria (I think it was salmonella and a family of things that included shigella and some other potentially nasty bugs). The net result, according to RJ-Lee (the LCB’s lab proficiency certification consultants) was that PEAK was not able to accurately detect those bugs when they existed in the product being tested. The LCB subsequently avoided doing any investigation or epidemiological assessment of whether any harm had been done to any folks that consumed PEAK-tested product and let all of the product they had tested stay on the shelves until it sold to consumers. As you may recall, that was about 30% of the product on the market at that time.

      Wholesalers all across the state loved sending their product up into the far reaches of the PNW for testing. Some say it’s the water in Bellingham. I think it’s the proximity of British Columbia and the hope that some of that good BC Bud essence will be imparted on their samples as a result. Regardless, they were allowed to re-open a year later and chose to re-brand themselves as TREELINE Analytics. When they did, I considered suing them for identity infringement against my corporate identity (trees are STRAIGHT for the most part, wouldn’t you agree?), but I’m just not very litigious by nature.

      What I DO know is that the only thing RJ-Lee said about potency in their assessment of PEAK’s (ahem) capabilities relating to potency was that they saw no evidence of potency inflation when they looked at the PEAK potency data supplied to them by the LCB. Personally, I think THAT is a funny statement. If anything, it suggests something about RJ-Lee or that the LCB was in some way able to influence their messaging so that it took on a heavily sardonic undertone. As I believe you know, I have the very dataset that the LCB sent to PEAK for their assessment. Having analyzed that little sucker almost every way this side of Sunday, I REALLY REALLY REALLY think that RJ-Lee’s statement about potency inflation and PEAK was hilarious.

      Now we come to PRAXIS where, according to the LCB, the alleged issue is a pure THC inflation ploy (with a bit of evidence destruction and investigation obstruction thrown in for good measure). I truly hope whatever problems might have been in place in their operation were limited to potency assessment — particularly as they were one of the few labs that was offering pesticide testing for the market.

      For that matter, that is an interesting coincidence, as Testing Technologies is also one of the few labs offering pesticide testing to the market. It must really warm the heart of the patient community to know that 2 of the 5 labs that did pesticide testing at the time in the I-502 / SSB-5052 market were ones that had a history of being closed for what I will term “lab inadequacies”.

      Now, we zoom forward to today (March 2, 2021) where we are at a point in which the LCB has entered year 6 of it’s discussions on whether or not they should even require pesticide testing in their dirty little market and we have 6 labs capable of testing for pesticides. Among those 6 are Testing Technologies and Treeline Analytics (both with a history of closure, (assuming that I am correct that Treeline is just a new-improved brand name for the previously tarnished PEAK moniker). Throw in Green Grower (one of the old “Friendlies” from when I assessed the labs in the first years of the market), and 1/2 of the 6 labs currently testing for pesticides in regulated cannabis are ones that, for want of a better description, are entities that I often feel like coloring red in my spreadsheets once I’ve unblinded the data.

      For the record, if I were testing for pesticides in today’s market, I’d use MEDICINE CREEK ANALYTICS, CONFIDENCE ANALYTICS, or DRAGON ANALYTICAL LABORATORY to do those tests. Those are the labs I recommend when people I care about ask for my recommendation on where to test for pesticides. While my original assessment of the lab industry back in 2015/2017 ultimately included CONFIDENCE Analytics as a member of the “Friendly” lab group, I have changed my categorization of the lab and now consider them to be P.R.A.G.U.E. (Proficient, Reliable, Accurate, Good, Unbiased, and Empirical). For those who don’t know, the “Friendlies” were a group of labs whose reported test results seemed “Friendlier” to the folks trying to sell the tested product as indexed by a number of metrics attempting to quantify different aspects of what I conceptualize as “Potency” and “Safety” reporting. “Friendly” labs had a tendency to report either higher than normative / expected potency levels and/or to report QA Failure rates (potentially unhealthy stuff) at lower than normative / expected rates.

      Years of observation including some analysis and some discussions with both Confidence staff and others knowledgeable about the laboratory arm of the cannabis support industry have led me to change my opinion of CONFIDENCE ANALYTICS. While I now consider some of their people to be friendly (in a good way), I no longer consider their results to be “Friendly” (in that less good way I once used).

      I now include CONFIDENCE ANALYTICS (reachable at 14797 NE 95th St, Redmond WA 98052 206-743-8843) among the labs I recommend when asked. I even bought a few of them a beer pre-Covid. I don’t buy “Friendlies” beer.

      For the record, I am also partial to Medicine Creek Analytics (Fife), Capitol Analysis (Olympia), Analytical 360 (Yakima), and G.O.A.T.(Vancouver). I’ve made money directly or indirectly from those four in the past, but no longer do and haven’t for at least a couple of years. I am also leaning toward liking Dragon Analytical Laboratories (Tumwater) — but that assessment is not based on any quantitative assessment of their reporting. Similarly, I know little data-wise about Pacific Botanicals Laboratory in Seattle (on Aurora), but the fact that they have joined the “elite” few (Medicine Creek and Dragon are the others) that offer Heavy Metals screening, suggests good things to me. I’ll reserve any firmer categorization until I know more. Similarly for True Northwest, Inc in Olympia. I’m neutral on them right now.

      For all of the others, I have no opinion that I wish to share at the moment. I’m in too good a mood to invoke their names.

      I’m glad you like my acronyms, Shawn.

      I hope you enjoy what I believe will become a series of posts shedding light for consumers on which brands carry labels that are more — or less — worthy of their trust.

      I had friends (possibly past friends) whose farms and/or processing facilities were on this list.

      I have friends (possibly future past friends) whose farms and/or processing facilities and/or retail access points may well be on future lists.

      The consumers of state legal cannabis need better protection than the LCB (and DOH) are giving them. Perhaps my work will help at least some of them.

      The licensees of this state’s legal cannabis market also need to step up and stop doing *^&$%^ things as they pander to the false perceptions and desires of their customers.

      Sell good, honestly (and accurately) labelled product at a fair (and hopefully good) price. That’s all I’m asking of the industry.

      1. Hi – this is a response from Atomic Budz to this article. This article has again recently come up and damaged my business again – Atomic Budz.

        I appreciate we have watchdogs, public and private. It helps keep everyone transparent. The LCB is such a loser state agency. seems like WA could out-source this task and get a better outcome for the rest of us. of course that will never happen. but i digress..
        If you want to be taken more seriously, Straight Line Analytics shouldn’t you use a better title for the article? You are presenting yourself as a “analytical company” using ridiculous, misleading titles. I am not sure whether you intended this or not but it implies that everyone listed here is shady and might or might not be paying for better test results or the LCB should be monitoring labs closer for inflated lab results? which is it? If your intended action was to call out the farms on the list; you are severely mistaken. I cant speak for anyone else except for Atomic Budz. being on top of this SHITBAG list, you have damaged my business twice now that i know of.

        We used them when we were in a rush because they worked 7 days a week and we could get labs quicker. Nothing more. If you were more professional, you would have realized 33% of total test is a fine filter but looking closer you should have seen we were an outlier and not used us. Instead, you did not and you damaged my small farm and its reputation and just this week i had to deal with this. Your expose should have been more analytical and less industry rumor-ish.

        Atomic Budz does not need higher test results from anyone. Our product tested consistently before Praxis, during Praxis and after Praxis. In fact Confidence tested our Unicorn Poop at 34% just a week later after Praxis was closed. Today we continue to post higher than industry average on potency because we have a great product.

        1. John – My regrets for taking so long to get back to you — I have not checked WordPress since I last posted early this past summer.

          Whenever one uses a cutoff (e.g., 33%) to define groups, there are inevitably members that either just make the threshold for inclusion or just miss the threshold. That is why I tend to define specifically what I have done when I publish my analytic work and share that definition with my readers. You should know that I looked at the data across ALL wholesalers in deciding which were and which were not included in the published list.

          I’m glad that you are finding consistency in your cannabinoid numbers across labs. I’m also a bit surprised, given what I have seen coming out of some of the labs over the past 8 years. In any case, Confidence Analytics is one of the labs whose results I trust (I also like Medicine Creek Analytics, G.O.A.T. Labs, Capitol Analysis, and Analytical 360).

          I’m neutral on a couple of the labs (not enough data to make an assessment regarding them, IMO). There are a handful of labs still operating that I would never knowingly support by purchasing product that had been tested by them. The unfortunate fact, though, is that such labs currently represent the majority of regulated cannabis testing in the state of Washington. Consumers are, again IN MY OPINION, putting themselves at risk if they don’t include the lab that tested the product in their purchasing decisions.

          It is unfortunate that you do not see the public benefit in articles such as this. If the WSLCB had their act together with respect to consumer protection, THEY would have published a list of all of the wholesalers that they knew to have had inflated results due to Praxis’ alleged fraud. Unfortunately, they did not. My article(s), in part, filled that unfortunate informational void.

          All the best to you and yours.

  2. Wait, the HUGE phat panda empire uses them, and the shitbags at Ionic use them? surprise surprise. Who the f buys their shit after the REPEATED bullsiht they pull? – Stores don’t give a shit, customers don’t really give a shit, it’s obvious by their race to the bottom on principals and price. Stores just see dollar signs and gave up on any type of actually providing value to the industry. They take a bag from inventory, put it on a shelf, tell someone it’s good when it’s bullshit and collect the cash, buy a house, buy a Ferrari, repeat.

    1. Surprise — Grow Op is definitely big — not sure if HUGE is the right word when we look at the size of some of the cannabis farms cropping up elsewhere in the regulated world. For WA, I guess it’s a fair label.

      Not nice to call anyone such names as you call Ionic. While I agree that their recent propensity to test with PRAXIS makes their product Seemingly Have Intense THC, I prefer to ascribe that to Sucky Agency Governance — which is, as I attempted to point out, something I view as Bad.

      The LCB has had many opportunities (about 6 years’ worth now) to do something to change the cesspool that QA assurance testing has largely become. They have failed to seize each and every one of those moments.

      We still have some labs that I (for one) trust, but they are in the minority and they currently represent less than 20% of the testing done on Washington’s regulated cannabis.

      It’s as if the WSLCB wants there to be a robust unregulated cannabis market serving the unmet needs of consumers. Go figure.

      It is comforting to see some wrists being slapped on the lab side. It would be nice if the LCB did some proactive work to uncover questionable lab behavior rather than just limiting themselves to responding to public outcry, media reports, or employees sharing inside information with them.

      I’m thinking of categorizing all of the stores based on how the various labs are represented on their shelves. Do you think that might be at all useful to consumers — or anyone else?

    1. Thank-you very much, Dr. Eon.
      I appreciate your kind words. They mean a good deal to me.

      They are particularly welcome in the context of some of the commentary coming down on FB since I published this article.

      I guess it’s unpopular to help better inform consumers that are, according to the regulators, currently being deceived.

      Certainly the LCB seems to think so. It would seem at least one “industry association”, one “wholesale broker” and a handful of other interested parties have taken offense at my post.

      While I appreciate their criticism — to the extent it is constructive — I really do believe that it’s far past time that those who are increasingly being forced to source their cannabis from this mis-regulated system start getting some useful information about it’s growers and processors — and retailers — rather than relying primarily on the marketing drivel with which they are being bombarded.

      Good job on hitting 100,000 feet. Jake would have been proud of you.

  3. While you might think you did a great expose’ on Praxis and texting and the incompetent LCB, for us it damaged our reputation. We moved to them because they worked 7 days a week and we were able to get test results quicker. We used them for a short period of time. To be sure, we tracked our test results afterwards with confidence. We got our highest test result from confidence at 34% potency. All our other results sent stayed with in a percent or two of Praxis. Maybe others benefited from their shady practices, we did not. Now many months later I have a store thinking we are shady. My problem is with the completely stupid asinine title. You unwittingly appear to be calling all the farms that used Praxis, shitheads. WTF?? Did you not realize that? Maybe other farms benefited from their shady shit but not us. Amateur!

    1. John — I’ll accept your label of me as “amateur”, as I receive zero dollars for the stuff I do on HI-Blog.

      That does NOT, however, detract in any way from my passion regarding the gross incompetence of the WSLCB when it comes to consumer protection within the cannabis market they regulate.

      I would suggest that you re-read the article. The only blame I was intending to put forward was on Praxis and on the WSLCB (B.A.G.S. = Because Agency Governance Sucks).

      With that said, I DO believe that it is important for consumers to know the businesses that used the lab during the period when they were found to be fraudulently reporting results. It’s a shame that the WSLCB did not take the time to let consumers know which products might have fraudulently labelled product as a result of Praxis’ alleged wrong-doing.

      Perhaps one day the Agency will begin to embrace consumer protection as one of their mandates.

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