Frostiness in Washington bud may no longer be your best friend.
Today, I present evidence that supports the argument that Washington adults should, as a means of ensuring the quality of the cannabis they consume, be allowed to grow their own cannabis at home without the risk of being busted by state (or local) employees.
Since Sept. of 2017, the WSLCB has not required any product within Washington’s regulated cannabis market to be tested for yeasts and/or molds. The LCB now considers moldy bud to be fit for human consumption, so long as that mold has not produced unacceptable levels of certain mycotoxins known to have negative impact on exposed humans and other lab creatures.
Earlier this month, the Ike’s OK customer-safety testing program ran it’s first batch of pre-roll tests. Five samples of non-infused and five of infused pre-rolls were sent to Medicine Creek Analytics for the full suite of I-502 (potency and quality) and SSB-5052 (pesticides and heavy metals) testing. Prior to this sample run, Ike’s OK had focused on both flower and concentrates (dabs and cartridges). Pre-rolls are also popular inhaled products, so we felt they should also be included in the testing program.
The Certificates of Analysis (CoAs) for these 10 samples are now posted on the Ike’s OK (www.ikes.com/ok) page and any samples that failed any of the required QA tests will have been pulled from the shelves of Uncle Ike’s three Seattle-based stores. For failed samples, additional products from related vendor(s) and/or producer(s) will be selected for follow-up testing this week.
What I report on here is something that will not result in any product being pulled from the shelves of Uncle Ike’s stores. There will be no alarm bells rung within the Ike’s OK system. Notification texts will not be sent to tens of thousands of subscribers. Vendors will not be called to discuss follow-up steps. The LCB will not be notified that a product made available for sale at retail has subsequently failed Quality Assurance testing by a certified laboratory.
With that said, all 10 of the preroll samples tested showed levels of “Yeasts and Molds” in excess of the previous maximum-allowed level of 10,000 cfu/g (colony-forming units per gram).
That is a 100% failure rate against a quality standard that no longer officially exists in Washington.
The LCB thinks this is OK.
Uncle Ike’s is being agnostic on the point.
I, however, think that it is anything but OK.
I do not believe that levels of yeast and mold colony-forming units measured in the hundreds of thousands per gram of product is acceptable. I do not view such product as fit for human consumption.
If I wanted more mold in my diet, I’d eat more brie or utilize fewer food safety-oriented techniques in my pantry and kitchen. I WOULD NOT roll up a joint/cone/spliff/blunt with moldy bud or trim and then consume it or share it with friends.
Based on these Ike’s OK testing results, this is one adult Washingtonian that will be avoiding pre-rolls as a category within the regulated market.
To put some numbers on this (other than the 100% failure rate across 10 randomly-selected samples), the average cfu/g for non-infused pre-rolls was 88,000 and the average for infused pre-rolls was 172,000 (these mean differences were statistically significant using a t-test that does not assume equal variance in the groups). Presumably, kief and/or hash and/or the extra handling involved with infusing pre-rolls adds yeast and/or mold to the process. Either that, or infused pre-rolls are just inherently more “cheesy”.
My advice to joint-smokers: If you wish to smoke a joint in Washington, buy some nice bud and roll your own or get someone you know (with clean hands) to roll one for you.
It would be nice for Washingtonians if one of the sourcing options for safe legal product was from their own (preferably unregulated) gardens. That would give people that care about what they put (or don’t put) into their bodies some control over the quality of their cannabis.
The state legislature is now considering a pair of bills that would allow Washington adults to grow up to 6 plants each legally – a right which Washingtonians are currently denied.
If you’d like the ability to be able to produce safe product to roll into joints (or otherwise consume), please contact Rep. Derek Stanford –the current Chair of the House Commerce & Gaming Committee –and ask him to move HB-1131 to an Executive Session Vote for advancement to an eventual vote by the full House. His number is (360) 786-7928 and his e-mail is Derek.Stanford@leg.wa.gov
If you care about having the freedom to grow and ensure a supply of product of known quality, PLEASE DO THIS NOW. The legislative session is underway and the right honorable Rep. Stanford seems to be wavering on the importance of this bill. Remind him that if the state is unable to ensure the safety of it’s regulated cannabis that you believe that Washingtonians should be allowed to ensure the quality of their cannabis products by being allowed to grow their own — to their own standards.
One of the very few cases in which the use of cannabis is recognized to have resulted in a human death is a case where an immune-compromised patient was smoking moldy bud and developed a lung infection from that same mold — leading to that patient’s death.
Cannabis is a relatively safe product (certainly more so than are alcohol, nicotine, opiates or methamphetamines).
Let’s not allow fungus-infested product to compromise this most fundamental of cannabis’ many advantages.
I would appreciate it if you were to join me in petitioning the WSLCB, the Department of Health and the Legislature to re-introduce a focus on consumer safety in the Quality Assurance standards they set for Washington’s regulated cannabis and cannabinoid-containing medicines. Remind your regulators and the Legislators that feed off of the new taxes being generated by this market that it would be good policy to give consumers a reason to trust that the product in regulated stores is being held to reasonable safety standards.
Unfortunately, the product out there today is, all too often, not worthy of their trust.
We need HB1131
I agree. Further, we DESERVE HB-1131 (after all, we did pass I-502, didn’t we?).
To be the first (Colorado does not count, as it does not touch an ocean) state to launch state-legal cannabis and to be the ONLY state with legal cannabis that does not allow home-grow is an unfortunate irony.
… and it is such an easily fixable irony.
The levels you report are, if true, of great concern and need to be dealt with by every P/P but the solution is not just to “grow your own” and all these problems will magically go away! Most home growers will be far worse than professional growers at solving the many problems that cannabis is heir to and this will likely lead to more mold, yeast, pesticides etc on the pot grown at home making these problems worse.
Mold and yeasts etc are not usually present in quantities that are even visible to the human eye. The vast majority of home grows are not going to test their cannabis so these amateur growers will be flying blind. Washington State has, like most places, had a rude awakening to the fact that there are many potentially harmful substances that can be applied to the crop or that just grow there naturally and that subsequently show up in testing. As these issues are revealed most growers are, through necessity if nothing else, figuring out ways to eliminate the problem. It’s a lot or work and it take constant vigilance that I doubt very many home growers are qualified or inclined to apply.
The solution is just what you are doing. Publicize the results and let the industry be aware of the issue and work to solve it. Sunshine is a great disinfectant.
Agreed, Steve (go Sunshine!)— and I see no reason to believe that the test numbers I reported are not “true”.
For consumers that truly care — and remember that is often folks who ARE immuno-compromised or have respiratory issues or who (for whatever reason) consumer more cannabis than the average consumer — having the ability to control what is in their product is very important, and they are likely to be motivated enough to do so.
Legal homegrow is not a magic bullet for all, but the sorry state of quality in the regulated market (due directly to LCB regulation thereof, with complicity on the part of DOH, WSDA and — apparently — the Governor’s office) makes it a magic bullet and a necessary bullet for some.
The LCB apparently estimates that 1% of Washington adults would grow if allowed (that is about 51,000 people) … at least that is a number that they thought might scare the Chair of the House Commerce and Gaming Committee, so they pulled it out of some nook or cranny somewhere and threw it out to scare the tax machine away from allowing homegrow.
51,000 may TRY to grow. I would expect that most would have the problems you mention and would realize that growing “fire” is not easy. Even folks that can pump out a decent batch of homebrew beer in a few weeks might balk when they realize that many months of care are required to produce good homegrown cannabis.
I’d bet that homegrow would, within the first few years of it’s being allowed in Washington, ultimately be embraced by fewer than 25,000 Washingtonians. That would be less than 2% of the number of Washingtonians shopping in the regulated market. Further, I’d be willing to bet that very few of those would source exclusively from their own grows.
I believe you’d agree that a well managed grow of 6 or fewer plants is easier to control infestations in than a grow spanning multiple greenhouses or rooms.
I don’t imagine mold/yeast testing would be a huge expense that would lead to home growers from having their own tested. Especially those who are immuno- compromised, for them an oz of prevention is worth everything.
But ultimately the movement from the black to the white for the cannabis market can’t just be about money and taxes. It’s got to be about freedom as well. If people are free to make their own beer, they sure af should be free to grow their own cannabis. Tax revenue was the camel’s nose under the legal tent, it’s time to start moving the entire camel inside the tent as well.
Well said, Darin.
Thank you, Jim, for this analysis and call to action!
You are welcome, Allison.
Frankly, I was surprised to see 100% of the samples fail vs the old standard for Yeasts and Molds.
In the last 3 months of the good old days when the LCB required testing for Yeasts and Molds, approximately 5% of product being tested was failing this assay. I have always believed that lazy/substandard/money-grubbing interests that do not give a darn about consumer safety (or longevity) managed to get the LCB to remove this consumer-safety evaluation from the regulated requirements.
How sucking up to a well capitalized lobbyist advances the mission of the LCB (which has something to do with public safety) still escapes me. I must be denser than I think.
It seems pretty obvious that the pre-roll market is perfectly suited for the unscrupulous to dump their shake, trim and other marginal product into. It’s always about the money with some people.
So it seems, Darin. I was a bit shocked when the failure rates came back at 100%.
This is particularly important, as pre-rolls seem to be a common “purchase of convenience” for many.
All one needs is a source of ignition (and access to some of the very small portion of Washington state in which it is legal to smoke said pre-roll), and 1-2 (or more) people can be well-served by an inexpensive purchase that leaves no waste behind other than second-hand smoke, thc-tainted urine and blood and a fully decarboxylated roach that can be viewed as an edible that, rumor has it, may often be above the 10mg per serving limit allowed in the state.
I know of growers that use good quality flower for their pre-rolls.
In a way, pre-rolls are really only a different way of packaging a gram or two that includes the bonus of containing a quick edible dessert that conveniently becomes available just as the munchies begin to set in.
Thanks again for an insightful post Jim. The irony here is that if we still had the previous microbiological monograph for I-502 testing the “unfriendly” labs (those are the labs who presumably tell the truth and actually flunk samples, FYI) would be out of business.
We all talk about end user safety for rec users and patients alike. That end user safety is compromised in the relentless pursuit of the almighty dollar and business survival. It’s like Daryl Hannah described in the movie Wall Street…the thing about money is that it makes you do things you normally wouldn’t… So here we are as an industry turning a blind eye to the obvious. Material is making to the retail shelves that shouldn’t. We’ve seen that in the Uncle Ike’s OK program. Labs should be failing material in accordance with the 502 guidelines. I am glad we are seeing an organization step up and take a look under the industry kimono.
Obvious economic indicators point to an unhealthy financial ecosystem in Washington’s legal rec / medicinal market. To all you end users, come on for the love of all things holy, when you see retailers advertising $50 ounces (again RETAIL not wholesale) there is a huge economic problem. Ergo, people (LABS) pass material that shouldn’t pass, because to fail a sample is to lose a client. So what is a lab to do in an industry where the going prices for testing are in the jug? It’s that thing about money….
So what do we do with these data from the Ike’s OK program? I suggest first and foremost that we address the obvious. I formally pose the following question. What lab passed that material that tested 16x higher than the State’s guidelines for microbial contamination? Come on, it’s improbable that a product doesn’t get 16x the limit of gram negative bile tolerant organisms while sitting on the shelf. SO WHO TESTED THAT SAMPLE (and passed it) THAT MADE IT TO THE SHELVES? That lab should be investigated. That grow should be investigated. What is going on out there?
Again friendly behavior, inflated potencies, inflated terpenes and inaccurate micro passes, is the bane of this “regulated” industry. End user safety is truly being overlooked. It is not hard to find the “bad actors”.
Again….WHO passed that material and signed out that certificate of analysis? Was it actually signed out by a scientist? WHAT lab passed that material? Inquiring minds want to now. I’d pay good money to get that original cert that got that material on the shelves.
Thanks Jim and Uncle Ike’s.
Thank-you for your (as usual) thoughtful input, Jason.
I share your interest in which labs passed product failing the Ike’s OK program tests.
I have not been actively tracking the data, as I know myself well enough that it is probably best for me not to know (I, after all, dislike Cease and Desist orders and liability and that kind of thing).
With that said, every product that fails an Ike’s OK test for I-502 quality passed exactly that same test when it went to market (this counts only for the non DOH-required tests, as not all product is tested for pesticides and heavy metals in the non Ike’s OK world. Ike’s OK tests for them, because they are important to customer safety).
One of the ever-decreasing number of remaining labs (Molecular Testing Labs is off the newest list and Steep Hill seems to be inactive) passed this product and had an employee (presumably with some science-like credentials) sign off on that result.
Sure there’s variability. It’s all around us. Some of us are even comfortable with and embrace that fact.
Variability within a lot in excess of 700,000 colony forming units per gram does, however, strike me as a bit odd and a bit disturbing.
To your question — I’ll let you know what I find if I ever look into whether or not any of the remaining labs are popping up as being over-represented in products that are failing Ike’s OK tests making it to market in the first place.
Thanks again.
Great points. I think in the end we’re going to see that independent lab testing is going to turn out like Moody’s and S&P’s rating services in the run up to the Great Recession. Ratings for sale, driven in part from the fear of losing the business to the other guy. We have to have law and order, and the unscrupulous need to be identified, and driven out of business or compelled into acting correctly.
I agree.
We DESERVE HB-1131 – after all, we did pass I-502!
Many thanks.
If the bill does not make it out of the committee by this coming Friday (Feb 22), homegrow will remain illegal in Washington for anyone not holding a current valid medical authorization (and, even then, only having an “affirmative defense” if prosecuted for all authorized Patients unwilling to self-identify in the DOH database).
That sucks —- particularly when one considers that the DOH (Dept. of Health) modified the specifications for the Patient Database after the launch of regulated MMJ to include a quarterly report designed for and to be sent to the DEA.
I’m going down to Olympia early this week and hope I get an opportunity to bend Rep. Stanford’s ear (I live in his district).
I’d like to be able to grow legally. It would be fun to try …. and clearly should not be a crime.
Where’s Marches results for Ikes program? Was that it?! This wasn’t a stunt to push the Homegrown Bill, was it?
Ike’s OK was, in no way shape or form, a “stunt” and it was designed to address gross deficiencies in consumer protection resulting from the lack of adequate enforcement of quality assurance and labelling rules by the WSLCB.
I truly believe that the sorry state of Quality Assurance in Washington’s state-legal cannabis market makes a very good case for allowing all adults in WA the ability to grow small numbers of plants at home. If the state can’t keep regulated consumers safe, they should not — at the same time — be forcing consumers to use an unsafe system. That is MY opinion — and has nothing to do with the OK program.
During March, Ike’s OK is transitioning to “OK Cannabis” which will be administered by C.O.R.E. (Cannabis Organization of Retail Establishments). We decided that the focus required to transition the program was inconsistent with running a series of tests in March. So we did not.
In April (probably tomorrow), I expect to be selecting products from at least 10 stores for testing (using processes and rules based on those developed for the Ike’s OK program, but generalized to more stores).
I fully expect the number of stores participating in the OK Cannabis program to grow significantly over the next few months.
It was not “widespread”, it was UBIQUITOUS.
100% of the tested preroll samples (n=10) tested positive for levels of “yeast and molds” that would have failed back when the WSLCB required testing for yeast and molds.
They no longer require such testing …. hence (be careful of “frosty” product in WA).
It was not “widespread”, it was UBIQUITOUS.
100% of the tested preroll samples (n=10) tested positive for levels of “yeast and molds” that would have failed back when the WSLCB required testing for yeast and molds.
They no longer require such testing …. hence (be careful of “frosty” product in WA).