The Guardian Data Systems Blog

Our Perspectives on the Cannabis Industry

Cannabis Pesticides Uproar

Everyone is in an uproar over recent reports of lab tests finding pesticides on cannabis products. Tests on cannabis samples from California in October, performed by Steep Hill Labs, Inc. in Berkeley, reported finding pesticides in 84.3% of the cannabis tested.

mmj-pesticidesOregon recently released a “health alert” for tainted cannabis.

President of the Association of Commercial Cannabis Laboratories (ACCL), Jeffrey Raber, PhD, has concluded that “It is fair to say that around 50% of the cannabis being tested contains pesticides..” They don’t specifically list which various pesticides they have found. Our own government entities, the FDA and the USDA, have compiled long lists of approved pesticides, herbicides and fungicides that are considered safe for consumption and are heavily used on our food crops every day.

Reports on the Oregon debacle are saying the cannabis is “contaminated” with Spinosad, calling it a common insecticide in the marijuana industry.
Spinosad has been registered for use by the EPA since 1997 and is “considered a natural product, thus is approved for use in organic agriculture by numerous nations”   Spinosad is also a common insecticide used in America. It is regularly used on vegetables and fruit trees as well as grains to control leafminers, spider mites, mosquitoes, ants, and fruit flies. Not only is it sprayed on our food that we consume everyday it is “commonly” considered the organic gardener’s Godsend.

In the test done by Steep Hill, a fungicide called Myclobutanil was found present in about 50% of the cannabis tested.

qp-myclobutanil20ew-1gal-560x864Myclobutanil is a fungicide that is approved for and widely used on crops such as wine and table grapes and is also commonly used for commercial and residential landscaping, turf and public thoroughfares. California accounts for roughly 50% of all myclobutanil use in the US. In fact, more than 60% of all Myclobutanil used in California is used on the grapes, strawberries and almonds we eat. http://www.toxipedia.org/display/toxipedia/Myclobutanil
Myclobutanil has been found by the EPA to be environmentally mobile, ending up in surface water as well as rain and has a persistence that allows it to accumulate in soils.

There is no argument that we don’t want it on our marijuana, but isn’t it understandable that a portion of the amounts detected in the sample could actually be coming from residues in the soil and water as well as potential “blow over” when the fungicide is spread?

pesticide-useAll of those pesticides can be used on our food everyday but when used on cannabis it is considered tainted and contaminated. I guess it’s a case of what’s good for the goose isn’t good for the gander. Pesticide use is rising significantly in a time when one might assume the opposite. You might assume that of course use should be falling. If someone were to ask, you might think, of course we are more educated than we have been in the past about the dangers of pesticides and there is a big movement towards organic foods, so obviously pesticides use must be falling. But you’d be wrong. Just two years ago 41% of sample foods tested were found to be clear of not just dangerous levels but any detectable levels of pesticides. This year, when the Pesticide Data Program performed their 25th annual summary, testing thousands of samples from food groups that infants and children would consume, they found that up to 85% of the samples had detectable pesticide levels. Only 15% of the samples contained no detected pesticides. 441 samples were found to be what they consider worrisome. They found up to 496 different pesticides in the samples and many were found to contain levels that were above what would be considered as safe by the U.S. Environmental Protection Agency.
fdausdaThey also realized that many of them were found in foods that normally do not have any pesticide residues. For many of these foods there is actually no legal pesticide levels allowed. Foods such as spinach and strawberries, grapes and tomatoes as well as watermelon. Interestingly they even found chemical residues such as DDT, which was banned in 1972, and others that have long been illegal in the US. The FDA has also found that insecticide levels in honey were well above the legal allowance.

If Spinosad is “organic” and considered safe on our fruits trees and Myclobutanil is sprayed all over our grapes it’s easy to understand why growers might think it harmless to use on marijuana crops.

In essence, the reason these approved pesticides can’t be used is really just a technicality anyway, right? Each state has drawn up a list of pesticides that are considered “allowed” for use on the marijuana crops grown. But the lists vary greatly from state to state. California’s list is only 1 page and Nevada only allows 22 pesticides for use in their current medical marijuana market. Here in Washington the list is over 20 pages long and contains over 200 pesticides, very similar to the limitations in Oregon. The technicality that comes into play where pesticides are concerned in use on a crop such as cannabis is this: When it comes to pesticide use, the label is the law.

Pesticides are only allowed to be used on crops they have been approved for, but no pesticide has actually been approved for use on cannabis specifically.

Technically, any pesticide use on cannabis would be illegal, a violation of the label, even if it is approved for use on our food crops. That means that the states had to stick to only pesticides that are exempt from the EPA’s (Environmental Protection Agency) tolerance lists and have broad descriptions for use. They were also able to list some pesticides that are considered acceptable in organic practices.  So, the use of those other pesticides is technically illegal, even if they would or could be safe for consumption on marijuana just like they are on our food crops. There is definitely a bit of hypocrisy going on here where pesticide use in concerned.
There just hasn’t been enough testing done, whether it is in the use and consumption on our food crops or for use and consumption with cannabis.
Most of the tolerated levels set for pesticides that are used on our food crops were actually set for pesticide users and not consumers, which means they are tested for exposure but not necessarily for consumption.  Not only are they NOT testing the cumulative effects of the pesticides over time, but they are not testing any potential effects of the chemicals in conjunction with one another. Since the American diet tends to lend us to consuming many different types of these chemicals at one time many scientists feel this is too important a point to leave out when considering the safety of these pesticides.

When they set a tolerance level and say that it is safe it has been based on a threshold of that particular chemical’s individual toxicity and not taking into consideration the chemical cocktails we create when we combine food they way we do.

cannabis-pesticideFinding these types of pesticides on our marijuana crops poses another specific threat. We don’t know how many of these chemicals react to the particular method with which marijuana is consumed. Usually smoked or vaporized. This is especially true in the the case of Myclobutanil. In this particular case, what we do know is that Myclobutanil is converted to Hydrogen Cyanide when heated (i.e. smoked or vaporized), and Hydrogen Cyanide is extraordinarily toxic to humans. It can even be fatal in higher doses.

Consider the tobacco industry for a moment.

tobacco-pesticidesTobacco is a government regulated industry that has been a cash crop for decades. Cigarettes have been found to contain up to 7,000 pesticides and chemicals. Seven thousand! Smokers have been inhaling fertilizers, pesticides, herbicides, fungicides, you name it, that have been heavily used in tobacco cultivation forever. Studies have shown that over 90% of the tobaccos in the U.S. are genetically modified and covered with Roundup. It’s common knowledge that cigarette makers laced their product with chemicals, such as ammonia, specifically to make them more addictive. They are not burdened by labeling requirements forcing them to list the exact ingredients you will be exposing yourself to when you light up.
I think we all know why Big Tobacco gets away with their practices…..

Remember that argument that pesticides just haven’t been tested and approved for use on cannabis crops?

Well they have been tested and approved for use on tobacco. The EPA tested the tobacco with these findings, ”EPA has concluded that low levels of residues in tobacco smoke do not pose short-term health concerns requiring mitigation.” Interestingly they also pointed out that the “EPA does not assess intermediate or long-term risks to smokers because of the severity of health effects linked to use of tobacco products themselves.” Therefore the EPA has tested pesticides on a smokable plant product.
http://www.gao.gov/atext/d03485.txt

When the Pesticide Data Program does their annual testing of pesticide residues on commercial food they collect and test thousands of samples from farms all across the U.S. as well as imported products. But, they don’t require the farms to pay for this testing, a potentially extremely expensive process that could put them out of business. And they only do these tests once a year for their annual report. Cannabis business are required to test each and every cultivation, and then test each and every product that comes from that cultivation. Even if a cannabis cultivator wanted to avoid using chemicals and try cultivate biodynamically or even organically, there is no certification available. And even if they did get certified, that does not exempt them from state regulations that require them to perform the costly pesticide testing.

cannabis-lab-1For example, new cannabis testing rules that took effect on Oct 1st in Oregon are costing businesses tens of thousands and for some, costing them their business.

Processors are required to have samples from batches tested for pesticides and can now require as many as 32 different samples to be tested individually at a cost of about $400 per sample. One batch test can cost a business upwards of $12,000. That is of course if they can even find a lab to test it. Labs have to be certified to test for pesticides but the Oregon Health Authority (OHA) is too busy and short staffed to do the certifications. Where they used to have 20 labs in the state that could do the cannabis testing they now only have 3. This has caused wait times for results to extend into months causing products to be tied up, lack of products available to consumers and business to be forced to shut their doors.

Is this just an effort by regulators to act like they are allowing a legal cannabis industry while at the same time making it virtually impossible to have one?

We do have a responsibility to our patients and consumers to cultivate ethically with public health in mind. The argument here isn’t that we shouldn’t be upset about pesticide use in the marijuana industry. But there needs to be a balance achieved between regulators and the industry. They can’t keep putting unrealistic rules, testing protocols, and expectations on this industry that they don’t require of our very own commercial agricultural industry. Or the tobacco industry for that matter. Both are industries that in terms of public health effect a significant portion of the population. True, there needs to be more testing to determine the true safety of these chemicals in they way that they are regularly being consumed. But the powers that be can’t just target one industry while turning a blind eye for other industries that are using the same chemicals.

In the meantime we will remain vigilant, fighting for our industry and advocating for equality and fair treatment.

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