2018 marked the first time in history that California's epic cannabis industry was required to test products prior to them hitting the shelves. For testing labs, this meant the daunting task of setting up shop to test everything from flowers to vape pens, pre-rolls dipped in hash oil to gummy bears, and topical creams to coffee (to name just a few).

Having worked for two different, major cannabis testing labs over the course of the year, I have had first-hand experience with transitioning California's cannabis industry into a regulated market, as well as many of the challenges associated with such a process. I thought sharing my experiences and thoughts on the roller coaster ride my colleagues and I experienced over the course of 2018 would be a great way to reflect on the first year of regulated cannabis in the golden state, and serve as a helpful account for scientists in states only just flirting with legalization.

Here are four things I learned from working in the cannabis testing industry in 2018:

1. Imposing testing requirements on a large, illegal industry is difficult

January 2018 had the potential to be one of the best months ever for testing centers across California. It made sense to think that because cultivators, manufacturers, and distributors were going to be required to test their products before they hit the shelves that labs were going to cash in quick.

In hindsight, we were wrong.

Laboratory revenue projections were far lower than expected at the beginning of the year for a few reasons. One obvious reason was expense: testing product and complying with regulations is not cheap. The beginning of the year saw large, vertically-integrated companies doing the most testing, with the majority of smaller growers and businesses holding back. The result was a lower overall sample load for labs.

Another factor testing labs did not consider? The black market. Imposing regulations on an illegal industry (according to the federal government, anyway) and expecting everyone to comply immediately was a naive notion. I do not have numbers on this, but 2018 may well have been one of the best years for California's illicit cannabis trade. This makes practical sense, of course: if your product, worth millions of dollars, failed for pesticides after years of doing business, would you just destroy it? or would you sell it in a state where cannabis is still illegal, and the black market thrives? If the cost of attaining your state license would put you out of business, it would make more sense to sell "underground" until you could afford to be compliant. Legal cannabis is certainly not the most lucrative market for smaller growers, and unfortunately many have had to close up shop. This writer believes that cannabis will go the way of small-batch brewing and vineyards over the long term.





2. Regulations limit the scope of edible products on the shelf, but they're safer and more predictable

Several manufacturers that jumped into 2018 with the hopes that their speciality edible would soon be sold for all of California to experience had a rude awakening. Why? It turns out that creating an edible with consistent cannabinoid potency is not a walk in the park. Regulations require that servings for edibles be consistently, or homogenously, dosed throughout the entire product. Some products are not so difficult. For example, people have been experimenting with dosing chocolate and brownies as far back as the 1950s. Other edibles, though, such as licorice, granola, and sodas (to name a few) pose a manufacturing challenge. Now ganjapreneurs must accurately and consistently dose servings, which can only contain a maximum of ten milligrams of tetrahydrocannabinol (THC).

What do these tighter dosing requirements mean for consumers? Because edibles are more consistent, so too is the experience that follows. Gone are the days of buying a pot brownie from your friend's "guy" and not knowing whether you'll be able to stand after eating it for fear of it being a little too strong. Now consumers can be sure that the five milligram edible they bought from one dispensary last month will be the same next month, even if it's from another dispensary. This only makes sense: for example, most people do not think twice about if their bottle of ibuprofen is actually the dose specified on the bottle - it just is. As cannabis moves closer towards personalized medicine, accurate dosing will be crucial to helping patients treat their ailments.

Accurate dosing can also help people learn what they like, and how much THC (or CBD) is right for them. I like to introduce my friends and family to cannabis using edibles, such as Kiva's Blueberry Terra Bites, which come in manageable five milligram servings. This is a great way to "build up" to higher doses, and to experiment with what works for different people. Of course, dose is only one part of the equation. "Set and setting" - that is, one's mindset and the setting within which one experiences a high - is equally as important.





3. Testing labs still have a lot of work to do to catch up to the regulations

Perhaps the biggest obstacle testing labs have faced this past year is the lack of consensus/standard methods for testing cannabis products. Testing for pesticides, particularly, poses a challenge to laboratories, who are required to meet strict quality control criteria established by the Bureau of Cannabis Control (BCC). By now, many labs have figured out how to test for pesticides at the limits required in flower samples, but concentrates and infused products, such as edibles, pose an entirely different challenge.

For one, concentrates, as their name suggests, contain much higher concentrations of cannabinoids, as well as other plant material, which interferes greatly with pesticide compounds, rendering reliable and accurate analysis challenging. Even scientific instrumentation companies, such as PerkinElmer and SCIEX, who both claim to have developed methods for successfully recovering all of the required pesticides in cannabis flower at the limits required, have yet to introduce methods for concentrates as of this writing.

Infused products pose a similar challenge, depending on the product. Water-based topicals and beverages might be easier to analyze than a pectin-based gummy bear, for example. Because infused products are often made using concentrated extracts, they also sometimes suffer from higher concentrations of pesticides. This is less of a problem in edibles, as the amount of THC extract allowed in a single edible is only 100 milligrams. In a two gram edible product, this small amount dilutes the overall concentration of any contaminants present. As they say, "dilution is the solution to pollution."

The fact that even experts such as PerkinElmer and SCIEX have difficulty meeting the regulatory requirements has left labs in a state of tension. Without consensus methods to reference, a costly amount of research and development is required to meet regulatory criteria. If labs are not up to spec, a visit from the BCC could spell absolute disaster. Some labs have resorted to desperation in order to stay in business, and have paid the price.

Fortunately, people like Susan Audino and members of the AOAC and ASTM are hard at work researching, developing, and publishing consensus analytical methods for cannabis.





4. California now has some of the cleanest weed around

Consumers are the real beneficiaries of California's cannabis testing industry. Now that maximum allowable concentrations of pesticide and mycotoxin residues, residual solvents, microbial contaminants, and heavy metals impurities have been set, California cannabis users have access to some of the cleanest cannabis in the world. (I say "some of" because Canada's pesticide regulations, which go into effect on January 2nd, 2019, are actually even stricter than California's regulations, requiring testing for ninety-six pesticides compared to California's sixty-six, and with lower allowable maximum residue levels). This is even compared to cannabis available to consumers in California this time last year, when only a handful of pesticides were required for testing.

Users can rest easy knowing that what they are inhaling or eating (or wearing) will have been tested and contain only small traces of contaminants, a vast improvement over cannabis of the past, which was completely unregulated. Ultimately, testing cannabis is about maximizing public health and minimizing potential risk. This is one of the reasons I enjoy working in the testing industry - knowing that I am helping make a difference to first-time users, experienced veterans, medical patients, and curious tourists alike.





2018 was nothing short of a roller coaster ride. Now that all of the regulations for testing have kicked in (the third and final phase of cannabis testing went into effect on January 1, 2019), labs are tasked with optimizing their operations to maximize quality, efficiency, and customer service. As the science of cannabis advances, so too will the quality of products manufactured and tested.

Here's to an exciting new year! :)

Disclaimer: The views and opinions expressed in this article are those of the authors and do not necessarily reflect the official policy or position of EVIO Labs.