Looking at some of the recent social media banter that has arisen in response to the Ike’s OK customer-protection program, it is clear that not all consumers in Washington have ready access to the information that the WSLCB makes available to let people know which licensees are alleged (by the WSLCB) to have violated various rules and/or laws. This post includes a list of licensees alleged to have violated rules relating to the use of pesticides, soil amendments, fertilizers, other crop production aids, unauthorized solvents or gases, or of having allegedly adulterated usable marijuana with organic or nonorganic or other compound(s).

The WSLCB periodically posts a listing of all VIOLATIONS (including both alleged offenses that were issued an Administrative Violation Notice (AVN) and alleged offenses that were issued a Warning Letter) up on their Frequently Requested Lists web page. However, they only include the 6-digit license number of the alleged violator, and not information that humans can readily translate into which licensee is alleged to have been in violation of the indicated rule or law.

This post lists the “tradename” of each wholesaler that has had one or more alleged violation of the Pesticide Rules (corresponding to either WAC 314.55.084 or WAC 314.55.087(1)(f), and consisting of allegedly (MJ) Using unauthorized pesticides, soil amendments, fertilizers, other crop production aids. )

In addition, I include asterisks beside the Tradenames of two licensees that are alleged by the LCB to have either :

(MJ) Using unauthorized solvents or gases in processing. (WAC 314.55.104)

Or

(MJ) Adulterate usable marijuana with organic or nonorganic chemical or other compound. (WAC 314.55.105)

These three classes of violations strike me as ones that fall into the category of “alleged actions that could reasonably be viewed as introducing unhealthy additives to regulated cannabis, if those actions were really occurring”. The tradenames in question may or may not correspond to the name of the “brands” as they appear on Retail shelves. Unfortunately, with the now 13-month-long absence of traceability data, I am not easily able to infer which brands or “dbas” are associated with these licensee tradenames.

On a technical note, I used the VIOLATIONS database current through September of 2018 and the Marijuana APPLICANTS file current through Oct 9, 2018 for most of the information contained herein. Those were merged in EXCEL using VLOOKUP and using the 6-digit license number available on both files as the ‘link” key to enable cross-file merges.

A small number of records in the violation file had no corresponding records in the Oct 9 applicants file, which I assume means the businesses either closed or had an event (location or ownership change) that resulted in the change of it’s license number. To get business-identifying information for those records, I scanned through a number of my historical copies of the applicant database to try to figure out which business was, historically, associated with the license for which the violation was alleged (only one such record is on this sheet, and I have placed it last on the list and have included BOTH business names that seem associated with this license number …. take that last record with a bigger grain of salt than the others).

I make no judgement or assertion regarding this list, other than it corresponds very closely to what the LCB recently posted on their website relating to violations (and licensees/applicants). Getting an AVN or a warning letter does not mean any rule has been violated. I am, however, under the impression that getting one (or the other) implies that the LCB is under the impression that a rule may have been violated. I also know that I have almost never seen an LCB-generated data file that was without error.

Enjoy the list, and please keep it away from children (unless they are MMJ Patients — then use your best judgement as the exceptional caregiver that you no doubt are).

The counts in the following list correspond to the number of LCB-alleged “Violations”, and their breakdown as either AVNs or Written Warnings corresponding to one or the other of the following rules: WAC 314.55.084 or WAC 314.55.087(1)(f) -(MJ) Using unauthorized pesticides, soil amendments, fertilizers, other crop production aids.

Trade Name Total Violations AVNs Written Warnings

HARMONY FARMS 3 3 0

BMF WASHINGTON* 2 2 0

SPINNING HEADS 2 2 0

MOLECULAR GENETICS RESEARCH ASSOC. 2 0 2

BBB FARMS 1 1 0

BIG RIDGE FARMS 1 1 0

BLUE SKY GROWERS 1 1 0

BUDCO FARMS 1 1 0

CHIPPER GARDENS * 1* 1 0

CRESCOMAX 1 1 0

DOUBLE DELICIOUS 1 1 0

DOUBLE DUTCH 1 1 0

ECO VENTURES 1 1 0

FREYA FARM 1 1 0

HAZY DAZE 1 1 0

HERBSCAPES LLC 1 1 0

HOMETOWN HERBS 1 1 0

JBM ENTERPRISES LLC 1 1 0

J.R.’s** 1 1 0

KHUSH KUSH 1 1 0

KUSH GARDEN 1 1 0

LADY EARTH BOTANICALS 1 1 0

M AND R DISTRIBUTING 1 1 0

MEDIGROW 1 1 0

MOMMA CHAN 1 1 0

NEW LEAF ENTERPRISES 1 1 0

NORTH COAST GROWERS 1 1 0

NORTHERN GROW LLC 1 1 0

ORIGENS 1 1 0

ROOTWORX 1 1 0

SHELBY ECKROTH 1 1 0

STILL URBAN NURSERY 1 1 0

TREEHAWK FARMS 1 1 0

TRIPLE R FARMS, LLC 1 1 0

TRIPLE T FARMS 1 1 0

UNAFLORA 1 1 0

ZENTA GARDEN 1 1 0

CLOUD 9 GOOD BUDZ 1 0 1

CULTIVAR FARMS 1 0 1

D AND L ENTERPRISES 1 0 1

NW HERBAL GARDENS 1 0 1

ROYAL TREE GARDENS 1 0 1

SPOCANNABIS 1 0 1

Blewett Pass Farms** 1 0 1

*Note: BMF Washington also has one AVN for (MJ) Adulterate usable marijuana with organic or nonorganic chemical or other compound. , and Chipper Gardens has one Warning Letter for (MJ) Using unauthorized solvents or gases in processing. (Warning Letter)

**Note also that, in the last row of the table above, I believe the license number in the VIOLATIONS database referred (at the time of the alleged violation) to “Blewett Pass Farms”. However, the Oct 9 licensing/applicant file associates an entity called “Washington Gold” with that license number. A violation was alleged to have occurred — but it is not crystal clear which of these wholesalers was associated with the alleged violation. (UPDATE 11/29/2018 — the alleged violation in question WAS tied to Blewett Pass Farms and NOT to Washington Gold. My thanks to Cody from Washington Gold for clarifying (and for doing so in a polite manner). My further thanks to Matthew from Cobalt CC for clarifying that the alleged violation listed in the initial post was, actually alleged against J.R.’s and not Cobalt CC.)

Be careful in what you buy. It truly helps to know something beyond marketing hype regarding WHO is growing the cannabis you buy and/or processing it and HOW they operate. If you know the farm and you trust them and you like their product, good for you. If not, I repeat, BE CAREFUL IN WHAT YOU BUY.

Try to avoid any negativity toward the businesses listed above, as their interactions with the LCB enforcement and education division have very likely educated them about the inappropriate nature of prior alleged practices and the general good karma that comes along with producing and processing products in a way that makes them suitable for human consumption.

Most importantly, : look to HI-Blog later this weekend for my long-overdue post relating to the LCB/WSDA complaint-driven boondoggle surrounding LCB-funded and WSDA-executed pesticide testing (using data through Sept of 2018).

In that post, I will gently point out how willfully negligent the LCB has been (and continues to be) in keeping pesticide-laden product out of the hands, mouths, and lungs of regulated cannabis consumers in Washington State. I will also point out how many of our tax dollars they have spent being so willfully negligent in their duties.