a good laugh
After legalization’s rickety lift-off, it’s no surprise that business is still booming for some local dispensaries.
The rotating postal strike, short supply and online-only status via the Ontario Cannabis Store (OCS) presented many consumers in the province with little alternative to a sluggish delivery process and frustratingly barren shelves. Quebec, for its part, responded to too little product or delays by reducing retail hours and New Brunswick had to temporarily shut down some stores.
If that were not enough, add the recent report of mould found in product from a licensed producer (LP) in Ontario. The recall, which involved RedeCan B.E.C’s lot 4B2L and began Nov. 30, revolved approximately 13,344 units of recalled product that were sold between Oct. 17 and Nov. 21, 2018.
The alert noted the affected product, dried cannabis sold online through the OCS and the B.C. Cannabis Stores, “may contain mould. In certain individuals, exposure to mould can result in allergic symptoms, such as sneezing, coughing, wheezing, runny nose or nasal congestion and watery or itchy eyes.”
Whatever the location presumably, it is likely some cannabis consumers have been left to return to their proven dispensary of choice, taking their chances with illicit—yet timely and abundant—cannabis.
As the rallying cry of many LPs and legislators has centred on the lack of quality control surrounding illegal growers and sellers, it seems a potentially risky move for those who continue to choose to use the illegal market. So how is illicit cannabis different from its legally produced counterpart?
Testing for safety and consistency
A core selling point for LP cannabis has been cultivator obligations towards safely produced, packaged and sold products. “There are so many requirements regarding their production practices for all cannabis,” explains Sherry Boodram, CEO of cannabis research and regulatory consultant for CannDelta, a regulatory and scientific cannabis consulting company based in Toronto.
“It’s very similar to the pharmaceutical industry… cultivators need to comply with constant sanitation and monitoring of equipment, and of personnel,” Boodram points out.
Once an inspector for Health Canada’s Controlled Substances Program herself, she says the key difference between
licensed and unlicensed producers—and the cannabis they cultivate—is third-party testing. “Testers make sure a sample of each batch produced is sent to analytical testing facilities, who send the results to LPs to verify they’re within specifications,” Boodram reports.
“The production of cannabis is subject to some of the most stringent requirements in the world to protect the health and safety of Canadians,” notes information provided by Health Canada. “Licensed producers are required to utilize good production practices in their facilities, such as having a defined sanitary program and having a dedicated quality assurance person. They are required to test every product lot for mould, bacteria and other potential contaminants, as well as potency levels, before products can be released for sale to the public,” the department adds.
The number of inspections a facility receives can vary by the LP’s history of compliance, Boodram says, adding that if they’ve consistently demonstrated compliance, the frequency of inspections decreases to bi-monthly, quarterly or semi-annually as deemed appropriate by Health Canada.
“Inspections occur more frequently for newer licensed producers, or for licensed producers that have demonstrated significant non-compliance,” she notes. Boodram adds that for those less-vetted LPs, inspections tend to happen once a month and are most often unannounced.
Testers look for chemical contamination, the percentage of THC, THCA, CBD and CBDA (“raw” CBD”), the presence of residual solvents, total bacteria count, yeast and moulds, E. coli and chemical contaminants such as pesticides, toxic fungus and heavy metals. The limits for cannabis, Boodram says, are based on outlines by international publications referenced in Canada’s Food and Drugs Act.
Solvents, for example, are each limited to 5,000 parts per million (a unit used to describe highly diluted concentrations of substances) with the exception of water, carbon dioxide and nitrogen. “If cannabis oil was produced via an ethanol extraction method, then residual ethanol may be present in the cannabis product, but it cannot exceed that limit,” she explains. “The LP can’t release it to the public.”
As another example, Health Canada notes licensed holders are required to “test cannabis to ensure it is within generally accepted tolerance limits for herbal medicines for human consumption, as established in any publication referred to in Schedule B of the Food and Drugs Act.”
Testers also verify the plant’s terpene content—playing a role in the entourage effect, terpenes can work in tandem with cannabinoids like THC and CBD to affect how one’s body receives the effects of the plant—is in line with producers’ claims, as well as extraneous matter, moisture content and the dissolution and disintegration of tablets and capsules.
To keep cultivators honest, Boodram says the federal government has inspectors conduct periodic evaluations of both their cultivation facilities and their cannabis for the aforementioned attributes.
Facility and cannabis inspectors use a variety of measurements and testing apparatuses to evaluate “compliance”, each one dependent on the equipment used and the strain in production.
Boodram says their reports are classified according to the scope and degree of severity of the deviation, and that “severity” is based upon the potential for risks to public health.
“For example, an observation would be ‘high severity’, if it were determined that all batches of cannabis were treated with a pest control product that hasn’t been registered under the Pest Control Act,” she illustrates. Conversely, Boodram says, “a much less severe observation would be if maintenance records indicated that an air filter was changed on Nov. 7 instead of Oct. 29 as scheduled.” If an LP is deemed non-compliant, she says it could face shutdown.
Legal providers under legal obligations
Illegal cannabis providers under zero obligation to test Dr_Microbe / iStock / Getty Images Plus
After legalization’s rickety lift-off, it’s no surprise that business is still booming for some local dispensaries.
The rotating postal strike, short supply and online-only status via the Ontario Cannabis Store (OCS) presented many consumers in the province with little alternative to a sluggish delivery process and frustratingly barren shelves. Quebec, for its part, responded to too little product or delays by reducing retail hours and New Brunswick had to temporarily shut down some stores.
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If that were not enough, add the recent report of mould found in product from a licensed producer (LP) in Ontario. The recall, which involved RedeCan B.E.C’s lot 4B2L and began Nov. 30, revolved approximately 13,344 units of recalled product that were sold between Oct. 17 and Nov. 21, 2018.
The alert noted the affected product, dried cannabis sold online through the OCS and the B.C. Cannabis Stores, “may contain mould. In certain individuals, exposure to mould can result in allergic symptoms, such as sneezing, coughing, wheezing, runny nose or nasal congestion and watery or itchy eyes.”
Whatever the location presumably, it is likely some cannabis consumers have been left to return to their proven dispensary of choice, taking their chances with illicit—yet timely and abundant—cannabis.
As the rallying cry of many LPs and legislators has centred on the lack of quality control surrounding illegal growers and sellers, it seems a potentially risky move for those who continue to choose to use the illegal market. So how is illicit cannabis different from its legally produced counterpart?
Testing for safety and consistency
A core selling point for LP cannabis has been cultivator obligations towards safely produced, packaged and sold products. “There are so many requirements regarding their production practices for all cannabis,” explains Sherry Boodram, CEO of cannabis research and regulatory consultant for CannDelta, a regulatory and scientific cannabis consulting company based in Toronto.
“It’s very similar to the pharmaceutical industry… cultivators need to comply with constant sanitation and monitoring of equipment, and of personnel,” Boodram points out.
Once an inspector for Health Canada’s Controlled Substances Program herself, she says the key difference between
licensed and unlicensed producers—and the cannabis they cultivate—is third-party testing. “Testers make sure a sample of each batch produced is sent to analytical testing facilities, who send the results to LPs to verify they’re within specifications,” Boodram reports.
“The production of cannabis is subject to some of the most stringent requirements in the world to protect the health and safety of Canadians,” notes information provided by Health Canada. “Licensed producers are required to utilize good production practices in their facilities, such as having a defined sanitary program and having a dedicated quality assurance person. They are required to test every product lot for mould, bacteria and other potential contaminants, as well as potency levels, before products can be released for sale to the public,” the department adds.
The number of inspections a facility receives can vary by the LP’s history of compliance, Boodram says, adding that if they’ve consistently demonstrated compliance, the frequency of inspections decreases to bi-monthly, quarterly or semi-annually as deemed appropriate by Health Canada.
“Inspections occur more frequently for newer licensed producers, or for licensed producers that have demonstrated significant non-compliance,” she notes. Boodram adds that for those less-vetted LPs, inspections tend to happen once a month and are most often unannounced.
Testers look for chemical contamination, the percentage of THC, THCA, CBD and CBDA (“raw” CBD”), the presence of residual solvents, total bacteria count, yeast and moulds, E. coli and chemical contaminants such as pesticides, toxic fungus and heavy metals. The limits for cannabis, Boodram says, are based on outlines by international publications referenced in Canada’s Food and Drugs Act.
Solvents, for example, are each limited to 5,000 parts per million (a unit used to describe highly diluted concentrations of substances) with the exception of water, carbon dioxide and nitrogen. “If cannabis oil was produced via an ethanol extraction method, then residual ethanol may be present in the cannabis product, but it cannot exceed that limit,” she explains. “The LP can’t release it to the public.”
As another example, Health Canada notes licensed holders are required to “test cannabis to ensure it is within generally accepted tolerance limits for herbal medicines for human consumption, as established in any publication referred to in Schedule B of the Food and Drugs Act.”
Testers also verify the plant’s terpene content—playing a role in the entourage effect, terpenes can work in tandem with cannabinoids like THC and CBD to affect how one’s body receives the effects of the plant—is in line with producers’ claims, as well as extraneous matter, moisture content and the dissolution and disintegration of tablets and capsules.
To keep cultivators honest, Boodram says the federal government has inspectors conduct periodic evaluations of both their cultivation facilities and their cannabis for the aforementioned attributes.
Facility and cannabis inspectors use a variety of measurements and testing apparatuses to evaluate “compliance”, each one dependent on the equipment used and the strain in production.
Boodram says their reports are classified according to the scope and degree of severity of the deviation, and that “severity” is based upon the potential for risks to public health.
“For example, an observation would be ‘high severity’, if it were determined that all batches of cannabis were treated with a pest control product that hasn’t been registered under the Pest Control Act,” she illustrates. Conversely, Boodram says, “a much less severe observation would be if maintenance records indicated that an air filter was changed on Nov. 7 instead of Oct. 29 as scheduled.” If an LP is deemed non-compliant, she says it could face shutdown.
Legal providers under legal obligations
Illegal cannabis providers under zero obligation to test Dr_Microbe / iStock / Getty Images Plus
