Microbes Ingesting Solvents?

Part 2 of Cannabis Testing Lab Results Summary Series

You may be asking yourself why I might postulate that bacteria are ingesting solvents out there in the hard reality-based objective world of Washington’s State-legal Cannabis Lab-Testing Industry?  Aside from the possibility that the little things probably also enjoy alcohol (at low levels), it is an impression that arose while looking at the lab testing result data on both Residual Solvents and Microbial Screening.

My previous post on Moisture testing and it’s surprisingly low rate of failing cured bud (see HI-Blog) detailed what I’m doing, but I’d like to repeat here that my series evaluating lab testing results corresponds to data on testing for the period spanning June, July, and August of this year.  This period was chosen, as I had shared some of my early work with people in the Cannabis Testing Lab Industry to increase their awareness that external eyes were watching.  These most recent data also cover a period during which the labs would have been expected to have “shaken the bugs” out of their internal protocols and procedures.

As such, the data chosen afford an opportunity to see the “best” that the labs have to offer using a reasonably large sample of test results.

OK … back to drunken bugs.  My coverage of these two testing panels will be limited, as the truly interesting things here are things I’m seeing at the level of the individual labs.  I’ll share the detail of that in the final posting of this series, but will share some blinded lab-level highlights below.  I’m not going to include charts in this article (sorry to my picture-hungry readers … .I’ll make up for it in next week’s posting on Foreign Matter and Cannabinoid Potency Testing).

Residual Solvents (bug-food)

At the lab level, there are some disturbing patterns in these data.

Overall, of the 14 licensed Cannabis testing Labs in the State, only 8 conducted more than a trivial number of tests for residual solvents in extracts during the 3 months ending in August.

For the 900 tests conducted, 37 were recorded as having failed the solvent test (with values of residual solvents in excess of 500 parts per million).  This represents an overall failure rate of about 4.1%.

Four of the labs testing for solvents did not fail a single sample.  Of the four that failed samples, one failed less than ½ of a percent of it’s tested samples, two failed between 3-4%,and one failed almost 1 in 7 tested samples (14.2%).  The failure rate across time is fairly constant (statewide), and the sample size is relatively small.  However, having a single lab (with a large proportion of the reported tests) showing a failure rate almost 4 times larger than anyone else is a bit surprising.

It is of interest, and of some concern, that another 4 tests had levels in excess of the allowed threshold, but were recorded as having “passed” the residual solvent test.  One of these samples was recorded as having a residual solvent level of over 78,000 (which suggests that the sample in question contained over 7.8% residual solvent, by weight).  It is surprising that this product appears to have been passed, as it’s solvent levels are over 150 TIMES the allowable level.   One wonders if dabbing this product it might not result in a little back-flash?  Regardless, inhaling it (or otherwise ingesting it) is likely not going to be good for whoever ultimately bought it (I may trace this specific lot through the system to see where it was sold …. Yet another question to put on the to-do list).  At best, this is sloppy work.  At worst, it is feeding into a theme that is showing up as I continue to compile my lab-level testing report card — namely, that some labs seem to be failing less product than seems to be expected.  What is particularly interesting is that the four “failures to report failures” are not randomly distributed across the labs.  Stay tuned for details later this month – but there increasingly appears to be an issue at the level of  the individual labs that the State has granted the privilege of testing Washington’s regulated Cannabis.  The labs that are keeping recreational cannabis users safe.  The labs that will soon be keeping medical cannabis patients in Washington safe.

Microbial Screening (bugs, germs & poop)

Statewide, during the 3-month period in question, over 10,000 screening tests were conducted for the following microbial thingies: (with failure rates in parentheses).  About 80% of these tests were on Flower lots.

• aerobic bacteria                    (0.55% of tested samples failed)
• bile-tolerant thingies         (2.1% of samples failed)
• coliforms                                (0.67% of samples contained bad shit)
• e-coli and salmonella         (0.05% of samples were very bad shit)
• yeast & mold                         (2.6% of samples failed)

Yielding an overall failure rate of 4.1%.

So, about 1 out of every 25 microbial screening tests conducted in the last three months failed at least one microbial test and, hence, is considered unfit for consumption as is.   That is big money on the line for our producers and affiliated processors (well into the millions of dollars already).

I don’t know what a “good” or “expected” failure rate should be, but the beauty of large datasets containing the results of purportedly PRAGUE tests is that one might reasonably expect the distribution of failures to follow some sort of rational form.  If, for example, a lab is doing 5 times the test volume of another lab, one might expect to see more failure in the high-volume lab than in the low-volume lab.  As we’ll see when I post my lab-level report card, this is not always the case.  Suffice to say that two of the top 3 volume testing labs in the state did not fail a single sample for bugs, germs and/or poop during this period (and they represent almost 40% of the samples tested in the the state).  Maybe they only deal with clean growers, and not the dirty little unhygienic ones being seen by the other labs.

Cynical  Jim (and I have not completed my assessment on this, so it’s just an impression at this point) seems to see a pattern emerging wherein labs that tend not to fail ANYTHING and/or tend to fail things AT VERY LOW LEVELS have a tendency to have a higher share of the lab-testing market.  Just a correlation at this point.  No conspiracy or failing of human nature is being implied. I’m way too sunshiny a type of person for that.

However, the experimental psychologist inside of me is just salivating at the possibility of tracing some of the producer and processor relationships with the labs and their evolution across time (as a function of pass/fail experience).  I’m guessing I could do another degree with this stuff (would that make me a “Master Doctor”?).  Probably won’t make many friends.  Might  help to make Washington’s State-legal Cannabis a bit safer, though.

Anyway, in large part from my study of the “American Herbal Pharmacopoeia Cannabis Inflorescence Standards Manual (rev. 2014)”, I’ve come to the conclusion that testing for bugs & germs & poop (and heavy metals and pesticides and other things) is a complex process.  It is a process that is, fundamentally, dependent upon representative sampling and objective, unbiased testing and reporting.  It is dependent upon machine calibration.  It is dependent upon sample preparation (or, as I like to envision … why is this sample 100% ash …. Oh!, perhaps because I just smoked it … I’d say it has 55% THC …. Great bud.  Next Sample, please!).  It is complex … and it should be PRAGUE.

Regardless, complexity should not be a shield behind which bad (or corrupt) business practices are allowed to hide.  These are certified testing labs.  They are supposed to do complex.   They are supposed to be good at complex.

I’ll leave you today with another aspect of this testing that will enter into my lab-level report card – the size of samples required by the different labs.

With relatively standardized methodology, all of this anti-microbial screening takes a certain amount of product and a certain amount of time to do correctly (e.g., one has to “grow out cultures”).  Taken to an extreme, if a lab allows a sample of one one-millionth-of-a-gram to incubate for 1 millisecond, no failure is likely to be seen.  There is a REASON for a minimal (and, ideally, standardized) sample size for some of these tests.  If samples are smaller, they will tend to fail less frequently (systematically).  Similarly, there is a reason that some of these tests take days to do properly.

On that happy note, the average size of samples reported ON A PER-LAB BASIS (looking at Flower only) ranges from a low of 2 grams to a high of 5 grams.  The overall average sample size of flower tested  is just over 3 grams.

There is no reason that I can see for variability like this to be present.  I’d love to hear differently from the experts in the industry …. Please use the comments capability on this blog to let me know how my thinking here can be improved.

I am sure it is not lost on the typical farmer that having to submit 3 grams less per sample to the labs decreases the effective cost of the test by about the number of dollars that the farmer could otherwise receive by selling  that product.  Those sawbucks add up over time.  Might even be able to pay some taxes with them.

I appreciate everyone’s patience on my frequency of posting (I’ve been spending time working with a pro on an upcoming facelift to my professional website, and I wanted to limit the amount of content needing to be transferred over) … I’ll try to have my foreign matter and potency posting up this coming week … and the “Lab Report Card” post up before Christmas.

I’d love to hear what you think of this work (even without charts and pictures).

Jim