Enough on the Labs, Already! My Closing Words on a Filthy Issue.

It’s been a labor of love, these past two years putzing with the laboratory data and occasionally digesting (and deflecting) ad hominen feedback.

(The above logo, of a baby Cannabis clone being suffocated in a condom, comes from the website of the supposed “Washington Cannabis Laboratory Association” — be careful of this group, as one should probably be slow to trust an organization that would advocate for the mis-treatment of a little helpless baby plant).

Lots of interesting stuff, lots of potent stuff, and lots of filthy stuff. I’m going to put the lab stuff on the back-burner for now, as it simply does not pay (literally or figuratively), and commercial dynamics in the industry are increasingly catching my attention — and that of my clients.

My shock, disbelief, disappointment and sadness have come through in many of my postings on the labs. These clearly non-PRAGUE almost emotional outbursts have emerged over what I’ve consistently seen in the data and the apparent lack of visible enforcement efforts on the part of the Liquor and Cannabis Board to address the issues that have infected large portions of the State-legal Cannabis Testing industry in Washington. The lack of attention to the issue of lab HONESTY (operationalized as PRAGUEness in my posts) is harming Washingtonians today. I would not be surprised if it has already killed some of us.

Lest you all come to believe that I am, simply, a cynical old fart with an axe to grind against the Friendly labs and their pointy-headed new member, please find attached an open note that I sent to all of the labs currently serving Washington’s Cannabis industry the other evening.

I sent it out the night before they were all scheduled to meet in Ellensburg yesterday for a magnificent and world-shaking come-to-kumbaya meeting of the labs called by one of the Friendlies through an industry organization that they have unfortunately infested.

To be clear: I am a cynical old fart — but I also occasionally provide what I believe to be positive and constructive input. As always, this input and the narratives I share are primarily informed by the data we, as Washingtonians, are so fortunate to have available.

Judge for yourself whether I have achieved my ideal of being more than a mere raker of muck or thrower of stones through the note below.

I hope they (whomsoever they may be) consider my suggestions.

I appreciate all of you that have engaged through the comment threads on my HI-Blog posts. The constructive commenters and the destructive ones have all had things to share, and I benefitted from them all. A sincere thanks. It has been fun.

Here’ my note to the labs (less a 2-paragraph irrelevant preamble)
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To Washington’s Certified Testing Labs: on the eve of your May 15, 2017 retreat.

I trust you will have a productive meeting in Ellensburg tomorrow.

As I will not be in attendance inside the meeting room tomorrow, I wanted to share a few thoughts with you in advance of the meeting.

In case you are not aware of my prior work relating to Cannabis Quality Assurance and Potency testing in Washington, I’d recommend you check out the posts categorized under COMPLIANCE and TESTING on HI-Blog (www.highintelligence.org). There are now 12 such posts, in total. The ones from Nov and Dec., 2015 are those in which I initially differentiated between a number of labs based on the QA and Potency data they had been reporting during the summer of 2015.

Some History:
Just over 2 years ago, with the release of the LCB Traceability database, a small team of CASP-affiliated volunteers began examining the Washington lab-testing data. That group developed a handful of interactive charts that allowed easy filtering and drill-down into the data. This open-source effort was called the Cannabis Transparency Project and it’s intent was to make the information contained in this extraordinary database much more accessible to operators, regulators, consumers, and other interested parties.

That work was done with a primary goal of enhancing the transparency and value of these data by making it easier for more “interested eyes” to inspect the information being produced by both the labs and by the licensed operators within the State-regulated cannabis industry.

One of the first things the CTP team noticed was an extremely odd distribution of values relating to moisture in tested samples of flower. Something was clearly odd with the distribution around the 15% mark … and the pattern did not seem consistent across labs. Subsequently, a handful of labs stood out from the pack as we began looking at the other QA test results and (with, in hindsight, more than a few regrets) cannabinoid levels.

Variability across labs was significant and did not appear random. Then, the primary developer of our early work took a job out of town, and development on the Cannabis Transparency Project ground to a halt.

Two years later … and almost three years into the brief history of this industry, you find yourselves about to meet en masse to, hopefully, move toward addressing the current crisis of inappropriate and dangerous lab diversity.

To that end, and in my absence from your meeting room Monday, I would like to offer you some unsolicited advice regarding your efforts to improve the service that your sector is supplying to this industry and to it’s customers.

Take it as you will. It comes from my heart.

Suggestions & Input:
To the extent that you wish to self-police, may I respectfully suggest that you not cede power to any one lab or any small clique within the labs. If you develop proposed new standards or policies or tests or guidelines or checklist or systems, please attempt to do so in a transparent way that does not allow any one lab or any small clique within the labs to co-opt your good efforts toward their own ends.

Do not default to taking an easy path that is laid out for you “because it’s already been built”. On the unlikely chance that you have not done so yet, look very closely at the rules the LCB is scheduled to sign off on this coming Wednesday morning. They will re-define much about how you are supposed to do the things that you do. Some of your peers appear to have had a differential hand informing those rules.

Specifically, I would caution you to relegate those labs classified as “Friendly” in my original lab assessment to a non-leadership role in whatever organizations and/or processes you create to make lab-testing in Washington better and more worthy of the trust of both consumers and licensees.

The four labs classified as Friendly that are still in operation in Washington are: Confidence Analytics, Integrity Labs, Testing Technologies, and Green Grower.

I make no value judgement about the data produced by these labs during the June-August window that I examined back in 2015. As experts, I would hope that each of you examine them and form your own opinion. Those initial data come from a time early in the formation of your industry. They come from a time when the labs operating at the time did not know that “interested eyes” were looking closely at what they were reporting.

The current sorry state of your industry has been differentially determined by these labs. Be careful in fighting fire with fire.

Should you develop a website to commemorate your efforts tomorrow, I would caution you to not use the one that has been posing as a coalition of 4 of you for the past year. It has a good DNS name — but a sullied brief history. Start afresh … or wrest it from the hands of it’s current owner and use it as something other than an additional self-promoting arm for that counterpart.

I recommend, as part of your solution set, that you embrace the principle of transparency.

If you attempt to develop processes/standards/SOPs/whatevers that address a lack of standardization in the data being produced across the labs, please do so in a way that lets “correct” be unambiguously understood and that also allows all of your peers to participate without differentially advantaging a few.

If you move toward making more of your lab results publicly available, for example, why not consider using an external open-source platform (not controlled by one of the labs) to achieve that goal? If that sounds reasonable, I’d recommend considering OpenTHC — an effort I’ve been contributing to since the demise of the Cannabis Transparency Project became clear. David Busby of WeedTraQR would be the guy to talk to about that, if you are interested.

It would also be helpful were you to express support for an active surveillance effort assessing your ongoing proficiency. I’m not sure how that might be best implemented, but it would likely take the form of both forensic examination of the data you produce (similar to the work I’ve been doing … but with more PC language used in communicating results) and a well-planned and effectively-executed independent assessment of your ongoing real-world proficiency.

I have been uniformly unimpressed with the positions I’ve seen and heard your industry take with respect to what IS achievable in terms of QA Testing and Potency assessment. I understand the concept that all measurement is imperfect and that there are all kinds of potential biases that can impact results. Going forward, please try to cut through the BS and come up with an accurate assessment of what your proficiency actually is (I prefer PRAGUEness to simple proficiency, as it makes the repeatability and unbiased aspects of “good” explicit).

If, as I believe is the case for most of you, your goal with this current effort is to focus on truly improving the mess that your industry has created, your efforts will have my support and you will have the gratitude of most in this industry and, no doubt, of many other interested parties.

I am glad to have met many of you and believe that you are what my archetype of a testing lab would be in a market that did not so clearly reward unsavory behavior:

Proficient, Reliable, Accurate, Good, Unbiased and Empirical.

On a loosely-related note, there appears to be increasing interest in and attention to terpene profiles. Terpene levels are not currently in the LCB database or reporting requirements. It would be nice, as part of your efforts, were you to suggest that such testing be standardized (the terpenes evaluated and an apples-to-apples measurement thereof) and, perhaps, required for medical product (once, of course, a standardized method for testing the appropriate terpenes exists that is not controlled by one of the labs doing the testing).

This might be a very good area in which to consider posting “your data” on a publicly available open-source platform (a collaborative effort transparently leveraging the totality of the information you are collecting… as opposed to 18 different ways to get to pieces thereof).

Please consider the research (formal and informal) that such collaborative transparency would enable. Think of the patient-, industry- and consumer benefit that could accrue. Think of how this might help to mitigate some of the damage that I sincerely believe has been done to those parties by the behavior, over time, of some within your industry.

Think of how a sincere, professional, honest effort on your collective part could help the emerging industry you support, and help differentiate Washington product and producers and production approaches in a fact-based manner informed by good science. If you do that well, I suspect that the success of your industry – and your positions within it – will only improve.

In the PRAGUE world that I hope your efforts will help achieve, I look forward to being able to better evaluate the products being sold in this market by the labels that your efforts inform.

If your path forward is PRAGUE, please let me know if I can be of any assistance.

Sincerely, and wishing you all the best in those efforts –

Dr. James MacRae
Straight Line Analytics
jim@straightlineanalytics.biz
HI-Blog: www.highintelligence.org