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Category: Cannabis Testing

Seed to Buds

Meet Randon. He’s the operator of Well Rooted Genetics here in Oklahoma and he’s a connoisseur of consumption, with food and cannabis! He’s a big time foodie and has a memory with smells that take him back. He has learned about curation and flow with the different experiences he has had, with the plant having more textures and smells than any other species we have. He enjoys a good salad mix and bringing people together, because we’re ALL artists.

I had the opportunity to attend the very first exploration dinner, “Seed to Buds”. Which was an experience where artisans of two separate crafts came together to create. This is where the Underground Ghost Kitchen comes in. It was an experience curated by Randon with Well Rooted Genetics and the UGK team. Roger curates the events and Jesse is the main chef for private dining events.

By providing experiences like this in Oklahoma, we’re essentially bridging the gap and blending the two worlds, by elevating the state and opening up new doors for the evolution of plant medicine. The goal of this dinner pairing was to utilize all of the plant in ways that compliment luxury ingredients.

Upon walking into Randon’s beautiful home, I was greeted with a cocktail and smiling faces. More people started rolling in, all faces of industry gems. Conversations and laughter flowed throughout the whole night. There was good hash rosin present, along with glass tip joints, that I have to say I need more of in my life! The glass tips are such a game changer when it comes to taste and flow, so take note. Everyone found a seat at the table, with a guided menu on what to expect for the evening and then it began.

There were many many intricate dishes that made this experience special, along with the option for mocktails for those that requested them. The UGK team also caters to those with food allergies and different preferences. The dinner menu was set up to complement strains like Zacio, Birkinz, Frosted Waffles, and Gelenade. Here are some descriptions on what I got to taste!

The snacks were a favorite of mine and consisted of Pani Puri, herbed boursin, greens and a lavender clover club cocktail to pair with Gelonade. There was also a cauliflower salad with asparagus, espuma and a Monstro Striga Cerasuolo d’ Abruzzo to pair with Zacio, and for the main course we had an herb crusted loin coated in East Side OG kief, with peas, potato, and a Maison Passot Fleurie wine paired with Birkinz. To cleanse our palates, we smoked Superboof that was rolled with a glass tip by Zenoa Cultivation, along with orange granita, mango sorbet and strawberry. (the mango sorbet was a favorite of mine). We then followed that with a dessert that was a creme fresh honeysuckle lemon cake with a Lambrusco drink, paired with Frosted Waffles. All of the signature craft cocktails were made by bartender Paul, with Thirst Wines.

We had Chef Jessie Gomez explaining every dish to us, down to each ingredient and herb used and why. As the dishes were presented at the table, it was something I appreciated so much! It brought an intimate experience for everyone there. The cocktails were all so delicious and I truly enjoyed every one, with every dish!

What an experience this seed to bud dinner pairing was! Such a beautiful thing to be a part of. From all of the yummy and refreshing drinks to pair with the food and different tasty strains from local growers, it was beautifully curated with so much intention and passion poured into it, from the creative minds that brought an experience like this to life!

Cheers to some really good company and really good cannabis. So cool to see it! This is what we need here in Oklahoma and I’m stoked to have been a part of this in Oklahoma City. It’s amazing what all we can do together when we combine the things we all love.

Congress Boards the MJ Research Train

by Sarah Lee Gossett Parrish, Cannabis Lawyer

In the wake of passing the MORE Act, which I wrote about in my December 2020 column, two other Acts related to marijuana were passed by Congress at the end of 2020. The U.S. House of Representatives approved the Medical Marijuana Research Act (“MMRA”) on December 9, 2020. MMRA is bipartisan legislation introduced by U.S. Representatives Earl Blumenauer (D-OR) and Andy Harris (R-MD) that addresses the burdensome impediments to legitimate medical research. Subsequently, on December 15, 2020, the U.S. Senate approved its own bipartisan bill, the Cannabidiol and Marihuana Research Expansion Act (CMREA). The CMREA also promotes cannabis studies and addresses current impediments.

More Act by Sarah Lee Gossett Parrish

A 2017 report by the National Academies of Sciences, Engineering, and Medicine found that “research on the health effects of cannabis and cannabinoids has been limited in the United States, leaving patients, health care professionals, and policy makers without the evidence they need to make sound decisions regarding the use of cannabis and cannabinoids.” Thus, passage by the House and Senate of MMRA and CMREA is good news moving into 2021. It appears that Congress finally recognizes the value of cannabis research, and plans to encourage studies by removing antiquated federal roadblocks. The caveat is that, in order for federal legislation to become law, it must be passed by the House and the Senate, and signed by the President. Hopefully, Congress will reach an agreement on a unified version of these two bills during the early months of 2021.

Barriers to Cannabis Research

Federal law severely limits studies concerning health benefits of cannabis. There is a burdensome registration procedure, protocol reviews are redundant in many instances, security requirements are onerous and unnecessary, especially given that approximately ninety-nine percent of Americans now live in a state where marijuana is legal in some form, and there is just a complete lack of significant research. Limitations also apply to where marijuana for research can be obtained and unfortunately, the quality of that marijuana has been poor—a recognized fact now—which has inevitably hampered accurate results of any significant research studies concerning its health benefits

Cannabis Testing by Sarah Lee Gossett Parrish

Source Limitations for Marijuana Used in Research Since “marihuana” remains a Schedule I substance under the federal 1970 Controlled Substances Act (“CSA”), the Drug Enforcement Administration (“DEA”) regulates its cultivation for research purposes. The DEA controls registration requirements and establishes annual aggregate production quotas under the authority of the CSA. Unbelievably, the DEA has issued only one registration for research marijuana cultivation—to the University of Mississippi. Thus, only the University of Mississippi has been authorized to grow marijuana for use in research studies. Every few years, the University designates the land where marijuana crops are grown based on current and expected demand. Then, the marijuana is grown, harvested, stored, and made available in bulk or as particular elements of the plant, for use in research. The subpar quality of the University-grown marijuana renders it almost useless in conducting serious studies that might yield reliable, usable data leading researchers to significant conclusions about marijuana’s health benefits.

Additionally, studies have shown that this marijuana has lower levels of THC and CBD as compared to commercial grade cannabis products and is, in fact, genetically closer to hemp than the marijuana varieties sold at dispensaries in states where marijuana is legal. Given that marijuana and hemp are genetically distinct, reliance upon the low-grade marijuana cultivated at the University of Mississippi for research about its health benefits is problematic. Participants in studies who consume the varieties cultivated at the University may experience vastly different effects than patients and adult-use consumers that obtain their marijuana product from dispensaries, yielding unreliable results and faulty conclusions. However, efforts by the DEA to expand the number of federally authorized marijuana cultivators for research purposes are underway, and passage of the above pieces of legislation will likely ensure that higher quality marijuana becomes available for research purposes.

Medical Marijuana Research Act

The MMRA achieves four main goals. It addresses the poor quality and inadequate supply of medical-grade marijuana available for use in research; provides a clear path for researchers to study cannabis products used by patients and adult-use consumers pursuant to state-legal programs; streamlines the unduly burdensome, redundant process that researchers must navigate before obtaining a license to conduct marijuana research while guarding against misuse and abuse; and requires that the Secretary of the U.S. Department of Health and Human Services provide a report on the status and results of new research concerning the health benefits of marijuana.

The full text of the MMRA can be found here.

Cannabidiol and Marihuana Research Expansion Act

The CMREA, passed by the Senate, is primarily intended to streamline the application process for researchers to study marijuana and to encourage the Food and Drug Administration to develop cannabis-derived medicines. The congressional summary of the Act states that it allows “accredited medical and osteopathic schools, practitioners, research institutions, and manufacturers with a Schedule I registration” to cultivate their own cannabis for research purposes. This provision would insulate researchers from the requirement of using the poor quality marijuana cultivated at the University of Mississippi.

The Act also specifies that physicians can discuss the risks and benefits of marijuana with patients, and, in similarity to the required report under the MMRA, requires the U.S. Department of Health and Human Services to submit a report concerning the potential health benefits of marijuana and addressing barriers to cannabis research and how best to overcome those barriers. The CMREA has been endorsed by mainstream medical organizations, including the American Academy of Pediatrics, the American Medical Association, the American Psychological Association and the American Society of Addiction Medicine.

The full text of the CMREA can be found here.

 

Differences in MMRA and CMREA

One major difference in the MMRA and the CMREA is that the House bill (MMRA) allows scientists to obtain marijuana from dispensaries in legal states for research purposes, whereas the CMREA allows them to cultivate their own marijuana for such purposes. Both provisions are clearly designed to circumvent current federal requirements that marijuana used for research purposes must be cultivated at the University of Mississippi. Another difference in the two pieces of legislation is the provision in the CMREA protecting physicians from penalties under the CSA, to allow discussion of risks and benefits of marijuana products with patients.

Will we see more federally-approved marijuana research projects in 2021?
Stay tuned.

Information contained herein provides general information related to the law and does not provide legal advice. It is recommended that readers consult their personal lawyer if they want legal advice. No attorney-client or confidential relationship exists or is formed between you and Ms. Parrish as a result of this article.

Cannabis Testing

Inexact Methods Amidst Exact Science

by Sarah Lee Gossett Parrish – Cannabis Business Lawyer
Cannabis Testing Series Part I

Recently OMMA amended its Rules concerning testing requirements for medical marijuana and even generated a one-page diagram to illustrate the guidelines for ease of compliance. However, these amended rules fail to address the overall issue that plagues cannabis testing across the country—inexact methods amidst exact science. Clearly, the lack of standardized protocols to assess cannabis products for potency and safety poses a huge problem for testing laboratories, patients, and, in those states where adult use is legal, recreational users.

Disharmony in state regulations and the processes used by state-licensed laboratories that test cannabis is extremely disconcerting.

When it comes to determining maximum residual limits (MRLs) of contaminants and adulterants, and specifying the levels of tetrahydrocannabinol (THC), cannabidiol (CBD), terpenes, and the other currently-known constituent components in cannabis (which exceed 80 in number), it is possible that two certified labs could utilize two different testing methods on identical samples to reach two similar, but not identical conclusions.

In fact, a 2018 report by Marijuana Business Daily disclosed that there are numerous accounts of labs producing starkly different potency measurements for identical products, with results varying by as much as 40%. This information is troubling and confirms that the issue must be addressed by the industry as a whole and by our own OMMA.

Are OMMA’s Residency Requirements Unconstitutional? by Sarah Lee Gossett Parrish

Ideally, such lab certification requirements and the testing processes and protocols would be developed for the cannabis industry as a whole, at the national level. However, given marijuana’s continued status as an illegal, controlled substance under federal law, a national, standardized set of testing regulations is unlikely to be developed in the near future. But that does not preclude the development of same here in Oklahoma. This standardization would reduce product recalls and make it more difficult for rogue labs to engage in pay-for-results schemes like the recent debacle involving an OMMA-licensed laboratory that was stripped of its license upon discovery of its dishonest testing methods.

While many labs consider their processing and protocols to be proprietary, confidential information, arguments to the contrary are substantial. Standardization of testing methods would eliminate the variability in test results for marijuana potency and in testing for contaminants. Lab protocols often differ in the specific solvents or reagents used during extraction and analysis, and the instruments used by labs can have different manufacturers and calibration standards, both of which will contribute to variations in testing results.

When labs arrive at different results for tests run on identical samples, chances are high that each laboratory is analyzing its sample using a different method.

Without properly validated methods and laboratory certification programs, this lack of uniformity in test results will continue, to the detriment of patients and medical marijuana businesses here in Oklahoma.

Additionally, the wide variety of cannabis products can, in and of itself, complicate testing and contribute to the lack of uniformity in test results, particularly when those conducting the testing do not have formidable scientific backgrounds and/or degrees. Some cannabis products are easier to analyze than others, and each product must be subjected to a customized cannabinoid extraction method before ingredients can be successfully tested. Many employees in Oklahoma testing laboratories are not steeped in scientific degrees or backgrounds. Thus, differences in test results are all too common.

Oklahoma Seed-to-Sale Tracking by Sarah Lee Gossett Parrish

While safety testing is, at least in principle, more standardized than potency testing because labs can rely on methods federal agencies have approved as to other botanical products, there remains a serious concern about the lack of uniform directives as to safe levels of contaminants and application of those levels to smokables versus edibles, the former being a mode of consumption that poses different risks than edibles.

More studies are needed concerning thermal combustion and degradation of pesticides prior to inhalations, to ensure safe threshold levels are known and enforced.

OMMA should consider this variant in its requirements for the testing of smokables versus edibles, and develop standards applicable to each type of medical marijuana product to ensure proper testing and regulation of same.

While lab certification procedures and uniform testing standards should be a top priority for every state, every patient, and every cannabis business, this does not seem to be the case in Oklahoma or in any other state, currently. Efforts must be focused on these important issues to ensure that cannabis products available to patients here in Oklahoma are safe, and that the laboratories licensed by OMMA who are testing those products place integrity above profits, are operated by knowledgeable persons with backgrounds in the sciences relevant to cannabis testing, and are equipped with clear and concise regulations that specify uniform testing methods and outline acceptable potency and safety testing results.

What’s the take-away?
Stay tuned.