Quality Control – Whether or not it’s realized, we all benefit from smart, sensible quality control & regulations every single day.
From the humble potato chip to the big screen TV, almost all goods and products go through some fashion of quality checks to ensure the end result is up to par; without quality control practices, that potato chip might have been nibbled on by a rat, or your new television set might explode after being plugged in the first time.
In the United States, the FDA (Food & Drug Administration) typically oversees regulations designed to keep our food & drugs safe. So if the FDA is regulating consumable goods, that must mean that cannabis also has a standardized set of quality control measures… right? The answer to that question isn’t so cut-and-dry.
In today’s article we’ll be talking about quality control, how it relates to cannabis, and what the (often serious) ramifications of a lack of quality control can be. Let’s dive in.
What is Quality Control?
Quality control is the act of ensuring, well, quality in a manufactured good. As a producer of goods and wares (and often services as well) it’s important to have a level of standardization in your product.
As with the above examples of the rat and the TV set, quality control measures ensure that the end consumer (IE: you) isn’t at risk for engaging with your brand.
The forms that a company’s quality control procedures take may vary, but in many cases these practices are enforced to a standard of some fashion, with various governmental branches overseeing different industries or aspects of labor (the ATF for alcohol/tobacco/firearms, OSHA for worker safety, etc.)
Quality Control & the FDA
In particular the FDA has a large number of responsibilities under its umbrella, with regulatory powers over all food and drugs sold within the United States. If it is meant to be consumed (and isn’t alcohol or tobacco), it likely falls under the purview of the FDA.
But what about weed? And other cannabinoid products? What agency in the federal government regulates cannabis and hemp? Well….
Cannabis, Supplements, Legality & Reviews
… of course there is no federal agency that currently regulates cannabis production or consumption.
While the DEA enforces cannabis law as it pertains to nation-wide prohibition, there are no regulatory boards that oversee cannabis (or hemp) as a consumable good. Let’s take a quick detour into why that is:
Under US federal law, there are essentially two “types” of products that can be made from the hemp/cannabis plant: Goods that contain less than 0.3% Delta 9 THC, and goods that contain more than 0.3%. Any good that contains more than 0.3% Delta 9 THC content is considered federally illegal; full stop.
This law also applies to the plant itself – Any plant containing less than 0.3% D9 THC is considered “hemp” under the law and thus legal, while anything above that limit is considered “cannabis” and only legal under the purview of certain states (and if you would like to learn more about the other differences between these two plants, please visit our article “The Differences Between Hemp & Cannabis” for further reading).
Cannabis products such as CBD oils or CBN powders (and even Delta 8 THC) are allowed under federal law, so long as they can be verified to be below 0.3% D9-THC content. However these products are not considered food-stuff or pharmaceutical drugs. They instead fall into the interesting loophole of “dietary supplements”.
What are Dietary Supplements?
We’ll talk more about “dietary supplements” in our upcoming article “The Potential Dangers of Contaminated Cannabis”, but in brief:
A “supplement” is defined in the Dietary Supplement Health and Education Act of 1994 (DSHEA) as a “product taken by mouth that contains a “dietary ingredient” intended to supplement the diet”.
Though most supplements come in the form of pills, gelcaps, liquid medicines and the like, other forms (such as snack bars) are allowed, so long as the labeling and packaging does “not attempt to represent the product as a conventional food” nor attempt to make claims that it will “cure, treat, mitigate, or prevent depression and other mental health disorders”.
If you read the above paragraph and thought to yourself “gee, that sounds kinda broad”, you would not be alone in that line of thinking.
The category of “dietary supplements” contains a large amount of potential entries, and with very little oversight and regulation as to what goes in them (and again, for more on this topic, please check out the above link).
Supplements & Health Risks
Tales of people being hospitalized due to taking dangerous supplements are not uncommon.
With a lack of thorough oversight, supplements can typically contain whatever the manufacturer decides, and at whatever level of cleanliness/overall quality they decide to produce.
Supplements often contain ingredients that may have unknown side effects, or even worse (and due to lax regulatory controls on supplement manufacturing standards), can include chemicals such as pesticides and heavy metals (lead, nickel, mercury, etc), many of which can be highly toxic.
Growing in the Legal Cannabinoid Market
Being from a plant, cannabis & hemp are grown much the same way as other plants – Light, water, fertilizer, proper temperature control, etc.
Different growing techniques and conditions can alter your overall yield and crop harvest, and often the more a grower is willing to spend, the more volume they’ll be able to produce.
Cutting corners in search of a profit can be easy, though. Skimp out on your water filtration? Undesired chemicals can make their way into the root system (and ultimately buds) of your plants.
Using a cheaper, grey-market, unapproved pesticide to increase your crop yield? Said pesticide may have harmful effects on humans, but you just increased your margins by 28%.
Ultimately, with a lack of strong federal oversight on the growing process of cannabinoid-bearing plants, there are no impositions on manufacturers to follow basic health & safety guidelines for growing their crops (as said basic guidelines don’t exist in the first place.
What Does Sensible Cannabis Quality Control Look Like?
To begin with, sensible cannabis QC starts at the growing level. Manufacturers of cannabinoid-related products should be using approved pesticides (or none at all), clean soil & water, proper fertilization, and the like.
Likewise, harvesting & manufacturing should also be subjected to the same types of procedures as other digestible goods – You no more want that rat we mentioned in the intro nibbling on your bud than you do your potato chips, and basic, universal cleanliness standards that apply to other food-stuffs and goods meant to be consumed should be natural to apply.
Beyond the production stage, though, are tests designed specifically to help with cannabis quality control that can be done at the third-party (IE: not the original manufacturer) level.
“Gas chromatography” (often abbreviated to “GC”) is a method of passing a non-reactive gas (hydrogen, nitrogen, and helium are common) through a material, essentially carrying assorted molecules away from the desired test subject for analysis.
In this way, laboratories are able to look for and analyze numerous compounds present inside cannabis, even beyond cannabinoids. Pesticides, metals, and other contaminants are able to be detected by the GC analysis and in their proportional amounts – Important when, for example, testing CBD products to ensure they are below the 0.3% D9-THC mandate.
The Importance of Third Party Testing
Typically lab test results for cannabis products are posted publicly on a manufacturer’s website, and will be done by an independent third party; operating under a “wolf in the henhouse” philosophy, third-party lab tests are meant to show a level of accountability, as it is to be assumed that the third-party laboratory can provide it’s results without bias toward the original manufacturer.
These types of tests often apply to both THC-bearing products and other legal cannabinoids as well; in general, it is our recommendation (and the recommendation of most medical professionals) to make sure the cannabis or hemp products you purchase have easily accessible, verifiable third-party testing results, that check not only for cannabis compounds but other potential contaminants.
For legal cannabinoid products, such as CBD, there is at least some fashion of governmental oversight – Again, as legal cannabis products must be marketed as supplements and not food/drug items, the amount of oversight available is slim but still present. But for substances that the federal government has declared illegal, such as delta 9 THC?
The Wild West
If a substance is federally illegal it moves beyond the purview of the FDA and, as mentioned earlier, into the authority of the DEA (Drug Enforcement Agency).
Delta 9 THC-bearing cannabis, despite being legal in several states, is still illegal at the national level, meaning there are no firm directives on a national level as to how cannabis should be grown, treated, harvested, and the like.
Individual states, such as California, are starting to implement their own state-run regulation boards for cannabis goods, with state-approved testing requirements, content regulations, and more.
However, this is on a per-state basis; not all states have implemented these types of quality controls and the level of regulation can vary heavily from area to area. Without a dedicated federal-level governmental bureau to standardize quality control measures, the cannabis industry still remains highly unregulated.
What Happens Next?
Unfortunately, without oversight on a federal level, the above-mentioned issues will continue to persist.
Even if individual states enact regulatory boards there is still a lack of unification in those regulations – Each state will likely, either in large or small parts, have differences in their requirements, leading to overall confusion in how cannabis products should be tested and checked for potential concerns.
Though signs seem to be trending toward a greater nationalized legalization (or at least decriminalization) of cannabis, there are no guarantees that this will happen swiftly or at all.
And while we wait for legislation at the national level individual states are still caught flailing when it comes to their own sensible cannabis regulations; this isn’t even to mention areas such as Idaho where all cannabinoids are illegal, or Mississippi which recently saw 73% of its state population vote in medicinal cannabis laws, only to have them overthrown by the state supreme court due to technicalities in how the ballot measure was gathered.
Is there a solution? Again, federal legalization and regulation of cannabis – similar to the existing regulations we have surrounding food goods and drugs – would be the most thorough answer to the question.
But, in the here-and-now, the best option is to look for cannabis, CBD, and other cannabinoid products made by manufacturers who are open and transparent about their quality control practices.
As said above, our advice is if a manufacturer’s website doesn’t at least offer full and third-party verified laboratory results for their cannabis products, it’s best to stay away.
We hope our article has helped leave you feeling more informed about your choices when buying legal cannabis products. Our bottom-line advice? No lab tests, no buy. Happy smoking!