I started Steadfast in 2013 because I learned decades ago about the critical importance of cannabis medicine. At that time, it was clear that the testing called for in the draft of Michigan’s proposed cannabis-regulation bill was undeveloped.
Simply stated, the testing methodology did not exist. It was not until years later that regulatory legislation was passed in the state of Michigan. Steadfast was established with the clear mission to ensure that Michigan consumers could safely rely on the accuracy of its testing data.
In 2015, Steadfast equipped its laboratory and opened its doors in Hazel Park. While those doors were opened only after two years of scientific method development, it would still take several additional years before Michigan’s regulatory framework was established.
The truth is that cannabis testing was not really a business in those pre-regulated years, but it remained a passion of mine. It was with great pride that Steadfast served the citizens of Detroit and surrounding areas by providing its consumers, for the first time, with accurate cannabinoid and terpene data.
Since I chose and remain passionate about this business, I should not complain when Steadfast confronts the same issues in Michigan that cannabis testing labs have faced in all newly regulated markets. These are the very issues that impact the safety and satisfaction of cannabis consumers.
This blog is the first in a series on being a Cannasumer, i.e., a cannabis consumer armed with the knowledge needed to make the best decisions when buying cannabis products.
For example, a Cannasumer will not assume the described proportion of indica vs. sativa is very meaningful in predicting the effects. Cannasumers realize that there is a significant genetic diversity of cannabis, and any attempt to describe it as a mix of two stereotypes fails to provide a reliable prediction.
Cannasumers also know that the effects that one person experiences may be completely different from the effects felt by someone, or everyone, else. If genetic testing is not accurately provided, then who can be confident about that indica/sativa ratio claim?
While consumers often focus on the THC percentage, Cannasumers know better than to assume that a higher percentage of THC on the label equates to a stronger or better effect.
It is common Cannasumer knowledge that the primary component of cannabis flower is THCA, which does not provide a “high,” and that THCA is converted to “active” Delta 9 THC during combustion in a process called decarboxylation.
The Cannasumer knows that most of the THCA during smoking/vaping is lost and not absorbed into one’s endocannabinoid system. The Cannasumer also understands that other factors, such as the amount and mix of terpenes as well as the mix of cannabinoids, are the primary differentiators that determine a Cannasumer’s satisfaction.
Cannasumers must not assume that the THC percentage shown on the label is accurate. One of the biggest complaints across the cannabis industry is that labs, both new ones and ones that have provided data for a while, do not provide accurate cannabinoid potency data.
Even worse, in many of the country’s regulated cannabis markets, a phenomenon known as potency inflation is happening. This occurs when a lab overstates the amount of THC — and once initiated, there is a domino effect in which different state-regulated labs compete to provide ever-inflated potency numbers in an attempt to cultivate business.
In certain states, the potency numbers are ridiculous on their face. Moreover, Cannasumers know that a true 30% THC flower is rare, and they also realize that 40% THC on the label is impossible to achieve for bud.
Cannasumers demand high-quality cannabis and will go to extreme lengths to obtain it. For Cannasumers, potency inflation results in a negative experience because they realize the potency was inflated and the quality did not measure up to the price or expectations.
Cannasumers are the biggest consumers of cannabis; therefore, Cannasumer satisfaction has far-reaching implications for the overall success of, and prospects for, regulated cannabis markets.
It is now legal to “grow your own” in an ever-increasing number of states. There are also long-established illegal markets, as well as regulated caregiver systems, that compete with the newly regulated markets.
In the event Cannasumers have a negative experience when buying weed — whether because of potency inflation or any other reason, such as moldy weed — they are more likely to thereafter ensure they purchase only high-quality weed. On the other hand, Cannasumers drive success in regulated markets that offer a large selection of high-quality and accurately tested cannabis products.
In Michigan, anyone 21 and older can legally grow up to 12 plants, which is enough to satisfy the needs of many a Cannasumer. It has been reported that sales at Michigan grow stores, which sell growing equipment to individuals, have skyrocketed since mid-2020.
There is one caveat, however: Growing is an art and a science. It is exceedingly difficult to grow high-quality cannabis — so growing is not for everyone. Even many Cannasumers do not have the skill set needed to grow high-quality flowers, but they will go to most any length to purchase and consume very high-quality cannabis. The “grow your own” trend in Michigan represents a strong headwind for the regulated market and cannot be ignored.
Michigan Caregivers are individuals who are licensed by the state to grow up to 12 plants per patient for up to five specified state-licensed patients and themselves (72 plants maximum per Caregiver). Michigan has an army of Caregivers; many of whom have honed their art over many years.
Up until late 2020, there was insufficient supply from licensed growers. Consequently, Michigan permitted caregivers to sell their “excess” into the regulated market. That was only a temporary situation because of the imbalance it created between licensed growers, who pay high license fees and have spent significant sums in their initial investments, and the multitude of Caregivers who did not bear those costs. It also opened the door for out-of-state cannabis to illegally enter the regulated marketplace.
In 2020, Michigan disallowed Caregiver cannabis to be sold into the regulated market. So, where did the excess Caregiver supply go? Did it disappear? No, it is still there, and it continues to compete with licensed Michigan growers.
The biggest reason that Michigan represents a difficult market for any cannabis producer is that state Cannasumers know cannabis quality differences down to minor details. Michigan Cannasumers are among the most discerning cannabis consumers in the nation. They continuously seek out only the highest-quality bud.
Fortunately, Michigan regulators have focused on keeping potency inflation in check. When Steadfast reports the rare 30%-plus flower into the state’s seed-to-sale system, we know that a state regulator will inquire as to the proprietary of the test and “request” that the result be rechecked.
With the explosive proliferation of the market and the multitude of new testing labs licensed over the last 12 months, it is important that both regulators and Cannasumers stay alert. In fact, Steadfast’s recent internal testing of commercially available cannabis indicated potency inflation is already common in Michigan.
“Lab Shopping” is a term used in the cannabis industry to describe the actions of producers who shop around for testing labs that provide inflated potency numbers. In regulated markets, Lab Shopping also uncovers labs, whether acting fraudulently or incompetently, that are improperly performing safety tests, thereby passing cannabis that falls below state requirements.
In Michigan, producers know their financial viability depends on providing consumers with safe product that has been accurately tested. However, their ability to provide safe product to consumers is compromised by labs that improperly test, and thereby provide inflated potency and/or inaccurate safety data.
“Accreditor Shopping” is a term used to describe when testing labs are looking to obtain their ISO 17025 accreditation. Different accreditation agencies and auditors have different requirements for meeting the ISO standard, so testing labs can shop around for an agency that will provide such ISO accreditation. The following is an example of Accreditor Shopping:
Michigan cannabis-safety-testing labs are required to be ISO 17025 accredited within one year of licensure. Despite attempts by multiple labs to get a certain microbial method accredited for measuring yeast and mold levels in cannabis, ISO auditors found the method was not properly validated (the “Improper Test”) and withheld its approval.
Undeterred, some Michigan labs went Accreditor Shopping and successfully latched onto a different agency/auditor with lower requirements that was willing to approve the Improper Test.
I specifically asked this accreditation agency why it approved the Improper Test. It responded by stating: “(The approving accreditation agency) has provided accreditation for competent testing performance of the method listed on the accredited laboratory’s scope of accreditation but does not have any authority to determine its appropriateness for specific uses.
Those types of legal acceptance determinations are established by regulatory bodies (local, state, federal) and in many cases by industry groups identified by regulatory bodies as eligible to establish and monitor applicability.” In other words, this Accreditation-Shopped agency/auditor approved a method despite the fact that it does not know whether the method is appropriate for testing yeast and mold levels in cannabis.
This is in stark contrast to the way other ISO auditors conduct an assessment. While it would seem to be the job of the ISO auditor to require that methods meet defined specifications required by the applications for which they will be used, it is not always done that way.
I specifically asked a leader of a leading accreditation agency for cannabis labs in Michigan about this case. She did not understand the explanation provided by the agency that approved the Improper Test, stating: “I am not clear why (the approving accreditation agency) would say they don’t review techniques labs choose to use based on state regulation. If the lab has a protocol to meet certain state regulations, then it should be applied during their assessment.”
However, she is still trying to answer my follow-up question about why an auditor within her organization approved the Improper Test also. I will keep you posted.
It was more than disheartening to finally realize, after almost three decades in analytical testing and after leading a half-dozen labs through ISO 17025 accreditation, that the difference between auditors can be so stark and that such serious errors are made.
The state regulatory agency (MRA) later intervened to ban the sole use of the Improper Test. This disturbing event highlights the need to meticulously scrutinize laboratory accreditations and the varying requirements different auditors might apply to approve cannabis testing methods.
If you are a Cannasumer, you already know the necessity of evaluating cannabis products. What steps should the remainder of the cannabis consuming public take to assure their personal safety? The answer is simple: Education.
Steadfast submits that consumers must start their education process by becoming familiar with the various state-approved testing laboratories, particularly those testing the cannabis they purchase and consume. The consumer should research the backgrounds of labs, as well as the past records of the owners and management thereof, to determine the reason those labs ventured into the cannabis industry.
If a lab’s owners or management have previously been suspected of and/or implicated in improper practices, then consumers should be extremely wary of purchasing/consuming products tested by those labs. If you determine that a lab is a branch of an entity in another state and is known for potency inflation, be wary that such potency inflation may part of its corporate DNA. Seek a lab that is transparent and willing to take the time to answer your questions.
If you do your own research and find a trustworthy partner in safety testing, then you are well on your way to becoming a Cannasumer. For those consumers who have had negative experiences and feel “ripped off,” confused or scared of the products you purchased, allow Steadfast to guide you on your journey to become a Cannasumer.
Let Steadfast be your partner in safety testing. Get the answers you seek by contacting us at (248) 242-2291 or by emailing firstname.lastname@example.org.