BENCHMARKS OF AN ACCOUNTABLE ANALYTICAL LABORATORY
BY LEAH BRAGGS
AFTER TAKING TWO heavy samples from the very same harvest to two different laboratories for analysis, we expected some variation in the test results, but figured they’d at least be in the same ball-park, right? Regrettably, precisely the opposite proved to be true, encouraging us to investigate who is holding these analytical labs accountable for their results. After some research (google) and talking to some friends in the biz, sadly we learned that nobody is really holding anyone accountable. Sure there are some government agencies collecting fees on a state level but who’s actually paying attention? Nobody. At least not yet.
As states legalize cannabis for both medical and recreational use, it is clear that lawmakers and patients are both concerned with the quality of the cannabis available for consumption. Legislation in every state continues to call for lab tests to be performed by state-approved laboratories, but recent studies have found that inconsistent results are more common than not when it comes to cannabis.
The Journal of the American Medical Association recently published findings that only 17% of cannabis products were accurately labeled for content in San Francisco, Los Angeles, and Seattle. The study randomly selected 75 products from 47 different brands and independent testing found that 17% were labeled accurately, 23% were under labeled, and 60% were over labeled with respect to THC content. Even though the testing of cannabinoid content is being required by more and more states, without a standard method to regulate labs, results will always vary from lab to lab.
Emerging from the pack are a couple of regulatory and advisory panels that hope to set the record straight about which labs are putting out accurate numbers. The Emerald Test® is an Inter-Laboratory Comparison Proficiency Testing (ILC/PT) program for evaluating how accurately labs perform, by comparing how well the lab measures an anonymous sample. These programs are the standard in many testing industries, including environmental, food, pharmaceutical, water, petrochemical, and others. The results provide a benchmark for the industry in general, by elucidating how well the labs perform collectively. The data can also be used by the individual labs to demonstrate proficiency to their customers, or used internally to identify areas in need of improvement. The ILC/PT is now used by some state regulatory bodies as a component of certification programs, and is commonly a requirement for various ISO certifications. Finally, the results provide a measure of assurance and reliability to the industry as a whole, and particularly to those who depend on the testing lab’s results for safety, health and product performance.
The Emerald Test® is offered twice each year (though individual PT’s are always available).
The Emerald Test® takes place in the Spring and Fall of each year, with enrollment open for a set period of time. The components of each test are determined by the Emerald Test Advisory Panel. Test Samples are manufactured by an ISO 17043 accredited PT provider and require overnight shipping. After receiving and testing the sample, labs have a window in which to complete the test and submit their results through an electronic data portal. Data analysis provided by AOCS using software designed to meet requirements of ISO 13528:2015.
Labs receive their individual results, and once analysis is complete, receive the overall test results, to see how they performed in relation to their peers. Individual lab data is held in strict confidentiality and labs that perform within a specific tolerance are awarded an Emerald Test Badge. The only setback to this methodology is that the test cannot be performed on whole plants but rather a controlled solution due to Federal regulations.
The NELAC Institute’s National Environmental Laboratory Accreditation Program however accredits qualified laboratories for testing under the Clean Air Act (CAA), Clean Water Act (CWA), Resource Conservation and Recovery Act (RCRA) and the Safe Drinking Water Act (SDWA) and cannabis testing. NELAP offers Cannabis Potency Proficiency Standards intermittently via its individually licensed state accreditation programs. They typically offer testing for THCA, THC, CBDA, CBD & CBN and not the complete offering, but this is a fine way to measure the effectiveness of your procedures internally as a lab and at the very least shows that a lab intends to do the right thing wherever possible. Because of NELAP’s individually qualified state labs, like ORELAP in Oregon, they are able to offer testing of actual cannabis plants because of their intrastate nature.
Beyond looking for The Emerald Test’s Emerald Badge of Approval, or NELAP Accreditation, there are some simple steps you can take to make sure you are getting the proper analytical test results you paid for. First and foremost, don’t even consider a lab that doesn’t harvest their own results in-house. Sent out for analysis? Who’s accountable? And besides, even just one middleman increases your margin of error or cross contamination. Analytical chemists are best suited for testing cannabis ideally because of their ability to navigate the complex matrix of cannabis. The competency of the individual testing your cannabis products is more important than the equipment being used itself.
That said, detecting pesticides at 100 parts per billion or 0.1 parts per million is difficult to do by any other method except liquid chromatography-tandem mass spectrometry (LC-MS). Furthermore, you should try to get a one on one with the scientist who will be performing the test. Ask them about their equipment, procedures and guidelines or accreditation and try to get a feel for their passion for their craft and their propensity for perfection. For more accurate results, give the lab a sufficient amount of varied flowers from head colas to side colas and even popcorn. Try to make the sample indicative, ratio-wise of the overall batch you intend to label with those particular results.