Green Point Research, a vertically-integrated phytocannabinoid-rich hemp biomass originator and processor launched a new webinar series in collaboration with ACS Laboratories (ACS) last month, which focused on hemp testing, including what farmers need to know about having their plants tested throughout the growing and harvesting process.
Green Point Research Chief Legal Officer, Light Townsend, provided compliance expertise and best practice guidance during the educational series.
Roger Brown, President of ACS, spoke during the first webinar and noted that ACS receives samples from 44 states. Since Florida has the strictest restrictions of any state in the hemp market, Brown said it is better to test here if a company wants to sell nationally.
Each of the three webinars focused on a different aspect of testing and compliance. Here are some highlights from the series:
Day 1: 5 Steps to Hemp Compliance with Strategic Testing
- Lot Design
Making sure you are strategic when deciding your lot size is important. While the growing rules are not specific about lot size, only one strain of hemp is allowed in each lot. Farmers can also have multiple lots. Some farmers opt to keep their lots small to mitigate risks. If one plant tests too high for THC levels, the entire lot has to be destroyed.
- Test with a USDA Compliant Lab
Labs are required to be registered with the DEA and USDA. It is a red flag if a lab will not show farmers their registration(s). Finding the right lab to test with takes experience.
- Strategic Testing Timeline
In order to be compliant with state regulations, Florida farmers only need to have their product tested for THC potency before the plant is harvested. However, farmers are encouraged to test “from soil to oil.” Testing soil before planting for things such as pesticides and heavy metals can impact your crop. Testing can also be done throughout the life of the plant before it is harvested to ensure it stays on track for low THC levels, or to check its microbiology and pesticide levels.
Thirty days before the harvest, farmers must notify the Florida Department of Agriculture and Consumer Services (FDACS). If using ACS for testing, they must be notified 15 days before the harvest for their hemp clipping potency test. Results from those tests are sent to both the farmer and the FDACS. In order for a plant to be compliant in Florida, it must have less than 0.3% THC.
- Monitor the Potency
Stress causes hemp plants to produce more THC. Regulations call for testing of total THC. The formula is (THCA x 0.8777) + Delta9. There is an allowed variance of plus or minus 0.5%.
- Publish Your Results
Results are given as Certificates of Analysis (COA). The certificate includes results from all tests done, including cannabinoids, safety and potency. Having a COA provides customers with confidence and transparency.
Harvesting hemp only requires the potency test, but if you want to sell the product, more tests are required. Other testing can include testing for 67 different pesticides, as well as heavy metals and mycotoxins.
Day 2: How to Read a COA for Hemp Testing
Joseph Jeffries, an account executive with ACS, went over the COA in greater detail for day 2. He also went over some regulation and labeling issues that are often seen in the hemp industry. The Journal of the American Medical Association found that 70% of product labels misrepresented their potency. The same study also found that 20% of products contained unmentioned THC. Some of these problems, Jeffries said, stem from a lack of education and a national standard in testing for the young industry.
Each COA will have a header that includes a date and important information about the product and company. The results summary will have detailed percentages from the tests taken. It will also include a breakdown of the common cannabinoids found in the product and their potencies. One main test looks at 11 different cannabinoids, but some labs can test for up to 17. This data is important because it shows exactly what is in your product. Remediation is possible for some products if test shows failed results.
The bottom of the certification should be signed off by someone at the testing lab, and should also include a license number and contact information for that lab. If a COA does not include that information, it is considered a major red flag.
Other red flags for COAs are a lack of, or failed contaminant testing, results missing common cannabinoids, noncompliant THC levels, CBD levels with more than 10% variance from what the product claims, or less terpene content then claimed.
Day 3: Hemp Post Harvest Success
Masha Belinson, who works in corporate development with ACS, led day 3 of the webinar and focused on terpenes. Terpene tests are not required, but are a good way to differentiate your product in the market. She added that if farmers are growing for consumption, they need to shift their thinking to trichome farming: genetics, cultivation, and then curing and drying. Farmers need to be mindful of all three elements at once.
Terpenes are the “steering wheel of cannabinoids,” Belinson said. They are responsible for the fragrant aroma in plants. They are denatured by oxidation, which happens during the drying and curing process. Testing is readily available for at least 38 different terpenes. Farmers can test for terpenes after extraction and after product production. If something is added to the crude, it must be tested again. The final product has to be tested by law.
Balinson also went over new FDACS rules that went into effect in mid-September. The entity is now regulating any hemp product that can be taken through the nasal passage or mouth. Anything that’s inhaled must be packaged in containers which reduce exposure to light. Testing requirements for smokable hemp need to show that the farmer worked with a designated lab that proved the product had less than 0.3% THC, and it is free of contaminants such as mold, pesticides, and metal. Ingestible products follow the same rules, except they must also be tested for Vitamin E acetate, 2,3 butantedione (which is a diacetyl), and aspergillius.
Anyone who sells smokable hemp must also have a Hemp Food Establishment permit, including online stores. Inhalable products must follow the same labeling requirements are ingestible products. Smokable product also needs the name and address of manufacturer, the amount of each cannabinoid per unit, no medical claims that could label in a drug, and the disclaimer “this hemp extract product is not intended for ingestion.” Smokable hemp cannot be in open displays accessible to customers.
Here is a link to the full webinar series: https://www.youtube.com/playlist?list=PLP4xBk_i24IpsPtdmFpRHuYsRR4TyVOtf
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