We have taxed our planet for far too long. While many people still debate the validity of concepts like global warming or industrial pollution, retorting about how cold the winter was, or finger-pointing at who’s to blame (e.g., SUVs vs. industry vs. the sun), others look at data and take action. Every industry, especially new, major players like cannabis and hemp, needs to be mindful of quality, of reproducible and safe products and experiences, and of the need to exercise sustainability every step of the way.
To date, no federal testing requirements for hemp or cannabidiol (CBD) products exist outside of checking that total tetrahydrocannabinol (THC) levels are compliant. Some states (e.g. Florida) have decided to spring to regulatory life. Regardless, there are companies that proffer expertise to neophyte and veteran businesses that understand the intrinsic need to incorporate sustainable, compliant routines, but don’t have the answers regarding how to make that happen.
I spoke with Ian Rice (CEO), Phil Engfer (COO), and Valentina Temerario (Certification Director) at Envirocann to discuss the aspects of the cannabis and hemp industries that are particularly lacking from a quality assurance (QA) and quality control (QC) perspective. Envirocann is a 3rd-party certification organization that validates that best management practices “are used to grow and process cannabis and ensures environmental stewardship and compliance to local and state regulations” as per the company’s website. The team performs regular on-site inspections and requires analytical data on each crop or product they certify, providing a robust examination of every aspect of the Cannabis sativa ecosystem.
“In hemp farming and processing, there may be little or no oversight in terms of farming practices, pesticide application, labeling requirements, worker safety, environmental stewardship, and overall supply chain safety,” said Rice. “Heavy metal contamination, for example, is a serious consideration with hemp being a metal bioaccumulator.”
A Lack of Unified Standards
Rice also pointed to the troublesome fact that there are no QA/QC label requirements for hemp and CBD post-process products, such as edibles, skincare formulations, and tinctures.
When it comes to federally illegal, THC-rich products, there are obviously no national standards regulating cultivation and manufacturing. “Standards, regulations, and QA/QC measures vary state by state,” Rice said. “In California specifically, the regulations are so strict, it’s challenging and expensive for producers to even achieve them. A lack of sensible standards affords a competitive edge to the long-standing black and traditional/gray markets.”
Rice feels that gaps in analytical and product standardization induce risks that could be damaging to the environment while presenting downsides for the end-user.
At the Grow
When considering cultivation operations, Envirocann evaluates the entire growing process, from the site to the materials and practices used to cultivate the plants.
“Envirocann audits best practices regarding natural resource and waste management and workers’ safety,” Temerario added. “At the EnvirOganic level, we look for a demonstration of organic practices and materials that mirror the USDA NOP [US Department of Agriculture National Organic Program].”
“We have a unique focus on SCRM [supply chain risk management] – our 3rd-party inspectors collect live leaf tissue samples from the field throughout the grow cycle and our certification staff reviews the lab tests beyond a “pass/fail” to get ahead of any potential contamination prior to crop harvest and processing,” Temerario continued.
According to Temerario, this guidance enables Envirocann’s clients to stay ahead of “a particularly well-known and ongoing issue in the market – the issue of flower and trim showing no detections, yet when extracted, showing failing levels of pesticides or heavy metals.”
At the Dispensary
Envirocann also distinguishes licensed dispensaries backed by exemplary management and educated staff and are introducing the “confidently clean and comparable to organic isle” for cannabis retailers.
Unfortunately, the federal government’s lack of direction regarding hemp testing and product labels means there’s minimal transparency in some hemp farms and product manufacturers. “Many hemp farms follow a similar model to our conventional food system,” Rice added, “that being monocrop culture, rampant use of restricted materials and fertilizer salts, and exploitation of workers.”
“In processing facilities,” he continued, “there are no regulations regarding environmental contaminants, such as yeast, mold, and bacteria (think Aspergillus and Escherichia coli), which is not only gross, but also poses a risk to consumers using hemp and CBD products as a health supplement.”
Social Justice and Natural Resource Conservation
The Envirocann and EnvirOganic certifications focus on natural resource conservation (e.g., maintain/improve conditions, such as biodiversity, water, land, energy) and social justice. Companies who recognize the need for demonstrating best management and organic practices on their farms and in manufacturing operate as environmental stewards.
“The way in which we require regular inspections and audits of the sites we certify provides greater transparency into production practices, particularly with pesticide and chemical use,” Engfer explained. “We are regularly observing the impact on the environment and considerations of worker safety onsite. Examples of how Envirocann has augmented worker safety include: eye and handwash stations, hazardous materials/areas clearly marked/labeled (either bilingual or with pictures), proper training for tasks, access to shade, breakrooms, drinking water, or places to safely store food.The social justice component of our certification requires producers to demonstrate achievements in two of three categories: worker health and safety, compensation or community outreach.” Regarding compensation, Envirocann looks for fair wages, equal wages across genders, that compensation meets or exceeds the cost of living for the demographic, compensation for overtime, amongst others.
EnvirOganic v. USDA Organic
The EnvirOganic certification evolved from the USDA organic program, mirroring the processes for documentation, audit, and verification of organic practices. “EnvirOganic goes above and beyond the USDA NOP, however, by requiring more frequent inspections (rather than once per year) and additional lab testing requirements (e.g. 100% of Envirocann and EnvirOganic crops are sampled and tested for pesticide residue),” Rice explained. “Arguably, the most valuable aspect of EnvirOganic certification is the SCRM tool that decision makers use to highlight the cleanliness of their crops and move the crop through the supply chain while maintaining its value.”
Federally Legal v. Federally Illegal Operations
Three markets exist when it comes to Cannabis sativa. There’s the fully illegal black market, the traditional gray market (state legal/federally illegal), and the new, federally legal hemp market.
“The current regulatory schemes are making a best effort attempt to transition the market from black to gray to licensed,” Engfer explained. “A big focus of our services at Envirocann is to assist the traditional market transition to the licensed market, a transition of growers to farmers.”
Interestingly, Engfer highlighted “label claims, pesticide use, and basic best practices, especially in terms of worker safety” as the main differentiators between the federally legal and federally illegal markets.
“In completely illegal operations, however, there’s no oversight to ensure, for example, that pesticide applicators follow proper precautions to protect themselves and other workers from exposure to chemicals, unsafe processing locations, and general pollution and long-standing environmental degradation,” Engfer added.
The mushrooming industries surrounding C. sativa aren’t pumping the brakes any time soon. If anything, they’ll continue their unprecedented growth. Every business in the ecosystem uses resources, natural and human, to cultivate their ideas into tangible reality. Natural resources, however, are increasingly diminished, necessitating universal awareness of how we can still grow, just more responsibly, sustainably. Luckily, there’s people like Ian and Phil and Valentina at Envirocann that can act as our chaperons to a greener way of life.