New mold testing requirements are not the result of corporate greed or government corruption — they are vital for public health.
The Oregon cannabis industry has a little bit of a problem. On March 1st of this year a new rule created by the OHA went into effect, one that many growers fear will completely put them out of business and has been decried as the Oregon government attempting to squash small organic growers in favor of large hydroponic operations. The rule?
Cannabis now has to be tested for several pathogens. Previously cannabis products only needed testing for E. coli but now the OHA has added Salmonella and several species of Aspergillus molds to the list, notably A. flavus, A. terreus, A. niger, and A. fumigatus. It is the new mold testing requirement that has caused an uproar amongst growers and consumers that favor organic products.
The argument goes like this: the Willamette valley is warm and sometimes rather humid, encouraging mold growth. Many organic methods, like foliar applications of compost tea and fungicide-free growing, create an environment in cannabis flowers that is very appealing to Aspergillus mold. The guidelines set by Oregon, then, are biased and intended to destroy organic operations (often smaller businesses) and serve the interests of big indoor growers and mold remediation companies that promise to kill mold on harvested bud.
Others give the Oregon government the benefit of the doubt. Each one of these molds can invade humans and cause serious disease and death. This tends to happen to the immunocompromised, like cancer patients, those on immunosuppressants, or HIV patients, but can also take advantage of chronic respiratory infections to gain a foothold in healthier individuals or those with chronic respiratory conditions like COPD. In rarer instances it can indeed kill healthy people with no other health conditions, though this is rare and probably requires a pretty large dose of spores straight to the lungs. At least one of these, A. terreus, can also cause skin and nail infections. Pathogens should probably not be tolerated in medicinal products, right?
It Gets Worse
Nobody is mentioning probably the most dangerous aspect of Aspergillus mold on cannabis: Aflatoxin. Aflatoxin is hepatotoxic and carcinogenic, both when the dose is acute and when it is chronic. Dangerous amounts are more common on seeds and nuts but aflatoxin has been found on tea, more tea, spices, wine, milk, small grains, and so much more. Oregon previously did not test cannabis products for aflatoxin, directly stating that aflatoxin isn’t a big deal unless the product is oily nuts or grains:
“Some states have required testing of cannabis for aflatoxins produced by certain Aspergillus species. Oil-rich seeds must be present to produce these toxins on plants. Commercial cannabis does not contain these seeds. As a result, the Technical Expert Work Group recommends against such testing”
This is patently untrue and dangerous. The new regulations fortunately require testing for mycotoxins, including the most dangerous aflatoxins. Aspergillus flavus, one of the pathogens they now test for, is also one of the molds responsible for aflatoxin contamination. Even if a cannabis product tests negative for aflatoxin, if Aspergillus is present on or in the product aflatoxin can be produced after testing is done, especially if not stored properly. Aspergillus niger, another of the pathogens being tested for, produces a few different mycotoxins including ochratoxin. A. fumigatus can produce gliotoxin. A. terreus can make all kinds of funky junk, including gliotoxin, citrinin, patulin, and a bunch more. I’m being kind of pedantic with all the chemical names, but all the chemicals listed are at the very least cytotoxic and many of them are linked to long term, potentially deadly side effects even with very low chronic exposures.
I guess I’m trying to say this: this testing is generally a good thing, and in the case of the current testing requirements they probably don’t go far enough. The tests also include heavy metals and pesticides but they should include water content testing to reduce the risk of mold growth in the final product. Any product intended for medical use should have very little tolerance for these molds or the toxins they produce because they could very likely end up in the bodies of people who have health issues that might make them susceptible. Mycotoxins can also turn weed into a chronic health risk if there is not an emphasis on quality and rigorous testing, both by the government and by producers. If this puts organic producers in jeopardy then so be it, as these baseline tests are generally intended to prevent illness and death and producers have a responsibility to keep their customers safe.
Best Practices, or Lack Thereof
In the end keeping consumers safe comes down to best practice. Aspergillus is certainly common in the environment, but there are several steps that need to all happen to turn aspergillus spores into a health problem. The cannabis industry is rife with underpaid workers and money-grabbers who don’t necessarily care about good practice. It is also full of people who are well-meaning and passionate but don’t understand a lot of the science behind things — as an example, why spraying compost tea on flowering plants is probably a recipe for disastrous mold growth. Agricultural products are challenging to produce and cannabis is no exception — you have to produce a plant safe for consumption and then harvest and store it in a manner conducive to keeping it safe. Oregon growers are very often failing to do this. Willamette Week even inadvertently included a direct admission to this exact failure, unknown to all parties involved:
“Niestrath, among other organic farmers, avoids stripping any natural fungi from the plant that aren’t dangerous. Niestrath even sprays his cannabis with what he calls “compost tea.”
This is an educational opportunity. Spraying plants already susceptible to mold with compost tea is a great way to grow carcinogenic mold, not high quality flower. This is because compost is full of mold, which is fine. It’s compost. What’s not fine is steeping this compost, mold and all, in water and then spraying it on your plants! Compost tea holds agricultural promise but in this case is almost certainly downright dangerous. I’m not a huge pesticide fan but encouraging fungal growth with regular foliar applications of mold spores seems more damaging than using most fungicides. That is not even mentioning that overhead irrigation with plain ol’ water can encourage mold growth in the right conditions, no compost tea needed. The grower is wetting the flowers and keeping the nooks and crannies moist, letting latent mold spores flourish. Adding mold spores and nutrients via compost tea is just making it that much easier for mycotoxins to appear in the finished product.
Organic producers have organic approved fungicides and, if they don’t want that, non-chemical best practices (like not using overhead watering or foliar applications during flowering) they can use to prevent these issues from happening. They just don’t seem to know or care. To give both the growers and scientific community a bit of leeway, I will mention that this gap in understanding is perhaps because of all the stigma and red tape around cannabis, meaning that a lot of these practices are not well understood by the scientific community and not well understood by the cannabis community. Not to mention that many products are not labeled for use on cannabis even if they are sorely needed.
If cannabis producers expect to stay in business they need to stay educated on potential risks and the best practices in hemp/cannabis production. There is a fair amount of sketchy pot being grown and a lot of handwavy woo-woo pseudoscience that drags the entire industry down, perpetrated both by big and small growers. The FDA should assist in providing education to both growers, processors, retailers, and end consumers as well.
I’m not arguing against growing your own or bartering amongst friends and neighbors. I’m also not trying to attack people for wanting organic cannabis; I do see the appeal. The problem, however, is that huge amount of the bud in the valley is riddled with bugs and moldy and if that is all organic growers can put out, they deserve to go out of business.