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Manufacturers should be REMOVING contaminants, not trying to DILUTE them out.
Dilution is a hot topic within the CBD industry. And while it is sometimes used to create products with varying potency, other times it is used to make oils comply with the law.
In our Solution to Dilution article, we discuss how some manufacturers and formulators are using dilution to keep THC levels under the legal limit. However, this might not be the only reason they use dilution. Some manufacturers are using this technique in order to mask high levels of toxins such as pesticides and heavy metals.
Some CBD manufacturers are using dilution to mask high levels of toxic substances such as pesticides and heavy metals.
Until this point, there has been no federal regulation on pesticides in industrial hemp. In Colorado for example, the only pesticides currently allowed for use on hemp are those which have broad crop usage labels, do not have tolerance limits and are also approved for use on tobacco. The state provides a list of pesticides approved for use on cannabis.
The Environmental Protection Agency (EPA) is the government body responsible for setting tolerance limits for pesticides on foods and commodities. However, because hemp was only recently approved as an agricultural commodity under the 2018 Farm Bill, the EPA has not yet approved pesticides specifically for use on hemp. That is about to change.
On August 21 2019, the EPA released a statement asking for “Public Comment on Pesticide Applications for Hemp.” The purpose was to obtain the public’s opinion on expanding the use of 10 existing pesticides for application on industrial hemp. This is part of the commercial legalization of hemp process outlined in the 2018 Farm Bill. This means that the EPA is taking the necessary steps in order to roll out effective pesticide guidelines for the hemp industry as it begins to expand in 2020. Pesticide approval and regulation is good news for farmers and consumers alike, as it eliminates especially dangerous pesticides. However, the approved pesticides are still of concern if the residue amount exceeds the tolerance limits established.
The EPA is currently in the approval process for pesticides to be used specifically on hemp.
Prevalence of Pesticides in Hemp
In 2016, Steep Hill Labs reported that 84.3% of cannabis samples tested positive for pesticide residue. Although this was a few years ago and was focused on samples of medical cannabis, the findings are still concerning in the context of industrial hemp and CBD production. Although regulations have become stronger for medical and recreational cannabis, industrial hemp is still in the beginning stages of legalization and regulation.This indicates that pesticides are of major concern in the CBD industry.
An article published in the Medical Cannabis and Cannabinoids journal entitled “The Trouble With CBD Oil” states, “If any of these contaminants [pesticides, heavy metals, solvents, etc.] were present in hemp used for CBD extraction, they would likely end up in concentrated form in the resultant oil.” A pesticide analysis lab indicated that, “The general rule-of-thumb for pesticides in concentrates is this: expect about a tenfold increase in pesticide burden versus the flower used for extraction.” This means that the concentration of pesticides in the plant material multiplies by 10 when extracted and concentrated into an oil.
Clearly, pesticide use in the unregulated industry is widespread and, in the case of CBD oil production, can become concentrated in the finished product if it is present on the plants. So why aren’t more CBD products testing positive for pesticides? In many cases, the answer is dilution.
“The general rule-of-thumb for pesticides in concentrates is this: expect about a tenfold increase in pesticide burden versus the flower used for extraction.” – Confidence Analytics
Diluting CBD Oil Can Mask Pesticides from Analytical Labs
Many third party and in-house analytical labs have equipment with what is called a “Limit of Detection” or LOD.This is the minimum amount of substance that the instrument can detect in a given sample. For example, the LOD of THC with current industry standard testing procedures is about 0.1%. If the actual concentration of THC was 0.05%, the equipment would not be able to detect it and would report a “Non-Detect” level of THC.
The same goes for pesticides. However, since there is little regulation specific to CBD, test methods and LODs vary widely between labs. The California Bureau of Medical Cannabis Regulation released detailed guidelines for testing in the medical cannabis industry, including a list of pesticides and their LODs. However, the same has not been done for the CBD industry on a federal scale.
Unscrupulous manufacturers may exploit these LOD’s and lack of regulation by reducing the concentration of pesticides, heavy metals or other contaminants to below the LOD. Therefore, the toxins will not be detected. To reduce the concentration, they add extra oil in a process called dilution. This is similar to adding extra water to lemonade that is too sweet.
Untrustworthy manufacturers may use “limits of detection,” or LODs, to their advantage by reducing the concentration of pesticides, heavy metals, or other contaminants to below the LOD. To reduce the concentration, they use dilution.
Think about it this way, if a basic food product like an egg tested positive for a pesticide above the legally established tolerance limit, it would be removed from the shelves immediately. This happened on a massive scale in Europe when millions of eggs were removed from the shelves for having high levels of an insecticide. Egg producers cannot cut the egg in half or mix it with clean eggs before testing to lower the amount of pesticide in the egg. Whatever is in the egg cannot be modified. CBD oil, however, is a different beast. There is no standardized ‘unit’ of CBD, such as ‘one egg’ or ‘one apple.’ Therefore, formulators can mix contaminated oil with clean oil to mask contaminants from analytical instruments.For a deeper explanation of dilution in the CBD industry, visit our blog here.
Why is Dilution a Bad Idea?
Keep in mind, simply because an oil does not test positive for pesticides now does not mean that it has disappeared. In fact, the ratio of pesticide to CBD is identical. When a manufacturer dilutes a pesticide, it also dilutes the CBD by the same factor. This means that in order to get the same amount of CBD from a diluted oil compared to a pure distillate, the consumer must take a larger dose. Whether it is one gram of 500mg CBD oil (pure distillate) or 10 grams of 50mg CBD oil (diluted), it is the same amount of CBD AND the same amount of pesticide. The difference is that the lab CAN detect the pesticide in a sample of the pure distillate, but it CANNOT detect it in the diluted oil.
The ratio of pesticide to CBD is exactly the same. When a manufacturer dilutes a pesticide, it also dilutes the CBD by the same factor.
Some bulk CBD oil manufacturers may use this technique to mask pesticides in their low quality oil. This is very dangerous. Here is a message for other manufacturers in the industry:
If your CBD oil tests positive for a pesticide, dilution will not solve the problem and “make the pesticides disappear” . Instead, spend time understanding the COA and discuss it with the lab that reported the COA. If it is contaminated, The lab can then help you determine the best path forward on the contaminated oil.
It is important to know your CBD manufacturer is reputable and employs high quality processes and products. Always request a current Certificate of Analysis to ensure the products are free of pesticides and other contaminants. Until the industry is more regulated and the tests are standardized, one should be careful when purchasing CBD products in this exploding market.
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