The recent recalls of medical cannabis by three Canadian licensed producers have provided fresh fodder for dispensaries and illegal growers who contend that their products are just as safe, if not safer, than those regulated by Health Canada. While there have been recalls by Canada’s licensed producers for excessive levels of bacteria and mold, as well as one case where the amount of potential THC exceeded the labeled amount by more than 50% (Health Canada has yet to define a universal variance, though the producer opted to perform a voluntary recall), the back-to-back-to-back pesticide-based recalls were the first in the industry’s short history that concerned the use of particularly toxic pesticides. More concerning was the fact that one of the pesticides used was myclobutanil, a pesticide that when combusted, emits hydrogen cyanide, a compound so poisonous that upon the discovery of myclobutanil in Colorado cannabis, the state legislature was compelled to order mass recalls and introduce emergency legislation to ban its use in cannabis production.
Should licensed producers wish to maintain consumer confidence in the system in the wake of these recalls, they need to take it upon themselves to educate consumers about the motivations behind why growers, both licensed and unlicensed, would use a pesticide like myclobutanil, and what the consequences for its use would be. Myclobutanil’s target pest, the parasitic fungus known as powdery mildew (“PM”), is readily identifiable for the powdery white spots that cover the leaves and stem of the plant. A challenge to eliminate for even the most experienced growers, the economic costs of a PM outbreak can provide a clear explanation for consumers as to why growers are compelled to put their thumb on the scale to eliminate the problem. Industry insiders know that, like other funguses, PM thrives in hot, humid, and poorly ventilated environments, and that its spores can quickly spread through densely packed grows. The consequence of not addressing PM hit growers’ wallets as the fungus feeds off the plants’ nutrients, causing them to become weaker and bloom less. Moreover, its white powdery coating on the leaves and bud give the final product a distinctly unaesthetic appearance, a major issue in an industry where the look of the product is a priority for consumers and where product in dispensaries is often prominently displayed in clear containers. The damp mildew smell of infected buds is also a deterrent for prospective consumers who may also be less than thrilled at the myriad of health risks associated with inhaling mildew. Simply put, if the grower manages to get it on the shelf, it might just stay there.
Given the potential costs associated with an outbreak of powdery mildew, large growers have adopted proactive measures to combat the fungus. However, the costs can be prohibitive for the undercapitalized or the unregulated. Sophisticated HVAC systems that can responsively modulate a grow’s humidity and temperature while providing adequate airflow throughout the grow space can have upfront costs of hundreds of thousands of dollars. Prevention can also require the grower to space out individual cannabis plants throughout the grow to permit adequate airflow and avoid the trapping of moisture within the canopies. A consequence of this spacing is an overall reduction in grow space, and in turn, the amount of cannabis that can be produced per square foot. While there are many ways to combat PM, myclobutanil’s cheap and effective application remains a powerful temptation for growers looking to cut corners, and its seemingly innocuous application on popular foods not meant for combustion, such as apples and grapes, may inadvertently give consumers a false sense of security when they consume it.
For illegal growers who, by their nature, are not required to submit their products to government sanctioned labs for any form of testing (nor are they allowed to), the temptation to deploy a cheap pesticide spray in lieu of making expensive capital investments can be overwhelming. End users, after all, are extremely unlikely to run their own tests, and the effects of consuming these pesticides may not be fully realized for several years. Investigations by The Globe and Mail have already revealed a willingness for dispensaries to sell cannabis containing dangerous pesticides designed to fight PM, including dodemorph, which is outright ‘not approved for human consumption’. Consumers may be tempted to think that ‘my guy’ would never engage in such behaviour or buy from those who do: however, the complete absence of testing, the relative invisibility of pesticides, the absence of immediate consequences, and the clear financial gains, create a potent combination of incentives for illegal growers, all of which current and future consumers need to understand.
The recent recalls have, without a doubt, been a black eye for the entire North American industry as it seeks to attain mainstream acceptance. For consumers to write off the whole system in favour of wholly unregulated growers, however, would be foolhardy. While the industry’s infancy and equally nascent regulatory regimes have made it clear that there is still plenty of room to define what constitutes best practices, both in terms of testing and reporting, in the face of new information regulatory authorities in both Canada and the United States have demonstrated a willingness to adjust their practices to demand safer products for the consumer. As the system matures in the interim, legal producers should make efforts to educate consumers about the challenges and incentives facing all growers, and resist the perception that pesticide problems are confined to those grows that are reported in the news. The critical change that results from consumer education and these public and regulatory discoveries is a vastly improved system, with increasingly safe product, processes, and oversight.
- Michael Miller and Steven Looi are founding members of Initiative Capital, a cannabis-focused venture fund based in Toronto, Canada. Steven is an IT/Urban Agriculture entrepreneur and has invested in numerous cannabis companies on behalf of his family office. Michael is a Toronto-based venture capitalist and a cross-industry advisor.
Featured image via Flickr/ Jeff Kublna.