The pesticides behind Health Canada’s type II recall of Organigram products

Peter Chen looks at the pesticides behind the recent recalls of ACMPR cannabis

Product recalls are a reality in almost every industry sector. According to the Canadian Food Inspection Agency (CFIA), 200 to 300 food recall incidents occurred yearly in Canada between 2006 to 2013. While recalls are an unfortunate event, they do show that measures are in place to ensure consumer safety. The recent recall of dried marijuana and cannabis oil products from Organigram raises concern regarding how unregulated pesticides were found in products from an organically-certified producer, and more importantly, what kind of risks do these pesticides pose to human health?

The pesticides that were found in the Organigram recall were myclobutanil and/or bifenazate. In brief, these pesticides are low toxicity and are not likely to affect human health when ingested orally. However, the main point of contention around cannabis is the lack of information purporting to the risks of combustion and inhalation of these compounds. It is for this reason that they are not one of the 13 approved pesticides for use on medical cannabis in Canada.

Here is a breakdown of these pesticides:

Myclobutanil

  • Myclobutanil is the active ingredient in several pesticides, including Eagle 20EW and Nova40W
  • Fungicide commonly used on apples and grapes
  • Low acute toxicity when ingested orally
  • Not approved for use in tobacco and marijuana plants
  • Human health effects from the combustion and inhalation of myclobutanil have not been evaluated

Bifenazate

  • Bifenazate is the active ingredient in Floramite
  • Miticide used on fruiting vegetables such as peppers and tomatoes in Canada
  • EPA reports inhalation toxicity – Category IV (practically non-toxic)
  • Used in unregulated marijuana markets
  • Not registered for use on cannabis
  • Human health effects from the combustion and inhalation of bifenazate have not been evaluated

The glaring concern is the lack of information regarding the effects of combustion and inhalation of these compounds. Tolerance levels will vary significantly depending on the route of administration. When a substance is ingested orally, it is metabolized by gut enzymes and filtered through the liver prior to entering the bloodstream. Inhalation, however, is a more direct route of entry into the bloodstream.

Since dried cannabis typically requires some form of combustion, this could change the entire chemical landscape of these compounds. Myclobutanil, when exposed to heat, decomposes to produce mainly carbon monoxide, hydrogen chloride, and hydrogen cyanide. While this may appear alarming, it is important to note that combustion of dried marijuana itself also releases carbon monoxide and hydrogen cyanide, not to mention benzopyrene and tar. As mentioned previously, myclobutanil is currently not approved for use on tobacco and marijuana plants in the United States or Canada; however, it is approved for used on tobacco plants cultivated in China. In a 2012 study, researchers found that approximately 10% myclobutanil was present on the tobacco leaves 21 days following treatment. While these levels are considered non-lethal, they may still be clinically relevant.

The recall of oil products may be of greatest concern since bifenazate and myclobutanil are both soluble in many of the solvents used in cannabinoid extractions. Therefore, they are likely co-extracted (at varying recovery rates) during the oil production process. Extraction of cannabinoids will typically involve concentrating the extract, which will concurrently increase the levels of any pesticides present.

The nature and amount of unregulated pesticides detected in the Organigram recall should pose little to no risk to consumers. Perspective-depending, these recalls may cause some to question the quality and safety of legal marijuana, while others are glad that Health Canada now has their backs when it comes to providing them with a safe product and weeding out unwanted chemicals.

Featured image via Wikipedia.

This article was edited to note the pesticides in question are myclobutanil and/or bifenazate, not necessarily myclobutanil and bifenazate.

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2 comments

  1. Robert Reply

    This is bullshit pull their license and close them down they sprayed this stuff on the cannabis sick people are using knowing it was not approved because they were getting it cheaper than the approved stuff.
    Then they recall it months later after it's most likely been consumed and then tell their customers there's nothing to worry about can they really prove these patients won't be affected years from now.
    Medical patients grow your and don't ask for the government's permission this same government licensed these LP weasels and are not looking out for patients.

  2. @SurlySemantics Reply

    The Health Canada recall states "lots containing residual levels of myclobutanil and/or bifenazate that exceeded any of the levels permitted in food production", http://healthycanadians.gc.ca/recall-alert-rappel-avis/hc-sc/2017/61750r-eng.php.

    According to a Colorado Green Labs blog, "Chronic exposure to dilute hydrogen cyanide (ex. 0.008 parts per million) is not immediately deadly (10), but is known to cause serious neurological, respiratory, cardiovascular, and thyroid problems (11, 12, 13). Cannabis retaining even marginal amounts of myclobutanil (ex. 0.03 ppm) could potentially expose consumers to non-lethal, but clinically relevant levels of HCN." http://www.coloradogreenlab.com/blog/eagle-20-and-myclobutanil-in-the-context-of-cannabis-cultivation-and-consumption

    According to Health Canada, the MRL (Maximum Residue Level) for Mycobutantil on food is 9.0 ppm. http://www.hc-sc.gc.ca/cps-spc/pest/part/consultations/_pmrl2015-15/pmrl2015-15-eng.php

    This would indicate that type II recalled lots had in excess of 9.1ppm of residue (if mycobutinal). Oil products may have residue levels concentrated 250x the starting material (potentially 2,275+ ppm).

    Since these levels exceeds the MRL for orally ingested food, and there is a lack of information regarding combustion and inhalation of this product, how can you confidently ascertain that this recall "should pose little to no risk to consumers"?

    I also wonder:
    1) Why is a Licensed Producer using unapproved chemicals in the first place?

    2) How does said LP claim to be "Certified Organic" (by Eccocert Canada), if it's using synthetic fungicides?

    3) Why does their website still claim: "Organic Growing Methodology
    •Subject to audits
    •Regulated soil
    •Organic fertilizers
    •No synthetic / chemical pesticides
    "? Do they enjoy blatant false advertising? https://www.organigram.ca/our-story/