A look at the challenges and solutions of lab testing in Canada
George Smitherman, Tom Ulanowski, and Brenna Boonstra question inconsistencies and propose potential solutions for analytical labs and cannabis testing in Canada
April 17, 2023 By Treena Hein
As Canada’s regulated cannabis industry matures, as with any new industry, there are growing pains to address. In cannabis, these include profitability and taxes, consumer education, and quality control.
The latter topic – quantifying levels of THC, CBD, contaminants, and other parameters – has become a convoluted issue for the sector. Analytical lab testing has been subject to scrutiny since the inception of legal Canadian cannabis, and the time has come for solutions.
As George Smitherman, CEO of the Cannabis Council of Canada (C3) explains, while the primary focus of his organization is tax issues and profitability for LPs, “we are also concerned about standardization of testing to get consistent test results for THC and more.”
Smitherman expands by saying, “the range of test results that can come from the same batch is undermining credibility and confidence in our regulated system, and we need to get to the bottom of it. There have been many examples of results from the same batch being inconsistent.”
Along with inconsistent results, inflated THC test results is an ongoing industry concern, says Brenna Boonstra, risk advisory director at Deloitte Canada. “It’s not new,” she says, “and we will likely see it continue for dried cannabis as producers and labs try and retain their customer base in a market where price is often fixed to THC content.”
The notion that different labs can provide higher THC results for the same batch compared to other labs results is something called ‘lab shopping.’ But as Smitherman explains, it’s possible only for those LPs who can and wish to spend the money on it. He’s not sure of the extent of this practice but says that “regardless of the frequency and scale of it, it’s not a good look for a highly-regulated industry, and we can certainly improve on it.”
Boonstra also points out that since testing methods aren’t yet mandated in Canada, it means there’s a potential situation currently in place where labs can change methods in order to have ‘more desirable’ test outputs.
“This happened with microbial testing too,” she says. “Labs using qPCR for testing microbes saw lower levels compared to plate testing results, so qPCR was the method selected for use. In an environment where Health Canada doesn’t require standardized methods, method selection for favourable results will likely continue to happen with THC.”
Tom Ulanowski, a professional chemist and chair of the C-45 Quality Association (C-45) further explains that labs are not subject to specific standards regarding not only testing method performance but also equipment.
Those at C-45 have been working on this issue for some time, as ‘a national private-sector advocate for compliance and quality in the Canadian cannabis sector.’
For years, says Ulanowski, C-45 has recommended that Health Canada enhances regulatory oversight of analytical testing licence holders.
“Under the current Cannabis Regulations, the quality assurance person for each licence holder is responsible for evaluating the analytical services offered by each lab and ensuring that validated methods are used to generate analytical results,” he explains.
However, he says there are many disadvantages to this current framework, namely that cannabis processors must inherently trust each lab, especially if the lab itself does not have any additional third-party accreditation.
“It is our hope that one day, labs – and the methods they use, especially for cannabinoid potency testing – will be scrutinized directly by the regulator,” says Ulanowski, “ensuring a level-playing field and minimizing the chance of biased results.”
Ulanowski also points to data from multiple jurisdictions in North America which suggests the average THC content of dried cannabis is approximately 20 per cent – but in general, anything over about 30 per cent is considered to be statistically improbable. “And yet there are a number of labs in Canada that seem to consistently issue certificates of analysis for dried cannabis products with THC potency above 30 per cent,” he reports.
Ulanowski questions the cause of these high potency results: “Is it biased sampling by the licence holders, inappropriate sample preparation methodologies prior to testing, or poor test method design and validation?” he wonders. “I suspect it’s likely a mix of all three, but a regulated analytical testing program would be able to identify and solve this pressing issue.”
It’s clear the issue of testing accuracy and consistency must be resolved, but the best way to address it is yet to be agreed upon.
It’s a positive, says Smitherman, that many in the industry have already thought a great deal about solutions. He adds that there are already a lot of data about best practices for testing procedures, and on specific factors that affect testing as well.
For example, there already exists plenty of reliable information on why and how degradation of terpenes in samples can occur and how this affects analysis.
Smitherman is sure, however, that “our industry can figure this out for itself.” He stresses that across the Canadian cannabis sector, “we have a lot of strength in terms of subject matter experts and we at C3 just need to be the catalyst. Hopefully we will make progress with that this year,” he notes.
Smitherman continues, wondering whether the solution will involve bringing some labs and LPs together to brainstorm and discuss. Or “maybe it will involve sending samples from one batch to all or many accredited labs and then digging into the outliers.”
“But however we proceed, there has to be industry-wide broad-based collaborative,” says Smitherman. “We could wait to be further regulated as an industry or come up with something on our own. Doing the latter is preferable, of course, and a good opportunity for us to mature as a sector.”
Sidebar: A look at other testing trends
There are those in the industry who question whether a shift towards in-house testing may help ensure test results are accurate and consistent. However, many such as Boonstra don’t see this happening widely because the specialized labour and equipment are very expensive – and to do testing economically in that situation would require economies of scale.
Ulanowski agrees. He says that while internal testing for cannabinoids, terpenes and chemical or microbial contaminants does potentially offer faster turnaround times in addition to other potential benefits, the capital and ongoing costs are not justifiable for most cannabis firms.
Instead, he says that “in today’s highly competitive market, companies are looking to focus on their core strengths and rely on other businesses for ancillary services, instead of pursuing a vertically integrated model. Moreover, third-party labs typically offer the advantage of independence and credibility, avoiding any real or perceived bias.”
Some Canadian companies do use in-house testing for R&D purposes, says Ulanowski, but Boonstra does not expect to see that for DNA testing and breeding to any great extent. Like quality testing, she says, DNA testing is unlikely to see widespread adoption in the industry because “the genetics are too complicated.”
Treena Hein is an award-winning freelance writer with almost 20 years’ experience, based in Eastern Ontario.
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