Episode 112- The Science of Cannabis: Cultivation, Testing, and Quality Control

In this episode, I am joined by Kyle Baker, founder of Clean Theory. During the episode, we explore the complexities of cannabis cultivation and testing. We also discuss the evolution of third-party lab testing, the challenges of maintaining high standards, and the importance of robust quality control measures. Kyle explains the nuances of state regulations, the impact of remediation processes, and the health concerns associated with current practices.

The conversation also highlights the differences between commercial and home growing, highlighting the importance of proper cultivation techniques for ensuring product quality and safety. The episode makes the case that Illinois’ stringent regulations actually hinder the production of high-quality cannabis. Whether you’re a professional or an enthusiast, this episode offers valuable perspectives on the ever-evolving landscape of cannabis science and policy.

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The auto-generated transcript is available below.

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website at riverbluff collective.com to find those amazing deals on these amazing products folks you must be 21 plus to purchase and please consume responsibly I want to be very clear these have derived products are not sold in dispensaries if you’d like to find a place to purchase them once again the best place to go is riverbluff collective.com but if you’re really looking for it in store at the bottom of riverbluff collective.com you’ll find the store locator and that’s where you can find a River Bluff Collective store near you off the top of my head I know there’s one in East debuk Illinois so check that out have fun enjoy the products responsibly and enjoy this episode of The Cult [Music] memo Kyle happy Friday my friend how’s it going dude ah it’s going great Cole how are you great doing great and I just uh was reminiscing in the other day and realized before we got on the phone call that I believe I have a picture of you and I the first time we met uh let’s take a look I’m sharing it on my screen right now where were we at again was it the Hideaway the hi that was that was the seller seller the seller yes yeah that was uh during an SIU event yeah and you know what was cool what I thought was really cool about this is you know this was a bar so we were able to get our the beverages that we wanted uh but they also you know said we were able to smoke cannabis out on the patio which was something I had not had the experience of doing uh let’s just say with permission at a bar before Carbondale is pretty cannabis friendly um you know I would say probably about 2018 uh the university began to Endeavor in creating this is on the farm bill side be began saying you know we really need to create curriculum and and study the science behind this cultivar and from there uh the city really got behind that and basically said you know and this is from one of the city council members and I forget his name who said this but they basically instructed people that a dog you know not picking up your dog’s mess on the sidewalk is a greater offense than smokeing cannabis and and kind of since then it’s it’s been okay now state law obviously you know you shouldn’t be uh you know there’s certain rules and regulations there from a public perspective but but Carbondale uh seems to be very friendly towards it yeah yeah and we won’t be talking about this today but I just had to mention it or kind of underline the point that you made before I have you tell us a little bit more about yourself as you just said uh the 2018 Farm Bill gave universities Across the Nation more access to the cannabis plant than ever before um and I think that you know a lot of the conversation which again we won’t necessarily be discussing today is about those intoxicating canono and the public policy around it uh but I don’t feel like enough people are applauding the fact that like this 2018 Farm Bill gave colleges the access that they have now you know it’s really awesome I me yeah I I’m actually sitting at the University now here at SIU um you know it it when you start to look at the a side of business and that’s how you is typically in a school you know you’re talking about a new cultivar with over 85 years of missing Science and Technology what a huge opportunity you know and while we talk about hemp it’s all the same thing cannabis attiva it’s all the same thing so when we get into the legal conversations of what is marijuana versus cannabis uh you know it gets a little bit hairy but us in the scientific Community have a very clear understanding it’s all the same damn thing you know right right well hey dude uh you know we kind of just jumped right in why don’t we back up for a second and Kyle please introduce yourself to my audience um tell us a little bit about yourself right so uh my name is Kyle Baker I’m one of the founders and csos of a company called clean Theory uh we specialize in deodorization and microbiology uh compliance issues uh in in and around the Cannabis industry so kind of a weird combination of botanist microbiologist and chemists heck yeah and um as always folks if you check out the show notes I’ll have information so that you can get connected with Kyle um so definitely check out the links in our show notes um didn’t mean to jump in there uh anything else you wanted to mention uh with regard to work that you do or you want to jump right in my friend yeah let’s Jump Right In uh you know we get to work a lot with the university a lot with different cannabis companies been doing it uh since 2017 uh gone back even a little bit further to 2014 so we’ve seen a lot of interesting things in the industry and kind of seen it grow and evolve and uh some great things and some not so great things absolutely absolutely yeah and today we’re going to be talking about Cannabis Testing uh which there’s a few different layers to that topic we’ll peel the onion in just a moment but I want to remind folks really quick that you are listening to the coal memo if you want to watch it um again links are in the show notes so that you can do just that we release every episode of the podcast in audio video and transcrip transcript form uh so if you’re unable to locate the episode description on whichever platform you’re listening from just take note of the episode number and visit the memo.com from there you can use the search functionality in our top right hand corner search up Kyle Baker and you’ll find this episode for example and then of course you will also find any other links that we referenc during the episode like the ones that I just mentioned so that you can connect with Kyle um I just wanted to say really quick before we get started if you’re not listening to this episode of the co memo on patreon you’re listening to this episode a bit later than our patrons you can become a patron at the memo.com patreon it only costs $3 a month and it gives you uh immediate access to our episodes as they release another way to support us is at the memo.com support but one of the best ways to support us folks I really have to like emphasize is absolutely free subscribe to or just follow the show leave us a positive review if you’re listening to us from a a podcasting platform leave us a positive review that helps a lot favorite the episode give it a thumbs up or just share it with your best friend your engagement and support is appreciated and helps this show to meet other well to find other listeners and so like I said we’ll be talking about Cannabis Testing today and like you just mentioned Kyle just a little bit more plug for its clean Theory right if people were to Google it it’s clean theory.net if you wanted to go look for it cool yeah uh I I guess you know like you had said earlier that’s that’s kind of what you guys do it’s not just the testing at the end of the process it’s like the whole process ensuring that it’s like holistic right yeah yeah the the name kind of it was myself and my co-founder Christian he actually came up with clean Theory we actually had different names and stuff before and we rebranded we were talking about germ Theory when Louis past Jer and kind of the the history of how we figured out what microbes were prior prior to I think what was it 18 I’m G to get my dates wrong late 1800s yeah uh you know people used to think microbes were like from The Ether you know it was the vapor was coming you know so it was like kind of those early discoveries and germ Theory really did a good job telling the story of what things are that made people sick and why things grew in certain ways uh we took that and kind of ran with it and said you know what clean Theory tells a really good story you know yeah and one of the things that I liked and I think this is the best point maybe to start kick off our conversation like I mentioned uh when we started the episode there’s a few layers to our conversation so we’ll we’ll dig into them but one of the things I I guess I wanted to start with with regard to Cannabis Testing is the impression that it gives people because some of the things that we’ll be talking about are maybe some of the ways that we can improve Cannabis Testing right so I just wanted to start off with this phrase thirdparty independent lab testing now I had to think about this for a while like how do I start off with this topic and what I had to think about is what did I think when I first heard that phrase like what phrase popped in my head for some reason like what Pops in my head when I hear third- party independent testing is double blind and maybe that’s just a bad assumption for me but I guess the reason I bring that up is because I think that’s the same assumption people are jumping to I don’t mean to like just you know color everybody’s beliefs but when you hear third party independent those seem like two really strong buzzwords that like make it seem like these uh entities are totally unrelated well not bashing lab companies when I say this but you ever watched an infomercial and it said something like tested by a third party lab and you know it has these outrageous claims which oftentimes come they’re not real yeah that’s kind of what I I think about when I hear that um you know there’s a bit of an origin story to why we have third part laps and it kind it started in 2014 with Colorado um and when they were developing the regulation they went to the state and they said hey we need to have testing and the state said uhuh no way you know we’re not touching that with a 10- foot pole and so that was kind of the beginning of well we have to do something and that was the creation of the third party lab so in typical third party or typical parallel Industries food pharmaceutical um even different Realms of manufacturing like automobile parts you have a a state entity that comes in and goes okay what’s going on here how does this work or a federal entity that has certain standards and are able to assess the quality and safety of a plant uh or of a a widget if you will that’s not the case in cannabis because it could not ex physically coexist with the legal structure that they had state to state and when we look at regulation as a whole so when we talk about EPA State Departments of a these are typical Federal standards and regulations uh that the states adapt and what they call rubber stamps so they say if what the FED says we’re going to do we’re going to do it again schedule one narcotic no medical value so those entities could not do that which means that there were no standards still are no standards to this day um and the states made up literally made up third party testing um and then when you look at limits microbial limits often times these are not necessarily based on really solid uh scientific findings uh for example a lot of the regulation uh that we see was based upon averages found in the plant and think about that you know so when we look at average microbes found in a plant well and then you make that the limit that’s a little bit different don’t you think yeah yeah so that’s kind of the history of why we have this third party testing um I believe there are some states that are now going to begin to require State Testing and create State Labs do you have any speculation on why like my guess my speculative guess why Colorado government was hesitant to test do you think it was like liability it was such a new thing and they weren’t they didn’t want to be like put a Colorado stamp of approval on it and then well you know I I think you get into a lot of politics okay when you start to get into the relationship between the state and federal government um I know State Departments of Agriculture that are forced to work with their state legal Recreation or medical cannabis systems that do not like cannabis and they are make it very difficult so you know there I think there’s an air of politics involved with with that Co mingling of those different programs yeah and I guess just to highlight the point that that I appreciate by the way the background on on testing because I wasn’t aware um you know that that some of this stuff it makes sense that it started with Colorado since that’s kind of you know where the adult adult use cannabis markets began in the United States um but one of the things I guess I was trying to highlight um is the idea that yes again this third party independ lab testing makes it feel like some random agent’s going to come in and take this random sample and from what I can tell from what I understand nothing can be further from the truth you shop for your lab maybe sometimes you pick the samples um that that is the case so you know so you know we’re in Illinois here but it’s different in every state right so every state has little nuances you know some states the lab comes out they select a sample or have a pre-selected sample or maybe you got a really good relationship with that lab and you go you know you should take that piece over there you know uh and then others you know you get to select your own samples and and and and turn them in and what we know about the microbiology of the plant is you know you have different uh different cfus different levels throughout the plant and when we talk about batch testing normally you know we take a one gram sample and depending on the state that one gram can represent up to 20 pounds sometimes up to 50 pounds so you know I don’t know if you’ve ever seen 50 pounds of weed but things can happen inside of it that might not be great like mold you know when you put it in there you’re you’re curing it so it’s a little bit different uh I don’t necessarily know from a testing perspective if we’ve got it all right yet I think that’s part of of uh you know part of discussions like this of you know saying well what is with this you know how do we how do we look at this better yeah yeah and like you say we’ll probably we’ll definitely be diving into that um I guess my last thought on this this topic that I started with you didn’t say exactly like this but this is the note that I take well actually you said something the effect of this is an industry where the client just like any other industry is going to pay the person they’re you know seeking services from for the best result and what I wrote down is capitalism is going to capitalism what any thoughts on that last note there I mean you’re not wrong you know there are really great guys out there throughout the country that really are trying to do this the right thing um and I got to tell you they’re getting trounced a lot you know there these lab guys are getting beat up um I have a a good colleague he’s actually one of our advisory members he got out of the industry because he’s trying to do the right thing and he would get slammed when he failed somebody then he would lose money then word would get around oh that guy’s just failing people to fail people you know I got friends that are in the uh growing side that are you know directors of compliance and stuff like that you know and they get frustrated with Labs because they go oh well their Machinery is contaminated or this that and the other so what happens is you know the ABS that give the best results end up getting the most amount of business and what that means is number one in order to get my product on Market it has to pass certain uh microbial limits right it has to be below those limits but addition to that what the market is trading on is THC right now we go back to that whole thing we talked about earlier there’s no standards in this industry right so incubation time you know typically we like a gold standard of standard of 36- hour incubation times there’s Labs out there doing 24 hours and 48 hours that can mean a huge difference in what they call Colony forming units cfus and their growth you know in terms of how many there are at the end of that test um and then the testing procedures around THC if you don’t calibrate your equipment properly you can get a higher amount or you can get a lower amount what do you think the customer is going to want well that one says it’s 36 uh or or 45% THC which by the way is not genetically possible don’t believe that crap uh um but yeah you’re gonna you’re going to go for number one how do I get my product on the market and number two how do I make my product more attractive to the end consumer and those are driving factors yeah and like you say as of now now the way that people I would say a majority of people the way they shop is they go in and they ask the question what is your highest testing flower right that’s it’s just such a cliche but it is true I mean you ask any bud tender and that that’s what they’ll tell you um well you need to go to like a wine store and just go up to them your videos and be like what is the highest alcohol content wine you have here today yeah you know well exactly that’s that’s kind of an example I like to use where it’s like you don’t go to the liquor store and grab ever clear because it’s 99% alcohol and you’re like yeah let’s do it no you know um that’s not at all how we do it the other thing about it that I find interesting and I know that maybe this tiptoes us into like the way we can start to improve Cannabis Testing and this first one I don’t know that Cannabis Testing Labs really are at fault per se uh like I don’t know that it’s a shortcoming of the methodology the testing methodology but I’m curious your thoughts it’s like this idea that this joint I’m smoking right now it had a label on its package like you know that said that it tested but of course we should acknowledge the fact that this joint was not tested the label is representative of the sample that was tested so like this is like this gives me an indication of what you what I’m saying sorry I feel like I didn’t that well that is typical of nearly every agricultural segment you ever I have to ask you that yeah you ever go get a tomato at the grocery store yeah hell yeah all right those are tested you know those are batch tested uh so in most other other industries of things that we eat and consume uh has a very robust uh process and standards behind it that make sure that when it gets to the grocery that’s not going to make you sick like I don’t when I go to the grocery I buy a bell pepper I’ll eat it you know yeah there there might be pesticides but I’m not worried about getting leria or salmonella and dying tomorrow um and the reason that is is because of those robust processes and standards and those quality control checks all throughout the process of getting that doesn’t happen in cannabis so with your joint we’re in Illinois I think it’s a 20 PB bch in Illinois I can’t quite remember might have gone up to 50 yeah we’ll just pretend this joint’s from Illinois sure yeah sure you know maybe it’s from massachusett there’s some good stuff coming from the different the East Coast man and the Midwest I gotta tell you yeah sorry to cut off your point though anyways oh it’s okay it’s okay um the the way it’s tested right now that is a representation of what the test was that you got you know and and there’s probably quite a bit of variation between what the test was and what that is both in content and and whatever else might be in it and in fact you know if people check out their labels at least in Illinois and in some other states too the the labels sometimes acknowledge that that the potency may swing like 15% plus or minus it is but I I will say this you know like Illinois and and states that do have robust testing I feel confident going to a dispensary that that’s not going to have pesticides in it or things like that that I feel good about you know uh when we go to other markets I mean there’s been a lot of news about California I don’t know if you’ve noticed pesticides and they you know they don’t test for that in Illinois you are not allowed to use pesticides period and a story you can lose your license over it so it’s something that these manufacturers take very serious uh but that’s also very difficult to grow cannabis at scale without using really uh really strong tools and and processes and Sops to make sure that your facility is clean so it’s not easy yeah well um and I want to talk more about that in a moment but one point you brought up that I was extremely excited to talk to you about when you just brought up the Tomato example and compared it to cannabis I don’t know if people realize like I really wanted to underline what you just said where cannabis is tested as the in product but a lot most of our other everyday products it’s there’s like several tests throughout the life cycle and of course yes in end test that’s a representative of the batch oh my God yeah so you know in food let’s talk about beer for a second um or you know canned anything you’re Distributing at a National level to hundreds and hundreds of thousands of people if there is a problem microbial issue you can kill people right so the way that they prevent that is they have quality control checks at every part of the process of the creation of whatever is going into that can the beer uh the sanitation aspect of the can checking the the microbial limits you know final product testing it’s robust they have entire departments devoted to those processes so that the end of the day they don’t hurt people so why why is that well uh because when you kill somebody or hurt somebody or make them sick it’s very expensive the government calls it statistical value of life always kind of gets back to money it’s very strange um so if I hurt somebody in the food industry or the beverage industry uh it could be Criminal it could be civil right in terms of penalties and when we’re talking about you know billion dollar a year Industries and servicing millions and millions of people throughout the country if not the world and I’m Distributing those products if I don’t have those quality control checks in place then my risk of hurting somebody is greater right so that’s why that exists it’s it’s a it’s a risk management strategy and the cost of those systems uh are far less than what it would cost if you hurt somebody yeah and I guess the the point of the system that I thought was really fascinating I think I tuned in to like maybe something new and this is how we ultimately line this up we’ve been talking about it in the podcast for a while but I joined like a event you had for clean Theory where you were talking through some of the things that you did and you you talk about how like you almost replicate what you just spoke about and I guess the the point I’m trying to make not just to make a clean Theory pitch I just brought that up because that’s how I learned about this concept right to like underline like the the other tests that happen I think you mentioned like air quality like I get the point I’m trying to make that the compare and contrast is cannabis the end product is tested but there are from what I understand and what you explained there are several other tests that really should be happening at these facilities and on the products can you talk bit more about that well yeah so like um when we’re looking at specifically uh indoor agriculture right there’s a what we’re really trying to do is replicate the outdoors which by the way is stupid hard right and we’ve done really amazing things from an engineering perspective and lighting and environmental control systems but there’s a whole another world that we can’t see and outside you know like literally outside we have this whole system of checks and balances competitive exclusion and predators and prey it’s it’s a war out there that we can’t even see and what happens on the inside well we’ve done all these fun engineering things it’s this is a part of stuff that we don’t see so things like irrigation systems right uh that feed the plant on a daily basis we have got pipes and nutrients and all kinds of water activity inside of that is a place we don’t even see so there’s biofilms and bacterias and different molds and and that can lead to Downstream issues like fusarium and pythium uh so if we don’t test those things regularly I could be growing my plant everything going great and then the next day all my plants are brown what happened oh well that that’s fusarium uh that you’re your plants are done so have fun you know so like tests like that also benefit the the the product from a from a revenue perspective you need to protect it um you know a lot of facilities use HVAC systems right so you got air flow massive amounts of air flow moving through trying to condition that space well just like our houses we have filters and filtration and intercoolers couple that with high organic loads a lot of stuff grows on it and there going to be some nasty stuff that grows on it you know we’ve had deaths in cannabis as a direct relationship to you know different end of toxins and mic toxins that people are allergic to that has to do with air quality that’s a direct representation to the environment that the plants in if it’s not on point you’re going to have Downstream issues betrus or powdery mildew uh aspergillis and the list goes on and on and on so yeah there there’s this deep relationship U of the environment and the ability to keep it as clean as possible not sterile but sanitary I think is the right word to use uh that make sure that the the plant itself is healthy and also more importantly that the people um you know in in our tenure so far in this industry and I’ve been saying this for years we will see you ever see the misoa commercials yeah we’re going to see that in cannabis I promise you with COPD they used to they call it um um grower cough you cultivators cough that’s a real thing you know people are getting COPD and you know you know histoplasmosis pulmonary aspir gilis they’re having lung issues it’s because the environment that they’ve been working in for a long time is not conducive to humans being in it it it has mold and bacteria and things that are not being addressed it’s huge problem huge problem when we were doing our early test this is probably or five years ago now we were tracking um particulate matter and particulates measured in different segments uh pm10 to pm2.5 and then below pm10 you know larger particulate matters pm2.5 is really problematic those are the things that can like bypass our our natural uh protection components in our body but we were trying to establish uh you know what percentage of that mass those particulate matters was biological we came up with 18 % but an interesting thing that we found out was this uh there’s an entity called ashray and ashray set standards for air quality the air quality in cannabis was rated as light industrial it turned out to be the same as poultry bars that’s insane yeah you only know till you know so you know yeah I go ahead no no no it’s just it’s these little interesting Nuance things that you don’t see yeah you you know once you begin to understand oh well yeah we need better filtration that you go you know that really matters right well and I just I don’t think people think about like when you said what you said I was like wow this seems unique for cannabis and I think people make a lot of assumptions like I say not only the third party independent lab testing but I think people think when they get a product they’re like this is exactly what the label says and as the Chicago Sun Times showed and it just basic logic tells you and the regulations even acknowledged there is variance and you know what I mean everybody’s acknowledging that so but I’m just saying these people make this assumption and uh one of the points you just made I think a lot of people might cons uh assume that you know part of the regulations are you must must have like clean air filtration systems and stuff and it’s like I don’t know that state Regulators are going in there with like an air meter and like testing air I think they’re literally just testing your end batch that’s correct that’s correct and and and and a a a growing I don’t want to call it a problem but a growing loophole is this concept of remediation right which when we look at the market there’s a lot of products out there that have been remediated and then and we we we kind of use that as a bad word it doesn’t have to be but a lot of times the way these manufacturers are using remediation Technologies and there’s all kinds of different ones and which one you choose matters as well um the the consumer doesn’t know so if I go to the grocery store if I buy something that’s irradiated for example or remediated it has to be labeled right doesn’t exist in campus right right so what they can do is they can cover up problems way back in the in the the the supply chain so the customer has no idea kind of like being go like going to the grocery store and going to the bread aisle and picking up a loaf of bread and they’re you know right what if there was mold growing all over that before but oh we we killed it uh you know we just we didn’t store it properly we didn’t cure it properly it had mold all over but we we put it in a machine and now it’s fine so you’re you’re good to go right well and then the other thing that I I don’t believe this is unique to Illinois but I know for a fact it it’s a thing that’s in Illinois is if a batch fails testing you can remediate that product into an oil which can be used in Edibles yeah so again different regulations different states sure uh there’s states that you you cannot sell a remediated product so what they do is they REM they put it through a remediation process before they send it to testing yeah and they get around it that way uh Pennsylvania I believe is an example of a state that if it is if it fails that product can only be used for a topical but not an edible um I will say this you’re you’re if a product fails testing and we call this Pro this concept called diversion right and that that that is a concept that’s used in apples and oranges pun there but uh there are ugly apples and ugly oranges they exist when we go to the grocery store we get the best looking ones believe it or not a lot more ugly and they don’t sell them to us and they go to make things like juices and uh different uh fruit purees right so that is diversion right and that exists in cannabis so if there’s a problem with cannabis what you know maybe it it doesn’t meet a certain standard or it’s BBD or C Bud they might choose to send that to an extraction method and there’s all kinds of different extraction method but generally speaking that method of extracting the cannaboids from the plant destroys anything that would be harmful for for us as humans and I think that is a completely acceptable thing but you want to limit that as a manufacturer you don’t want to do diversion all the time means you’re losing money yeah and uh you know just a brief tangent on remediation um like do you think there are any health concerns like I’ve seen in other states before you answer that question I’ve seen in other states they’ve introduced or even like pondered the idea of requiring cannabis to be labeled if it’s been remediated and I’ve seen some of these uh remediation companies Lobby against that saying it would confuse consumers and so I guess my again my question is do you think they should be labeled and do you think there’s a health concern I know that’s two questions but so so let’s talk about labeling so I’m friends with some of these guys by the way so they watch this I’m G make sure they get it so they’re like hey uh so we we go back and forth you know I I do think that if if a product is irradiated or oated uh it should have a label that represents that right uh I think that is the right practice to do period you know and my rationale for that goes all the way back to 1906 for the food Purity act right um if you ever read the poison Squad if you haven’t I highly suggest you do very interesting period of History where uh it started kind of the the beginning of the food industrialization period for that act food manufacturers didn’t have to put a label on what was in the food so they put all kinds of crazy stuff in it like for Malahide and talc and all kinds of different poisons and preservatives to try to make food last longer as we move from a from a more agrarian society to a more uh uh Urban Society right and that was a problem we didn’t have really great Refrigeration the result was people were dying left and right people were poisoned literally this guy uh uh Harvey um um the the guy who headed headed this thing um he he basically went before Congress and fought and won and Congress said you know what if you’re a food manufacturer you got to label this stuff so my rationale goes behind behind that it’s it’s not so much it’s not a I don’t care if it confuses the consumer it’s a right to know not not an option so and and we that has been a long hard fought thing in our history and you know argue with that you know that’s what I say so you know gives them less wiggle room to to say well you know no it’s already been decided at any rate um you know and then the other thing about remediation is it oftentimes hides problems in the process so if I’m growing in a facility that is a problem that has things like sick building syndrome that’s like things where stacky botus grows and I’m having people work there number one your employees are in a bad bad place man uh they’re they’re going to get sick eventually and then your plant health is is is is a problem and now you’re going to put it into a device that covers up those issues a lot of the forms of remediation don’t resolve things that can be a broader problem like so yeah we can breathe in certain varieties of aspir Gillis and it can create basically lung fungus but then there’s another thing of what those funguses and molds and bacterias make which are called endotoxins and mot toxins it’s kind of you kind of think of the excrement of of the the processes of those things growing those are also toxic and those are also a problem remediation doesn’t remove those from the equation and they’re not being tested for and then we get into the cause you know the the the cause and effect of REM remediation so you have things like chemical remediation so you’ve got energy energy basically you can use which is called ionization nonionizing uh products which is like radio frequencies uh microwave and then you have chemical right the chemical there’s no designation for a chemical remediation like there’s no radula equivalent for ozonation and the problem with that is Ozone and they they’ll tell you everything under the sun oh it’s a safe chemical it’s natural well so is arsenic ozone has a a problem with what’s called multi-generational chemistry and that it’s so reactive with volatile organic compounds AKA tpes that it creates from Malahide and that’s winding up in the final product nobody’s talking about it so you’re using that to try to cover up an issue and you’re creating another issue at the same time um and you can never go back and increase the quality so like what we want to talk about with people is is all about prevention it’s in those robust structures that you do on the back end of saying grow a quality plant and it becomes a profit Center you know uh but I would say from a remediation standpoint a ionizing a radiation is probably the safest you know and that’s what we see a lot in the market so long as it’s not used to cover up a problem and that it’s labeled and that’s kind of where my personal stance is on the matter um you know I see you got a joint I mean would would you want it to be labeled if that was uh irradiated or oated yeah yeah absolutely so I went off there I apologize no it’s all good but I mean it sounds like you you addressed both the questions that I threw at you which is yes you think they should be labeled and yes you think there are possible possible health concerns definite health concerns it’s not possible it’s an absolute so if you look at I mean it’s this is risk management the more product that fails the higher the probability of that product getting on the market number one number two is that the more product that is bio burdened and I have to put through a process to correct that issue the higher probability that other things are going to happen so if I’m oating I’m using ozone there’s a high probability I’m creating for Malahide somewhere in that process it’s getting packaged and it’s going to stay in that package until it’s opened and it’s not to say it can’t go away eventually we use different types of uh derivatives for Mal for Malahide all the time in food like formalin for example for example irradiation is probably one of the safest like you can look this up with the World Health Organization but again label it and and then uh you know things like microwaving it definitely destroys the Tarpin and it Heats it up changes the profile of it like there’s there’s you when you remediate you can never improve quality you’re not improving quality it’s always decreasing you can never go back in time and and and increase quality it happens at the beginning right right you can’t you can’t bring it back and um yeah it’s um thank you for addressing the topic of remediation because I don’t even think a lot of people are aware of it but I definitely wasn’t aware of the definite safety concerns because it’s funny you know usually people when when people talk about the uh the black market or the the traditional Market if you will um they will say things like if you get the Vapes they’re going to have formaldahyde in it and maybe that’s been true in some anecdotal cases I don’t know but it’s just crazy that you just pointed out a case where it’s like you know I mean we’ve had companies I’ve had companies on this show that do aention you know what I mean so it’s like to know that about the technology is is pretty crazy so they probably don’t even know they’re not told yeah well I will tell you that one thing I’m not going to name the company’s name because it was obviously an allegation but there was a a situation apparently where one of those machines broke at an Illinois cultivation Center and it was like leaking the gas into the room and like like a lot of people like suffered Health consequences as a result oh I mean you need that’s a a funny thing they say it’s not a chemical uh um yeah I I the it is a powerful oxidant it’s a carcinogen and it can lead to scarification of the lungs so when you’re talking about like what we deal with a lot is industrial hygiene and what we call the hierarchy controls so you’re always trying to eliminate variables that harm people at the end of the day while still maintaining efficacy you know ozone is up there on the danger side when you’re using it at concentrations that when you breathe in it’s going to be a problem and the problem is this when they’re using ozone if it is above a level to kill microbes it is above the oia limit that is safe for people if it is below the oosha limit that is safe for people it is ineffective for microbes so pick one what do you want right wow yeah that’s scary well um terrifying and they put machines inside of these facilities and they make all kinds of fancy names up in marketing for it maybe it’s a an RO a reactive oxygen species right well and I’ve even noticed bi oxidane I’ll keep it at this because I think this would you know I don’t care to people can figure it out um but I’ve even noticed people move away from the word remediation they’re calling it other things now um I got to know this I might as well say it it’s fine because uh you know like they so this is what we’re about to get into anyway so maybe it’s a good segue um as you mentioned it’s kind of a good segue to a similar topic but as you mentioned there’s a lot of people that do these topics I mean there there’s a reason that these companies that offer these Technologies are as successful as they are it’s because a lot of these big companies need it and so so you know after a Chicago Sun Times investigation what a lot what I’ve heard a lot of these companies have Incorporated is instead of remediating they do what’s called a kill step it’s still remediation they just remediate it before they send it to testing in order to ensure they pass testing right yeah so that’s what I meant yeah yeah the kill step I’ve I’ve had some discussions with some colleagues about that no uh okay so a kill step is an inline process that that is meant to kill right but again the quality control checks behind it if it already failed testing so what I’m saying is is what I I don’t apologize for cutting off but I meant they do it to guarantee they pass testing because the standards are just so hard to comply with you know well and in that so and in that case a kill step is so if I am doing the things I need to do to reduce my cfus and let’s say I would pass testing if I didn’t need to do a final kill step but I want to create an assurance to make sure okay fine that’s a kill step that’s a kill step because you what you’re doing is you’re you’re not spending a lot of time in the remediation portion and I’ll do this by a way of example because I I know exactly what you’re talking about now typically what we see from a testing perspective regardless of the cfu count Colony forming units is that they are so high that they have to spend lots and lots of time inside of these remediation devices sometimes up to 9 hours sometimes up to 36 hours long time for them to be effective to get what they call an ND a non-detect when that happens number one from a business perspective it creates what’s called a bottleneck so I can’t get my product out but more importantly what that means is that there is such a high level of Bio burden that that would have never passed test right the way that it’s considered a kill step is that when I’m going through you know I started as a seed I moved through my vegetative state and my flower I’m into Harvest cure and I were to test and at that point I’m below the thresholds already and if I wanted to go through my process and then I wanted to do a final kill step for 20 minutes an hour to guarantee that thing those things were low that’s a kill step the problem is once again we do not have standards to clearly delineate what is a kill step and what is remediation so there’s a lot of marketing uh latitude that is given to these different things yeah and you know one of the points that that really helps us do this transition um that you just brought up and we’ve brought up a few different times in case people didn’t know um what are cfugs it’s Colony forming units PR gram or something like that right cfus so whenever we see see a cfu that means Colony forming unit so typically what we’ll see it is is written as is CFG Colony forming units per gram gotcha yeah and you know I I referenced the Chicago sometimes investigation earlier I’ll have it linked in our show notes and I also sat down folks that are listening with the uh people that were behind this investigation on the podcast way back in the day so if you want to hear if you don’t want to read the article you can listen to them tell the story about how they wrote the articles um in one of the articles they list the testing standards for Illinois and how they compare to other states and I thought this would be an important point to highlight and this kind of opens us up to this next topic so maybe we’re not covering all of our bases but at least for yeast and mold Illinois it looks like it allows up to 1,000 cfug let me zoom in here a little bit so it’s readable for everybody um Michigan allows more um total East and mold up to 100,000 cfug so in in other words if I’m if I’m not mistaken Illinois allows for a tenth of what Michigan allows am I doing the math right and then in California at least at the time of this writing there were no testing requirements for total yeast and mold Connecticut recently increased their limit again at the time of that writing this was in 2021 um anything to add before I like ask the question that I actually already asked you uh it’s my question about hom grow an ideal product but any thoughts before we move on to that like just about the standards as they stand so so one of the problems I believe with testing as a whole is when we look at one we talked about earlier how this whole thing came to be we’re talking about a plant really what we’re talking about is farming you know and and this is not a sterile condition situation right now we don’t differentiate between good bugs and bad bugs when I say bugs I don’t mean insects I hate those things I’m talking about microbes here right so we we Clump everything into a collective basket if we will when we’re when we’re conducting these tests but there’s other Concepts out there even supported by the EPA that use what concepts of what’s called competitive exclusion right so and this is related to Hom grow too because you can use this stuff for hom grow it’s great things like bailus subtilus lactic bacteria you ever had cheese coal yeah me too yeah so bacteria is used to make that stuff right it doesn’t hurt us it’s actually beneficial to our bodies there’s a synergistic relationship and in commercial cannabis across this country we can’t use those amazing biological entities to prevent things like powdery Milo and betrus through these mechanisms called again competitive exclusion or will fail test so it pushes the envelope of these producers to do things that they probably wouldn’t otherwise do you know maybe they are you know are trying to create a kill step you know and to prevent certain things uh and the testing again back to the testing it’s just it doesn’t differentiate between good and bad and that I think is a big problem when we start to look at the scalability of the industry and how do we make it better and safer for for humans yeah and that was that was sort of my point in bringing this up it’s like you know a lot of people will boundy about the fact that as we just pointed out Illinois technically speaking does have stricter standards than most of those other states and in fact I think some people say the strictest in the nation um but that like you said strictest doesn’t mean best outcomes um I have a clip that I wanted to share but uh it looks like maybe you might be are you pulling something up or anything uh yeah I’m sending you there’s a company called medicinal genomics they have the microbial testing regulation by state it’s a good resource sweet sweet I will put that into the show notes but if people are watching and want to see what we’re talking about so that they can Google it uh here it is on my screen cannabis microbial testing regulations by state so yeah oh nice this is a comparison um between all of the different testing oh nice this is so cool so you can sort folks if you’re watching I’m this little sidebar I can change the type of testing so for like ecoli looks like Illinois doesn’t even have according to this zero limit zero oh zero limit gotcha um but like for salmonella it looks like we’ve got a nondetect non- detect this is really cool so if folks W to here’s the no this isn’t what we were talking about earlier this is what we were talking about earlier 1,000 and as the report said Michigan has 10 or 100,000 right for and this is for total East and mold were you saying something Kyle no I was just watching what you’re doing here just interesting yeah super cool super cool so like I said you know I I really I’m glad you kind of LED off with that point because that was kind of the point that I was about to make before I transitioned to homow which is that it doesn’t seem that strict equals better um again any thoughts on that before I play this little clip my God yeah so um growing at scale is very different than hom grow and and the amount of people that you can touch with a scalable business is very different than me growing at home and going to the farmers market right uh we have a system already in place called cottage rules that show us how that works but you know a lot of Growers have to meet um water activity limits right they got to get the water activity down in order to where things don’t grow in a package and typically that’s between 0.55 and 65 aw but man I hate that because I got buddies a grow and I like things that are a little bit sticky and there’s no way that it’s going to meet the criteria for State regulated testing and I kind of get down and I I talk about this a lot because you it always should be our choice and and I think you you’ve been a big advoc advocate for hom grow and stuff but you ever go to the the restaurant and get a steak and and you ever order one rare right they have an aster at the bottom of the the menu and it says something to the effect of you know don’t don’t eat that raw steak you’re going to die yeah I mean I got eggs the other day I got uh eggs over easy the other day and it makes the point that you know if you kind of get them cooked that way you’re risking it right but it’s your choice correct you know so like hom grow you know and and and and small batch cannabis I think that we need to look at a different standard a different Cottage rule for those you know maybe you know really good cannabis is refrigerated and we find shelf stability it goes in the fridge okay we just put it on there or whatever yeah you you jumped right to the point that I was you know that I was going to make which is that it seems like the fact that Illinois is a cpg a consumer packaged good state in other words I’m not saying there was actually a a a post that went viral on LinkedIn the other day whoever made this post they did a good job in terms of like it’s always about that first line you know you got to like trigger people on like both sides and this guy did great he basically said like attention cannabis is cpg and so it triggers people on both sides of that debate to be like yes it is and no it isn’t and I take a nuan stance where it’s like some of it can be Edibles for example Vapes topicals cpg do it up but flow I’m not saying it can’t be cpg I’m saying that everybody agrees fresh veggies are better than canned veggies I’m not saying you can’t have canned VG I’m not saying you can’t do canned veggies you get my point yeah I mean it’s like saying that we can only have Little Debbie you know cupcakes and you know the hell with that Baker down the road that made the delicious you know handmade one you know no it’s growing at scale is different than growing in a boutique way heck even even wine making you know right what’s the concept terar you know in different areas you know different characteristics you know the guy that we’re in Southern Illinois is going to grow maybe he grows it outside it’s going to be different than when they grow it up in Chicago or in Humble or if you grow it indoors he’s got a different strain different Nutri you know there’s so many different variations and uh to say that it only can be grown by you know inside under these conditions it just it just it’s a plant so exactly yeah well said well no no it’s totally I would let you go I would you can go on honestly it’s like you’re preaching to the choir here dude um and that that’s like I said you know I want to acknowledge that point before I go any further which is that it’s like almost somebody said this to me once I said I told them like I’m an idiot I don’t know what the hell I’m doing I still don’t know what the hell I’m doing but my first grow ever and my latest grow it’s all better than anything I’ve ever tried at a dispensary and I still acknowledge I don’t know what the hell I’m doing and and the question begs if these are licensed professionals why am I able to grow and then so but what people tell and I wanted to acknowledge this point really quick that you just made they said well of course Cole you’re tending to like maximum of five plants and you’re giving them the love and the respect they deserve versus somebody else that’s doing this at a commercial scale that has to apply commercial techniques of course Cole you have better flour and I’m like all right yeah fair enough but the guys I know that grow at scale you know from a national level all the way down to a state level they’re great Growers at scale but man you go to their Gardens totally different story and they’ll tell you like oh I you know I can spend time well they don’t have time to do it anymore but sure it’s a totally different scenario it’s a great book called The $64 tomato tomato uh it’s kind of fun to read that’s that’s funny but the point I was going to make what little I have learned about growing cannabis I it’s actually given me a lot of um empathy for these licensed Growers that are growing at a massive scale and I know that might sound like surprising but like now that I know the correct processes I’m like how yeah how I have trouble doing it with five plants how would I do it with two what is it 200,000 squ Fe or whatever they have I think it’s whatever it is the point even 14,000 like if that was the maximum I could do it’s a lot so my thing is because it’s all even like just trimming five plants like that is a uh almost a dayong affair if you do it right you know let those plants get good and big like it’s it’s a long process and then you’ve got a week of drying hopefully low and slow then you’ve got curing I I just don’t even feel like uh cannabis cultiv ators are curing it all to be honest um to accelerate the process right yeah and again I don’t mean there’s so many different ways we can go with this but really the point I was trying to make was the little I have learned and we’re about to play this clip that kind of makes a similar point but it’s different is that just the way we have this Market structured and I think you might actually have a little bit of push back on this and I I hope you do like um I feel it’s not conducive to even allowing a fresh product in other words like like the standards are so strict like Co like me I I don’t even know if I submitted a batch if it would pass testing because it’s you know what I consider to be fresh good cannabis ready to go might have too much moisture to sit on the Shelf you know what I mean well yeah so so the the term so you have Rh humidity that’s what most people kind of think but there’s a a a food science measurement called water activity aw is what it looks like and water activity is the available moisture to microbial growth this is a pretty defined science it doesn’t change whether it’s weed or beef jerky um So within cannabis that level is 0.55 to 65 okay that means that you can still have a sticky product and it can still be moist but the water available for microbial growth is there if it’s above that number it might indicate that that product needs to be refrigerated the thing is there’s no there’s no studies around it of shell stability right so even with if we had all the processes in the world for prevent preventing microbial growth during the process and limiting it and then using a kill step or a mediation method at the end uh you’ve seen Jurassic Park right life finds a way y okay and life does find a way so when I put it in a package and it’s too wet or it has a little maybe one little microbe in there and it sits it’s going to grow just like our bread molds just like our our Apple rots uh so you know if that got to the wrong customer it could hurt them and sorry go ahead no simple as that it could hurt them it could make them sick heal them are they immune compromised are they allergic so it is about risk reduction not risk elimination but risk reduction and then the question is how do we begin to discover those things right and like another pitch that I think we you gave a couple examples that I think a lot of people will relate to the steak brought up the eggs um another example I think just like with regard to this that people would really relate to is like the experience of buying produce like I went to go get strawberries the other day and grapes strawberries were great The Grapes were a depressing story I did not end up purchasing them and it’s because I was able to inspect the product I have my own little inspection I’ve talked about it on the show before I like squeeze the grape to see how firm it is sometimes I pop it in the mouth I found out that’s shoplifting not the hard way I want to be clear somebody called me out on the podcast they’re like you know that’s shoplifting I’m like seriously sampling [ __ ] no you gota gotta try the fruit before you buy it I mean yeah it’s not like I’m like [ __ ] an apple and eating it right um but you know with strawberries I’ll visually inspect them a big thing for me is like if I can smell them when I walk by like if they’re very aromatic it’s like damn that’s probably a good batch of strawberries so there’s a lot of these different techniques that I use that to identify like fresh produce that honestly when I go to states that serve deli style I have similar techniques I smell the jar I don’t touch it or anything uh but you know in my experience in the traditional Market sometimes one would let you pack a bowl or something you get a little bit of taste for it just like a little bit of a grape you know so I mean like I guess what I’m saying is is again it’s like the purchasing experience we’ve set up right now is just not even conducive to that experience it’s like basically we’re just allowed to go buy green beans right now and it’s not that people can’t make good Cann green beans but yeah you’re not wrong you’re not wrong you know uh I think within our lifetimes we’ll see some good changes that probably are more aligned with what we’d like to see but it’s probably not going to happen for another five to seven years s you know we’re still talking about you know different regulations that haven’t even come through uh and and you know they’re not putting regulations out without standards so and those aren’t done yet uh you know it’s but but we’re making progress I think you know you know keep talking about these things of hom grow you know I see all the time talking about it it’s definitely a needed thing yeah like you mentioned this this this pie is pretty big you know I can grow tomatoes but I’m still going to the damn grocery store and buying some too it’s fine exactly well said well let’s watch this little clip and then we can close it out uh start to close out um the show so here’s the clip it’s from episode 59 of the show with uh Dr Bob Miller who’s from Labs cool for it’s overall success I want to talk about one aspect I I apologize hopefully won’t be too in depth in chemistry but a situation right now we’re living in Illinois in Illinois today we have a pesticide test that we cannot do the test requires us to test for 350 different pesticides if we were to even get the materials of known Purity it would cost us hundreds of thousands of dollars even to be able to do that but what it makes it worse is it says the specification should be the tightest specification of any product that would have that pesticide so for example we’re having arguments right now having a pesticide and we’re using a specification of what’s in cheap because the way the regulation is written you have to test for 350 and the criteria you have to use is the tightest of all specs for all types of food stuffs so the absurdity of that situation is just Paramount what’s it driving non-compliance no since none of us can actually do the test every laboratory is doing something different many of them are not even doing the test so with the intention of creating the most stringent criteria actually caus the opposite it actually is causing non-compliance so really important about regulations so yeah just an interesting point you know that not wrong yeah and like I guess just to close it out close out that Loop that we’re on again people say that Illinois has the most the strictest standards in the nation with regard to Cannabis Testing that doesn’t necessarily equal good it seems and like sometimes people will say well okay look how many recalls are in Michigan you want to talk about comparisons how many recalls are in Illinois well guess what one of the findings and you can again check out the show notes folks in the Chicago Sun Times the state of Illinois protects operators again from issuing they don’t have to issue a refund or sorry a recall I’m stumbling with my words probably because I’m on my third joint but um you get what I’m saying here like uh you can’t you can’t prove something you don’t have data like so if you’re trying to make that case what I just laid out if you’re trying to say well Michigan has so many more recalls it’s like well you can’t actually say that confidently because we don’t know the number of recalls in Illinois so a little known thing and this happens all over in every state whenever there’s a problem that’s found generally speaking like say say at the dispensary they’ll send their guys out to go pick up the product from the store and say nothing not a bad game plan well but that doesn’t account for things that were sold so in a typical recall situation if there’s an actual there’s a public recall right yeah and I want to be clear I was saying that comedically I wasn’t like but that that it’s a common practice and it speaks to the newness of our industry and and the political garbage let’s just call it what it is that dictates regulations that don’t make sense and a lot of times it’s a case of the law leading science and not science leading law yeah yeah that’s crazy you just you just said it right there you know because that’s like the whole conversation about hemp basically we won’t get into that but it’s B that’s basic you just put that in a bottle you know like it’s the like the law is sort of arbitrary because as you acknowledged I think earlier you know you’ve got cannabis then there’s the legal term hemp and then there’s the legal term marijuana and they’re just arbitrary terms it’s all Cannabis sativa L right is that what you said earlier yeah so y anyways well we covered a lot of ground today Kyle I want to thank you for your time and I think we should do this again maybe uh in Carbondale after some quatros because it’s been a while let’s do it come down to SIU get some of the guys out and uh we go we’ll go revisit the porch or the the cellar the patio that would be lovely and uh I guess just wanted to ask you before you go was there anything that we didn’t cover today that you specifically wanted to mention before we go or good to close her out H we’re good to close out man it was great talking to you and let’s do it again it’s always fun cool so once again it’s clean theory.net right CLE theory.net that’ll be in the show notes folks Kyle thank you again I really enjoyed my time with you and folks I hope you found as much value in this conversation as I did we’ll see you on the next one take care everybody bye

The Cole Memo