Evelyn Alvarez is currently the Quality Assurance Director at Encore Labs. She has ten years of experience working on analytical instrumentation and in regulated lab environments including work on EPA and OSHA methods. She received a degree in Environmental Science with research experience on pesticides.
Evelyn was recently quoted in a Refinery29 article that revealed an unfortunate element of the unregulated Delta-8 THC market. That being that some Delta-8 THC producers will falsify lab results, also known as certificates of analysis, (COAs) they post online.
We cover that topic and others in our discussion, including:
How COAs differ from state-mandated compliance tests How the lack of regulatory oversight of Delta-8 THC products puts consumers at risk Red flags consumers can look for when reviewing COAs The recent increase in Delta-8 THC products How the process of synthesizing Delta-8 THC from hemp may introduce contaminants that most labs are not testing for and more
Thanks to This Episode's Sponsor: Encore Labs
Encore Labs is the premier cannabis testing facility licensed in California with an ISO/IEC 17025 certification. They offer state-wide comprehensive analysis to cultivators, infused product manufacturers, distributors, providers and dispensaries not only for regulatory purposes but also to characterize the unique aspects of your cannabis.
Learn more at encore-labs.com
Additional Resources
Encore Labs websiteI Took A Delta-8 Gummy Before Going On A Run. Things Got Weird — Really Weird (Refinery29 Article)CannMed ArchiveCannMed Community Board (Facebook Group)Healthcare Provider Medical Cannabis Research Study
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View the Transcript
Good afternoon, Evelyn, thanks for joining us. Hey, thank you for having me. Very excited to talk about these very important topics for consumers. Yeah, about that. So, you were quoted in a pretty wild article that came out last month on the website Refinery29.
I find the story concerning in a lot of ways. But let's just start, I guess, with the general premise. So, I don't know if you want to kind of explain how you got involved in all of this or if you want to if you want to do that first.
Sure. Yeah. And to some of the concerns that it raises. Yes, so a while back, we got an email to our lab and Molly, the journalist from Refinery29 was reaching out, initially just asking some very straightforward questions about a Delta-8 product that she was going to write a review piece on.
When I started digging into the sample information, I realized that the reports were very clearly fabricated, just completely made up. When I reached back out to her with that information, she was pretty blown away as well. And that just kind of started a good back and forth between her and I, which ended up turning into this great
piece by her. I mean, she really went down the rabbit hole and spoke to many different people in the industry, you know, from researchers to regulators. It turned into being a good highlight for everyone, you know, for consumers, especially in terms of safety.
Yeah, exactly. So. So basically, Molly had taken this Delta-8 THC gummy and had a pretty intense experience. Right? More intense than she was expecting or that was advertised. And so, she went to the website and looked at the COA that was listed there, as many of these products have.
And she looked at it, everything looked good, less than 0.3 THC, no residual solvents, everything looks good. But she goes one step further and actually reaches out to the lab. How? How common is that, do consumers actually reach out to your lab to confirm a COA that they see online?
Prior to Delta-8, not very common. Now that Delta-8 products have become more and more popular, we've gotten a lot more inquiries to our line. And it's good that people are asking these questions that, you know, there unfortunately is fabrication out there.
There's unfortunately not enough education about what these products are and what regulations, if any. But there are. So, the more that people can pull in and ask us questions, you know, we're happy to help essentially relay the data to them.
We can't go into say in terms of the physician's end of things, but we can interpret the results. Right, so I guess before we get too deep into it, can you briefly explain sort of what a COA is and why it is important for cannabis users and patients in terms of product safety?
Yeah. So COA, simply put, is a summary of the results of testing performance products. So COA stands for certificate of analysis, depending on the number of tests requested. It can tell you a lot about a product. So, it's cannabinoid profile.
You know how important it is, how much THC or CBD is in it. It's terpene profile. We test for a lot of harmful things, things like pesticides, heavy metals, residual solvents, microbials, mycotoxins. All of those are important in terms of safety if we detect it.
It's one of those harmful compounds. You shouldn't be consuming it. Just the whole safety profile alone is super important for the consumer if they are purchasing these CBD or Delta products. How do they really know that that's what is in the product or how do they know that it doesn't contain Delta-9 THC?
I've heard of situations where people consume CBD products and then end up failing the drug test. You know, maybe if they would have gone one step further to look for the report, it could have helped.
More importantly, for patients that are trying to dose, if they want to make sure that what is labeled on the container is actually what it contains so that they can have accurate dosing for whatever it is that they're trying to to focus on.
Exactly, and so these COA’s that the manufacturers put up on their websites, it seems like a lot of the things that they're testing for is similar to what you would do for compliance testing for products that are on a dispensary shelf.
Is that fair to say? Is it really the same battery of tests that are done for these COAs? Does it depend on what the manufacturer requests? What are the differences between the two types of tests?
That is a very important question. It really depends on what they are requesting for testing or compliance testing here in the state of California. There are very specific regulations that we follow really from the beginning of testing to the end.
And I can kind of get into how the sample arrives to the lab and this is important. For a compliance sample, we are required to send one of our trained samplers out to the facility, and we are required to sample something that is unbiased and representative.
And there are a lot of other requirements say the larger the batch sizes, the larger sample we pull. So even just getting to the lab, a compliance one is something that we picked. We refer to non-compliant samples as R&D, so things like CBD and Delta-8 that are submitted, those don't have any requirements.
Manufacturers can send them in, they can drop them off, they can cherry pick if they still wish. It's unfortunate, but they do. So, from the get go you're getting something potentially different than what you're buying because of how it was submitted.
When it gets to the lab, that was a great question that you asked, what kind of testing is performance? So for compliance testing, we perform the whole gambit that the state requires. So a lot of what I mentioned earlier, pesticides, mycotoxins, heavy metals.
However, for these noncompliance tests, it's whatever the manufacturer requests. So if they're only concerned about cannabinoid profile, that is the only thing that we test because they have no requirements. So if it did have something harmful, since we're not testing for it, there's really no way for that to be communicated to anyone.
Yeah. And furthermore, even if that were requested by the manufacturer say mycotoxins or heavy metals or something like that, if you report that back to the manufacturer, is there any mechanism for that to be reported also to some sort of regulator or anyone to make sure that that product still
doesn't make it to the market like I assume is in place for compliance testing? Yeah, another huge difference, there is no requirement for that information to be submitted anywhere else than to the person that requested it or anything that is non-compliance for our compliance results.
The state has really specific regulations. When we finish and approve the results, we are required to simultaneously report it to the distributor that the people who submitted the request to the testing to the State of California, the Department of Cannabis Control.
And we have to upload it to a system, track and trace system. In California, we use metric and all of that case, you know, digital data for everything. So even if this distributor tried to transfer it elsewhere, say, to a retail shop, they won't be able to do that because those failed results are stuck with it.
And even so, since we notified the Department of Cannabis Control, they're already going to take action on that. But for these non-compliant samples, those manufacturers really aren't required to do much. Maybe they're good actors and they're going to go back and mediate their batch and submit again for testing and then sell the product.
But maybe they're not and they're just going to submit a different sample and still push it through elsewhere. Right, and like you mentioned earlier, the fact that they can sort of submit samples that may not exactly be representative of an entire batch.
Yeah....
