Accessing edibles is harder than ever in 2017, with dispensary raids taking place last week from Vancouver Island to New Brunswick. Patients are in a tight bind in this environment of enforcement, as licenced producers (LPs) are running out of product for patients, partially due to recalling cannabis that is unsafe for human consumption. While patients can legally make edibles for themselves, many instead go outside the existing Access to Cannabis for Medical Purposes Regulations (ACMPR) for access, exercising patient rights in accordance with the R v Smith Supreme Court case.

On top of the recent recalls from several licensed producers, mainstream media outlets including the Globe and Mail made the effort to test both edibles and flower coming from dispensaries. The investigations found that ⅓ of the flower samples contaminated, and many edibles misrepresented their dosages on their labels. As such, it’s important to take a look at Quality Assurance (QA) issues for edible producers, and some of the challenges they face in the current grey market. As edibles are not yet a part of the ACMPR, there is no standardized regulatory body like Health Canada to ensure product quality.

Currently, Health Canada certified laboratories (licensed dealers) are not permitted to test edibles for patients, only dried bud and oils (extracts including RSO, infused coconut oil, butter, etc.). The high cost of testing, along with the restriction on licensed labs to not test edibles, are both barriers to this emerging edible market. With continued QA issues on all sides of the industry, cannabis patients are left without a safe and legal source of edibles.

Currently there are no dosage requirements for edibles, as they are not included in the federal regulations. Many consumers are looking for high dose edibles so they can get the most value out of their purchase. As a result, most edible makers compete for customers, and attempt to adjust their dosages to provide the most value per milligram of THC. As testing is expensive to perform on each batch, edible makers who test their products often conduct testing at the beginning of their R&D process, although the cannabinoid content may vary from batch to batch, and item to item. Furthermore, depending on the homogenization of a product, each bite can contain a different concentration of cannabinoids. For example, some producers spray their product with a cannabis tincture, meaning there is variance from the centre of the spray to the periphery, making it difficult to consistently dose each item.

Consumers often end up disappointed by edibles, as packaging sometimes lists a higher dose than the product actually contains. On the other hand, some edible producers have products that are stronger than advertised. Health Canada recently published its task force recommendations for low dose edibles, which should be a wake up call to the edibles industry to be more honest and precise about dosing. Many edible producers are already coming out with new labels to reflect accurate dosage, believing honesty is the best policy.

A photo posted by Fritz's Cannabis Company (@fritzscannabiscompany) on Jan 27, 2017 at 6:26am PST

Health Canada has banned solvent-based extracts like Butane Honey Oil (BHO) from sale by licensed producers in favour of ice water, CO2 or ISO extracts, which are often blended with a carrier oil. As physicians are concerned about consistent dosing with edibles, many prefer cannabis oil so that the bioavailability is consistent and doesn’t interfere with the absorption of nutrients from other ingredients. According to Dr. Mara Gordon, “bioavailability is affected by quantity of food, hydration, and stress.” Studies have shown that carrier oils are vital in improving bioavailability, increasing product potency 2.5-3 times. At the same time, some patients have complained of stomach issues from taking pure cannabis oil watered down with carrier oils to meet Health Canada’s dosage requirements.

The bioavailability of the product will also depend on the method of extraction, as glycerine, coconut oil, butter, BHO, ISO, etc. each have a unique bioavailability. According to patient advocate Alexander Repetski, “Cannabis in a coconut oil is metabolized differently (and some studies say more effectively) than many other carrier agents because of the large amount of medium chain triglyceride content.” On top of the bioavailability of extract, route of administration (eating v.s. sublingual) affects product strength. Not all edibles are consumed by eating, and oral hard candies or tinctures often hit much harder than other products, as the THC is absorbed through the mucus membranes of the mouth and throat instead of in the stomach.

Also, despite popular believe that craft cannabis products don’t need this testing, pesticide detection is important, especially if edibles are labeled organic. The same issues that exist with product recalls for LPs also exist in the grey market, and some responsible brands are beginning to have batch numbers in case of product recalls. Pesticide levels can be concentrated in oils and extracts, so without full testing of every batch there is a risk to patient health and product quality. If you are making edibles as a patient or an emerging cannabis brand, make sure to obtain the lab sheets for any extracts you’re purchasing. If you’re using them in food products, don’t buy extracts unless they’ve been tested for mold or pesticides. While there are licenced producers like Organigram that claim to be organic, certification beyond Health Canada may be needed for organic craft cannabis products to ensure consumer safety.

As the edible industry gears up for legalization, we need to evaluate where we currently stand, and how the industry can scale up quality assurance measures so that cannabis businesses currently outside the ACMPR can be included in legalization and regulation. Due to the high costs of complying with Health Canada regulations, the best strategy is for craft cannabis producers to come together as a community to achieve high quality standards.

- Lisa Campbell

Featured image via Flikr.