In June 2022, CULTA released a strain called Amnesia OG (Amnesia Haze x Biker Kush). The strain was notable because it broke Maryland’s THCa record. The testing results showed THCa coming in at 40.9% and total cannabinoids at 44.9%. When you thought it couldn’t get higher, Amnesia broke it’s own record with 42.72% THCa and 48.5% total cannabinoids in May 2023. To better understand how we arrive at these scores, our Marketing VP Renier Fee tracked down Daniel Kulakowski from Green Analytics, an independent lab in Maryland that tests cannabis for consumer safety. They discussed lab accreditation, COAs, “lab shopping,” and adult-use legalization. We learned a lot about how cannabis is tested and think you will too!
Hey Daniel. Thanks for making the time to answer my questions.
CULTA has been a longtime customer. We’re so excited to be featured on your blog. Thanks Renier for reaching out to us with this opportunity!
Of course! Let's get our readers acquainted with Green Analytics first. What does your company do?
Green Analytics is a state-registered independent testing lab for the Maryland medical cannabis program. All products sold in medical dispensaries are required to be tested for cannabinoid and terpene potency, as well as screened for contaminants that could impact patient health (including heavy metals, pesticides, mold and microbes, residual solvents).
How many states do you operate in?
Green Analytics operates in MD, PA, NJ, VA, WV, MA and NY.
There are several independent testing labs in Maryland. What makes Green Analytics different?
Green Analytics MD is the longest tenured lab in state. We are able to draw on a wealth of experience and resources from our partner labs in other states operating under the Green Analytics umbrella. This knowledge base helps us develop and optimize accurate and precise methods, share ideas and improve procedures. We take great pride in helping our clients solve issues, providing all root cause analysis support when we report a surprising result.
As the Laboratory Director for Green Analytics, what are your job responsibilities?
The number one priority is ensuring accurate and precise test results. I am also responsible for interfacing with clients, troubleshooting equipment, optimizing methods and working to make the lab more efficient.
Green Analytics is a contracted lab for cultivators and extractors in Maryland, but you operate at an arm’s length, right? How do you ensure independence?
Leadership and employees at our company operate with the highest levels of integrity. We are an ISO 17025 accredited laboratory, this means that all data we provide are subject to external audits by our accrediting body, A2LA. In addition, our results are subject to audits by the Maryland Medical Cannabis Commission (MMCC). Every result we provide must be supported by raw data, a valid calibration, method validation and certified reference materials. As part of our accreditation, we are required to have policies to ensure impartiality. There is no opportunity for results to be edited or altered without being made obvious to our accrediting body or the MMCC.
Operational procedures also ensure objectivity. There is a secondary review process so no one person can manipulate results without a result being flagged. Test results are siloed, so that the employees preparing samples and running the assays have no influence on analysis of reported data.
We are an ISO 17025 accredited laboratory, this means that all data we provide are subject to external audits by our accrediting body, A2LA. In addition, our results are subject to audits by the Maryland Medical Cannabis Commission (MMCC). Every result we provide must be supported by raw data, a valid calibration, method validation and certified reference materials. There is no opportunity for results to be edited or altered without being made obvious to our accrediting body or the MMCC.
To bring everyone up to speed, the A2LA is the American Association for Laboratory Accreditation. Is the accreditation a requirement by the MMCC to operate a lab in Maryland?
Yes, the MMCC requires all independent testing labs to be accredited to the ISO 17025 standard.
Certificates of Analysis (COAs) are the official test results produced by the labs. What is the process for dispensaries and medical patients to request and review COAs?
The lab is required to upload COAs into Metrc, the state seed to sale tracking database. These COAs are available for review to dispensaries. Dispensaries are also provided the COAs by our clients when product is sold. Patients can review these COAs before purchase at any dispensary.
What are the most common misunderstandings about test results?
Test results are only guaranteed to reflect the sample we have to test in the lab at a single time point. While we do our best to represent the entire batch or lot of product (through statistically significant sampling patterns and homogenization efforts) there is a portion of variation within a batch that will always remain difficult to fully capture in a single test result. Also, even dried and cured cannabis or finished infused products are not static. The product is changes over time and can be sensitive to environmental conditions. Cannabinoid and terpene profiles can change during storage and transport. CULTA does a great job at working to understand and limit this variation through stability studies and environmental control procedures.
Maryland medical patients were in disbelief of our high-testing Amnesia OG potency results. I'm sure some of that suspicion came from reports that other states inflated their numbers. Cannabis businesses in California and Arkansas have received flack for "lab shopping," when companies seek out labs that will deliver inflated potency results, or for that matter, deflated contaminate results. Should we be concerned about that in Maryland?
This could happen in Maryland, but there are controls in place to help ensure integrity of Independent Testing Laboratories. In addition to accreditation requirements, the Maryland Technical Authority requires laboratories to meet AOAC Standard Method Performance Requirements for potency testing. The state commission needs to be aware of this possibility when conducting independent investigations of products with seemingly inflated potency, no matter which lab they were tested in. As the MMCC transitions to the Maryland Cannabis Administration (MCA), I hope they continue to devote resources to making this a priority.
At the end of the day, we believe that it's inaccurate to equate potency with quality. Do you agree?
I absolutely agree. Cannabinoid potency is only one known variable that influences the medical or psychoactive properties of cannabis products. THCa just so happens to be the compound present in largest concentrations but this cannot be equated with product quality.
It is well-known that terpenes (both profile and concentration) strongly influence the patient experience. In addition, there are hundreds of other compounds (other cannabinoids or flavonoids, for example) in cannabis flower that are understudied and overlooked, all likely to each contribute in some small or large way to the overall effect of the medicine.
Amnesia OG is also notable because it contained trace amounts of delta 9 tetrahydrocannabivarin, better known as THCV. It's said that THCV has appetite-curbing and energy-boosting properties. What cannabinoids are you most excited about and why?
While I think THCV has interesting medicinal potential and have enjoyed THCV containing products, I am most excited to understand the residual complexity of cannabis holistically, rather than individual cannabinoids. I believe the interplay of major and minor cannabinoids (including those we do not even know about yet) has the greatest impact on the endocannabinoid system. I am excited to see developments in this field of study as cannabis becomes easier to access by research institutions.
What is going to happen to testing labs once Maryland launches its adult-use program on July 1, 2023?
We anticipate the demand at dispensaries from adult users will cause an increase in the amount of flower and infused products produced by licensed growers and processors in MD. Licensed cannabis intended for adult use currently has the same testing regulations in place as the medical program. Labs should be busy but we have been preparing for this increase in volume for the last year.
Will COAs still be available to the public?
Yes, as far as we know. We believe this level of transparency is important for patient and adult user trust in the program.
Any final words?
It’s an exciting time in Maryland to see the transition from medical to recreational. If new operators want to work with us or if medical patients want to learn more about testing, we are here to help.
Thank you Daniel for shedding light on the lab industry.
Thank you! And good luck on July 1st!