Green Guide Spring 2015
Before looking into it, I naively assumed Washington State's groundbreaking marijuana legalization law had given us a unique opportunity to do things "right," which meant, to my mind, a crop that's not only legal but pesticide-free, organic, and eco-friendly. Maybe we've all already given up hope when it comes to fruit and vegetables grown by giant agribusinesses, but weed, given all the tree-hugging, organic-food-eating, GMO-avoiding hippies who love it, must be different. Right?
Wrong. What I discovered was that legal weed is most certainly not pesticide-free, although to be fair, there are severe restrictions on the kinds of pesticides recreational marijuana growers are allowed to use. Pesticide use is so commonplace in agriculture that the question becomes one of degrees rather than absolutes. In a storybook version of reality, we would be smoking pesticide-free fatties with the Lorax and satisfying our munchies with unsprayed apples 100 percent of the time. But as glorious as that would be, that doesn't reflect the economic or ecological reality of agriculture.
When the Washington State Liquor Control Board (WSLCB) was inventing rules for pesticide use on recreational marijuana plants, they turned to the Washington State Department of Agriculture (WSDA) for some expert advice. The WSDA studied pesticides typically allowed on hops (a close cousin of cannabis), tobacco, and food products. The rules in place are a result of that work.
The state appears to have done a good job at regulating a previously unregulated and unstudied area of agriculture—a plant the federal government still classifies as a Schedule I drug. All pesticides used on any crop in the state of Washington must be registered with the Department of Agriculture, and the list of approved pesticides is available via the Pesticide Information Center Online (PICOL), a database operated by Washington State University. There are, by my highly scientific estimate, a metric shit ton of allowed pesticides in our state. How many of those pesticides are recreational pot growers allowed to use on pot that ends up in your body? Two hundred and seventy-one.
That number is not nearly as upsetting as it may sound, given a little context. At a recent meeting of state and local officials working with the recreational cannabis industry, one attendee voiced concern that 271 legally allowed pesticides seemed like a large number. In response, Erik Johanson, the WSDA's special pesticide registration program coordinator, offered this sobering bit of information: "If we were talking apples, the number would be 1,000."
When it comes to regulating recreational marijuana pesticides, the WSDA did what government agencies do best when faced with uncertainty: They played it safe. They chose to only allow pesticides that were exempt from any tolerance level requirements—thresholds established by the Environmental Protection Agency (EPA) that dictate the amounts at which pesticides become harmful when consumed, inhaled, or otherwise encountered. Being exempt from those requirements is the EPA's way of saying a substance is so benign, they didn't feel it necessary to study it further. Also, thanks to the popularity of edibles, the WSDA chose to consider the harvested buds as a food product—though they are not technically classified as such by the legislature—disqualifying a bunch of nasty stuff intended for use only on ornamental plants or otherwise inedible crops. This led to that relatively small list of 271 pesticides. It is primarily composed of the type of essential oils that might lead you to overpay for a bottle of shampoo.
Many of the allowed pesticides with scary names aren't even that scary: azadirachtin is an extract of neem oil, potassium laurate is just soap, and bacillus subtilis is a bacteria with antifungal and probiotic properties that occurs naturally in our gastrointestinal tract. None of them are listed on the Pesticide Action Network's list of "bad actors." Is each and every one of the 271 legally allowed pesticides something you would feel comfortable gently misting over a field of adorable puppies? No. I found two somewhat troubling substances on the list: pyrethrins and their trusty sidekick piperonyl butoxide (PBO). Pyrethrin is listed on PAN's "bad actors" list, and while PBO is not, it is a chemical synergist for pyrethrin, working to enhance its effects. The duo is most commonly found in fogger-style bug bombs with brand names like Doktor Doom and X-clude.
Those two ominously named brands are not on the PICOL list, though they are still available for purchase at your average gardening supply store, a clear indication of their popularity. Doktor Doom and X-clude may not be on the PICOL list, but other fogger bombs with the same active ingredients are. (The PICOL list is organized by brand name, not active ingredients.) Pyrethrins are classified by the EPA as a botanical insecticide, being the active chemical ingredients of pyrethrum, an extract of chrysanthemum flowers. Pyrethrins and PBO are, given their inclusion on the PICOL list, exempt from residual tolerance requirements and thus safe for human consumption in any amount, according to the EPA.
But if you've ever used one of these foggers, you know they're some pretty heavy shit. Before you use one in your house, you have to cover all exposed food products and remove yourself and your pets from the area for at least several hours. In the context of growing marijuana, they cannot be sprayed directly onto a plant or the plant will die. Most growers agree they should not be sprayed onto plants at all. "It leaves a lot of residue on plants," said Dustin Hurst, head grower at Monkey Grass Farms in Wenatchee, explaining that it's especially risky to use these products late in the plant's flowering stage when the flowers begin to enclose into buds, potentially trapping pyrethrin residue within. Daniel Curylo, "lead instigator" at Cascade Crops in Shelton, concurs: "You don't want to be spraying all sorts of crap on your product, because the residue—I don't care what anybody says—that stays on there."
Indeed, a 2002 fact sheet from the Journal of Pesticide Reform cites a study in which pyrethrin residues were found in carpet dust more than two months after application, which is a bit unnerving when one considers the crystal-encrusted tendrils of a flowering pot plant. A later study, published in 2013 in the Journal of Toxicology, found that up to 69.5 percent of pesticide residues can end up in flowers at the point of inhalation. So, if pyrethrin/PBO foggers are being used at any point during the flowering stage of the plant's growth—which would not explicitly violate any of the WSLCB's rules—you're likely smoking some of it.
How big a problem is that, health-wise? The Journal of Pesticide Reform cites concerns about pyrethrin ranging from disruption of hormonal systems to the chemical's EPA-granted status as "likely to be a carcinogen by the oral route." The EPA's own human health risk assessment of pyrethrin suggests that long-term inhalation of pyrethrin in significant amounts can cause "respiratory tract lesions" in rodents. Scarier still, the JPR factsheet notes that pyrethrins are absorbed by humans most rapidly via the lungs.
If you're curious about what may be on the marijuana you get in a recreational store, ask. Every pot grow operates differently, but under WAC statute 314-55-087, growers are required to keep accurate records of all pesticides applied—when, how much, by whom, etc. The WSLCB's team of inspectors can check these records to ensure proper use at any time. And every grower is required to make this information available to recreational stores that carry their products.
What Kinds of Pesticides Are Recreational Marijuana Growers Using?
So why would any pot farmer worth a damn want to use the stuff on their plants? Because weed farmers have to deal with pests like any other farmers do. "I think you could bleach everyone and everything, and [spider mites] would still get in," Hurst, the Monkey Grass Farms grower, told me.
"Everybody gets it—spider mites, stuff like powdery mildew, it's everywhere," said Curylo from Cascade Crops. Spider mites, which appear as little black dots on the bottom of a marijuana plant's fan leaves (the part of the pot plant most likely to be superimposed over Bob Marley's face on a T-shirt), are the bane of growers, along with mold and bacteria. Left unchecked, these infiltrators can ruin an entire harvest. Getting rid of them is a constant battle, and growers have typically employed a wide variety of weapons, most benign but some less so, like pyrethrin.
But pyrethrin does have legitimate uses. According to various gardening supply store managers I interviewed, if growers are using it right, it's primarily as a "reset button" between grow cycles when all the plants have been removed from the grow room. Given the surfaces available for pyrethrin to cling to in the absence of fuzzy budding plants, it's not likely to linger. Regardless, most of the growers I spoke with—both licensed and unlicensed—indicated that they preferred to use lower-impact pest solutions anyway, for both economic and ethical reasons. Most relied heavily on AzaMax, a brand name of azadirachtin. Azadirachtin, as I mentioned previously, is just an extract of neem oil, an age-old Indian cure-all and a very hot seller during scabies outbreaks at Evergreen. Curylo said he planned to stop using even AzaMax, because he has found it cheaper and just as effective to mist using a diluted hydrogen peroxide solution.
To keep growers from using products even nastier than a fogger bomb, the WSLCB maintains the authority to pull, at random, a sample of any grower's weed to run a comprehensive pesticide residue panel on it. If any unapproved pesticides show up, growers face a $2,500 fine and 10-day license suspension to start. The penalties for repeat offenders escalate rapidly, culminating in a permanent loss of license.
There are, of course, recreational marijuana consumers who will argue that all weed should be subject to pesticide residue testing before sale. That was certainly my first reaction when I discovered that the residue test was not part of the required panel of tests that all pot goes through on its way to market. But the system of randomized testing seems to provide a significant enough disincentive for growers to ensure compliance. Given the amount of time and money most people have invested in their operations, a 10-day suspension is a pretty serious deterrent.
I asked Phil Tobias, who runs Sea of Green Farms in Seattle, whether randomized testing motivated him to stick to the approved list, and he replied, "Yes. One hundred percent. We would get fined if we were to use something else, and we can't risk that." His primary methods of pest control? Ladybugs and ionized water. (Ladybugs think spider mites are delicious.)
Hurst, from Monkey Grass, concurred: "If there's someone there watching over your shoulder, you're gonna make sure everything is perfect."
Nick Mosely and Bobby Hines, from pot-testing lab Confidence Analytics in Redmond, were also quick to praise the PICOL list. Hines said the existence of the PICOL list "absolutely" put weed grown under I-502 a cut above everything else. "It's not just the penalty," added Mosely, "but also that there's a resource they can look to that guides them toward healthy alternatives." And indeed, a booklet distributed to regulators and enforcement personnel from various state and local agencies includes a section on encouraging integrated pest management, a holistic method of pest control that attempts to avoid the use of any pesticides at all. Mosely also suggested that many of the bad practices being employed were not due to maliciousness so much as an absence of education. "A lot of [underground growers] just don't know that Avid is so poisonous. They just know their buddy told them it works," said Mosely. "If they know that Avid is dangerous—it's not on the list, but here's a list of things that do work—then they'll go to that."
Mikhail Carpenter, a spokesperson for the WSLCB, says the agency's inspectors have the power to decide what constitutes improper use of a pesticide, and can immediately shut down and quarantine any grow operation that they feel to be unsafe, pending appeal. He also stressed that the WSLCB's enforcement officers, when checking grow facilities, will be examining these records closely to ensure accurate record-keeping and responsible usage. He assured me that if they were to find a grower using pyrethrin bombs dangerously close to harvest, they would put the kibosh on it. So while responsible use of foggers may not be specifically codified into the WSLCB's myriad of regulations regarding legal weed, it is subject to the (hopefully) expert oversight of the WSLCB's inspectors.
If the thought of any pesticides of any sort, no matter how benign, freaks you out, simply avoid growers who use them. There are plenty out there who don't, and there is even a third-party organization—Certified Kind—that certifies weed as organic in the absence of USDA certification.
As far as pesticide disclosure goes at our local shops, Uncle Ike's is ahead of the game, offering a small printed card listing all their suppliers and the substances applied to their products. Ganja Goddess isn't far behind. I spoke with someone there identifying himself as Al Green, who did not serenade me with his rendition of "Can't Get Next to You" but did assure me that, while they did not have a list printed up, they would be able to provide the required information to customers upon request. The gentlemen I spoke with at Cannabis City and Ocean Greens were both "not really sure," though I have no doubt they'll amend that uncertainty once their bosses remind them it's required.
The liquor control board hasn't performed any pesticide audits yet, but Steve McNalley, senior microbiologist at cannabis testing lab Analytical 360 in Sodo, confirmed that his lab was setting up to perform the audits and expects to do so in the "next couple of months." He suspected that the WSLCB likely hadn't performed any audits yet because they wanted to let growers get up and running before introducing any potential fines. Hines and Mosely told me that calibration for pesticide residual tests was also quite expensive and that screening for all the disallowed pesticides that might be out there was an arduous process, something like looking for a "needle in a haystack of needles." Arduous but worthwhile, according to the WSLCB. Carpenter indicated that the agency intended to scan for as broad a range of pesticides as possible, and will be shouldering the expense of the tests, at least initially.
What Kinds of Pesticides Are Medical Marijuana Growers Using?
You might be wondering: Why make all this fuss about the finer points of pesticides under I-502 if most growers play it safe? Well, because legal growers are facing extremely stiff competition from the unregulated medical and underground markets. The fact that legal recreational weed is verifiably free of mold, bacteria, and harmful pesticides is perhaps recreational stores' most serious competitive advantage over the black market and the medical marijuana market. This distinction is a pretty important one, given the stakes, and I'm a bit surprised legal growers and retailers haven't publicized it more aggressively.
A couple months back, I interviewed a few black-market marijuana growers about their take on the cannabis landscape in the wake of legalization, and one of them, Darryl, said something that stuck with me. I asked him why, if legal weed was tested to ensure it was free of mold and harmful pesticides, he nevertheless insisted that black-market weed was better. He replied, "Well, the black-market growers are much more boutique. It's more of a craft market. They've been doing it longer, they've got more experience, and they don't have the same restrictions the legal growers do as far as overhead and regulation."
Now, I believed Darryl when he told me he is personally dedicated to organic, additive-free growing. But something about his answer didn't sit right with me. He was essentially claiming that the black market didn't need testing or any governmental oversight whatsoever because consumers could just trust the experience of seasoned growers. That would be a great argument if the black market (and the medical market, which was not affected by the passage of I-502) were entirely composed of responsible, experienced growers. But...
I've witnessed questionable practices firsthand. I've heard countless tales of growers who are just in it for a buck, turning to harsh chemical pesticides for the quickest, easiest solution. Ian Eisenberg, the Ike of recreational marijuana store Uncle Ike's, told me of buying weed at medical shops and listening to the budtenders extol the organic, locally grown pot they were selling, only to see those same budtenders buy pot from a guy who just pulled a black duffel bag out of a car with California plates.
When I asked another black-market grower, Josh, if he'd ever seen questionable growing practices, he replied: "Definitely. People using household pesticides out of Lowe's or Home Depot. I've heard some wild stories."
And Chase, an all-natural home grower who also works at a larger medical grow, had a similar tale to tell. "It's more common than you think, unfortunately," he told me, in regards to usage of sketchy pesticides in the black and medical markets. "You can go into a [medical] shop and they're not going to tell you, 'Oh, we had to spray that one last week.'" He also added that in certain urgent pest situations, his boss at the medical grow had instructed them to use stronger pesticides that would definitely not pass muster under I-502, though Chase did not specify which ones.
Not knowing where your weed came from or what's on it is pretty scary when you start to delve into what's out there. The worst pesticides that I've heard of being used on weed are all still available for purchase, as many of them have legitimate uses on the type of plants you look at but don't eat or smoke. Aqua Serene, a gardening supply store in Fremont, sells both Forbid, an insecticide that was instantly described to me as "horrible," and Eagle 20, a fungicide that received a rating of "gross" from Markia Gwara, the store's manager. I wanted to know why, exactly, they would still sell these if they wouldn't use them in their own garden. She told me that there is still a market for them—albeit a shrinking one—and their store is, after all, a business. She was quick to emphasize that she does her best to steer people away from harsh pesticides in favor of natural methods, but regardless, they're for sale. Most of the people asking for them were, according to her, "not as savvy of gardeners or old-timers who have stuck to their ways."
Would banning these products from stores help? Probably not. All of the worst culprits—Avid, Floramite, Forbid, Eagle 20, and their ilk—are available online for those who really want them.
Rick, who was working the counter at Hydro 4 Less in Tukwila when I stopped by to ask about the pesticides they stock, said that he occasionally gets customers in the store asking for the heavy hitters, which they don't carry. He noted that often the same customers come back but don't ask again, which he reads as a sure sign they're getting it elsewhere—either online or from other shops.
And, harsh chemicals aside, there is always the possibility of mold when buying from untested sources. Much of the weed not legally sanctioned by I-502 is grown in dank basements, hung up to dry in dank basements, and trimmed in dank basements. "The stuff that comes out of people's basements is often riddled with mold. Basements are moldy and it's Seattle and it's wet," McNalley, the microbiologist from Analytical 360, told me. "Basement molds are stuff that you really don't want in your lungs." He continued, "I would recommend smoking the legal stuff as opposed to anything that's unregulated. I'm for regulation. Having that limit [on microorganisms] is going to keep things safer overall. You could go to a dispensary, you could buy a nug, and it could test in at only 120 colony-forming units, but that doesn't mean anything if you don't get the test done. And no one's getting the test done." This could change—in Seattle at least—under the mayor's proposed rules for medical shops, but until then it's still the Wild West.
If You Aren't Sure, Get It Tested
Getting weed from a medical shop or "the guy" will almost undoubtedly be cheaper than going to a recreational store, because unlicensed growers operate without the burdensome expenses and taxes involved in I-502 compliance. Testing is expensive. Rachel Cooper, from Monkey Grass Farms, estimated that the tests they run on their marijuana cost around $3,000 per month.
Of course, weed that's been tested is much safer to consume. This quote, from a paper entitled "Testing Cannabis for Contaminants" by the BOTEC Corp., a California lab testing company that advised the WSLCB on its pesticide rules, sums up the situation in the unregulated market nicely: "As a high value crop, cannabis will no doubt prompt some growers to use any and all measures to maximize yields, regardless of burdens or risks placed upon employees, customers, or their surroundings."
It is an unfortunate truth that, in the absence of regulation, some people are going to cheat in pursuit of wealth. For every 10 medical growers who are dedicated to growing beautiful, organic weed and are willing to send their product in to the lab on their own dime, there's one guy with dollar signs in his eyes spraying his plants down with Avid because it's easier and passing it off as "all-natural." Provided he's got his medical authorizations in order, there's currently no way to stop that guy from using any pesticide legally available.
Beyond the fact that it still feels weird and amazing to be able to walk into a clean, brightly lit store and purchase weed, it feels even cooler to know that the weed you get from that store is pretty much guaranteed to be free of harmful pesticides and mold. People have made much of all the things that I-502 screwed up—and that list is not a short one—but it's heartening to discover something it got right.
So unless your medical shop or your "dude" is willing to require suppliers to run testing through a certified lab, like Confidence or Analytical 360, and provide you with a list of pesticides used on their product, it's probably worth paying the premium at the recreational store if you're at all concerned about the purity of your pot. A sandwich board with a green cross and the word "organic" painted on it guarantees you nothing. A dude weighing out a sack on a cluttered coffee table while Phish videos play in the background is not a safe source. When it comes to weed safety, I think Uncle Ike put it best: "I don't want to take someone's word of honor, I want my shit tested."