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Letters for January 26

Readers sound off on organic labeling, OONA, and Steep Hill labs.


"The Cannabis Clean-Up Team," Legalization Nation, 1/5; "Steep Hill Cleaning Up the 'Bathtub Gin' of Ganja: Pics and Links," Legalization Nation Blog, 1/5

Not Legit

One must be careful when reading articles like this. This is not real journalism with research behind what is said. This lab is not founded or based on peer-reviewed scientific methods. In a compared study with a lab that uses methods similar to what is used by the Dutch government, steep hills values for potency did not come up with the same numbers. This is an unfortunate problem for an industry that is trying to be legitimate. Labs in this industry must have peer-reviewed methods by legitimate scientists.

Jake Pritchett, Oakland

Lacking Cred By Choice

A recent article in the East Bay Express showed a glimpse into the inner workings of Oakland-based laboratory Steep Hill, where cannabis-based medicines can be tested for potency and quality. In the article, the founders of Steep Hill expressed the ambition to "Clean Up the 'Bathtub Gin' of Ganja," referring to the chaotic times of the prohibition. In other words, the services they provide will once and for all separate the good cannabis from the bad, and everyone can feel safer.

As a scientist with a Ph.D. in analytical chemistry of cannabis, I have been involved with legal and international cannabis research for more than ten years. Over that time, I have worked with universities, the Dutch government, pharmaceutical companies, and the Dutch medical cannabis grower Bedrocan. My experience includes developing the Dutch official quality-control methods, researching the Volcano vaporizer, and isolating some of the first cannabinoid standards. More recently I have become involved in clinical trials and international policy, mainly focused on the US. As an established medical cannabis expert, I would like to raise some questions about the ambitions expressed in the newspaper article.

According to the article, "The cannabis quality control lab Steep Hill has scientific validity problems." The methodologies used for potency testing and quality control are firmly kept secret, as the founders of Steep Hill feel confident that any form of peer-review is unnecessary, and self-validation is sufficient. At the same time, the ambitious lab is drawing national attention, and may even be featured in National Geographic soon. Because of the reasons I will argue below, anyone concerned with the future of medical cannabis should wonder if this is actually a positive development. For the moment, there is no reason yet to cheer the accomplishments of potency testing, because we actually do not know what we are cheering for.

Steep Hill is, without a doubt, one of the leaders in the field of potency and quality testing, if only because the number of cannabis testing laboratories is still quite small. But as usual, with leadership come great responsibilities as well. For a laboratory selling analytical results, this responsibility comes in the form of using methods that have been thoroughly validated. This means that you are absolutely sure that the results are reliable, reproducible, and most of all, transparent. "Validations in cannabis come in the form of self-validations," commented co-founder David Lampach in the article. But it is good to realize that this is a choice of Steep Hill, and not a necessity. Self-validation may be a viable option for the medical cannabis industry as a whole, as opposed to central regulation by the government. However, self-validation should not be used as an excuse for obscurity by any single laboratory.

The justification Steep Hill gives is that they want to protect their scientific method. This makes sense, and they are entitled to make a few bucks on the service they have pioneered. Also, there is no need to disclose the person who developed the method, and even publication in a peer-reviewed journal is not really needed. Even the lack of a scientific training of the two founders may be forgiven. After all, well-designed methods for potency and quality testing carry the signature of quality in themselves. But in the case of Steep Hill, who is supposed to recognize that quality, if no one is allowed to look? Steep Hill counters this argument by pointing out they compare results with other "pot-labs." But again, what do we know about those labs, what is actually being compared, and what labs are we talking about, anyway? The basic message here seems to be: just trust us, because we know what we are doing. This is clearly not acceptable, when so much is at stake. A nice label saying "Steep Hill certified safe" is good marketing for sure, but it does not necessarily guarantee patient safety. In fact, safety claims that are not validated by sound science, specifically about pathogens, may be a lawsuit waiting to happen.

I personally agree that Steep Hill still seems to lack scientific credibility, but that is mostly their own choice. Peer-review and method validation have a very clear purpose; to allow knowledgeable and trained individuals to have a critical look at what you are doing. The goal is not to try and take you down, but simply to check if your product lives up to the expectations. And if there is one thing we have learned from the recent economic crisis; companies have an almost inherent tendency to blow those expectations out of proportion. It is therefore not more than reasonable to allow some form of checks and balances.

Such outside interference does not need to be a threat to business. Under normal scientific conditions, there is enough information that can be communicated about your methodology, without giving away your trade secrets. These results are summarized in an extensive validation report, which should be finished before actual testing begins. For the services Steep Hill offers, this includes parameters such as extraction recovery, linearity, specificity, reproducibility, and number of duplicates analyzed. Also, it would not hurt business if it was known where their cannabinoid standards come from, and how often the analytical systems are checked. And finally, all results should come with clear reports and an explanation of the calculations that were used to obtain those results.