As I said in my last article, audits are meant to make the lab better, not closed unless there was a severe deficiency found or what could be the case, a lab doing all the right things but also puts the WSLCB in a position that shows they don’t know what they’re doing.
I question the auditing group and their intentions by arguing and shouting down people who hold the same degrees they do. By doing so, The RJ Lee Group has demonstrated that they really don’t care about the process or science but instead are chasing the money grab of being the go-to expert in a billion dollar industry. The problem is, there are two ways to skin a cat here.
The thing about audits is, the auditor is there to prove there is a process followed, not how its followed, and that the technicians involved are all trained and competent. If you show all this, then you’re good to go. It’s not the auditor’s place to define your process or even tell you it’s wrong, as long as a lab has a written procedure and abides by it than it’s up to the consumer, in this case, the growers and pot shops who choose to go above and beyond.
An appointed board, not an elected one controls the cannabis industry in Washington State. This makes things an uphill battle, like fighting a faceless corporate conglomerate that has no obligation to consumer safety but will say the right things to save face.
When it comes to things business things are debatable. When someone makes a dollar, someone else loses one but not always the case with The WSLCB, a group, an institution that is in charge of some of the wealthiest commodities but not elected by the people they’re supposed to protect; there is special interest here that is not the Washingtonian consumer.
Even though there are fewer people in jail here, citizens still suffer for believing in the plant, assets loss and ruin due to The WSLCB rules. Let us not forget about their settlement to have a lawsuit dropped about secret meetings they conducted.
Is There A Such Thing As Excess Testing?
There is still speculation as to the reason for the shutdown because the three reasons given by The RJ Lee Group are not enough to close down a lab, again I wonder whose best interest the RJ Lee Group has in this situation. As a consumer, one can never have enough information. There is no such thing as too many tests.
Recently there was a rule change petitioned by people in the Industry, people who wanted more wiggle worm for selling their products. When I502 came about the WSLCB tried to separate medical and recreational marijuana by testing requirements, something I always found troublesome. Why would something be ok to smoke recreationally but not medically, this is not real regulation of a plant consumed by humans. All products should be required to be tested that is real regulation with 100% disclosed information only the can the consumer have an informed decision, instead of the “we only require these tests for medical and these for recreational.”
The test I am talking about is the microbial assays for coliforms, total aerobic bacteria, and total yeast and mold. On 8/31/17, the LCB issued a rule change to the WAC to remove the requirement to test those, and added mycotoxin testing (for 4 types of Aflatoxins and 1 type of Ochratoxin) and raised the limit of Bile-Tolerant Gram-Negative Bacteria from 1000 colony forming units per gram (CFU/g) to 10,000 CFU/g.
Now I know this is all dirty talk is getting you all worked up but stay with me. The following is what Analytics 360 has been doing that the WSLCB asked them to stop doing according to John Brown, CoFounder and Chief Technical Officer “We removed the pass/fail status from the non-mandatory tests and supply the CFU/g counts. Mandatory tests have CFU/g and a pass/fail status. When the rules changed, we removed from our certificate of analysis, that is. The rule change can be found on page 8 & 9 of OTS-8358.2, page 13 of this document is the start https://lcb.wa.gov/sites/default/files/publications/rules/2017%20Proposed%20Rules/WSR_17_12_032.pdf”
So again, I will ask, can one test too much? Can a consumer and grower know too much about their product?
With all this said, let us look at the report and examine the three reasons suggested for the lab closure. For transparency, you will find the summary letter here.
- Lack of validation methods
- Incorrect calculations of potency and micro test
- Lack of uncertainty data
1. Lack of validation methods. This one honestly disgusts me. So you mean to tell me the one organization that has been auditing labs since the beginning of I502 is just finding the oldest lab in Washinton has no validation methods? (Sneezing bullshit). Besides the same auditing group RJ Lee Group, they also had the same auditing team from 4 years prior. Something like a lack of validation methods would have been found on day one, not eight years later.
2. Incorrect Calculations of Potency and Micro Test. Again this is not a reason to close a lab because it comes down to math which can be met with an agreement or an amendment, not closure. And as for the potency debate, I still call bullshit simply because each lab has their process and potency will be found to differ from lab to lab, so why punish this one lab for sticking to their consistency?
3. Lack of Uncertainty Data. Again this is as sexy as it sounds and again, this is something that would have been found on day one.
Process and calculations are the bread and butter of a lab; this is something a technician refers to and abides by. Besides the lack of professionalism noted in my last article, these three issues make me question the real intent of the RJ Lee Group and The WSLCB as 21 families remain unemployed waiting to hear if or when they have a job again.
I plan on posting Analytics 360 response letter once it cleans up. Presently the response documents is a collective of 10 pages responding to sexy math along with corrective actions that they acknowledge but again, not a reason to put 21 families in jeopardy.