Organic Cannabis: A Pipe Dream?

The Canadian Food Inspection Agency requires the Canadian organic industry, led by the Organic Federation of Canada (OFC), to update the Canadian Organic Standards every five years. The last update was in 2015 and preparations for the 2020 update are underway.

On October 17, 2018, Cannabis was legalized for recreational use in Canada, and on November 28, OCO invited four experts to chat with us about organic certification for cannabis as part of our #YourStandardsYourSay webinar series.

What is Cannabis?

Cannabis plants

Cannabis is a flowering plant that is dioecious, meaning that there are male and female plants. Its psychoactive component, delta-9-tetrahydrocannabinol (commonly and legally known as THC), produces a “high” when ingested and is consumed both recreationally and for medicinal purposes. The highest concentration of THC is found in resin on the unfertilized female flower.

Other substances associated with cannabis are CBD (Cannabidiol) and hemp. CBD is another chemical compound found in cannabis which does not produce intoxication, and is being studied for its therapeutic uses. “Hemp” is a term for cannabis plants that have a THC concentration of less than 0.3%, and industrial hemp can be used to produce food, textiles and oils. CBD can be also be extracted from hemp.

Demand for Organic Cannabis

According to Adam Gibson of the Canadian Health Food Association (now with Consumer Health Products Canada), there is considerable overlap between consumers of cannabis and consumers of organic products. The Canadian Organic Trade Association’s data shows that 83% of Canadian millennials buy organic weekly. Similarly, cannabis use is highest among Canadians aged 15-24, followed by 25-44 year olds. As these voters become the majority, Gibson says that policy around organics and cannabis will become front of mind for politicians.

We ingest cannabis smoke or vapour into our bloodstream in a more direct manner than food. With the more efficient delivery system comes a higher dose of pesticides.

When asked why consumers should be concerned about toxins and/or pesticides in cannabis, David Perron, Head Grower at the Green Organic Dutchman, said it’s all about the delivery method. When we ingest cannabis smoke or vapour into our lungs, it enters our bloodstream in a more direct manner than when we ingest food. With the more efficient delivery system comes a higher dose of pesticides. In 2017, Canadian news outlets reported that a federally licensed conventional medical marijuana company was caught using a banned pesticide, myclobutanil, which transforms into hydrogen cyanide when heated.

Can Cannabis be Certified Organic?

Both cannabis and hemp are regulated under the 2018 Cannabis Act, which is separate from drug laws under the Controlled Drugs and Substances Act, and food laws under the Safe Food for Canadians Act (SFCA). This approach, says Gibson, follows the government’s approach to alcohol and tobacco, with cannabis falling somewhere between the two. “It’s unlikely that you would ever see an organic logo on a package of cigarettes,” he says, “but you might see it on a bottle of wine.”

Since cannabis is not governed by the SFCA, it cannot be certified organic by the CFIA and use the Canada Organic logo. This doesn’t mean it can’t be certified at all, says Dave Lockman, Certification Manager at Pro-Cert Certifications. Though lack of regulations mean anyone can technically call their cannabis product “organic”, Pro-Cert provides internationally accredited certification for cannabis products that fall under the scope of the Canada Organic Standards.

Getting to Certification

Cannabis stakeholders look forward to organic certification as a stamp of legitimacy for a stigmatized industry, but there are few areas where certification stumbles:

Who should regulate?

Cannabis is currently regulated by Health Canada, while all food, seed, or animal feed labelled organic is overseen by the CFIA under Agriculture and Agri-Food Canada. “Until these two departments at Health Canada and Agriculture Canada start working together, we can’t have normal organic certification,” said David Cohlmeyer, OCO board member and cannabis consultant with Dicentra.

Hydroponics and Soil

The Canadian Organic Standards for greenhouse production don’t allow the use of hydroponics, which is often touted as the best method for cultivating cannabis. Cohlmeyer, who sits on the OFC’s Greenhouse Working Group, doesn’t think this will change any time soon. That’s because soil and the ecosystem it supports are an important part of organic production (read more about the debate around hydroponics and aquaponics here). What’s more, organic systems should include soil regeneration practices like crop rotation. This is difficult for cannabis producers, who often run single crop operations.

Artificial Lighting

Indoor cannabis plants, from Plantlady223 (Wikimedia Commons).

Outdoor growing has recently been licenced, but most cannabis production still occurs in warehouses using artificial light. The Canadian Organic Standards permits supplemental lighting in greenhouses, but there is disagreement about what this means. While cannabis consultants Av Singh and David Cohlmeyer interpret the standard to mean that artificial light must supplement natural light, Dave Lockman isn’t so sure: “As a certifier, you interpret the standard in a regulatory way…essentially ‘if you were to stand in front of a judge, would you be able to justify your decision?’” He continues, “The way the standard is written now, there is not enough there to prohibit artificial lighting or require a certain amount of natural light.”

Both Singh and grower David Perron point out that artificial lights require heavy energy consumption, though Perron notes that energy efficient LEDs are getting closer to the full spectrum found in natural sunlight.

Labour

Labour standards are not specifically mentioned in Canada’s Organic Standards, but labour is an area of concern for many in the organic industry. Av Singh notes the use of temporary foreign workers in the cannabis sector, and the increasing push for gender equity and participation of Indigenous people and people of colour. While there is still room for improvement, he’s happy to see the industry looking to address these challenges.

Although the practices of organic farming can be more labour intensive, such as applying fertilizer as a dry powder, the increased people power is a positive for Dave Perron. The staff he works with at Green Organic Dutchman are passionate about agriculture, and help build public acceptance of the cannabis projects they are working on.

Rigorous Product Testing

Cannabis must go through rigorous product testing before it can reach the market.

In order for a cannabis crop to reach the market, it must go through intense testing for heavy metals, toxins and pesticides. Perron says that many of the substances he’s permitted to use under the Canada Organic Standards will result in a false positive for his crop.

Additionally, he is required to test for pathogenic bacteria like salmonella, and report on levels of all microbes. However, organic production in Canada does not allow irradiation, which is often used to kill off bacteria in conventional cannabis production. Plus, Perron says not all microbes are bad. “Yogurt would never pass this test because it’s full of good of bacteria, but,” he says, “[cannabis] is considered medicine, and we need to make the cleanest medicine possible.”

The Future of Organic Cannabis

We asked our experts and webinar participants where we will see the greatest demand for organic cannabis moving forward. “Edibles” – like cannabis-infused confections, baked goods, and beverages – is the consensus. While edibles are not yet legal in Canada, US states that have legalized them have seen strong market growth in these categories.

CBD and other cannabis-derived health products are another area of potential growth. The demand for organics in natural health products already exists, explains Adam Gibson: “People would want to know that something they are taking for their health is prepared in a way that will not negatively impact their health, including cannabis based products.”

David Cohlmeyer adds that organic cannabis products will also be in demand as people search for higher quality cannabis. For example, some say that irradiation found in conventional cannabis production destroys the flavour and aromas of the product.

While the government of Canada met their promise for legal cannabis by 2018, the rushed legislation process created all sort of regulatory oddities. The next few years will be full of regulatory adjustments, and OCO hopes to see government certification for organic cannabis as a policy priority going forward.

“It’s challenging, but [certification] has been a rewarding process,” says grower, David Perron. “With cannabis you can really see an increase in the quality of the final product when we’re doing a really good organic growing system.”

This webinar was sponsored by Dicentra Cannabis Consulting.

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