Canopy Growth Corp (WEED)

[Bonno]

Hey happy, read and learn.

LP Soil Scandal?
By David Malmo-Levine on November 10, 2021
FacebookTwitterRedditPinterestShare

CANNABIS CULTURE – “Hey farmer, farmer, put away that D.D.T. now.

Give me spots on my apples.

But leave me the birds and the bees.

Please.”
– Joni Mitchell, Big Yellow Taxi, 1970 (1)


Image #1: Joni Mitchell – Big Yellow Taxi (Official Lyric Video) – youtube.com

In a recent CBC news story titled “Unregulated cannabis not as potent as advertised, study finds”, one could find a perfect example of pro-pot cartel propaganda. The story’s title suggested a scoop on over-inflated potency claims by the black market, but the CBC also decided to question the purity of black market cannabis:

“The study also found that illegal cannabis products were contaminated with microbes and pesticides. These chemicals were negligible or not found at all in legal products. ‘Pesticides are not allowed to be used in licensed products,’ Botelho said. ‘There are regulations in place in order to protect the safety of the consumer.’” (2)


Image #2: cbc.ca

I found this part of the article to be quite misleading. There was no mention of the many times the Licensed Producers were caught using banned pesticides, nor any mention of the fact that the illegal producers and retailers were shut out of the market using bunk science regarding cannabis psychosis to justify hard-drug regulations and an artificial low limit on the number licenses for a product that should actually be regulated as a soft drug like organic coffee beans currently are. This missing context is vital to explain why the article seemed so one-sided to cannabis industry veterans like myself.

The study the CBC reported on – “Analysis of Illicit and Legal Cannabis Products for a Suite of Chemical and Microbial Contaminants” (3) – conducted by the New Brunswick Research and Productivity Council (RPC) – was also misleading. The study looked at 7 samples of unregulated buds and 5 samples of regulated buds from a potential sample size of thousands or tens of thousands all over Canada, and then both the RPC and the CBC drew conclusions about the entire industry.


Image #3: rpc.ca

There was no random selection of samples – for all we know the “personnel legally authorized to obtain and submit illicit cannabis” helping to conduct the study could have picked the sketchiest, skankiest, shwagiest samples he or she could find from the illicit market and compared it with the most bomb-ass diggity samples from the legal market, in order to solidify their “rich history in providing cannabis analytical services to industry” that the conductors of the study bragged about – you gotta keep your customers happy, after all.

According to the RPC study, there were no pesticides at all found in any of the legal buds, and each and every nug of illicit herb was dripping with pesticides. I’m not claiming this is never the case. I’m sure there is some excellent legal cannabis, and I’m also sure there is some terrible black market cannabis. What I am arguing is that the process by which we evaluate the quality of cannabis in the media and in academic studies is in itself unfair, and the history of this process is filled with fraud and conflicts of interest.

There is a massive incentive for the government to lie about how pure regulated cannabis is, and how impure unregulated cannabis is. One of the ways Justin Trudeau and his crew have repeatedly justified the cannabis cartel that has stolen the pot economy away from thousands of Canadian legacy growers and dealers is by claiming that the pot his regulations produce is cleaner than black market pot. (4)

Section 7 of the Cannabis Act states:

“The purpose of this Act is to protect public health and public safety and, in particular, to . . . (f) provide access to a quality-controlled supply of cannabis . . .” (5)

Time and time again this particular justification – like the other six justifications provided – has proven to be a fraud. (6) The Licensed Producers have supplied customers with moldy gummies, (7) have been caught using banned pesticides multiple times, (8) has worked with Health Canada to hide their contamination issues from the Canadian public, (9) has not been honest or transparent in discussions about quality control in the media, (10) and has proven to have a much more toxic product than the dispensaries they have attempted to replace in every head-to-head comparison up until this latest study. (11)


Image #4: cannabisculture.com

In spite of this quality-control clownshow, the government has maintained that their product is “of competitive price and quality and choice” with the black market, and that buying pot produced by Licensed Producers is “a healthier choice”. (12)

So when I was informed a few weeks ago that the Licensed Producers have been caught yet again selling a poisoned product, I was not surprised. But this time, the poisoned product wasn’t cannabis. This time, the poisoned product was soil used to grow cannabis in. And it wasn’t sold out in the open – it was sold out the back door.

With most (or all) of the 3-year-old Canadian Licensed Producer cannabis market suffering losses for the last two years, (13) it’s not surprising that at least one LP was desperate to cut their losses, scale down their production and raise additional revenue somehow.


Image #5: ca.finance.yahoo.com

So imagine my lack of surprise when I heard that gardening stores were claiming to be selling LP soil – and that it tested positive for pesticides banned by Health Canada.

My friend who shall not be named gave me the heads-up. Apparently her gardener had gone to his local gardening store in Burnaby and had been told that there was some “recycled soil” available from a “marijuana production facility” run by “marijuana producers”. According to the seller, they were offering it “to a number of recreational pot growers who are giving us rave reviews on its productivity”. (14)


Image #6: DML’s (Author’s) friend

When her gardener brought back a bag of the soil to my friend, she had it tested at MB Labs (mblabs.com) of Sidney B.C. – a licensed, accredited testing laboratory. The soil tested positive for pesticides, specifically “Imadacloprid” (91.9 ng/g), “Myclobutanil” (254 ng/g), “Paclobutrazol” (84.0 ng/g) and “Propiconazole (22.0 ng/g).

Imadacloprid is a pesticide used on plants and bare soil. It has been shown to be “very toxic to honeybees and other beneficial insects.” (15) It is the active ingredient in at least 18 different products made by Bayer Cropscience. The Canadian government issued some “label amendments” in 2019 and again in 2021 due to its detrimental effects on bees and other beneficial insects. (16)

Paclobutrazol (PBZ) tends to bioaccumulate in soil and water and has demonstrated toxicity to the developing organs of certain fish species. (17) The Canadian government issued some “label amendments” for Paclobutrazol in 2014 due to concerns over its effects on aquatic life. (18)

Propiconazole has demonstrated liver toxicity in a wide variety of animals, (19) as well as targeting the pituitary gland of other animals. (20) Due to these concerns, the government of Canada issued some “label amendments” for Propiconazole in 2017. (21)

Myclobutanil is of particular concern. Found in pesticides such as “Eagle 20”, (22) it cleaves into hydrogen cyanide when burned. Hydrogen cyanide was the poison used to kill people in the gas chambers in Nazi death camps. (23)


Image #7: pot-facts.ca

When I first talked to the supplier of this soil, they confirmed it was from a licensed producer, but would not say which licensed producer supplied the soil. They then requested the testing information – I gave them my friend’s contact info – and said they would respond to my questions after reviewing the data. After a week went by, I called again, and the person I talked to on the phone referred me to a different person – an employee, apparently – who responded by email, assuring me that the licensed producers were not involved at all, and that the soil was a “blend”;

“The history of this soil comes from having access to an abundance of old growth recycled soil for which we decided to make a blend (created in-house as an experiment) combining composted soil amender along with the recycled soil and adding vermiculite and peat for moisture retention. The intentions of this soil was to see if we could grow better tomatoes and peppers for which I’ve personally been doing in my home greenhouse with much success. At the same time, we have a commercial greenhouse client which is also testing a small amount on some of his stronger plants and late season root vegetables and finding success too. Knowing the heartiness that cannabis has we have since now offered it to a number of recreational pot growers who are giving us rave reviews on its productivity.” (24)

This employee went to great lengths to repeatedly assure me that the licensed producers were not involved.

“What I hope you will read is that there isn’t a Licensed Producer involved with this soil. As mentioned, the soil we blended was a mixture of our soil amender along with recycled green waste soil mixed with peat and vermiculite.” (25)

“Soil recyclers will accept all types of green waste to compost before it comes to us but I can guarantee you there is no knowledge on our part of any Licensed Producer or cannabis company that has provided pot plants/dirt to our soil sources.” (26)

The employer who I talked to on the phone did not explain why his employee initially held out the soil to be from a “marijuana production facility” run by “marijuana producers”, nor would he explain why he himself confirmed this information during my first phone call with him. He wouldn’t even reply to a question regarding whether the person he referred me to was an employer or employee. He merely insisted that I contact his associate by email, where their new story was waiting for me to believe or not believe. After discussions with my friend and her gardener, we deduced his associate was an employee, and that the explanation given by email was unsatisfactory.

I then contacted the Health Canada Medical Marijuana division ([e-mail]) and their “media relations” contact line (613-957-2983) on September 29th, to inquire about their rules – if any – regulating the sales of pesticide-ridden soil. I received a call-back the same day from Mark Johnson of their media relations department, who assured me he would respond to my question. On October 5th – the day the RCP study was reported on by the CBC, Health Canada got back to me:

“In regarding to your question to Mark Johnson, The Cannabis Act does not address the sale of soil.” (27)


Image #8: DML’s gmail

While the LPs might be able to legally sell their poisoned soil off to unsuspecting soil dealers, it’s understandable why they would want to do it in secret, as getting a reputation for selling bunk soil would easily turn into a reputation for selling bunk cannabis.

It saddens me that Health Canada did not express an interest in investigating reports of contaminated soil, or acting in such a way as to prevent such a product from being sold. Health Canada could easily prohibit the LPs from selling poisoned soil by regularly testing the soil for pesticides and then supervising the decontamination of such soil, getting the LPs to pay for the cost of that decontamination. Decontamination of agricultural soil using biological agents is a thing. (28)

By digging around on the internet a little, I was able to determine that Health Canada claims to have the ability to test the soil of Licensed Producers for pesticides.

“Inspectors may collect samples of cannabis and cannabis products from the licence holder’s site for testing at Health Canada’s laboratory. In addition, samples collected may include inputs used at the site, such as soil, fertilizer, carrier oils or PCPs (Pest Control Products). . . . Put adequate measures in place to reduce the chance that external residues and PCPs will contaminate the cannabis, by: . . . Testing inputs used during cultivation for contaminants (e.g., growing media or soil, water)” (29)

There are a number of reasons why Health Canada should routinely test LP soil. As was mentioned above, LPs have been known to use banned pesticides on many occasions. As well, American LPs using recycled soil contaminated by pesticides has also been known to have happened. (30) Contaminated soil can lead to contaminated cannabis products:

“Pesticide residue not only lingers in soil and plants, but can also linger in extraction equipment. Biomass contaminated with bacteria, pesticides, or other contaminants could conceivably find its way into regulated infused products that use cannabis oils extracted from raw materials, which are ultimately ingested or administered topically, exposing consumers to yet another health threat.” (31)

This problem isn’t an occasional problem, rather, it is everywhere. Myclobutanil alone has been found in a majority of the cannabis produced in California;

“It is said that California has the strictest regulations for cannabis production, however the 2017 statistics published by Jan Conway on Statista showed that 66% of the cannabis produced in California contained Myclobutanil, a chemical used as a fungicide that is also a known carcinogen. Myclobutanil has been banned for cannabis production in Canada, Colorado, Washington, Oregon, and Oklahoma but what pesticides are allowed in our local markets?” (32)


Image #9: amazon.com

The Myclobutanil contamination problem is so big that there are calls within the testing industry to conduct surprise inspections in order to deal with it:

“However, Wendy Riggs, director of MB Labs in B.C., said she would like to see more frequent unannounced inspections done by third parties to create greater separation between the regulator and producers. . . . ‘This is definitely a red flag… There is no safe level of myclobutanil,’ she said. ‘I suspect this is just the tip of the iceberg.'” (33)

The health effects of even small amounts of Myclobutanil are profound:

“Small doses of hydrogen cyanide are not fatal, but prolonged exposure is linked to various cardiovascular, respiratory and neurological illnesses.” (34)


Image #10: sciencedirect.com

“Broken Coast patients have not come forward to say they’ve suffered adverse effects as a result of using the tainted cannabis, but Organigram patients interviewed by the Globe said they lost weight, suffered severe aches and pains, developed strange itchy rashes, and coughed up wads of mucous after consuming product from the producer.” (35)

These health effects might explain the recent phenomena of “cannabis hyperemesis syndrome” (CHS) which has gotten a lot more media attention recently than the problem of pesticides from corporate pot. It is difficult to determine the cause of CHS if it occurs in people who believe they are using organic soil in their gardens, when the reality of the situation might be that the soil they are using is sold as organic but is in fact contaminated with pesticides from a under-inspected soil supply system. (36)


Image #11: celebstoner.com

I’m not a big fan of vaporizers (I like blowing smoke rings), but if the data regarding Myclobutanil is correct, vaporizers may offer some protection from Myclobutanil poisoning, as Myclobutanil releases hydrogen cyanide if heated past 400 degrees Fahrenheit, (37) whereas some vaporizers operate below that temperature. (38)

The amount of Myclobutanil found in the soil sample MBLabs tested was 254 nanograms per gram. 254 nanograms per gram equals 0.254 ppm. (39) This amount of myclobutanil, if found in cannabis itself, would fail even Oregon’s allowable levels of myclobutanil, (0.2 ppm) (40) which are ten times less strict than Canada’s allowable levels of Myclobutanil (0.02 ppm). (41)

Here’s the kicker. Health Canada has dismissed health concerns over myclobutanil in its LP cannabis on its website by claiming that hydrogen cyanide is present in cannabis smoke anyway – naturally:

“Here are the facts. When the cannabis plant is combusted, a number of compounds are produced, including very low amounts of hydrogen cyanide. Health Canada’s analysis of the recalled cannabis products show that the trace levels of myclobutanil that were present would have produced a negligible amount of additional hydrogen cyanide upon combustion, in comparison to the levels already produced by marijuana alone.” (42)


Image #12: canada.ca

Now … where did they get the idea that hydrogen cyanide is produced from marijuana smoke as well as from pesticides? The Health Canada website doesn’t say. Perhaps it was from a 2007 Health Canada study, which claims that “Hydrogen cyanide . . . were found in marijuana smoke at concentrations 3–5 times those found in tobacco smoke.” But this Health Canada study got its sample of marijuana from Prairie Plant Systems Inc. (PPS), Health Canada’s first Licensed Producer:

“The preparation of both the marijuana and the tobacco cigarettes, the combustion of those cigarettes, and the resultant analyses of all mainstream and sidestream smoke were carried out by Labstat International (Kitchener, Ontario). The analyses employed the Health Canada Official Methods listed in Table 1, unless specified otherwise. A commercially available fine-cut tobacco product was used (Players brand). A standardized, quality-controlled, dried marijuana product, made of flowering heads only, reference H55- MS17/338-FH, was obtained from Prairie Plant Systems Inc. (Saskatoon, Canada), which grows the material under contract to Health Canada.” (43)


Image #13: njgasp.org

It is difficult to understand what the authors of this study meant by “quality-controlled.” Of course the PPS cannabis used in the Health Canada study isn’t organic. PPS have never claimed their cannabis was organic. (44) PPS has claimed that they have “never” used pesticides, (45) but it’s hard to trust what they say, given that the late Dr. Lester Grinspoon resigned from the advisory board of Cannasat when Cannasat refused to share toxicology reports on PPS cannabis with him. (46) Cannasat had stock invested in – and business ties to – PPS. (47)

In fact, PPS Cannabis was grown in one of the most toxic areas in all of Canada: Flin Flon, Manitoba:

“The Canadian Environmental Defence Fund said mining smelters in Canada released more than 2.3 million pounds of heavy metals in 1998, including arsenic, mercury, lead and nickel compounds, all highly poisonous and harmful to people’s health and the environment. Ranked by facility, the fund’s report said Inco’s Copper Cliff operation in Sudbury, Ontario, was a major polluter, followed by Noranda’s Horne smelter in Quebec, then Hudson Bay’s Flin Flon smelter in Manitoba…” (48)

The blueberries grown around Flin Flon have been suspected of being contaminated by pollution, and PPS admitted to using local sources of soil and water for growing cannabis with:

“‘Community concerns have historically not been adequately addressed, and much information, including that collected by Health Canada (e. g., toxic metal levels in blueberries) has not been made available to the residents of Flin Flon.’ [iv]And from a Manitoba Conservation report: ‘Air pollution at Flin Flon near Hudson Bay Mining and Smelting continues to exceed provincial air quality objectives, with no noticeable changes from previous patterns. Records also show that, in Flin Flon, levels of particulates, and concentrations of lead and arsenic, sometimes exceed provincial objectives and guidelines.’ [v]A past interview conducted with PPS President Brent Zettl indicates that the water source used by PPS is drawn from a nearby lake, and that the growing medium for the cannabis is enriched local outdoor soil [vi]. If this is the case, this could well be the source of the reported contamination.” (49)

Maybe some cross contamination of blueberry pesticides got into that PPS cannabis. It is known that myclobutanil is used on berries:

“It is interesting to note that as of February 10, 2017, Health Canada has not required medical marijuana producers to test for banned chemicals. This is after product recalls from two Canadian medical marijuana producers because of the presence of a banned pesticide, including myclobutanil, which is a fungicide that can emit hydrogen cyanide when heated (see Robertson 2017b). Although the chemical is approved for use for some food crops, including lettuce, fresh fruit, and berries, is designed to be washed off and is banned for plants that are smoked, including tobacco. There are also health and safety concerns with respect to pesticide use in tobacco (MacKenzie, Freeman, and Winstanley 2016), another crop that is smoked. Some evidence suggests that the tobacco industry exerts considerable influence over the pesticide regulatory process (McDaniel, Solomon, and Malone 2005). However, there is currently little detail on the type and quantity of pesticides used on tobacco crops worldwide (MacKenzie et al. 2016).” (DML’s emphasis) (50)

Flin Flon is famous for being a wild blueberry growing area. (51) So famous in fact, their local music festival is called the “Blueberry Jam Music Festival.” (52) These blueberries have been tested for heavy metals, but not myclobutanil. (53) Health Canada appears not to care about the amounts of pesticides used in the blueberry industry, and has recently indicated it will allow even more pesticides to be used on wild blueberries. (54)


Image #14: cbc.ca

I’m not saying that the soil that was sold as “recycled from a marijuana producer” was probably contaminated with blueberry pesticide run-off. I’m saying that the LP soil was probably contaminated by the LPs use of banned pesticides, and that the blueberry pesticide run-off explains why Health Canada believes all pot gives off hydrogen cyanide when burned – their “quality control” sample used to come to that conclusion was itself probably contaminated in various ways.

Health Canada isn’t really famous for understanding – or caring about – contaminant concerns in the cannabis they regulate. The most surprising fact I have learned about their regulatory process in my many years as a pot activist is that they have no standards at all – zero – regarding limits to heavy metals in cannabis – or tobacco (55) in spite of a mountain of evidence of these radioactive heavy metals (originating in chemical fertilizers) being the source of most if not all of the tobacco-related cancers. (56)


Image #15: pot-facts.ca

When I talked to my friend about Health Canada’s position on contaminated soil sales – that Health Canada didn’t care about it and doesn’t regulate it – my friend had this to say;

“This isn’t about all LPs. This is about one nursery claiming they were selling LP dirt. Now the supplier claims it was never sold that way. I believe there is a cover up here but believe that not all parties are behaving badly and painting them all as being bad will hurt the credibility of the story. I think more work needs done to understand which LP provided the soil they are pretending wasn’t LP soil. I think the other banned substances bear further investigating and another sample of dirt from a different garden should be tested to understand what might be typical of soils found in garden stores. Is the It’s About Thyme nursery still selling this product? What are they telling people now? We turn away product from OUR dispensaries that is sold in others because those owners don’t care. Our members are trusting us to do the work for them and we take the responsibility seriously. Others, legal or illegal, are paying rent and buying cars.” (57)

My friend did end up testing another bag of soil from the It’s About Thyme nursery, purchased a few weeks after the first bag was tested, and after the nursery was warned not to sell that soil due to pesticide contamination. The good news is that the most recent test came back negative for 3 of the four pesticides found in the first bag: “Imadacloprid” (91.9 ng/g), “Myclobutanil” (254 ng/g), and “Paclobutrazol” (84.0 ng/g).

The bad news is that the most recent test revealed there was “Propiconazole” again, but less of it – 8.55 ng/g rather than the 22.0 ng/g found in the first test. The most recent test also revealed two other pesticides: “Fluopyram” (4.51 ng/g) and “Tebuconazole” (12.9 ng/g).

Fluopyram is a fungicide and nematicide (parasitic worm killer) used in agriculture. It is used to control fungal diseases such as gray mold, powdery mildew, apple scab, Alternaria, Sclerotinia, and Monilinia. (58) A 2014 study done by the Norwegian Scientific Committee for Food Safety concluded that “there is a moderate risk of effects on fish when (pesticides containing Fluopyram are) applied to beans/strawberries without the use of a vegetated mitigation bufferstrip.” (59)

Tebuconazole is a triazole fungicide used agriculturally to treat plant pathogenic fungi. (60) Tebuconazole targets the liver, the adrenals, the hematopoetic system and the nervous system in both rodent and “non-rodent” species. Ocular lesions are seen in dogs following chronic (long term) or sub-chronic (short term) exposure. It is categorized as a “possible human carcinogen”. (61) Perhaps the nursery in question should begin testing the soil they sell.

So the take-away from all of this is that one needs to test one’s soil to truly know what’s in it, that there is really no evidence that proves that LP cannabis is cleaner than black market cannabis, that Health Canada pretends to care about contaminants in cannabis but doesn’t really, that the government pretends to care about clean cannabis but doesn’t really, and the soil that you are told is perfect for growing pot in might not be.

If you’re worried about contaminants in your cannabis, don’t buy pot from a licensed producer – while some of their cannabis might be OK, LP pot is famous for contaminants, and corporate capitalism is famous for cutting corners on quality for the sake of greed. Instead, consider either growing your own with organic compost and soil you obtain from non-sketchy sources, or buying from an activist dispensary – be sure to ask if they test for contaminants. Most expert growers would scoff at using recycled soil for a pot garden – too many unknowns.

Oh … and if anyone knows of any nursery or gardening store selling soil from a “marijuana producer” … email me at [e-mail] and I will write an update to this story.

Citations:
1) Joni Mitchell – Big Yellow Taxi (Official Lyric Video) https://www.youtube.com/watch?v=2595abcvh2M



2) Unregulated cannabis not as potent as advertised, study finds – A recent study compared illicit and legal cannabis products in New Brunswick for potency and contaminants, Nojoud Al Mallees · CBC News · Oct 05, 2021

https://www.cbc.ca/news/canada/new-brunswick/cannabis-potency-study-1.6199374



3) Analysis of Illicit and Legal Cannabis Products for a Suite of Chemical and Microbial Contaminants, New Brunswick Research and Productivity Council, 2021

https://rpc.ca/english/press/Comparison%20of%20Illicit%20and%20Legal%20Cannabis%20Samples.pdf



4) “Khurram Malik, CEO of the Toronto-based cannabis company Biome Grow Inc., last month blamed, in part, the tough regulations imposed by Health Canada on the country’s 132 licensed producers for the lack of adequate supply to meet demand. He also said the federal department was taking too long to approve licences for grow-ops but added it was also taking time for cannabis producers to develop quality and compliant products.”

“Those who resisted legal pot now ‘caught flat footed’ on supply: Trudeau,” December 17th, 2018

https://www.bnnbloomberg.ca/those-who-resisted-legal-pot-now-caught-flat-footed-on-supply-says-trudeau-1.1184542

“And the strict regulations governing legal sales, the prime minister promised, would ensure that Canadians were consuming marijuana not adulterated with other drugs or toxins and would eliminate sales to minors.”

2 Years After Legalizing Cannabis, Has Canada Kept Its Promises?, Ian Austen

Published Jan. 23, 2021

https://www.nytimes.com/2021/01/23/world/canada/marijuana-legalization-promises-made.html



5) Cannabis Act (S.C. 2018, c. 16)

https://laws-lois.justice.gc.ca/eng/acts/c-24.5/page-2.html#docCont



6) The Cannabis Act Is A Fraud By David Malmo-Levine on April 18, 2021 https://www.cannabisculture.com/content/2021/04/18/the-cannabis-act-is-a-fraud/



7) http://pot-facts.ca/corporate-cannabis-companies-haven-st-and-agro-greens-supplied-canadians-with-mouldy-gummies/



8) http://pot-facts.ca/licensed-producers-poisoned-their-pot-with-gas-chamber-poison-28-different-times/



9) http://pot-facts.ca/health-canada-and-the-licensed-producers-have-both-hidden-dangerous-cannabis-contamination-from-the-public/



10) http://pot-facts.ca/canopy-ceo-has-a-misunderstanding-on-quality-control-issue-3-different-ways-media-only-calls-him-on-1-way/



11) http://pot-facts.ca/dispensary-cannabis-is-safer-than-lp-cannabis/



12) “I remain confident that as that new retail environment is built up by the provinces, as Ontario gets more stores opened and consumers have access to a product of competitive price and quality and choice, that they’ll make the legal and socially-responsible choice and a healthier choice . . .”

Blair ‘very confident’ more pot shops, supply chains can convert grey market cannabis users, Amanda Connolly, Global News, April 14, 2019 https://globalnews.ca/news/5161583/bill-blair-cannabis-black-market-canada/



13) Cannabis producer Organigram Holdings Inc. reports $10.2M third-quarter loss Armina Ligaya The Canadian Press Published Monday, July 15, 2019 https://www.ctvnews.ca/business/cannabis-producer-organigram-holdings-inc-reports-10-2m-third-quarter-loss-1.4508230

Cannabis producer Hexo’s loss surges; cultivation suspended in Niagara Published October 29, 2019 | By Matt Lamers https://mjbizdaily.com/cannabis-producer-hexos-loss-surges-cultivation-suspended-in-niagara/

HEXO posts loss of $56 million, driven by $17 million write-down on cannabis inventory Last week, the company laid off 200 employees and suspended cultivation at its Niagara facility and a portion of its Gatineau facility, Vanmala Subramaniam, Oct 29, 2019 https://financialpost.com/cannabis/cannabis-business/hexo-posts-loss-of-56-million-driven-by-17-million-write-down-on-cannabis-inventory

Canadian Cannabis Licensed Producer Index Suffers 18.2% Loss in October November 1, 2019 https://www.newcannabisventures.com/canadian-cannabis-licensed-producer-index-suffers-18-2-loss-in-october/

Canopy Growth plunges to record low after revenue drops most since cannabis legalization $32.7 million charge from returned products; $15.9 million writedown for excess inventory, Vanmala Subramaniam Vanmala Subramaniam, Nov 14, 2019 https://financialpost.com/cannabis/cannabis-business/update-1-pot-company-canopy-growth-reports-bigger-loss-on-charges

Canopy Growth won’t cut jobs despite losses, interim CEO insists ‘We simply don’t have enough places to sell our product in Ontario’ CBC News, Nov 15, 2019 https://www.cbc.ca/news/canada/ottawa/canopy-growth-jobs-loss-cannabis-1.5361044

Canadian Cannabis Licensed Producer Index Ends 2019 Down 44% January 1, 2020 https://www.newcannabisventures.com/canadian-cannabis-licensed-producer-index-ends-2019-down-44/

COVID-19: London-based WeedMD puts 40 workers on leave, slashes management pay, Dale Carruthers, Apr 27, 2020 https://lfpress.com/news/local-news/covid-19-london-based-weedmd-puts-40-workers-on-leave-slashes-management-pay

Cannabis company Tilray reports US$2.9 million loss on US$56.5M revenue in Q4 TD, Tara Deschamps, The Canadian Press, Feb. 17, 2021 https://www.thestar.com/business/2021/02/17/cannabis-company-tilray-reports-us29m-loss-565m-in-revenue-in-q4.html

Cannabis company Aphria reports Q3 loss, revenue up from year ago mark Tara Deschamps The Canadian Press Staff Contact Published Monday, April 12, 2021 https://www.ctvnews.ca/business/cannabis-company-aphria-reports-q3-loss-revenue-up-from-year-ago-mark-1.5383882

Aphria earnings: COVID-19 lockdowns hit sales, $361M net loss Jeff Lagerquist Jeff Lagerquist April 12, 2021 https://ca.style.yahoo.com/aphria-earnings-covid-19-lockdowns-hit-sales-361-m-net-loss-120918701.html

Benchmark Botanics Continues to Seek Long Term Financing – Announces Temporary Employee Layoff at Peachland Facility, August 23rd, 2021 https://money.tmx.com/en/quote/BBT:APH/news/8348522037938080



14) Tom Ciprian, [e-mail], September 18th, 8:03 am



15) Imidacloprid General Fact Sheet

npic.orst.edu/factsheets/imidagen.html



16) Re-evaluation Decision RVD2019-06, Imidacloprid and Its Associated End-use Products: Pollinator Re-evaluation Pest Management Regulatory Agency 11 April 2019

https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/pesticides-pest-management/decisions-updates/reevaluation-decision/2019/imidacloprid.html

Re-evaluation Decision RVD2021-05, Imidacloprid and Its Associated End-use Products Pest Management Regulatory Agency 19 May 2021

https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/pesticides-pest-management/decisions-updates/reevaluation-decision/2021/imidacloprid.html



17) Toxic Effects of Paclobutrazol on Developing Organs at Different Exposure Times in Zebrafish Wen-Der Wang et al. Toxics. 2019.

https://pubmed.ncbi.nlm.nih.gov/31817812/



18) Re-evaluation Decision RVD2014-06, Paclobutrazol Pest Management Regulatory Agency 16 October 2014 https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/pesticides-pest-management/decisions-updates/reevaluation-decision/2014/document-paclobutrazol-rvd2014-06.html



19) https://www.federalregister.gov/documents/2019/08/12/2019-17143/propiconazole-pesticide-tolerances



20) APPROVED: 9 June 2017 doi: 10.2903/j.efsa.2017.4887 Peer review of the pesticide risk assessment of the active substance propiconazole https://efsa.onlinelibrary.wiley.com/doi/pdf/10.2903/j.efsa.2017.4887



21) Re-evaluation Decision RVD2017-03, Antisapstain and Joinery Uses of Propiconazole Pest Management Regulatory Agency 13 October 2017

https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/pesticides-pest-management/decisions-updates/reevaluation-decision/2017/propiconazole.html



22) https://www.reddit.com/r/microgrowery/comments/5otrm8/psa_eagle20_is_deadly_do_not_use/



23) http://pot-facts.ca/licensed-producers-poisoned-their-pot-with-gas-chamber-poison-28-different-times/



24) Tom Ciprian, [e-mail], September 18th, 8:03 am



25) Tom Ciprian, [e-mail], September 26th, 9:16 pm



26) Tom Ciprian, [e-mail], September 27th 2021, 4:12 pm



27) André Gagnon (He/Him – il/lui) Media Relations Advisor | Conseiller en relations avec les médias Serving Health Canada and the Public Health Agency of Canada | Au service de Santé Canada et de l’Agence de la santé publique du Canada (e/ce) [e-mail]; Government of Canada | Gouvernement du Canada, personal communication.



28) Potential of Biological Agents in Decontamination of Agricultural Soil Muhammad Kashif Javaid, Mehrban Ashiq, and Muhammad Tahir, Scientifica (Cairo), 2016 May 3 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4887633/



29) MANDATORY CANNABIS TESTING FOR PESTICIDE ACTIVE INGREDIENTS Requirements, Health Canada, August 30, 2019

https://www.canada.ca/content/dam/phac-aspc/documents/services/publications/drugs-health-products/cannabis-testing-pesticide-list-limits/Mandatory-Cannabis-Testing-Requirements.pdf



30) “‘We have recently begun to see residual pesticide and fungicide toxicity in the soil of clients who have amended compost into their soils,’ says Soilscape Solutions co-founder Samuel Deyton, a certified master soil consultant. One common denominator seems to be the use of compost from facilities that accept waste from the viticulture (grape) industry as part of their compost production feedstocks. Further research has revealed that it is legal for the California viticulture industry to use pesticides and fungicides in their management programs that contain residuals that are banned in the production of cannabis. ‘Of these substances, one in particular seems to stand out among the rest — myclobutanil — which is used as a fungal pathogen suppressant on vine grapes,’ Deyton says. ‘Unfortunately, this substance is so resilient that even the thermophilic (high heat) composting process cannot affectively break down the carbon ring structure of the compound. Thus, feedstocks containing the toxins will contaminate the finished compost products. When compost containing these toxins is applied to soils in which cannabis is being cultivated, the cannabis plants accumulate these toxins in their plant tissue, as cannabis is both a dynamic and toxin accumulator. This can lead to failed pesticide and fungicide screenings of finished product bound for sale to consumers, and especially so for concentrates.’”

PESTICIDE USE written by Russell Pace August 28, 2017

https://www.marijuanaventure.com/pesticide-use/



31) https://www.cannabissciencetech.com/view/an-essential-element-for-commercial-cannabis-and-hemp-manufacturing-practical-cleaning-solutions-for-extraction-and-processing-equipment



32) https://cannawestseattle.com/2020/06/09/clean-cannabis/



33) https://globalnews.ca/news/6233169/health-canada-testing-data-pesticides-in-pot/



34) https://acslabcannabis.com/blog/cultivation/hydrogen-cyanide-in-cannabis-no-its-myclobutanil/

35) https://www.canncentral.com/myclobutanil-why-are-some-licensed-cannabis-producers-using-this-banned-pesticide



36) CNN Pushes Hilarious Medical Study About Recreational Drugs https://www.youtube.com/watch?v=H7WCPvkPXFI

“Cannabis hyperemesis syndrome burst upon the medical scene in 2004, when a group of Australian researchers wrote about 19 chronic marijuana users who had repeated episodes of abdominal pain and retching. The researchers followed nine of the patients over time and found symptoms went away when cannabis use was stopped but returned when it was restarted.” https://www.cnn.com/2021/09/17/health/marijuana-vomiting-wellness/index.html



37) “When Myclobutanil is applied to tobacco or to marijuana, very serious health problems do occur: Myclobutanil releases highly toxic gases if heated past its boiling point of 205°C (400°F) Butane lighters, such as those used to ignite marijuana for consumption, produce temperatures in excess of 450°C.”

https://cleanlight.nl/why-you-should-never-ever-spray-myclobutanil-on-cannabis-plants/

“We also know that myclobutanil turns to hydrogen cyanide when it’s heated beyond 401°F.”

https://acslabcannabis.com/blog/cultivation/hydrogen-cyanide-in-cannabis-no-its-myclobutanil/



38) “The THC in cannabis vaporizes when heated to between 338 F and 372 F. This is not hot enough for the plant material to burn so many of the toxins associated with smoking are not released. On the original Volcano classic vaporizer, this range is between 4.25 and 6 on the temperature dial.”

https://volcanotips.com/volcano-vaporizer-guide/volcano-temperature-settings/volcano-temperature-setting-basics/

39) https://calculate.plus/en/categories/fraction/convert/100/ng-per-g/to/ppm



40) “If a lab test were failed, it would contain pesticides at or higher than the required action level. Oregon’s action level, or the measured amount of pesticides in a product that the OHA deems potentially dangerous, for Myclobutanil is 0.2 parts-per-million (PPM).”

November 30, 2016 Steep Hill, ACCL Find Pesticides in Over 50% of Cannabis Samples By Aaron G. Biros https://cannabisindustryjournal.com/tag/myclobutanil/



41) “One sample tested on Dec. 12, 2018 contained dangerous levels of banned pesticides, including myclobutanil at 14 ppm and bifenazate at 3.1 ppm. The limit for both chemicals is 0.020 in dried cannabis flower.” “Health Canada data reveals roughly 95% of pot samples tested negative for pesticides”, Andrew Russell & Patrick Cain, Global News, November 29, 2019 https://globalnews.ca/news/6233169/health-canada-testing-data-pesticides-in-pot/

42) Clarification from Health Canada on myclobutanil and cannabis https://www.canada.ca/en/health-canada/news/2017/03/clarification_fromhealthcanadaonmyclobutanilandcannabis.html

43) A Comparison of Mainstream and Sidestream Marijuana and Tobacco Cigarette Smoke Produced under Two Machine Smoking Conditions, Chem. Res. Toxicol. 2008, 21, 494–502, Safe EnVironments Programme, Tobacco Control Programme, and Drug Strategy and Controlled Substances Programme, Health Canada, Ottawa, ON, Canada K1A 0K9, and Labstat International Inc., Kitchener, ON, Canada N2C 1L3 ReceiVed July 31, 2007 njgasp.org/wp-content/uploads/2014/05/Chem_Res_toxic_tob_vs_marij_smoke_2008.pdf

44) CLEAN INNOVATION IN FOCUS: THIS ISSUE FEATURING Prairie Plant Systems Inc., A special publication prepared by CETAC-WEST with support from NRC-IRAP and the Government of Alberta https://cetacwest.com/wp-content/uploads/2017/06/Prairie-Plant-Systems-CetacWest-SuccessStory.pdf



45) “‘CanniMed Therapeutics has never, and will not in the future need to use pesticides, fungicides or PGRs in the manufacturing of our medical cannabis products because we follow a strict GMP process, following 281-points of quality control,’ said Brent Zettl, President and CEO, CanniMed Therapeutics Inc.”

Independent Laboratory Analysis Confirms CanniMed Medical Cannabis Products Free from Pesticides, Fungicides, and Plant Growth Regulators February 22, 2017 https://www.businesswire.com/news/home/20170222006516/en/Independent-Laboratory-Analysis-Confirms-CanniMed-Medical-Cannabis-Products-Free-from-Pesticides-Fungicides-and-Plant-Growth-Regulators



46) “Dear David, In response to your last e-mail let me briefly outline my reasons for resigning from the Cannasat Scientific Advisory Board. 1) When I first heard the complaints about the PPS marijuana which was being sold as a medicine I became concerned about heavy metal and other contaminants and shared my concern with Andrew Williams of Cannasat and asked him if I could see the toxicology reports. I was promised that they would be sent within two months, as soon as they were available. I asked for them several times over the course of more than a year; I never received them.”

https://www.icmag.com/forum/talk-about-it/medicinal-cannabis-forum/51162-poll-is-it-right-for-health-canada-to-charge-a-1-500-per-cent-markup-on-marijuana



47) “In mid-2004 Cannasat purchased a non-controlling minority interest in Prairie Plant Systems (PPS).” https://www.cannabisculture.com/content/2005/04/12/4181/



48) http://www.planetark.org/dailynewsstory.cfm?newsid=9602 Community http://safeaccess.ca/research/flinflon/flinflon.htm



49) http://safeaccess.ca/pr/csapr8.htm



50) Toward a Regulatory Framework for the Legalization of Cannabis: How Do We Get to There from Here? Author(s): PHILIPPE CYRENNE and MARIAN SHANAHAN Source: Canadian Public Policy / Analyse de Politiques , Vol. 44, No. 1 (March / mars 2018), pp. 54-76 Published by: University of Toronto Press on behalf of Canadian Public Policy https://www.jstor.org/stable/90019788



51) “The climate and landscape of the Flin Flon area promotes an abundance of wild blueberries.” flinflonsoilsstudy.com/wp-content/uploads/2013/07/FlinFlonSoilsStudySummaryPamphletJune2010.pdf



52) “Relatively new to the town is the Blueberry Jam Music Festival, a 4-day celebration designed for musicians and music lovers. Located at the Flin Flon Tourist Bureau & Campground, the festival brings in talent from out of town while also showcasing local artists.” https://www.travelmanitoba.com/blog/the-water-and-the-wild-10-things-to-do-in-flin-flon-manitoba/



53) The Flin Flon Soils Study An Assessment of Exposure and Human Health Risks in the Flin Flon Area SUMMARY DOCUMENT AND INTEGRATION OF RESULTS June 2010 flinflonsoilsstudy.com/wp-content/uploads/2013/07/FlinFlonSoilsStudySummaryPamphletJune2010.pdf

Manitoba Conservation Blueberry Study. Manitoba Conservation. 2000. (Unpublished). flinflonsoilsstudy.com/wp-content/uploads/2013/07/AppxCLiteratureReviewDataGapAnalysisandSupplementalData.pdf



54) Ottawa wants to allow more pesticide residue in wild blueberries The limits would be higher in Canada than they are in the United States CBC News · Posted: Jul 28, 2021 https://www.cbc.ca/news/canada/new-brunswick/blueberry-pesticide-residue-increase-1.6120711



55) http://pot-facts.ca/there-are-currently-no-legal-limits-to-heavy-metal-content-in-either-cannabis-or-tobacco-in-canada/



56) http://pot-facts.ca/big-tobacco-knew-radioactive-particles-in-cigarettes-posed-cancer-risk-but-kept-quiet/

http://pot-facts.ca/chemical-fertilizers-are-radioactive-and-the-real-cause-of-tobacco-related-cancer/



57) Friend of DML, personal communication



58) “Fluopyram,” Wikipedia



59) Risk assessment of the fungicide Luna Privilege with the active substance fluopyram, Opinion of the Panel on Plant Protection Products of the Norwegian Scientific Committee for Food Safety Date: 19.02.2014 https://vkm.no/download/18.2994e95b15cc54507161eed8/1501772354494/0ae9276074.pdf



60) “Tebuconazole,” Wikipedia



61) https://www.federalregister.gov/documents/2010/05/05/2010-10406/tebuconazole-pesticide-tolerances