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Cannabis Update WA
SFIREG POM April 2016
LATEST FROM WA

WSDA Requesting pyrolysis studies, or requests for data
waivers, were reviewed by the EPA in order to register approx.
31 tolerance exempt active ingredients for use on tobacco
(refer to attached spreadsheet).
 61 tolerance exempt ingredients that are currently allowed for use on
marijuana in Washington.

LATEST FROM WA
LATEST FROM WA
LATEST FROM WA
HEMP IN WA Licenses Coming! (2016)

WSDA To Create: Industrial Hemp Seed Research & Licensing Program ESSB 6206
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Industrial Hemp Is An Agricultural Product With Many Potential Uses.



Fiber - Textiles, Rope, Paper & Building Materials

Hemp Seed - Food And Oil, > Pharmaceuticals, Cosmetics, Inks, Soaps And Paints

Plants - Livestock Feed And Bedding
About 30 Countries In Europe, Asia And North And South America Permit Farmers To Grow Hemp.

Twelve U.S. States Have Legalized Hemp Production And Several Others Allow Cultivation For
Research Projects.
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Hemp Was Grown In Washington Before It Became Federally Prohibited.
As A Cannabis Plant, Industrial Hemp Is Considered A Controlled Substance Under Federal Law.
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2014 Farm Bill Defined Industrial Hemp & Authorized State Agriculture Departments &
Higher Education Institutions To Grow The Crop For Research Purposes, When States Legalize It.
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WSDA Rule-making Process After Bill Goes Into Effect On June 28
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Directs WSU To Conduct Research - Feasibility And Desirability Of Producing Industrial Hemp In WA
HEMP IN WA
Licenses Coming! (2016)
• The two species (or subspecies) of cannabis are
known as Cannabis indica and Cannabis sativa.
• - Long Stems = fiber
• Seeds for oil
WSDA Guidance on
WPS
agr.wa.gov/FP/Pubs/docs/4
87-WPSGuideCannabis.pdf
Personal Protective Equipment (PPE)
PPE is Worn to Protect User from Exposure to Pesticides
(e.g. Respirator, Chemical-Resistant Gloves and Boots, Protective Eyewear, etc.)
Outdoor Grow
Greenhouse
Indoor Grow
Examples of Pesticides That Can Be Used on Marijuana
 Azadirachtin (e.g. AzaGuard, Azamax, Azatin)
 Bacillus subtilis (e.g. Natria, Serenade)
 Canola oil (e.g. Earth-Tone, Garden Safe)
 Clarified hydrophobic extract of neem oil (e.g. Ferti-Lome,
Garden Safe, Natria, Trilogy)
 Copper octanoate (e.g. Camelot, Cueva)
 Hydrogen peroxide (e.g. Oxidate, Zerotol)
 IBA / Indole-3-butyric acid (e.g. Clonex Rooting Gel, Mad
Farmer, Rhizopon)
PESTICIDE MISUSE-
High Likelihood Of Misuse On Marijuana
Miticide
Abamectin
Insecticide
Bifenthrin
Chlormequat chloride PGR
Daminozide
DDVP (Dichlorvos)
PGR
Imidacloprid
Myclobutanil
Paclobutrazol
Permethrin
Propiconazole
Insecticide
Spinosad
Spiromesifen
Uniconazole
Captan
Chlorpyrifos
Clothianidin
Diazinon
Insecticide
Insecticide
Fungicide
PGR
Insecticide
Fungicide
Miticide
PGR
Fungicide
Insecticide
Insecticide
Insecticide
Possible misuse on marijuana
Possible misuse on marijuana
Possible misuse on marijuana
Possible misuse on marijuana
PESTICIDE MISUSE
Cyflumetofen
Acephate
from 10/8 inspection
Insecticide
Acequinocyl
Acetamiprid
Miticide
N6-Benzyladenine
PGR
Insecticide
NAA (1-Naphthaleneacetic acid)
PGR
Azoxystrobin
Beta-cyfluthrin
Bifenazate
Carbaryl
Chlorfenapyr
Chlorothalonil
Coumaphos
Cyfluthrin
Cypermethrin
Deltamethrin
Ethephon
Etoxazole
Fenoxycarb
Fenpyroximate
Imazalil
Iprodione
Malathion
Fungicide
Insecticide
Miticide
Insecticide
Miticide
Fungicide
Insecticide
Insecticide
Propoxur
Spinetoram
Spirodiclofen
Spirotetramat
Tebuconazole
Thiamethoxam
Trifloxystrobin
Zeta-cypermethrin
Insecticide
Insecticide
Miticide
Miticide
Fungicide
Insecticide
Fungicide
Insecticide
Insecticide
N6-Benzyladenine
PGR
Insecticide
PGR
Miticide
Insecticide
Miticide
Fungicide
Fungicide
Insecticide
PESTICIDE VIOLATION
PRODUCER/PROCESSOR LOCATIONS
RETAIL LOCATIONS
PRODUCER/PROCESSOR LOCATIONS
LICENSING
PRODUCER
LICENSES
ISSUED
PRODUCER/PROCESSOR PROCESSOR LICENSES RETAIL LICENSES
LICENSES
ISSUED
ISSUED
ISSUED
138
645
97
PENDING
BUILD OUT /
APPLICANT
PLACE ON
HOLD
PRODUCER/PROCESSOR
PENDING INSPECTION
RETAILER
PENDING
INSPECTION
147
19
33
304
RETAILERS
REPORTING
SALES
226 OUT OF 304
PRODUCER/PROCESSOR LOCATIONS
SALES (as of 3/2016)
Average DAILY sales
WTD
$2,855,558
SALES (shelf price)
TAXES
FY 2015
FY 2015
$259,785,729
$64,946,432
Total SALES* (shelf price)
FY 2016
Total TAX obligation
FY 2016 (in 3 mos.)
$639,830,597
$122,715,140
Sales & Taxes 2015-2016 - > $80M Feb/2016
PRODUCER/PROCESSOR LOCATIONS
WA LIQUOR & CANNABIS BOARD (WLCB) COMPLIANCE
PREMISE
CHECKS
COMPLIANCE
CHECKS
FY 2016
Jan-Mar/2016
2075
272
FAILED
VIOLATIONS
COMPLIANCE
ISSUED
CHECKS
FY 2016
27
FY 2016
199
Regulatory Structure WA
 WSDA – No Specific Authority – Asst. A.G. Opinion
 LCB – All Authority – Recreational
 DOH – All Authority – Medical
 WSDA – Authority over Food Processing
 Weights and Measures
 Pesticide Inspection Assistance Requested – By LCB
 Governor Directed WSDA to Help LCB w/ Pesticides, Food,
No Specific Authority over Cannabis
No Funding
No Residue Limits Established – Any detection could =
Destruct
Cannabis Regulatory Structure WA
Who Takes Action for Pesticide Misuse
No Pesticides Registered
for Use on Cannabis
Criteria and List of Pesticides that are legal for use is by Default
i.e. Not Illegal
Pesticides are Exempt from Tolerance on Food Crops &
Label Language is so Broad - can be used on Cannabis without fear
of Violating Pesticide Laws
Other Issues
Licensing – Applicators, Dealers
WPS Training
Is it Agriculture (County Land Arguments), Commodity
Organic Program will not Recognize
WSDA PESTICIDE Cases & Marijuana
 11 cases since Sept 2015 – All Complex, Time Consuming,
Expensive , 1 Major Finalized – Going to Court….
 3- New/Pending
 If Sample
- Extensive Marijuana Sampling Protocol for ISO Lab
 Expensive Lab Equipment – Solely Dedicated to Marijuana
 MOU with LCB to Inspect – They are Law Enforcement – we are
Investigators – They have Guns, we don’t – we don’t go without
them
 Lab Issues/Sampling
 Need 250 ml=
- No Extracts …
$3,100-$15,000!!!
Recent Case – Analyses Results
A.I.
Azoxystrobin
Tradename
Results
MDL
0.073ppm
0.002ppm
0.11ppm
0.016ppm
0.46ppm
0.011ppm
0.049ppm
0.0014ppm
(Biopesticide/antibiotic)
Cyflumetofen
(synthetic pyrethroid)
Bifenthrin
(synthetic pyrethroid)
Uniconazole (PGR)
Recent Case – Analyses Results
11/12/2015
NML-0020-15-003 fresh Marijuana
leaves and bud
Test
Reported Result
Units
Spiromesifen
0.12
ppm
Dinotefuran
21
ppm
Myclobutanil
0.21
ppm
Veg Room and
Flower Room
1(View On Map)
Recent Case – Analyses Results
12/30/2015
12/30/2015
NML-0020-15-004
NML-0020-15-005
Foliage from Veg
Room - All plants
sampled were
started after
11/12/2015
Foliage from
Mother Plants in
Veg Room
Veg Room
Lat: 0
Long: 0
(View On Map)
Veg Room
Lat: 0
Long: 0
(View On Map)
Analyzed by Trace
Analytics, Spokane
Boscalid 0.145 ppm
Fludioxonil 0.0013
ppm
Myclobutanil 0.051
ppm
Analyzed by Trace
Analytics, Spokane
Dinotefuran 1.197
ppm
Boscalid 5.788 ppm
Fludioxonil 0.0124
ppm
Myclobutanil 0.079
ppm
Recent Case – Analyses Results
12/30/2015
NML-0020-15-006
Waste Foliage
from all rooms
Waste Bag
Lat: 0
Long: 0
(View On Map)
Analyzed by Trace
Analytics, Spokane
Dinotefuran
13.435 ppm
Boscalid 81.788
ppm
Pyraclastrobin
0.399 ppm
Trifloxystrobin
0.078 ppm
Fludioxonil 0.417
ppm
Myclobutanil 1.212
ppm
Recent Case –Summary

There are 199 photo(s).

On September 15, 2015 the Washington Liquor Cannabis Board contacted WSDA to help investigate an
anonymous complaint alleging, Seattle, WA was using unapproved pesticides on their marijuana.
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On October 21, 2015 Alberto Isiordia (Compliance Program Manager, Brent Barnes (Asst. Dir) and I (Area
Manager, Compliance, Western WA ) with WSDA and Vanessa Garris from the Washington Liquor Cannabis
Board conducted an onsite inspection at___________, Seattle, WA.
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The firm has two licensed applicators. On November 12, 2015 a composite sample of vegetation (leaves,
stems, flowers) from multiple random plants growing in veg room and flower room 1 was collected
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The following chemicals were found in samples of marijuana: Boscalid, Dinotefuran, Fludioxonil,
Myclobutanil, Pyraclastrobin, Spiromesifen, Trifloxystrobin.
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All of the chemicals listed in 9 and 10 above are active ingredient in pesticides. None of these active
ingredients are contained in pesticides approved for use on marijuana. These results
indicate pesticides were used contrary to label directions.