DOH Medical Sales have skyrocketed in recent months. According to CCRS records, there were only 34 DOH Compliance samples statewide in the month of March. In July, that number ballooned to 1,561. That’s a 4,500% increase! 60% of all DOH Compliance tests submitted to CCRS in the month of July were from brands participating in the Certified With Confidence™ Program.

DOH Medical Sales as a Proportion of Total Market by CategoryOur friends at Headset helped us gather data related to Brands enrolled in the Certified With Confidence (CWC) Program, specifically looking at market share by category . Those Brands enrolled in the program command a respectable 23% of the entire I-502 market, based on retail sales data. Some product categories (like Capsules and Topicals) are almost completely owned by CWC participating Brands.

Price Advantage for DOH Medical Sales​

We also looked at the data to get a feel for how products sold by CWC participating Brands may enjoy a price advantage at retail. Within the five most popular product categories, products sold by Brands participating in the CWC Program earn themselves a noticeable price premium, selling for 13% more on average for Edibles all the way up to 43% more for Concentrates. These figures are based on the average retail sale price, including discounts, not including taxes.

*figures represent average pre-tax retail price per gram of product net weight except for Edibles where the figures listed are average price per milligram of THC.​

Of course, the price premium comes with a cost: it costs more for producers to get products tested to DOH Medical Grade standards vs regular I-502 compliance standards. Nonetheless, a breakdown of the numbers shows that the cost of the test pales in comparison to the premium enjoyed by the products.

Take Flower for example. If we assume a 15 lb lot size, the additional cost of testing to achieve DOH Compliance is $0.01 per gram ($70 add-on for the HM test divided by 6,804 grams in 15 lbs). That means the additional cost of testing in this scenario is just one penny per gram of Flower — less if the lot size is larger — and on average it translates to a $1.30 per gram premium on the retail shelf. The cost of testing is far outweighed by the additional gross revenue.

Take Concentrates as another example. If we assume a one kilo batch size, the additional cost of testing to certify that batch as DOH Compliant is $0.07 per gram ($70 divided by 1,000 grams), and on average translates to a $5.49 premium on the retail shelf. Again, an enormous revenue advantage compared to the associated cost.

What’s Next?​

Certainly, the brands participating in the CWC Program enjoy their price premiums and market share for reasons beyond their participation in the program. In fact, participation in CWC is just one of many ways that premium brands demonstrate their earned reputation for quality. At Confidence, we are proud to partner with industry members working to go the extra mile for Washington consumers, and we do what we can to enhance their visibility and sales.

Thanks to Headset.io, we’ve shown one side of the market’s coin. Next, we are working to identify the other side: patient purchasing behavior. How often are DOH products sold with a tax exemption to patients, and has the new tax incentive increased the overall pre-tax retail sales in the market? If you have insights on this topic, we’d love to hear from you about it.

While we continue this important work, one thing is certain: patients seeking Medical Grade products – whether or not they hold a medical card – now have access to a much larger range of brands, product types, and overall variety than they have enjoyed recently.

Call or write to us at: 206-743-8843, info@conflabs.com

Recently, the Washington State Liquor and Cannabis Board (the LCB) announced the closure of 18 licenses in the Brewster area of the Okanogan valley. In their memo, the LCB briefly explains how they arrived at their conclusion that a small area outside the town of Brewster is uniquely contaminated with a pesticide called DDT, which the LCB assert lays dormant in the soil in that area.

Days later, the LCB announced an emergency rule proposal, with intent to enact those rules without public comment, citing their statutory authority to enact emergency rules for the preservation of public health, safety or general welfare.

What is DDT?​

DDT stands for “Dichlorodiphenyltrichloroethane.” It was a popular pesticide in the mid 20th century for the elimination of insects. In the 1960s it started to become apparent that DDT was causing widespread environmental damage. Among other things, evidence showed that DDT was causing the shells of eagle eggs to become too thin which resulted in the death of their hatchlings and measurable declines in their population. In 1972, DDT was banned in the United States. However, its remnants can still be found in some agricultural areas where it was used heavily more than 50 years ago.

DDT is a polychlorinated chemical, meaning it has many chlorine atoms attached. It is readily absorbed in soils where it persists for long periods of time. Slowly over time, DDT breaks down into DDE and DDD, both of which are also damaging to the environment. Collectively, we call all three of these compounds DDX.

How is it tested?​

Gas Chromatography with Tandem Mass Spectrometry (GCMSMS) is the most trusted, most proven technology for chlorinated chemicals such as these1. While it is possible to test for DDX compounds using other technologies, those other technologies lack the ability to detect DDX compounds at low levels2. Comparisons of GCMSMS to other technologies finds that GCMSMS outperforms especially on chlorinated compounds3.

Unsurprisingly, the Washington State Department of Agriculture Laboratory (WSDA), the state-run lab which conducted the testing that resulted in the proposed rules, utilizes GCMSMS for the analysis at their lab. Likewise, Confidence Analytics employs the same technology for analyzing chlorinated compounds, including DDT, DDE, and DDD.

1. Luong, et. al., A practical Method for Trave-Level Analysis of Chlorinated Organic Pesticides by Gas Chromatography-Mass Spectrometry, LCGC North America, (2012) 30 (4), 342-348 (April issue)
2. Sutthivaiyakit, et. al, Confirmatory determination of organochlorine pesticides in surface waters using LC/APCI/tandem mass spectrometry, Anal Bioanal Chem, (2006) 384: 1236-1245
3. He P and Aga D. S., Comparison of GC-MS/MS and L-MS/MS for the analysis of hormones and pesticides in surface waters: advantages and pitfalls, Anal Methods, (2019) 11

We are happy to announce the addition of CBNA, CBCA, and CBL to our service.* Through our commitment to constant innovation, the science team at Confidence Analytics has recently added these 3 new cannabinoids to our “potency” method and our cannabinoid list now includes 17 cannabinoids!!

CBNA and CBCA are the acidic precursors of CBN and CBC, respectively, two cannabinoids we’ve been measuring for over 8 years. CBL is a new kid on the block.

As an analytical lab, we can only report accurate quantifications of cannabinoids when there are commercially available chemical standards. So while we have been detecting these three cannabinoids for a long time, we have not been able to report them to you until recently, when their standards became available from chemical manufacturers.

And while it took hard work to add these new analytes to our cannabinoid list, we are offering it to you for the same low price as before.

CBNA – for sleep?​

Long lauded as a super-sedative, a human study using CBN has not substantiated this relationship1. Rodent and lab studies have found it to be antimicrobial2, neuroprotective3, and an appetite stimulant4. Our lab regularly finds CBN and CBNA in products, including in freshly cured flower. Which is interesting because while the dogma sometimes suggests that CBN is only formed as a degradation of THC, the presence of CBNA (the acid precursor to CBN) present in fresh flower indicates it is synthesized by the plant, as well.

CBCA – a synergist?​

You’ve heard of the entourage effect, well get ready for CBC’s precursor CBCA. While not intoxicating on its own, it is believed to enhance and modify the effects of other cannabinoids5. It may also battle inflammation6, cancer7, and acne8. We are glad to have CBCA on our cannabinoid list.

CBL – a mystery.​

Not much is known about CBL. It does not occur in high abundance in cannabis flower. CBL is a degradant of CBC – created when CBC is exposed to light or acid – so it is no surprise we see it mostly in distillates, which tend to contain more degradation products.

Read more about our Cannabinoid List​

Now Testing More Cannabinoids in Cannabis, including THCV, at the Same Price

• Eight Cannabinoids by HPLC-UV
• Credit to Leafly’s cannabis glossary

What’s in a strain, and how do we know?​

Last Friday, May 20th, the scientific journal PLOSone published an article titled “The phytochemical diversity of commercial Cannabis in the United States” in which the authors describe their analysis of over 90,000 cannabis test results, asking the critical question: what’s in a strain? Confidence Analytics contributed to the research paper by providing anonymized data about cannabinoids and terpenes to the authors.

Authors Christiana J. Smith and Nick Jikomes are, or have been, affiliated with Leafly, a popular consumer-oriented website focused on cannabis use and education. Along with co-authors Daniela Vergara and Brian Keegan from the University of Colorado, the authors describe a sophisticated machine learning technique (aka “statistics”) they used to analyze thousands of test results from six US-based cannabis labs, including Confidence.

Notably, the findings appear to “debunk” the popular “indica-sativa-hybrid” model commonly used for strain categorization. Instead, the authors found that cannabis strains can, and probably should, be categorized based on chemical composition. If we believe that different strains of cannabis have different effects on the user, then those differences in effect must be the result of differences in chemical composition. The authors demonstrate that different strains of cannabis do indeed have different chemical compositions, and that these chemical compositions are repeatable between geographies and through time when the strains are of common lineage. Furthermore, the diversity of strains appear to be “clustered” based on their chemical compositions whereby strains in the same cluster are more similar to each other than they are to strains in a different cluster. The results of the study indicate there are more than three such clusters among THC-dominant strains, and the clusters do not align well with the common categorizations of indica-sativa-hybrid.

To categorize a strain, you must first know what’s in a strain.

This is exciting research, immediately applicable to consumer and cultivator decision making. Knowing why some strains are similar to others, and which strains, may help growers maintain a diverse product line, and may also help consumers identify strains, or groupings of strains, that they prefer based on similarity.

Importantly, this article in PLOSone references a previous publication in nature where the authors detail the unfortunate fact that while test results from cannabis labs can provide useful information about the chemical compositions of strains, many labs are not collecting data with enough precision or accuracy to make such meaningful inferences. We’ve discussed those implications on our blog before.

A new draft Policy Statement was recently released by the WSLCB.​

Here’s the highlights:

• On April 2nd pesticide testing requirements go into effect for Washington state cannabis (i502).
• Retailers have a “sell-down” period until December 31st to clear their shelves of any product not tested under the new rules.
• Producers and processors have a “phase-in” period until September 30th to clear their inventory of any product not tested under the new rules.
• Producer/processors who want to avoid the pesticide test have until April 2nd to get their products tested, and until July 1st to sell those products.

Earlier this month, the Washington State Liquor and Cannabis Board (WSLCB) approved a new set of quality control rules that will require pesticide testing of all inhalable cannabis products sold in the state. Those rules are set to go into effect next month on April 2nd (see our previous blog post on the topic, and review our white paper for more details). Adding to the complexities of those new rules, last week the WSLCB sent out a Draft Policy Statement concerning sell-down of product tested prior to the new rules.

In short, the Policy Statement addresses questions from the i502 community of cannabis growers, manufacturers, and retailers such as: “what about product that was tested before the new rules? does that product need to get re-tested once the new rules go into effect?”

According to the draft Policy Statement, the direct answer to the above question is: no, retesting of previously tested product will not be required, but with a time limit. Retailers have a “sell-down” period until December 31st to clear their shelves of any product not tested under the new rules. Producers and processors have a “phase-in” period until September 30th to clear their inventory of any product not tested under the new rules.

If a producer or processor is still in possession of products not tested under the new rules after September 30th, they would have the opportunity to retest under the new rules and thereby make the product eligible again for wholesale. The policy statement does not indicate how a retailer would rectify old products after December 31st, as retail licensees do not have avenues for WSLCB-sanctioned compliance testing. Presumably, the Retailer would have to destroy or return untested product.

On the surface, the Policy Statement makes sense. Products tested prior to April 2nd, the first day of the new rule enactment, would have been tested under then-current rules, and therefore are eligible for sale. The “sell-down” and “phase-in” dates listed in the Policy Statement are not enacted through regulation, only through policy, yet the WSLCB appears intent on upholding them.

Nonetheless, the rules are a step in a positive direction.

We sat down with Jhavid Mohseni of Aperon Corporation to talk about cannabis grading and the TOP 5 things producers and processors should keep in mind regarding the quality and care of wholesale material and the upcoming changes regarding mandated pesticide testing.

Q: First, can you tell us a little bit about Tamerlane and Big Tree Grading? How did they get started and why did you get involved in the business of brokerage and cannabis grading?​

Tamerlane came out of the overwhelming need I was hearing from producers/processors asking for help with sourcing or selling bulk material. I was literally asked by 100’s of operators and visited 1000’s of operations in order to learn how to help licensed operators to sell or source. That together with a question that had been on my mind since recreational legalization was starting, “How will cannabis be traded globally.”

Big Tree was born out of the need to have a seperate company and team providing the valuable service of standardization, appraisal, grading, and quality verification which exists in all other commodity markets. A separate entity was created to avoid any conflicts of interests that are created when a broker is also the qualitative grader and appraiser. Buyers and sellers require an independent third party service to grade and appraise their bulk wholesale material. Without it you’re buying or selling blind, or with a limited perspective.

Both companies work to address problems that stem from inefficient or complicated bulk sales and sourcing, the lack of trust that can occur between buyers and sellers and the limited transparency most buyers and sellers have on quality and fair market value for material.

Q: What does quality mean to you?​

To me, high quality is something you can trust, which demonstrates a care and thoughtfulness to providing a ‘better’ or ‘more improved’ experience.

Q: When grading a product what are the issues you see most often that reduce the value of a product?​

Some real issues started at the end of 2018 through the 1st quarter of 2021, when the increased demand and higher prices allowed bulk wholesale suppliers/producers/sellers to get sloppy, and cut corners. If you want to have what buyers want and provide a consistent reliable sales/sourcing opportunity, our advice is to do the following 5 things:

1. Sort your material by size and product type. A-flower in one bag, B-flower in another, and trim in another. If you have two types of trim, or two processes, keep that material separated. Mixing material dilutes the value.
2. Establish good material handling and processes. Leaving waterleaf on the plant when breaking down the material specifically contaminates the trim with unusable biomass. Ensuring that all large stems, sticks and stalks are also removed is key.
3. Properly Dry and Cure. So many times we see great weed destroyed with improper dry/cure, drying space, not enough, or too much burping, and more. Years of experience and appraisal services provide best practices for maximizing profit through proper processing.
4. Create adequate storage solutions. Anyone storing for any amount of time, should have cold, dark, and airtight solutions. Nitrogen flushed is even better. The enemy to your material quality is heat, light, oxygen, and time.
5. Perform Testing and Grading. Not testing your material from a lab, or skipping the 3rd party cannabis grading not only opens a buyer and seller up to manageable risk, but it also limits the value a seller can charge for their material. As markets evolve, and operators scale, consistency and reliability will receive a premium. Lab testing and 3rd party quality grading delivers that to the buyer.

Q: Talk to us more about what you are seeing with testing. WA State just passed rules to formally mandate pesticide testing in less than a month, how do you see that impacting the market?​

I see this change having a number of unintended consequences both positive and negative.

• It will force innovation in pest and mold control.
• It will frustrate and anger many growers who are not able to adjust or refuse to change.
• It will help usher genetic hunts not only for cannabinoids or terpenes, but also for plants resistance to pests and molds.
• This will bring about new ways to meet the requirements with inventive and imaginative practices.

Q: What steps would you recommend growers take to reduce any negative impacts?​

Start testing for pesticides now. Honestly, folks should have started in 2017 during the last big dip. If you are using something on the banned list, figure out how to grow without it ASAP.

Q: One last question on testing, how does lab data play a role in how product is graded and sold?​

Lab data is a critical value to any bulk wholesale lot or a packaged product heading to the shelves. A lab with solid SOP’s, testing standards, and the integrity to report actual true data provides an integral piece of transparency and insight for anyone evaluating the material.

Lab tests do not play a role in the qualitative analysis or final grade, but the lab data does play an important part of the reporting process, and the quantitative analysis that is reported on Big Tree’s Certificate of Grade or the Appraisal report.

Typically, tested material is more valuable, as the testing data and transparency provided from a quality lab, provide the buyer or seller with another layer of transparency. By knowing what the cannabinoid or terpene profile is, or that the material in question is pesticide free, it provides valuable information that obtains a premium in the spot price market and is definitely part of criteria included in power purchase agreements or a forward commitment.

Reach out to Big Tree Cannabis Grading for quality-verification and appraisal services, or Tamerlane Trading for quality -verified brokerage services. Mention the word ‘Certified’ to get in on a special Spring offering.

20% off your first month/deal at Tamerlane Trading.

10% discount on your first three months of the ‘Grading as a Service’ package, with a three month commitment at Big Tree Grading.

* Pie Chart: Most Common Pesticide Testing Failures as reported by Confidence AnalyticsTM​

AND THE VOTES ARE IN​

Spring brings pivotal change to the Washington State 502 Industry. It has been years in the making... lots of talk, discussion and chatter among the industry and the government. And here we are: Pesticides! Pesticide Testing, more specifically.

It is now crunch time. On March 2nd, the board made the final decision to implement required pesticide testing for end use cannabis products. The rules will go into effect April 2nd.

SO, WHAT DOES THAT MEAN FOR THE 502 INDUSTRY?​

Our own Nick Mosely has prepared a white paper outlining what may be coming with the enacted rules. “Pesticide Testing in Washington – A White Paper” is a balanced and direct assessment of the potential impacts to the industry, including growers, processors, and retailers. Each sector has a different vulnerability and opportunity in addressing the potential rules. The White Paper outlines some of the challenges the law would create and provides some suggestions to address them.

For instance, the new rules say that products that fail for pesticides would NOT be eligible for remediation. In preparation for this change, it may be helpful for the industry to adopt early pesticide testing of cannabis materials. Additionally, now may be the time to evaluate your testing providers. Have you discussed with your cannabis lab if they have necessary instrumentation, technical ability, and capacity to perform the new required tests? Without prior vetting, and planning, there may be bottlenecks in the supply chain due to laboratory unpreparedness. All industry sectors should ask questions, review the rules, understand what may be required, and get prepared.

CONFIDENCE ANALYTICS WILL BE PREPARED.​

For the last 6 years, Confidence has been providing pesticide testing services to the I-502 community of businesses, co-ops, and patients. We are actively engaged in increasing and expanding our pesticide testing capability in anticipation of this rule enactment. We encourage you to reach out with questions on how we can help your business.

* Pie Chart: Most Common Pesticide Failures as tested by Confidence Analytics. Data represent 452 pesticide detections that were quantified above the fail limit between January 2021 and October 2021. Data include samples of plant material and concentrates.

• During the same period of time, there were a total of 3,122 pesticide detections below the fail limit (detected, but pass). Those detections are not represented in the chart, because they pass.
• Detections below the fail limit occur 3x more frequently in concentrates compared to plant material. Detections above the fail limit occur 5x more frequently in concentrates compared to plant material.
• 15% of plant material samples have detections below the fail limit. If that plant material is concentrated, it can result in the concentrate failing.

Read more on our white paper:

“Pesticide Testing in Washington – A White Paper”

Read the full article here: https://tamerlane.com/news/confidence-analytics-goes-above-and-beyond-for-cannabis-analysis-and-consumer-safety

CCRS Reporting – It’s ALIVE! Frankenstein afraid of CCRS reporting.

With more milestones are on the horizon.

And much like Frankenstein’s monster it seems assembled from random body parts and regulatory hijinks, animated by the LCB. CCRS reporting has officially entered our lives eight feet tall and enormously strong but with the mind of a newborn.

This blog post is part of a series. See our other recent updates about CCRS:

• CCRS: Approaching the new guidelines

• CCRS: more info released by wslcb

• CCRS Traceability: It’s a GO!

On December 6th cut-over to CCRS came and went. This means Leaf is no longer necessary or sufficient for maintaining traceability reporting requirements. But this was just the beginning. Read on to learn about more important milestones on the horizon.

Milestone #1​

Licensees have until December 13th — that’s this Sunday! — to make their initial inventory reconciliation to CCRS. Debate ensues as to whether the deadline is 11:59:59 pm on the 12th (7 full days after the 6th of December) or 9:59:59 am on the 13th (7 full days after the actual launch of CCRS reporting) or whether the deadline is end of day on the 13th (and is end of day midnight or is it 5pm?)

We would suggest to avoid any problems you do it by the end of the weekend.​

Email from LCB: “The expectation by December 13th is that the initial upload of all of the CSV required reports has been completed. The weekly reporting requirement will be in effect after December 13th. WSLCB has defined ‘week’ as Sunday – Saturday. Additionally it is expected that a full transition to Webform Manifest use has taken place by December 13th.”

So what does that mean? Moving forward, licensees are to report their activity to CCRS at least once per week. The LCB seems to imply that any activity occurring during a week must be reported by 11:59:59 pm of the following Sunday to remain compliant. Does this mean that an activity occurring on a Saturday at 10 pm has 26 hours to report, while an activity occurring at 2 am on a Sunday has almost 8 full days to report? That’s what it sounds like.

Milestone #2​

Next, on December 18th, Leaf will officially be decommissioned and will no longer be available for licensees. This means the interoperability solutions developed by the WCIA and discussed in our previous blog posts become all the more important for keeping inventory moving through the supply chain.

Be sure your integrator is ready to….

1. get your weekly reporting out by the deadlines and
2. receive manifests and lab results via the WCIA interoperability solution.

We are here to help.​

As always, we at Confidence can help you navigate the lab integration portion of the CCRS. You can read through our past blogs or contact us directly at info@conflabs.com for more information.

This blog post is part of a series. See our other recent updates on CCRS traceability:

• CCRS – Approaching the new guidelines
• CCRS – More info released by wslcb

Yesterday the WSLCB responded to an inquiry from the Cannabis Observer’s Gregory Foster. The Cannabis Observer reported: “November 17th was the ‘go/no-go decision point’ for the internal WSLCB CCRS Traceability Steering Committee to decide whether to proceed… said [CFO Jim] Morgan, and ‘at this point, all signs are pointing to that being a go’.”

SO folks, as we have suggested in our earlier blogs – NO MORE TIME TO DELAY! Let us direct you to the most recent WSLCB bulletin on “How to Prepare for Success in CCRS: A “Quickstart” Guide for Licensees.”

More Resources.

Another resource: the WSLCB webinars, available on YouTube. Check them out – WSLCB Webinar September 8, 2021 and WSLCB Webinar October 4, 2021.

Also, a little more information on CCRS traceability integrators – Washington state has approved POSaBIT as an approved integrator. Other approved integrators include:

• Bamboo Metrix LLC
• Cultivera
• Dauntless
• Greenbits
• GrowFlow
• Intelligent Automation Consulting LLC
• Klick Track
• Leaf Logix Technologies
• Mister Kraken
• OpenTHC
• POSaBIT

As we reported earlier, the integrators have formed a consortium called the Washington Cannabis Integrators Alliance (WCIA) to develop technology standards and interoperability solutions after the cut-over date.

We can help.​

And finally, let Confidence help you in navigating the lab integration portion of the CCRS traceability. You can read through our past blogs AND you are invited to attend our webinar on November 30th. Reach out to info@conflabs.com for more information. The time is fast approaching to be sure everyone on your team and the other licensees you do business with are prepared and informed. Are you going to be ready?!? We are. And we can help.

For the FAST…. only THREE weeks to get ready.​

A WSLCB Bulletin entitled “How to Prepare for Success in CCRS” has been released that states:

“Those needing to modify data in Leaf should do so before the Dec 6th switch to CCRS. Leaf will no longer be available after Dec 18th.”

So folks, that’s just around the corner. (ONLY 3 WEEKS TO GET READY.)

And for the S-L-O-W…. time to get prepared.​

Time for producers, growers, manufacturers, processors, retailers and labs – ARE YOU PREPARED? It is a process. We got you covered.

While this change will certainly cause business disruptions and it will take time to develop a new seamless process, there are ways you can prepare and set yourself up for success. If you use Confidence as your lab of choice, we are here to guide you through the lab side of the equation, answer questions, and educate you on new processes [See below].

Another Bit of News… Cannabis Alliance Wednesday Webinar​

Just yesterday, the Cannabis Alliance hosted a comprehensive seminar on “Where are We at with CCRS?” The webinar can be found on Youtube and provides some conversational points with a number of industry leaders, including our own Bobby Hines. (Yay!)

More to Come. Including… A ConfLabs Webinar.​

Stay tuned for more information. Confidence will keep the information coming. If you want to attend our upcoming webinar ‘CCRS and Your Lab’ on November 17 or November 30, please let us know. If you have any questions, please reach out to info@ConfLabs.com.

New Chapters in Cannabis Traceability​

Next month a new chapter will begin in Washington state as the Washington State Liquor and Cannabis Board (WSLCB) takes the bold step of scrapping and simplifying the former seed-to-sale traceability program. The WSLCB has acknowledged stakeholders have long suffered using the state’s cannabis tracking software. Alas, a whole new world (of software – or not?) is planned with an effort to simplify the process for all industry participants.

So before we begin with the nitty-gritty, let’s start with a blog teaser...

The Highlights​

• The Cannabis Central Reporting System (CCRS) is a soon to be enacted records reporting system that will replace the former state run seed-to-sale tracking system (Leaf Data Systems).
• The new CCRS changes how licensees will exchange required transaction data between each other.
• The biggest concern is how businesses will maintain information (and data) integrity when conducting transactions (material transfers and lab results).
• The solution is: Interoperability.
• Interoperability is a system for standardizing communication conventions between industry stakeholders. In other words, it standardizes how, and in what form, data will be shared.
• Our own CTO, Bobby Hines, is leading the effort in standardizing the interoperability format for lab results.
• Current expected go-live is December 6th, 2021.
• Are you going to be ready?!? We are. And we can help.

Let us lead you through the WHO – WHAT – WHERE – WHEN – and WHY – of the CCRS – although not necessarily in that order...

WHERE TO BEGIN? At the Beginning.​

A long, long time ago (in legalized cannabis years) the WSLCB instituted traceability software that would track legalized cannabis from seed to sale. This meant the state, through the software, would have the ability to track the growing, producing, sales, manufacturing, lab testing, and retail sales of Washington’s cannabis crops. In other words, the state would be smack in the middle of business operations. This system – initially BiotrackTHC and then Leaf Data Systems – created some headaches and heartaches for the industry. In an effort to simplify, and recognizing the process was simpler in the state liquor and tobacco sectors, the WSLCB decided to revamp the system. Thus the (upcoming) Cannabis Central Reporting System (CCRS) was born and will soon replace the Leaf reporting system. (Get ready – it’s happening fast!)

What happens now? Maybe we should start with the WHY…​

The WSLCB recognized that problems existed with the Leaf system. Feedback and technical considerations were provided by the Traceability 2.0 Workgroup as part of the WSLCB’s Cannabis 2.0 initiative (2019-2020). A stated goal of the Workgroup was to address, and prevent, traceability system downtime and to remove the state from being in the middle of business to business transactions.

And it looks different, HOW?​

Leaf served as a centralized repository for all cannabis inventory, transfer, and sales tracking. However the new CCRS will be a one-way reporting system for all licensees, labs, and software providers. This means, in layman’s language, inventory management, including the centralized global ID creation and management, will now be gone. (Okay, this presents some other issues…. If it’s not one thing, it’s another!)

So WHAT’S the Good and Bad of CCRS?​

The good is “simplified” reporting , lack of downtime, and the state removed as a “middle” entity. The bad? ID numbers will not be generated by the new CCRS. The onus will now fall to each licensee, lab, and software provider to create these ID numbers. What’s worse? How will licensees exchange required transaction data between each other? How will businesses maintain information (and data) integrity when conducting transactions (material transfers and lab results)? Manual entry (UGH!) is more prone to error than automation – think fatigue etc. – and sprinkle in confusion when a license holder may be working with dozens of different vendors each using their own convention for forms, barcodes, and other documentation. Yikes! Well, the solution is: Interoperability. Okay, what does that mean? And how does that affect YOU – a stakeholder in the Washington state cannabis industry?

The WHAT of Interoperability: Or interoperability for dummies.​

We have been “schooled” by our own CTO, Bobby Hines. Interoperability is a system for standardizing data communication conventions between industry stakeholders – in other words – how growers communicate their electronic data with manufacturers, how manufacturers connect with labs, how manufacturers share data with retailers, and so on. So... how (and in what form) will data be shared when the Leaf system is dismantled? Read on.

A Bit More on Interoperability…​

In October 2021, a group of licensees, third party software providers (often called “integrators”), labs, point of sale providers, and industry organizations formed the Washington Cannabis Integrators Alliance (WCIA) for the purpose of discussing interoperability. This technical committee of ten, including Confidence Analytics, worked, (and are continuing to work) to establish such conventions (finding ways for everybody to talk the same language). Should the WCIA achieve success, widespread adoption could provide a self-regulated way of participating in traceability while greatly increasing information integrity (and speeding up stakeholder workflows)! WCIA’s goal is to encourage cannabis businesses to come together to create one, electronic, unified system for data recording to reduce translation errors, and transmission time between licensees, labs, and integrators. And this is an industry solution NOT a state solution!

HOW is interoperability a useful tool?​

A major benefit of Interoperability (Interop!) is reducing error and labor by creating an industry wide tool for automated information exchange. The Interop tool being developed aims to address, and resolve, formatting and standardization issues including the creation of a global ID (since that feature is not included in CCRS). Overall, an Interop tool such as this has the potential to save everyone time regardless of their role in the cannabis industry.

The benefits of adopting a centralized interoperability system are clear: it provides a reduction in data processing time, a reduction of potential errors, and ease of collaboration between various sectors of the industry. These benefits not only translate into time savings, but also into monetary savings. Time IS money – so stakeholders embracing Interop have the potential to be ahead of the curve once CCRS is live in December of 2021.

And tell me again, how do I use the CCRS? WHO is an Integrator (or not) and how does that help?​

If you’re a stakeholder, chances are you know who, what, and if you utilize an Integrator. For the rest of us, an integrator is...

...a software vendor who helps licensees track, control and report their inventory in real-time. This software vendor automatically submits compliance information to the state, on behalf of the stakeholder. Stakeholders without an integrator are often manually tracking and reporting this data via spreadsheets.

The majority of integrators are working and ready to employ this Interop system so if you have one, you are already in a good spot. If you don’t have an integrator you will need to, minimally, create your own manifest form that is WAC compliant.

We’ve got you covered.​

If you’re a Confidence Analytics customer, your LAB results email (as well as your results portal access) will provide a link to the data from our CCRS Lab Results CSV. These results copy/paste to any spreadsheet in the hopes of saving you a manual entry process. If you’re not a Confidence Analytics customer (sad face) contact your lab to assess how the process will work.

It goes live… WHEN?​

The current expected go-live for CCRS is December 6th, 2021. Ahhhh… that’s right around the corner! After that date, all licensees and testing labs are expected to be reporting to the CCRS. Leaf will remain online for a few weeks after that date, but reporting to Leaf will no longer be required or sufficient for compliance with WSLCB inventory reporting policy. Are you going to be ready?!? We are. And we can help.

What do I do NOW?​

Get in contact with Confidence if you have questions about how to integrate your lab results in this new world. We can offer you tools for a seamless lab integration so the required testing information you need to submit happens as smoothly as possible.

Is homegrown cannabis headed our way?​

Last week our own Lara Kaminsky, Program Director at Confidence Analytics, caught some press! Lara, in her capacity as the Government Affairs Liaison for the non-profit (501-c-6) The Cannabis Alliance, testified (virtually) in front of the Washington State House Commerce & Gaming Committee. WHY? Once again the legislature is debating and considering homegrown cannabis for the adult (21+) population (see HB-1019 for further detail). Washington state is considering a 6 plant per person – or a 15 plant maximum in a shared household – allowance. And besides age, the state would regulate site view.

To date, ten states with legalized recreational cannabis also permit a regulated amount of cannabis grown at home. Today, Washington only permits the medical cannabis sector (cannabis patients) to grow at home.

Legislative Supporters AND NOT.​

The Cannabis Alliance is in support of this legislation: seeing it as a reasonable opportunity for consumers to become more learned, and discerning, in their cannabis choices. (THC ain’t the only thing that matters!) Retailers too seem in favor. WHY? Lara told me: “Well, if it plays out like craft brewing and other boutique industries, consumers may find it “isn’t that simple.”” Or, it may show that cannabis really is nuanced: again THC is not all that matters! And information suggests that homegrown cannabis will not interfere with state revenue.

There are opponents to this bill including the Washington Association of Sheriffs and Police Chiefs which cited fear of crime and kid access as problematic. The Association views, as well as Lara’s testimony ( a brief snippet at least) – and other information – can be seen in the KIRO 7 report which covered this topic. (Check it out here.)

Where WE fit in.​

Confidence Analytics’ contribution to the legal cannabis industry is to provide accurate testing of the plant and developed products. Regardless of where it starts or lands (the plant, that is) – grower, manufacturer, patient – or a homegrown cannabis enthusiast – Confidence is available for testing.

The Cannabis Alliance: is a non-profit, membership-based association of individuals, businesses, government officials, and non-profit organizations dedicated to the advancement of a vital, ethical, and sustainable cannabis industry.

Cannabis use is on the rise with many adults trying cannabis for its therapeutic and medicinal benefits rather than just the recreational high. Due to medical and recreational legalization in certain states, and the subsequent openings of dispensaries and retail shops, cannabis testing has now become very important in the industry. Just like all other medical products, medical and retail cannabis must have proper information regarding potency and dosage, which is where testing comes into play.

There are regulations and requirements that cannabis products must meet, so labs around the world are performing tests to ensure these products are meeting and there are now regulations for cannabis that must be met. Companies that sell medical marijuana must have all items assessed, and this includes each strain that is offered. You will find that various strains, such as Gelato, have different potencies and different dosages, and all of this information is found and then included on product labels.

Let’s take a look at the major reasons labs are conducting cannabis tests and what these results mean to users. And read more on 10buds.com.

Consumer Safety​

This is the primary reason for cannabis testing. Labs ensure that cannabis products are tested for potency and safe for human consumption. This means products must meet strict standards, which can include looking for contaminants such as microbes, mycotoxins, solvents, pesticides, and heavy metals.

Compliance​

Each state that has legalized the use and production of cannabis will have regulatory bodies. These regulators determine, manage, and enforce compliance testing . Before any product can be sold, it must be examined by a third-party testing lab accredited or licensed by a regulatory body in the state. Compliance regulations must be met in order for cannabis to be distributed and sold.

Contamination​

All products that contain cannabis pass through various stages of production and are handled by many along the way. During each phase, contamination is possible and the product may be exposed to microbes, chemicals, pesticides, or other contaminants. Each individual state examines different pesticides and these can vary greatly. For example, California will test for 66 different pesticides, while Nevada only tests for 24.

Potency​

One of the important factors of cannabis testing is getting the proper ratio of THC to CBD, which indicates the potency of the product. It is important for labs to measure this ratio and report it accurately. Assessments are routinely performed to determine the potency for all types of strains. As a grower, this is mandatory and will result in the ability to offer something that consumers will feel safe buying, and ensures the highest quality and most accurate information on strain potency.

Conclusion​

Testing labs play a key role in the industry by routinely analyzing cannabis products that will be sold to consumers. Most lab companies are concerned with compliance data, which will allow the product to be sold in the state if it meets set standards. Aside from making sure compliance data is offered, the potency of each strain will be assessed to provide information on levels of THC and CBD.

With testing, cannabis products can be approved for human consumption, and users will get the numbers needed to make an informed choice. As the industry continues to grow, testing will ensure consumers are protected and producer/processors meet regulations.

Back in late 2019 (Yes, that feels like ages ago!) Confidence was approached by a Minnesota based non-profit organization (501(c)(3)) about testing some local CBD products. The Minnesota Hemp Farmers & Manufacturers Association (MHFMA) had become familiar with Confidence Analytics and approached our Operations Director, Pat Reynolds, for some assistance. Matthew Kaiser, MHFMA Program Director, had shared with Pat his frustration, and concern, over CBD label accuracy in the relatively unregulated CBD marketplace. What was in those consumer products that the MHFMA were seeing on the shelves of the retail space? MHFMA wanted to know! And we wanted to help.

Confidence Analytics has long held a deep concern, and commitment, for accurate testing. Accurate testing (and labeling) assists consumers in making informed decisions on all product purchases: from spinach to oatmeal to cannabis. The question: how could MHFMA and Confidence work together?

With aligned values, and a dedication to stringent testing standards, Confidence agreed to partner with MHFMA in providing results on a variety of hemp and CBD products. (Yes, I am tooting our horn! I am a believer in our company, our team members, and am a witness to values actually lived!) The outcome of that collaboration provided the headline of the June 17, 2020 MHFMA press release: Testing Finds Inconsistent Dosing, Signals Need For Self-Regulation. The compiled Confidence testing results indicated that 64% of the sampled CBD products tested were mislabeled. (Yikes – or not?) The full MHFMA article can be found here. It’s well worth a few minutes of your time.

Were the results surprising?​

Were the results surprising? No, not really. This was not Confidence’s first rodeo – we have been involved in cannabis testing since 2014 and have participated in several CBD “secret shopper” opportunities investigating CBD label accuracy. (Check out Leafly’s November 2019 Article.) As Pat said, “This isn’t the first time we have been asked to do this and [it] probably won’t be the last…. [However] ‘Minnesota’ were the first people that we actually donated the testing to… because that’s… how much importance… we place behind this message getting out there….” The message of course – is the information depicted on the label indicative of what’s actually in the product? Pat further recognized: “the purpose of exercises like this are not … to catch how, or point fingers at, the people, the producers, the manufacturers, [or] the businesses that are creating the products that were tested… because… I honestly don’t believe that any of these people are doing anything maliciously.”

I asked Pat, what do you think of the results? Pat weighed in on the lack of federal leadership and regulation – and how that contributes to a CBD marketplace of inaccurate results and unreliable CBD label accuracy. “[T]he purpose... [of] these exercise[s]… is to highlight the fact that there are no regulations [or] that the regulations are patchwork. That states are being left to figure it out on their own just like they are with the Coronavirus testing with no guidance and no leadership from the federal government.”

Is it Only a Minnesota Problem?​

Are the Minnesota results representative of the hemp market nationally or a Minnesota problem? Reviewing the MHFMA Press Release, the Leafly Article and other news sources (including a local Seattle King 5 News Investigative piece) – there certainly are inaccuracies in testing which lead to concerns over CBD label accuracy. Pat continued, “Absolutely this is not a Minnesota issue.” He continued. “The government hasn’t stepped in to regulate. So... it’s really, really hard for people to figure out [standards] especially when… there is no central regulation, state regulation – [they] look at the state regulations and they get confused. What are people supposed to do?”

What are businesses supposed to do?​

Well said Pat! What are CBD companies to do? Well, to begin with, organizations like MHFMA’s project regarding accurate CBD labeling, which helps promote to consumers the issues, is crucial. Education – education – education. Hopefully, that awareness will lead to government regulation and reform. In the meanwhile, organizational collaboration and self-policing is crucial.

What’s Next?​

Hopefully the MHFMA gets some traction and exposure in the Hemp and CBD space. Encouraging all stakeholders – from other non-profits to growers to manufacturers to consumers – to get involved is crucial. Consumer pressure can potentially help create, and drive, a “trickle-up” effect – that CBD players recognize, and can address what the consumer wants.

Accurate labeling is imperative! Confidence remains committed to providing professional and meticulous testing results. We pride ourselves on focusing on the science of the numbers.

Located in northwestern Washington state – closer to Vancouver, B.C. than Seattle – is the trendy city of Bellingham. (Bellingham fun facts: named for Sir William Bellingham who died in 1826. Sir Bellingham, who never even saw the ocean or the land that would be named for him, oversaw provision procurement for the Vancouver Expedition as Controller of Storekeepers Accounts for the Royal Navy. Bellingham is the home to Western Washington University and a gateway spot to the Cascades, including Mt. Baker and the San Juan Islands.) Bellingham is also home to our Tested with Confidence Program™ (TWC) retail partner – 2020 Solutions. Recently we had an opportunity to connect with 2020 Solutions about their shopper base. Here is some of what they shared:

2020 Customers want ‘CLEAN’ Cannabis:​

2020 Solutions, opened its doors in 2014 and now hosts three retail locations in Bellingham. The store recognizes that shoppers love having a wide range of cannabis purchase choices. They pride themselves on listening to their guests, especially when it comes to the products they want to purchase. One overwhelming request is for pesticide-free products. (As we mentioned in our previous blog using terms such as “organic” or “pesticide-free” presents challenges.) With a growing number of health-conscious people located in the Whatcom County area, the desire for quality “clean” products extends beyond the grocery store and the bike shop, to the shelves of their favorite cannabis dispensaries.

Tested with Confidence Program™ Provides Solutions to “Solutions”:​

Our Tested with Confidence Program™ has helped bridge the gap for the 2020 Solutions’ consumer. Company spokesperson Aaron Nelson shared that when 2020 Solutions heard about the TWC Program, they jumped on board as a retail partner. He stated: “Tested with Confidence is a beacon of quality for discerning cannaseurs, regardless of their budget. We carry a large percentage of TWC products and this makes it easy for our guests to be confident in their purchasing decisions.” Aaron continued, “We have many local growers like Trail Blazin’ Productions and SUB-X and this program simply and clearly highlights their commitment to top quality products.”

2020 understands the TWC Program is a voluntary compliance program in which brand participants use our lab, Confidence Analytics, to “go the extra mile” and test for pesticides and contaminants. Only final end products that “Pass” the Washington state guidelines are authorized to be in the TWC Program. And for that, our participants can proudly use the TWC sticker denoting their inclusion in the Program.

Customers Speak and 2020 Listens:​

2020 Solutions listened to consumer requests – and provided Solutions (pun intended!). And TWC is delighted to be a part of that . It’s no surprise that 2020 Solutions has been awarded Small Business of the Year by the Bellingham Regional Chamber of Commerce, Best of Bellingham and Best of The Northwest by regional publications. Stop by and check them out.

Standouts:​

There have always been “standouts” in every industry – people/groups/companies that make the “extra” effort in producing their products. Cannabis is no different. A few years back our lab customers were vocal with their frustration about not having their cannabis product recognized as organic. Organic being one of those “standout” attributes indicating extra care associated with a product and aiding consumer purchasing confidence. You see though, “Organic” is pretty much a federally protected label – governed by the U.S. Department of Agriculture under strict guidelines. And as you know – cannabis and the feds – well – for today are at odds. With weed being federally illegal – devoted and environmentally-focused cannabis folks weren’t, and still aren’t, allowed to use that organic label. Why does that matter? Because many consumers are concerned with what goes into the cannabis product that they use – whether by inhalation, ingestion, or application. From that thought process – and with the intent to fill a void – the Tested with Confidence Program™ was born.

Confidence created a program whereby like-minded brands committed to holistic practices, going the extra mile in their cultivation or sourcing, would be recognized with a label. That extra mile included non-compulsory testing for pesticides and contaminants in their cannabis. This means an extra commitment of financial resources for testing. And not just a “one and done” testing. The brands commit to each lot/batch. That’s a lot of extra cost.

Pesticide Testing Not Required:​

Let me backup – Washington state does not require pesticide testing! Yep, hard to believe. So these Tested with Confidence Program™ participants, utilizing state created benchmarks for medicinal cannabis product quality, pledge to deliver cannabis products (for general use) that meet or exceed those strict standards. And remember, they don’t have to do that; they do it because they care.

These select brands committed to the Tested with Confidence Program™ – when adhering to the program, testing every batch – and receiving a “Passing” grade for every batch – have the opportunity to put a “Tested with Confidence” sticker or imprint on their final end product. That means something. It means the final cannabis product – what you smoke, eat or apply – meets or exceeds Washington state standards even though they don’t have to. That is fundamental: we, Confidence Analytics, don’t create the measuring bar. The state does. The state provides the independent, allowable or permissible pesticide and containment “benchmark” while the lab simply measures the product attributes. It’s the best we can do, today, without organic standards available. Confidence Analytics and the Tested With Confidence Program points to unbiased standards maintained by the local government: the Washington administrative code.

So, what’s the point?​

In a marketplace devoid of the “Organic” pointer, the Tested with Confidence label is a valuable indicator of a cannabis brand’s commitment to consumer purchasing confidence.

Last week Confidence Analytics was recognized by Marijuana Business Daily. Reporter Bart Schaneman published a story titled “Covid-19 delays mandatory pesticide testing for Washington state recreational cannabis.” Our Tested with Confidence Program™ got some ink as well as our CEO, Nick Mosely and TWC Program Director, Lara Kaminsky. The article recognized that due to the coronavirus, Washington state delayed hearings on the implementation of state mandated pesticide testing.

With no state requirements attributable to pesticides and contaminants, Confidence recognized a couple years ago certain clients were interested in testing that went beyond state requirements. Without the ability to attach an “organic” label to products (a federal term that cannot be used in the cannabis world), brands wanted some consumer indicator that their product was – well, “cleaner” than required. And with clients, like SubX, wanting to be recognized for their efforts in exceeding state requirements for quality assurance testing, the Tested with Confidence Program™ was born. The Program provides a platform for brands to receive a labeling mark and media recognition indicating their products meet or exceed state requirements for pesticides and contaminants.

Read the full story here.

If you want to learn more about pesticide testing visit our FAQ.

Read the full article here: https://www.geekwire.com/2019/cannabis-testing-lab-confidence-analytics-raising-cash-expand-california/

What is Vitamin E Acetate?​

Vitamin E (also known as tocopherol) is a naturally occurring vitamin, essential to a healthy human diet and commonly found in food and supplements. Vitamin E is a fat-soluble antioxidant, which protects cell membranes and promotes a healthy nervous system.[1]

Vitamin E is available over the counter at most pharmacies. Most often, it is sold as Vitamin E Acetate, and in this form it can penetrate the skin. Topical application of Vitamin E Acetate may be beneficial for wound healing and protective against ultraviolet radiation, though there is no scientific consensus for this.[2][3]

Why would Vitamin E Acetate be in a vapor product?​

Vitamin E Acetate is commonly added to food ingredients as a preservative. The antioxidant properties of Vitamin E Acetate make it useful for reducing the oxidative degradation or “browning” of foods, especially oils. Cannabis oil distillates, in particular, are susceptible to oxidative degradation, causing the oil to change color from clear or light yellow to rose or deep red. Adding Vitamin E Acetate to a cannabis oil distillate may preserve its color.

Vitamin E Acetate blends (or “mixes”) more readily with cannabis oil than do more “traditional” vaping ingredients typically found in nicotine e-juice, such as propylene glycol and vegetable glycerine. Vitamin E Acetate may be used to thin a cannabis oil or thicken a terpene extract.

Is Vitamin E Acetate harmful?​

The National Academy of Medicine recommends adults consume 15 mg of Vitamin E per day.[4] Regular consumption of Vitamin E at the recommended level has been associated with a decrease in risk for Alzheimer’s disease, cancer, and a variety of cardiovascular and neurodegenerative diseases.[6][7]

Food. The US Food and Nutrition Board and the European Food Safety Authority both consider Vitamin E tolerable when consumed orally at amounts of less than 300 milligrams per day.[4][5] Consuming Vitamin E in higher amounts has been linked to excessive bleeding, drug interactions, and an increase in all-cause mortality.[2][8][9]

Skin. Topical application of Vitamin E is very common despite no scientific consensus of health benefits. In rare cases, topical application of Vitamin E has been associated with contact dermatitis, an allergy of the skin.[10]

Lungs. Vaporizing Vitamin E into the lungs is a relatively new behavior among Americans, and the risks associated with it are currently under intense scrutiny. In 2019, there has been a surge of vaping-related illnesses and deaths reported across the United States [11]. While the cause(s) of the illness(es) remains unknown, the Centers for Disease Control and Prevention (CDC) in cooperation with the Food and Drug Administration (FDA) are actively investigating, as are state agencies [12]. The FDA has announced they suspect Vitamin E Acetate may be the cause of vaping-related deaths. The CDC is urging Americans to only purchase vape products from trusted sources, and to consider cessation of vaping altogether.

How do I know which vapor products are free of Vitamin E Acetate?​

When in doubt, don’t purchase or consume a product you don’t trust. Only purchase from licensed retail. Review products online to verify their authenticity. Ask you budtender for advice. Most vaping-related illnesses have been associated with illegal cannabis products [11]. Trust but verify, ask for proof that your product is free of contaminants.

Confidence Analytics offers Vitamin E Acetate testing of vapor products.

Which brands can I trust?​

The voluntary “TESTED WITH CONFIDENCE” program is a listing of brands committed to transparent and holistic product manufacturing practices, going above and beyond state requirements for quality assurance. The current protocol under the TESTED WITH CONFIDENCE program has included terpene and pesticide testing of all finished products, to ensure purity. In keeping with this philosophy, the program is currently developing a strategy to screen products for Vitamin E Acetate. Look for the logo when identifying trustworthy brands.

TESTED WITH CONFIDENCE affiliation is not a guarantee or endorsement that a product is free from Vitamin E Acetate. Nor has it been confirmed that Vitamin E Acetate is the culprit in these vaping-related illnesses and deaths. TESTED WITH CONFIDENCE is a brand pledge from cultivators and manufacturers in their commitment to quality assurance.

I think I may have an illness related to vaping, what should I do?​

Doctors say anyone vaping who develops respiratory distress, including coughing, difficulty breathing and chest pain, should consult a clinician immediately.

Read More:​

Heylo Extracts Blog – How To Protect Yourself with Cannabis Vapes.

Leafly Health – Vape Pen Lung Disease Has Insiders Eyeing Misuse of New Additives.

ABC News – New York issuing subpoenas to 3 companies amid vaping crisis.

Images courtesy of @that_vazquez_again and @torihydrocannabinol

References:​

[1] “Vitamin E”. Office of Dietary Supplements, US National Institutes of Health. 12 July 2019. [2] Beijersbergen van Henegouwen G, Junginger H, de Vries H (1995). “Hydrolysis of RRR-alpha-tocopheryl acetate (vitamin E acetate) in the skin and its UV protecting activity (an in vivo study with the rat)”. J Photochem Photobiol B. [3] Panin G, Strumia R, Ursini F (2004). “Topical alpha-tocopherol acetate in the bulk phase: eight years of experience in skin treatment”. Ann. N. Y. Acad. Sci. 1031: 443–447 [4] Institute of Medicine (2000). “Vitamin E”. Dietary Reference Intakes for Vitamin C, Vitamin E, Selenium, and Carotenoids. Washington, DC: The National Academies Press. pp. 186–283. [5] Tolerable Upper Intake Levels For Vitamins And Minerals (PDF), European Food Safety Authority, 2006 [6] Li FJ, Shen L, Ji HF (2012). “Dietary intakes of vitamin E, vitamin C, and β-carotene and risk of Alzheimer’s disease: a meta-analysis”. Journal of Alzheimer’s Disease. 31 (2): 253–8 [7] Kirmizis D, Chatzidimitriou D (2009). “Antiatherogenic effects of vitamin E: the search for the Holy Grail”. Vascular Health and Risk Management. 5: 767–74. [8] Podszun M, Frank J (December 2014). “Vitamin E-drug interactions: molecular basis and clinical relevance”. Nutrition Research Reviews. 27 (2): 215–31. [9] Miller ER, Pastor-Barriuso R, Dalal D, Riemersma RA, Appel LJ, Guallar E (January 2005). “Meta-analysis: high-dosage vitamin E supplementation may increase all-cause mortality”. Annals of Internal Medicine. 142 (1): 37–46. [10] Kosari P, Alikhan A, Sockolov M, Feldman SR (2010). “Vitamin E and allergic contact dermatitis”. Dermatitis. 21 (3): 148–53. [11] https://www.nejm.org/doi/full/10.1056/NEJMoa1911614 [12] https://abc7ny.com/health/new-york-issuing-subpoenas-to-3-companies-amid-vaping-crisisw/5525981/