Consumer Safety: Farm to Sale Compliance in CBD

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American consumers are rising out of the cannabis disinformation haze to the fact CBD manufacturing is more of an effort of artisanship than crude mass-production. In this brief article we’ll explore the basics of what you need to know about hemp-CBD sourcing. 

Introduction

Hemp for Fitness is a consumer-direct seller of high quality full spectrum and isolate CBD products and an experienced manufacturer, wholesaler, or white label supplier of cannabinoids. Thanks to the growth of their business platform since 2014 (especially throughout 2019 after the signing of the 2018 Farm Bill), some recent developments include:

  • The manufacture of 70 kilos of CBG distillate on a monthly basis derived from regulated indoor Wisconsin and Colorado hemp. 
  • In their home state of Illinois, they’re processing CBN from CBD. Outside the lab, this actually happens in the cannabis plant naturally as well where CBD is the precursor of CBN and a THC metabolite.
  • In Oregon they’re working with farmers to process CBN from THC in small 3-to-5 kilo batches. Did you know CBNa (the acidic form of CBN) is produced by breaking down THCa? This is why high-THC cannabis flowers test higher in CBN as they age. 

Setting aside the cannabis chemistry lesson, it’s crucial consumers and smaller businesses understand CBD isolate and hemp extract supply chain models as our marketplace, national farming/processing situation, and regulatory environments evolve.

Supply chains mean everything in post-2018 Farm Bill America when it comes to hemp. They determine not only success levels of any hemp business model, but the brands involved in implementation. Imagine what could happen to a brand if it’s discovered – goes viral – their CBD products don’t contain the right or labeled levels of cannabinoids, contain toxins or too much THC…disastrous!

As we head into the 2020-2025 epoch of American hemp, button down your supply chain folks.

Let’s investigate core components to lend a hand:

Hemp Sourcing Methods

Where does your manufacturer get their hemp from? How many degrees of separation exist between them and the farmers they’re working with? For most, answers to these questions are likely to be a bit on the complicated side whether it’s national, international, or a mixture. 

Tapping the Open Market

As this article’s being assembled in September 2019, the American hemp farming community is growing by astounding numbers (over 500,000 acres planted in 34 states according to Vote Hemp’s recent 2019 U.S. Hemp Grower License Report). Hundreds of thousands being planted east & west, along with thousands of farming licenses flying into the hands of ambitious farmers and small businesses.

A good percentage are growing for cannabinoids, with fiber and grain crop licenses swelling exuberantly in their wake.

Many CBD manufacturers are going to lack rock hard supply contracts with farmers at this point.

Vote Hemp sees this is a fabulous sign of years to come, but overall acres harvested and processed is likely to be substantially less until state-by-state systems and infrastructure are established:

“Vote Hemp estimates that 230,000 acres of hemp will actually be planted and 50-60% of that will be harvested due to crop failure, non-compliant crops [re: testing higher than 0.3% THC] and other factors resulting in 115,000-138,000 acres of harvested hemp.”

There simply isn’t enough domestic hemp to go around yet, but there will be sooner rather than later. Until then many manufacturers are turning to open market spot purchasing to get what they can, from who they can, as they can – laying strain on their abilities to properly screen cannabinoid suppliers.

  • Yes, there’s still a lot of synthetic lab-created cannabinoids being fraudulently or deceptively sold as whole plant-based or broad full spectrum extracts.
  • Yes, there’s even a black market for cannabinoids outside hemp and recreational markets which can be dangerous. 
  • Yes, there’s a ton of mislabeling going on in both hemp as well as high-THC recreational products sold in state dispensaries.
  • Yes, internationally-sourced hemp biomass is far riskier because of an increased inability to vet and verify. This is forcing manufacturers to purchase highly-processed isolates or plant extracts they can test themselves once inside the U.S. 

When we’re looking at international sources, and even to a degree those claiming to be based in the U.S., paperwork can be easily doctored!

Aim for manufacturers and processors like Hemp for Fitness who maintain direct contact with specific farms, visit them regularly, and can prove it with legal paperwork.

Even then, whenever possible, it’s imperative to perform your own testing to validate COAs.

Aggregating Hemp from Multiple Farming Operations

Ideally for consistency, manufacturers and processors of ‘low to no’ THC cannabinoid-based consumer products should strive to work with a small number of farms (more on this momentarily) who grow essentially the same cultivars of low-THC/high-CBD cannabis – now legally defined as hemp. In practice this also minimizes logistical demands of trying to keep track of multiple farming methods, testing, involved parties, etc.

As Mick Warncke, Business Development Manager for Treehouse Biotech, recently put it in an enlightening email I received,

“A typical sourcing strategy of hemp processors is to create a network of many farms to save on costs through toll processing and to increase leverage for price negotiations. One risk of an aggregation strategy is a lackluster audit program. With such a wide reach, the producer needs to have an equally comprehensive vetting program of its many hemp sources”

The idea here is to create a supply chain where each product can be traced back to the originating farm with documentation for every batch – hence, from Farm to Sale. As the number of farms in a pipeline increases, so does the complexity of compliance and risk.

However, again, the most pressing concern here is product consistency. Cannabis, both recreational and industrial hemp-for-CBD, can come in a mindblowing number of strains. Each can vary widely from the next in terms of chemical profile. Meaning you could test 10-20 different batches from 10-20 different farms (who themselves may not be growing a consistent cultivar yet) and get 10-20 COA results showing different concentrations of terpenes and cannabinoids.

All this variance doesn’t bode well for consistent consumer experiences or aggregators trying to track everything. Here again we see more pressure on brands to get isolates rather than full spectrum extracts. 

Direct Supply Relationships

On one side of the spectrum, say to the left, you have smaller vertically-integrated state regulated farming operations producing and manufacturing their own plants into various CBD products, testing (along with 3rd party via the state), then offering them via a website and a presence in more localized retail outlets.

On the far right of our spectrum you’ve got these huge Wall Street-funded cannabis corporations turning to international sources and pumping out highly-processed CBD extracts which are further processed once in-state and then put into everything from fast food to soft drinks.

Around the middle you’ll have a growing number of brands like Hemp for Fitness that conservatively work with a small number of farms under direct supply contracts for larger ecommerce + retail supply. Small vertically-integrated farms can only offer so much at one time, and hemp crops or percentages of crops can go bust for a large number of reasons. For Hemp for Fitness and their ilk, while prices can be higher than brands on the right of the spectrum offer, they’re going to be of better quality (re: effectiveness!), safer, and more secure.

Airtight supply contracts are on par with vertical integration when done right.

  • More supply protection for manufacturers.
  • Increased chances of consistency over time. 
  • Easier verification and transparency. 

For isolates, technically, sourcing is less of a concern because the technology to extract single cannabinoids or separate and isolate them from complex plant extracts exists. It’s more of an issue when talking about full or broad-spectrum and whole-plant (or those claiming to be) products.

This next section should help paint a clearer picture. 

Testing & Processing Verification Methods

Due to the nature of producing cannabinoid isolates and extracts for use in consumer products, there’s compounding pressure to test everything – especially raw material or biomass. Primary focus is on:

  • Detectable cannabinoid levels and/or potency.
  • THC levels of course to differentiate between recreational and hemp-cannabis.  
  • Potentially dangerous pesticides, residual solvents, microbials, heavy metals and foreign matter. 

Beyond testing though, most consumers haven’t the slightest clue what kind of equipment, specialty knowledge, experience and resources are needed for production. To give you an idea, here’s a picture showing part of a lab associated with testing/processing Hemp for Fitness isolates like CBN, CBD, and CBG:

Then there are similar operations more focused on full spectrum cannabinoid oils or extracts at various potencies and formulations.

Please understand, that’s only part of this particular lab which could fit into the image. I won’t bother slapping you across the face with all the highly-technical names of what you see there and what all of it does. Many smaller farmers cannot afford this stuff! They simply don’t have the funding and expertise. When looking at massive corporate operations, the ‘labs’ or processing areas can be as big as a warehouse.

So, with all this being said, supply chains begin on the farm and from there jump right into serious commercial-level chemistry and nutraceutical production. If a farm is claiming to produce their own extracts, great, but what kind of equipment are they using and what kind of output can they handle?

There will always be a small market for these operations moving forward. For consumers after a bit more umph, providers like Hemp for Fitness are going to dominate the market’s middle ground due to consistency, quality, and price points. 

Bring on the Paperwork!

  • Industrial Hemp Farm Registration from the respective state’s Department of Agriculture.
  • State-level potency testing of the hemp crop, if completed. From there the resulting biomass which can differ from spot crop tests relative to farming and initial processing methods. 
  • 3rd party potency, pesticide, and heavy metal COAs of the raw material lot associated with products, as well as the extract or isolate batches. 

In closing, as an example, Hemp for Fitness is a conservative supplier who works directly with a small number of farms in multiple states who all possess required licensing. Testing happens in field, then on the raw biomass as well as isolates/extracts batch testing. To our left on the spectrum, you’ll have a growing number of vertically-integrated farmers with their own small-to-extensive labs and on/off-site processing and testing centers. To our right, larger and larger corporate supply chains focused more on gargantuan quantities of aggregate-sources.

Hope this helps both consumers and interested brands to get a better grasp of farm to sale compliance and supply chain issues. If you have anything helpful to add that would empower other readers, feel free to comment and we’ll gladly publish your thoughts.