Variables believed to be con-founders for this study encompassed population level and individual level variables that may affect the exposure and the outcome.These variables included state’s cannabis regulatory status, state’s COVID-19 infection prevalence, state’s percent urbanicity, age, sex, and education.State’s cannabis regulatory status is hypothesized as a con-founder as state’s legalization may be associated with state’s general policy.Second, it may be indirectly associated with sharing of cannabis through access to cannabis and cannabis use/prevalence in a state.State’s cannabis regulatory status was categorized as fully regulated for adult use, regulated for medical use only, and unregulated.State’s COVID-19 infection prevalence is hypothesized as a con-founder as infection prevalence may directly affect policies put in place and may effect sharing of cannabis given individuals risk perception toward or experience with COVID-19.COVID-19 infection prevalence was drawn from May 24, 2020, as this proceeds the dates used for state’s COVID-19 policy and the outcome thus minimizing issues of temporality.State’s COVID-19 infection prevalence was calculated per 100,000 persons given the population size of that state and was kept continuous.State’s percent urbanicity was hypothesized as a con-founder as density may directly affect state’s COVID-19 policy put in place and may affect sharing through opportunities to share.State’s percent urbanicity was drawn from the 2010 US Census and was kept continuous.Finally, individual respondent’s age, sex, and education may directly affect their sharing patterns and may be associated with COVID-19 state policy as a proxy for age, sex, and education distributions of the state.Age was recentered at the mean age and rescaled per 10-year increases.Education was dichotomized as high school or less or some college.Figure 4.1 graphically demonstrates these relationships in a directed acyclic graph.Overall, individuals living in states with more stringent policies in response to COVID- 19 were less likely to share prepared sub irrigation cannabis and cannabis-related paraphernalia compared to those in states with less stringent COVID-19 state policies even after controlling for potential confounding.
These findings were consistent for varying policies in June, July, and August 2020.Specifically, there were protective odds for sharing of cannabis per every 5-unit increase in policy score across these three specified time periods.Previous studies have looked at COVID- 19 state policies, masking, and stay-at-home orders on population movement and COVID-19 infection rates in the population.However, there are limited studies evaluating COVID- 19 state policies on individual level behaviors.Findings from this study and previous studies showed similar results of stringent policy on reduction of COVID-19 infections and promotion of risk mitigating behaviors for COVID-19.Sharing of smoking paraphernalia for cannabis, tobacco, and crack cocaine have been shown to be risk factors for respiratory infections.Thus, any strategies to reduce or limit sharing, especially during a pandemic of a respiratory illness such as COVID-19, are important to identify.This study demonstrates that COVID-19 state policies were associated such individual sharing practices even though policy and messaging may not have been directed toward this.Second, this study highlights the need for strong, consistent, and uniformed policy and public health measures for actions across the US for COVID-19 and other transmissible diseases risk mitigation strategies.As the strength of policies increased, individuals were less likely to share prepared cannabis and cannabis-related paraphernalia with others.Further, this study expands on the literature for semi-individual study designs to estimate the association that population level exposures have on an individual level outcome.There have been limited studies that have used this study design, such as motorcycle helmet law studies and air pollution studies.However, such a design provides a useful approach that is underutilized in epidemiology literature.Finally, this study applied a standardized method for coding of COVID-19 state policy.There is a large amount of heterogeneity in how COVID-19 state policy has been coded and utilized in studies, which may limit inferences drawn between studies.Using Lane et al.’s suggested approach for coding allows for more uniform analyses of COVID-19 state policy moving forward.There are several limitations in this study.First, the data comes from a non-representative convenience sample of those reporting cannabis/CBD use and may not be generalizable to all those reporting cannabis/CBD use in the US population.
Second, we used sharing of prepared cannabis and cannabis-related paraphernalia as a proxy for individual COVID-19 mitigation strategies and cannot make any conclusions about compliance with state COVID-19 policies such as masking.Third, there may be violations of independence in our exposure as one US state’s policies may influence that of another state with similar political agency.Fourth, there may be measurement error of our outcome.The time frames requested by the survey, sharing in past three months, may lead to recall in reporting.Social desirability bias may also be present given the nature of sensitive questions asked of our sample.However, the survey was anonymous which may limit this bias.Fifth, there may be differences in policy actions within states that is not captured here.Finally, we only looked at one time period early on during the COVID-19 pandemic and may not make conclusions on lasting differences in sharing of cannabis by COVID-19 state policy.Additionally, there are limitations to a semi-individual study design such as sufficient control of confounding, measurement error, proxy control of exposure, and model specification as seen in other individual based epidemiological studies.Since California’s Compassionate Use Act of 1996, cannabis has been legally available — under state but not federal law — to those with medical permission.Until 2018, however, no statewide regulations governed the production, manufacturing and sale of cannabis.Prior to development and enforcement of statewide regulations, there were no testing requirements for chemicals used during cannabis cultivation and processing, including pesticides, fertilizers or solvents.Residues were common in the legal cannabis supply — a 2017 investigation found that 93% of 44 samples collected from 15 cannabis retailers in California contained pesticide residues.Some studies of data from the unregulated period suggest a relationship between cannabis consumption and exposure to heavy metals , while others demonstrate that potentially harmful microorganisms may colonize cannabis flowers.A 2017 study raised concerns that in immuno compromised patients, use of cannabis contaminated with pathogens may directly affect the respiratory system, especially when cannabis products are inhaled.The currently prevailing statutes governing cannabis testing are contained in Senate Bill 94, the Medicinal and Adult-Use Cannabis Regulation and Safety Act of 2017 — which brought together all of California’s previous cannabis legislation, including Proposition 64, the Adult Use of Marijuana Act of 2016.Since MAUCRSA, state agencies have propagated regulations for both medical use and adult use.MAUCRSA amends various sections of the California Business and Professions Code, Health and Safety Code, Food and Agricultural Code, Revenue and Taxation Code and Water Code, and introduces a new statewide structure for the governance of the cannabis industry — as well as a system by which the state may collect licensing and enforcement fees and penalties from cannabis businesses.
These rules, however, may increase the production cost and therefore the retail price of tested cannabis, thereby reducing demand for legal cannabis in California.Thus it is important to understand the costs of cannabis testing relative to the value of generating a safer product.This article evaluates the challenges of safety testing regulations for cannabis in California.We first review maximum allowable tolerance levels — that is, the amount of contaminants permitted in a sample — under the state’s cannabis testing regulations and compare them with tolerance levels for other food and agricultural products in produced in California.We then briefly compare testing regimes and rejection rates in other states where medical and recreational use is permitted.Finally, we use primary data from California’s major cannabis testing laboratories and from several cannabis testing equipment manufacturers, as well as a variety of expert opinions, to estimate the cost per pound of testing under the state’s framework for the cannabis business.We conclude by discussing implications of this research and potential regulatory changes.Since July 1, 2018, all cannabis products have been required to pass several tests before they can be sold legally in California.The specific test for each batch of cannabis depends on product type.Types include dried flowers , edibles , vape-pen cartridges containing cannabis oil and a wide variety of other processed cannabis goods, including tinctures, topicals and cannabis in crystallized, wax or solid hashish form.In order to enter the market legally,vertical grow all these products must be tested for cannabinoids and a large variety of contaminants.Table 1 shows the substances measured in each test , provides a description of each test and specifies the products to which the test applies and the criteria for passing the test.Most tests, such as those for potency, presence of foreign materials, pesticides, heavy metals, mycotoxins, microbial impurities and terpenoids, apply to all batches.Moisture tests, however, apply only to flowers and solid or semi-solid products — while tests for solvents or processing chemicals apply only to processed or “manufactured” products.That is, the specifics of each test depend on which cannabis product is tested.Independent, licensed testing laboratories are responsible for receiving samples for testing from licensed distributors.The laboratories then conduct a full set of analyses, following the criteria established by MAUCRSA and specified by regulations.Laboratories must deliver to distributors a certificate of analysis indicating the results of each analytical test.A batch must pass all required tests before it can be released to retailers.Table 2 shows a list of residual solvents and processing chemicals, with the maximum permitted tolerance levels for legal cannabis.Tests evaluate two groups of solvents and processing chemicals , with a very low tolerance established for those in category I.Table 3 shows tolerance levels for pesticide residues and heavy metals.The maximum permitted tolerance levels for pesticide residues are particularly tight when compared with tolerance levels for other agricultural products in California.For many pesticides, the maximum residual level is zero, meaning that very stringent tests are required and that no trace of the chemical may be found.
Among pesticides with allowable limits above zero, the tolerance levels for inhalable products are particularly low.In some cases, tolerance levels for inhalable products are one-four-hundredth the levels for other products.To help interpret the cannabis tolerances, it is helpful to consider them in the context of food safety testing.The top row of table 4 shows, based on more than 7,000 samples, the percentage of California food products in which, from 2015 to 2017, any pesticide residues were detected.These percentages were above 60%.The second row of table 4 shows that, despite the high share of food products in which some pesticide residue was detectable, only 1.51% of samples in 2016 contained pesticide residue above tolerance levels set by the U.S.Environmental Protection Agency — and only 0.45% exceeded those levels in 2017.The bottom panels of table 4 show that, of the 7,000 samples tested, more than 12% of 2017 samples would have been above California’s product tolerance limits for inhalable cannabis.More than 3% of the 2017 samples would have exceeded even the less stringent tolerance levels established for other cannabis products.As shown in table 4, similar results apply to the samples for the other two years.In California’s licensed, legal cannabis channel, all products must be held by a licensed distributor while they are tested in an independent, licensed laboratory.Licensed testing laboratories do not publish their prices and the costs of testing services are not generally available.Testing prices depend on the number of samples to be tested, the type of product tested and the specifics of the contract between the distributor and the laboratory, among other factors.We collected detailed data to construct in-depth estimates of the capital, fixed and variable costs required to run a licensed testing laboratory in California.This information included the costs of equipment, facilities, maintenance, supplies, technical and non-technical labor, taxes and other inputs.We gathered data from established cannabis testing companies , new cannabis testing companies, laboratories that test other agricultural products, and other industry sources, including advisors of the cannabis industry and cannabis retailers.We collected prices for testing equipment, supplies, chemical reagents and other cannabis testing inputs by contacting the sales representatives of large equipment supply companies.We considered the costs of sampling and transportation to and from test facilities, adjusting those costs estimates according to the geographical configuration of testing laboratories and distributors across the state.Finally, we used data from the California Department of Pesticide Regulation and some assumptions based on experience in other states to estimate the share of cannabis that fails testing and therefore the lost inventory due to failed tests.