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Since the 2019 Vape Crisis, the cannabis industry has eagerly anticipated new standards and regulations regarding the production of vape cartridges and devices. The first to enforce new rules, the Colorado Marijuana Enforcement Division (MED) announced new regulations for the production and sales of cannabis oils.

As of January 1, 2022, “each harvest batch and production batch of regulated marijuana concentrate in a vaporized delivery device must be tested for metals contamination via emissions testing” by an accredited laboratory, according to the statement of adoption released last year (CCR 212-3).

Why Cannabis Emissions Testing is Crucial

Heavy metals contamination in vape devices and cannabis and hemp concentrates is not a new discovery. Lead, cadmium, mercury, and arsenic have been routinely discovered in both cannabis and hemp extracts. Heavy metals have a number of entry points into the cultivation and manufacturing processes of cannabis and hemp, including:

• Soil
• Water
• Fertilizers, Nutrients, and Pesticides
• Cultivation Machinery
• Production Processes
• Packaging Equipment
• Delivery Devices (inhalers, vaporizers, transdermal patches, bottles, and containers)

While phytoremediation may play a role in introducing these substances into the oils themselves, certain metals used in manufacturing the devices used to consume them may also be an entry point. Just as BPA from plastics can leach into foods and beverages, some metals used in overseas manufacturing processes for vape cartridges may present dangers to cannabis consumers.

Also similar to plastics and BPA, when heat is applied repeatedly, it can increase the opportunity for contamination. And just as continued exposure to BPA, an endocrine disrupter, can lead to multiple health problems and even cancer – repeated exposure to certain compounds created by extreme temperatures and cannabis are concerning.

Without emissions testing, consumers likely have no idea what they are inhaling.

Heat is Catalyst for Chemical Reaction

The science of vaporization is relatively simple. If we boil water, it turns liquid into a gas or steam. But heating oil doesn’t actually produce a gas. Rather, the process of heating oil breaks larger particles into smaller ones, creating an aerosol of microscopic droplets of oil. And, these droplets of oil may have undergone chemical changes from the original product due to the heat applied during the process.

Vape devices use heat to vaporize cannabis oils at extremely high temperatures, which can cause chemical reactions in some substances. For example, research has shown that certain terpenes will convert to benzene when heated at high temperatures, a well-known carcinogen.

In other words, what goes into the device at room temperature, may not be what comes out of the device after it’s been heated. Additionally, there is very little knowledge of the shelf life of vape cartridges or how the product may deteriorate or leach certain metals over time. Emissions testing and expiration date requirements should help shed some light on the matter.

Fortunately, the cannabis industry doesn’t have to start from scratch to set the standards. The nicotine e-cigarette market already has a set of regulations and standards for testing volatile organic compounds—additionally, the WHO set standards to define Threshold of Toxicological Concern (TTC) for chemical exposure.

The same methods and processing for testing nicotine-based devices can easily be adapted for the cannabis industry. As such, manufacturers can expect emissions standards for heavy metals, carbonyl compounds, volatile organic compounds (VOCs), and others.

Today Colorado, Tomorrow the Nation

In the legal market, consumer safety is priority number one. Although Colorado is the first state to enforce emissions testing, cannabis and hemp producers nationwide can expect the trend to spread. Cannabis producers in all legal states should anticipate similar regulations in the near future.

In addition to the plant-touching companies, ancillary cannabis businesses such as vape device manufacturers, equipment manufacturers, and packaging producers need to take note of the materials used in their production processes as well. As testing requirements increase, we can only assume we’ll discover other entry points for potential contamination.