A COA, or Certificate of Analysis, outlines any potential contaminants, including heavy metals and pesticides. More importantly, the COA lists the cannabinoid content of the seed’s parent. These details require special consideration as they help project the likelihood of hemp crop compliance.
How to Read a Certificate of Analysis
A COA will include the test type, test method, test ID, and the date of the testing was complete. This information is crucial as it relates directly to the product that is purchased and transferred; if an inspection occurs, this info is a must-have.
Depending on the type of test, a COA should also include total cannabinoid content. The list will likely include cannabinoids like THC and CBD, as well as CBN, CBC, and variations thereof. It’s important to note that THC comes in many forms – Delta 9-THC, THCa (it’s metabolic precursor), Delta-8 THC, and THCv. According to the Marijuana Marketing Act, the only distinguishing factor between hemp and “marijuana” is delta-9 THC – not delta-8, not THCv, and not THCa. However, because THCa may transform into THC during the decarboxylation process, it does contribute to a plant’s total potential THC levels. Hence, a COA may display “total THC” and “total potential THC” separately. The basic formula to calculate total potential THC is as follows:
(THCa x .877) + (THC) = Total Potential THC
This formula raises controversy, though, specifically because “total potential THC” is not included in the definition of hemp. In fact, the USDA’s most recent hemp farming rules seem to overlook many specifications regarding what actually constitutes hemp.
Understanding Hemp Crop Compliance
The hemp/marijuana distinction comes from a 1979 article by Canadian horticulturalists, Ernest Small, and his co-author, Arthur Cronquist. The article, titled “A Practical and Natural Taxonomy of Cannabis,” defined hemp as any part of the cannabis plant containing less than .3 percent delta-9 THC on a dry weight basis. According to the article, “young, vigorous leaves of relatively mature plants” are to be tested for total THC, not the flowers which are notorious for their cannabinoid production.
If we are to maintain our long-standing definition of hemp, it stands to reason that we should test large fan leaves for THC, not the flowers. At the very least, both leaves and flowers should be tested for THC to determine total potential THC. Surely this would deliver a better depiction of the whole plant’s cannabinoid content. As it stands, though, testing only the top few inches of the flower will result in higher-than-average cannabinoid levels comparatively.
However, thanks to incredible scientific advances, we now understand that the difference between hemp and marijuana is much more precise than merely determining whether or not cannabis flowers contain substantial levels of THC. Rather, hemp is a form of cannabis that is genetically modified through selective breeding to produce only trace amounts of THC. Specifically, genes that produce THC are “turned off,” while those that produce CBD are “turned on.” If both THC and CBD genes are deactivated, the resulting plant will only produce CBG, a precursor to both THC and CBD. In other cases, all cannabinoid-producing genes are deactivated to produce cannabinoid-free cannabis. All three cannabis mutations produce hemp plants, though some types are more popular than others. Though Type III (CBD hemp) is currently the most popular hemp plant to cultivate in America, Tyle IV (CBG hemp), is quickly growing in popularity.
However, remember that seeds always produce variations of their parents. Minor variations to a plant’s genetic sequence could result in THC production, as can stressful environments. Hence, seeds from strong genetic lines are paramount to hemp farming success. In addition to seed variety, farmers must also consider things like cannabinoid ratios, sample timing, and the reputation of the hemp seed bank.
Timing is Everything
Since the passing of the 1024 Farm Bill, states have regulated their own hemp testing protocol. The USDA only recently suggested testing a minimum of 15 days before harvest. However, states with their own approved plans may test according to their own rules, which may take place during very different timeframes. This discrepancy has caused a lot of confusion regarding hemp compliance nationwide. Whereas hemp may be perfectly compliant in one state, it might not be compliant in another.
Let’s take, for example, Oregon and Kentucky. Both states operate according to their own hemp pilot programs and, therefore, their own unique testing protocol. Whereas Oregon farmers can test hemp crops as early as 28 days before even beginning harvest, Kentucky farmers must test hemp crops no more than 15 days after harvest is complete.
There is obviously significant variation in these test procedures, which will result in very different cannabinoid levels. Even if the exact strain is grown in the exact same manner, if grown in different states, the rest results will also be different. That’s because cannabinoid development begins as soon as flowers begin to form. Because Oregon farmers can test crops early in the cannabinoid development process, their hemp plants are more likely to be compliant compared to Kentucky farmers who must wait to test until buds have nearly ripened.
COAs and Final Cannabinoid Content
Other factors that may affect a hemp strain’s total cannabinoid content include which parts of the plant are tested and by whom. For example, testing the top two inches of a cola (as the USDA suggests) will net much higher cannabinoid content compared to those who test the top eight to 12 inches. These specifications also vary by location. It’s essential to understand the testing specifications of COAs as they relate to their respective states as well as the state in which cannabis seeds will grow.
But perhaps the most significant factor in determining a hemp plant’s final cannabinoid content is the lab that tests it. An Oregon-based CBD company conducted a “lab-off” in which they submitted samples from the same crop to eight different test teams. Their results showed a significant discrepancy between labs, with one going so far as comingling hemp and marijuana strains, thus resulting in a non-compliant hemp lab test.
The Importance of Accurate COAs
A COA is a necessary document to maintain compliance. COAs displayed on websites serve as excellent examples but may not match the specific batch that is purchased. At Fortuna Hemp, all of our seed sales include a recent Certificate of Analysis that is specific to the particular seed batch. Though we do display sample COAs to help customers become accustomed to the layout and learn to read a COA accurately, an accurate COA is not released until after purchase. We believe this is the best way to ensure our customers know exactly what they are getting and to help them plan their next hemp crop as smoothly as possible.
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