Seeking a Better Understanding Regarding Cannabis Production

Survey Helps UC  Understand Cannabis Production Challenges in State

By Patrick Cavanaugh, Editor

Results from a UC Cooperative Extension survey of registered and unregistered marijuana (cannabis) growers in California will help researchers, policy makers and the public better understand growing practices since cannabis sales, possession and cultivation first became legal for recreational use.

“This survey is a starting point from which UC scientists could build research and extension programs, if possible in the future,” said lead author Houston Wilson, UCCE specialist with UC Riverside. A report on the survey results was published in the July-December 2019 issue of California Agriculture journal, the research publication of UC Agriculture and Natural Resources.

Houston Wilson, UC Riverside Entomologist

The idea of the online survey, during the summer of 2018, was to characterize broadly the production practices that were being employed,” said Wilson

Wilson noted that since he is an entomologist, there were certainly questions about pest management, so the survey was more broad. “It included questions about style of production, plant density, harvest frequency, water use, diseases, and even labor and licensing,” Wilson said.

The survey was conducted by a collaborative group of scientists. Project co-authors were UC Berkeley visiting scholar Hekia Bodwitch, Nature Conservancy senior scientist Jennifer Carah, UCCE biocontrol specialist Kent Daane, UCCE natural resources specialist Christy Getz, UCCE climate and water specialist Theodore Grantham and UCCE land use science specialist Van Butsic. Daane, Getz, Grantham and Van Butsic are affiliated with UC Berkeley.

The survey went to numerous growers via large grower organizations that are present in California. There were more than 100 respondents, and the researchers were able to use that data to characterize some of the production practices.

“As an entomologist, I was interested in the pest management aspects, and we got a kind of array of different insects that growers are dealing with and how they’re dealing with it,” said Wilson.

UC is Restricted To Help Cannabis Growers

The big limitation that’s on the university right now is it’s ability to actually physically visit farms, and talk to growers, and collect insects and sample plant materials. It’s not legal for research institution because of the federal support that the university receives. “So a remote online survey, was the best approach that we found to do this, at least at this stage,” said Wilson.

We’ve shown the data to the grower groups that we’re in contact with, and for the most part they’ve agreed that that it matches what they’re seeing. “We don’t think it’s a really skewed dataset, but we certainly need more detail in each of those areas of emphasis,” said Wilson. “What I’d like to do now is figure out a way to actually collect insects from some of these cannabis operations to confirm or deny the pest species that were indicated by the survey.”

One way to do that is find some opportunities with grower collaborators to have them collect the insects themselves and then bring that back to researchers. “We’re allowed to handle the insects, but we certainly can’t have any plant material on campus right now,” Wilson said.

“Like any cropping system you’re going to have insect problems. Generally speaking, cannabis production takes place indoor and outdoor, and those are in and of themselves going to have different pest complexes and different management options available to them,” noted Wilson. “But again, this similarly applies to other crops that are grown in or outdoors. So there’s kind of gray literature or white literature, whatever you want to call it, about cannabis production and pest management in particular.”

There is cannabis production information in books and online forums that have been published by non-university personnel. “There’s some good information, and there’s a lot of misinformation. However many of these growers have a lot of experience as they they’ve been growing, in some of these areas, for over 40 years,” Wilson said.

Ironically, cannabis is seen as new crop for university researchers, as if it’s a new type of apple. “So in that regard, we’re just trying to characterize how the crop is produced, and find out what are some of the basic agronomic features of it, what are the pest pressures, and how would you manage that,” said Wilson.

“The fact that it’s been this underground production model for so long is that when we come into the situation, and in my interactions with growers to date, I immediately acknowledge that I understand that they have a lot of experience with this crop. And I think these growers have a lot of knowledge about agronomic features, including the entomology aspects of it,” said Wilson.

As for the future UC work in the cannabis world—it’s to be determined.It certainly a secondary if not tertiary objective for me, he said.I work in perennial orchards and vineyard, so cannabis is very much outside what I am focused on, he said.But there was an opportunity to do a survey and so we did it.

The article in the UC California Agriculture journal is comprehensive look at who is doing what in the state right now with cannabis production. “Our production survey was certainly front and center in there as a background piece. And there were other articles that were getting into a specific issue with labor, or licensing, or other areas. Water use is a huge issue, as it is with any crop in California,” said Wilson.

Wilson noted that if cannabis were to become legal at the federal level, you might envision a future where UC creates a position that includes cannabis or is even specifically focused on that in terms of agronomic issues.

Highlights of Survey Findings

  • Growing outdoors in open air with sunlight was the most common practice (41%). Twenty-five percent of growers combined outdoor and greenhouse production. Just 10% said they grow the crop entirely within greenhouses.
  • Total yield per plant varied by growing location. Outdoor crops yielded on average 2.51 pounds per plant (about 40 ounces per plant), greenhouse crops yielded about 10 ounces per plant, while plants grown indoors with artificial light averaged about 3 ounces per plant.
  • The average growing season for outdoor growers was 190 days and they harvested one crop per year.
  • In the fall of 2017, the average cannabis sales price was $853 per pound for flowers and $78 per pound for leaves and other non-flower parts.
  • The respondents reported using no synthetic pesticides in their cultivation of the crop, suggesting reliance on organic pesticides, biologicals and biocontrol.
  • Most growers reported that groundwater was their primary water source for irrigation. Of those, 97% of the water extraction happened from June to October. Many growers said adding water storage was either cost prohibitive or limited by regulatory constraints.
  • Growers reported using more than 30 different soil amendments and foliar nutrient sprays. The most common was organic fertilizer, followed by composts and various animal manures and meals, compost tea and worm castings.
  • Growers are dealing with 14 different insect pests, 13 diseases and nine vertebrate pests, including gophers, mice, rats, deer and wild boars.
  • Powdery mildew was the most commonly reported disease, and mites, thrips and aphids were the most commonly reported insect pests.
  • Growers who hired laborers for harvest paid a per-pound piece rate from $50 to $200. The growers who hired seasonal hourly workers offered a starting pay of $15 to $20 per hour.

George Soares on How DPR Sees Cannabis

Soares: DPR Interpretation of Cannabis is Wrong

By Jessica Theisman, Associate Editor

George Soares, a partner in Kahn, Soares, and Conway, a law firm based in Sacramento, recently spoke about the issues surrounding cannabis. He is managing partner of the firm and represents several agricultural commodity and trade groups in Sacramento.

He spoke at the recent California Associations of Pest Control Advisors (CAPCA) annual meeting in Anaheim. He touched on the fact that the California Department of Pesticide Regulation (DPR) is not thinking of the public in their handling of crop protection materials on cannabis.

“The people of California have decided that cannabis can be consumed by the public,” Soares said. “The question is how to grow the cannabis under the regulation.

Currently, the chemicals and fertilizers used to grow the cannabis are all illegal.

“So far, the solution is that we make it legal by stretching the interpretation of the law,” he explained.

By law, pesticides have to be labeled for use, and eligible crops must be on the label.

“The pesticides being used are being interpreted in ways to make it legal to use on cannabis,” Soares said. “Think about the damage that is doing to the legal structure of what we all adhere to.”

“DPR would never let a pesticide be used off-label, but when it comes to cannabis, it looks like the government is willing to let it slide,” he said.

Cannabis Growers May Be Using Illegal Materials

Illegal Pest Control by Cannabis Growers

By Patrick Cavanaugh Farm News Director

Big problems are arising in the cannabis growing areas of California.

John Fournier runs Acadia Regulatory Consulting in New York State. He on an EPA list of registration consultants. And because his company is high on the alphabetical list, he gets calls from cannabis growers in California who are looking for help in dealing with pests and diseases on their crops. Because cannabis production is federally illegal and the registered crop protection material products fall under federal guidelines, there are essentially few materials that growers can use.

“The biggest pressures for cannabis growers are powdery mildew, fungus gnats, and mites. If a grower had a bad spider mite outbreak, they would want to protect a super valuable investment. The question is, what are they willing to do to protect that investment? And in a situation like that, maybe you’ll go buy a miticide off the shelf somewhere,” Fournier said.

“As long as it’s not restricted use, anyone can buy it and use it on your crop. In that situation, that’s going to be a product that’s not approved for cannabis use on the state approved lists, difficult to control legally. There are also fungus gnats, which are a problem with plants that are overwatered.”

A lot of growing happens underground, and growers will have a soil mixture that is overwatered, which is one of the most common problems in cannabis.

“When the soil is overwatered, algae will start growing in the soil, and fungus gnats will find the crop and start feeding on the algae,” Fournier explained. “And then they’ll start feeding on the fine root hairs of the crop itself so they can actually kill the crop, if the outbreak is bad enough. Fungus gnats can be controlled by either an insecticide to kill the gnats, or you can use a biocide to kill the algae. Again, the materials must be registered for cannabis.”

According to Les Wright, Fresno County Agricultural Commissioner, illegal cannabis farms have been raided and officials have found empty containers of rodenticides, nematicides, insecticides, and miticides, all illegal for use on cannabis. “We always find illegal crop protection materials and many of them had labels in Spanish, most likely from Mexican syndicates.

Again, there are no conventional materials registered.

Now here’s the part where it gets dangerous. According to Fournier, “In states where recreational cannabis has been legalized, I have spoken to people who have said they’ve discovered through some means or another … dangerous levels of pesticide residues on cannabis, where a grower had obviously used hundreds of times more than the labeled rate of an insecticide to save their crop, and obviously this could be dangerous to consumers.”

Cannabis Growers Not Following Regs

Cannabis Growers Must Adhere to Crop Protection Regulations

By Patrick Cavanaugh, Farm News Director

There’s a whole lot of trouble going on for California cannabis growers. They need crop protection products for pests – such as mites, aphids, thrips, and mealybugs – and diseases, including powdery mildew, alternaria and pythium.

Now legally grown in the state, cannabis meets the definition of an agriculture crop and must adhere to all agricultural regulations and best management practices. This includes all Pest Control Advisor-written recommendations. As few products are approved for application on cannabis in the state, as well as nationwide, a PCA can now be cited for recommending a product that has not been officially registered and approved for a use on cannabis, specifically. With legal cannabis production going mainstream in California, PCAs face this risky predicament regularly.

“I discussed this point with Department of Pesticide Regulation (DPR) Director Brian Leahy this past week,” said Rachel Kubiak, DPR Pesticide Programs Division, Cannabis Program Supervisor. “I think we are at a point now where it’s important that we make policy decisions so PCAs know, as stakeholders, what our expectations are. PCAs deserve for us to do that, so we are working internally right now to try to get a lot of answers to these questions.”

Cannabis growers will have to buy products from licensed agricultural dealers.

“I understand, in talking to different folks, that many companies are not comfortable with the liability of attaining DPR registration approval for cannabis application and are therefore advising not to sell product to cannabis growers,” Kubiak said. “I completely understand that.”

“Going forward as a department, the concern, I think, is to bring as many farmers into the legal crop protection market as possible,” Kubiak said. “They are going to go exactly where they have been buying the products from, right? And if PCAs do not sell to them, but the cannabis growers must buy from them, these growers will have to purchase their crop protection products online, from Home Depot, or anyplace else. I can almost guarantee you that 95% or probably more of the cannabis farmers I’ve talked to over the last couple of months have no idea what we are talking about regarding applying registered materials to registered crops.”

“They have no idea that you cannot buy product anyplace and apply it as a pesticide,” she explained. “They do not know how to store it. So we have a lot of work to do in a very short period of time to bring these people into compliance and understanding.”

The scenario is even dicier for California County Agricultural Commissioners. These commissioners are required to enforce regulations on cannabis, as they are for any other commodity.

“We are working with the county ag commissioners to figure out how we need to proceed with and advise on this,” Kubiack said.

“I will tell you, usually as a department,” Kubiak explained, “we are inundated by the environmental justice community. Yet, they have been completely absent to this point on this particular commodity. So it’s almost bizarre and unusual not to be hit continuously from the left. But understandably, again, we’re now getting into these forums in which the Ag community has a voice and an interest,” Kubiak said.

“I’ve heard from both sides,” she continued. “I have heard from different Ag groups and PCAs who have said, ‘You know, we see a need for this—by a whole industry of people,’” she said.

And that whole industry, the cannabis growers of California, is crossing the regulatory line in crop protection. It has been reported that cannabis growers are creating a lot of environmental damage as well as worker safety concerns. Cannabis is grown primarily indoors, and according to Kubiak, “People are using pesticides without any concept of what they’re doing. Normally we would recommend that they talk to a professional, but that puts licensed PCAs in a hard spot because they cannot write a recommendation for a product that is not legally approved for use on that product.”

Kubiak said DPR is trying to bring as many of cannabis growers into the light as possible, “so that we have some regulation. Again, clearly this has been going on for a really long time, but at least now we are trying to go into areas in which we have some regulation but where people are not necessarily informed. So we bring crop protection management more into the light than ever before,” she said.

Is the DPR at a big turning point in working with county Ag commissioners?

“In the absence of putting up a product list,” Kubiak asked, “what is quasi-legal and what is not quasi-legal? We are trying to come up with solutions to some of these dilemmas.”

“There are counties that want the flexibility. Boards of supervisors and their counties are economically dependent upon this newly emerging industry that’s been in the North Coast for decades. They want the ability to use discretion. Nevertheless, Ag commissioners in other counties clearly are not comfortable with that whatsoever,” Kubiak said.

Cannabis Regulations Needed

Regulations Needed to Protect Consumers, Workers

By Jessica Theisman, Associate Editor
Brian Leahy, Director of the California Department of Pesticide Regulations

With Cannabis being voted in to be legalized in California, regulations will need to be made to keep consumers and workers safe. California Ag Today met with Brian Leahy, Director of Pesticide Regulation out of Sacramento, about Cannabis.

“It is very complicated, but at the end of the day, our job is to help the growers create a crop that is safe for the consumer, safe for the environment and safe for the worker,” Leahy said. “This will all be done in conjunction with all of the other state departments that are working on this. It is the goal for the Cannabis growers to be just like any grower.”

Research is being done with the current Cannabis industry. New health protective guidelines are in the making. One major concern about the Cannabis industry is the amount of pesticide residue. This means that there worker safety issues along with human consumption issues. The industry is already taking steps to resolve this problem.

“The federal government does not recognize it; it’s not a crop. The producers have to remember it’s not a crop, so their laws even on worker safety, overtime, are not the same as agriculture,” Leahy said.