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A Proposal to Establish a Comprehensive Cannabis Varietal
Registry in Washington State
A collaboration between VisionWashington LLC. and The Center for
the Study of Cannabis and Social Policy
CO-AUTHORS:
David J. Mighell, Dominic Corva1, Michelle Sexton2
REVIEW, CRITIQUE AND ENDORSEMENT:
Sunil Aggarwal3, Gregory T. Carter4
June 10, 2013
Contents Introducing the Proposal
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About Us
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The Current State of Cannabis Phytochemical Analysis
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The Scientific Basis for a Cannabis Varietal Registry (CVR)
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The CVR Will Significantly Inform Commercial Research
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The CVR Will Significantly Inform Medical Research
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The CVR Will Richly Inform Current and Potential Cannabis
Consumers
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Conclusion
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1 Ph.D., Geography, University of Washington; Assistant
Professor, Political Geography, Sarah Lawrence College; Founder,
Center for the Study of Cannabis and Social Policy, Seattle, WA 2
ND, Bastyr University Research Institute Faculty; Postdoctoral
Fellow, University of Washington, 2008-2011 3 M.D., Ph.D (Medical
Geography, University of Washington), Resident, NYU Langone Medical
Center 4 M.D., MS. Professor, Department of Rehabilitation
Medicine, University of Washington; Physiatrist, Providence Medical
Group, Author, Scientific Basis supporting Gov. Gregoire’s 2011
Cannabis Reclassification Petition
http://www.linkedin.com/search?search=&keywords=Geography&sortCriteria=R&keepFacets=true&trk=prof-edu-field_of_studyhttp://www.linkedin.com/search?search=&title=Postdoctoral+Fellow&sortCriteria=R&keepFacets=true¤tTitle=CP&trk=prof-exp-titlehttp://www.linkedin.com/company/2584?trk=prof-exp-company-name
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Introducing the Proposal Current analytic methods for
identifying and tracking cannabis cultivars (“strains”) currently
test for THC,
CBD and CBN content, which constitute only three of the
approximately 30 principal chemical compounds
represented in cannabis varietals in various proportions. In
fact, it is the precise combination of the secondary
metabolites – terpenes, flavonoids and minor cannabinoids - that
are responsible for various qualities of the
human/plant biochemical interaction. The authors assert that
capturing and understanding a more complex and
precise profile of commercial cannabis products is necessary to
inform enlightened policy regulation.
At the same time, scientists have now demonstrated the means to
reliably capture exhaustive chemical profiles
of plant matter, and importantly, have demonstrated methods to
use the resulting quantitative data to
chemically distinguish cannabis varietals from one another. This
means that we now have the capability to
classify cannabis strains by common compositional relationships,
and identify morphological change in plants
over time and responsive to growing conditions. Thus, we can
baseline cannabis products made available to
Washington consumers, and manage important dimensions of product
continuity and quality assurance that are
not currently addressed in draft regulations.
We propose to establish a lab in Washington State that can
collect comprehensive cultivar profiles and analyze
them in support of Washington State policy goals, in particular
the need to establish analytic standards that are
based on robust scientific data that currently does not exist.
The data collection and analysis done by the lab
will be used to create a comprehensive Cannabis Varietal
Registry based on chemo-taxonomic analytical
methods that are far more comprehensive and informative than we
expect to be reflected in final rules for
recurrent crop testing for safety and potency.
The Cannabis Strain Registry shall be:
A single lab, site, with dedicated staff and purpose
Driven by the common needs of Consumers, medical science and
Washington’s Cannabis Industry
Fully Transparent, non-profit
Sustained by user fees (producers and processors)
In-service to medical and commercial research by freely
publishing the most comprehensive biological
information on cannabis in existence
Responsible to Consumers and the industry for the same
reason
A one-time requirement for the collection of a baseline profile
for all strains brought to market
While the requirements for the Cannabis Varietal Registry could
be equally satisfied by public or private
resources, we see this as an ideal opportunity to express the
aligned interests of the state and the private
cannabis industry.
About Us The Proposal is a collaboration between
VisionWashington LLC. and the Center for the Study of Cannabis
and
Social Policy.
VisionWashington LLC. began in 2011 as a rolling conversation
among colleagues - veterans of Washington's
software industry interested in the implications of our state's
commercial cannabis initiative and its parallels in
our experience in emerging industries. We have partnered with
the Seattle-based Center for the Study of
Cannabis and Social Research to create this proposal, but the
impetus and development of its ideas are rooted
in the process started by VisionWashington.
The Center for the Study of Cannabis and Social Research was
established to produce, review, and disseminate
objective research and opinions about the relationship between
Cannabis Policy and other forms of Social Policy
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including but not limited to Environmental Policy, Agricultural
Policy, Public Health Policy, Foreign Policy, and
Economic Policy. This proposal is one of many policy research
projects the Center hopes to house.
VisonWashington understood from their experience at Microsoft,
Intel and elsewhere, that the dawn of an
entirely new industry is an opportunity to set precedence, to
impart convention, establish customs and methods
that can become industry-wide standards as the eco-system
evolves. Characteristic of Washington’s foremost
technology companies in their finest hours has been foresight
and decisiveness at key moments in the evolution
of their respective industries. We assert that this is just such
a moment for Washington and for the Cannabis
Industry.
We began with the following question: How could Washington shape
administrative rules that might leverage
its unique status as “premier industry declarant” into one of
“cardinal industry authority,” and in doing so
establish a premium market reputation for leadership in industry
and regulatory practice that could be reflected
in the value of Washington cannabis products ad infinitum.
After extensive literature review, we have come to the
observation that the biological study of cannabis has
been so limited that there exists no classification system or
taxonomy to describe types beneath three primary
phenotypes. At the same time, we found that it has only now been
clearly demonstrated that strains can be
identified and grouped by chemotaxonomic similarities. What is
missing is a scientifically relevant sample
population of cannabis producers, and that is the opportunity
that has been made possible for the first time by
the passage of I-502. We expect that our project will help shape
industry standards in Washington State, and
that our results will guide industry standards in future
legalization policy development in other states as they
look to Washington and Colorado models.
The opportunity to be seized: The emergence of the world’s first
measurable class of regulated cultivators:
Scores of licensed producers - already subject to testing
rigor
Producing scores of varietals for the commercial market
Our principal objectives in the realization of this
opportunity:
The development of the world’s first and foremost scientifically
authoritative chemotaxonomic dataset
of cannabis cultivars
And from that study, the development of a cannabis phenotype
classification system
In sum, Washington has the opportunity to deliver a wellspring
of new learning and scientific data to inform best
practices for regulatory policy, as well as medical and
commercial research for years to come.
We assert that our recommendation for the establishment of the
Washington State Cannabis Varietal Registry
broadly serves the interests of all
stakeholder/constituents:
Science
Medicine
Education
Patients
Consumers
The WA Cannabis Industry
Regulators
The objective of this document is to describe exactly how.
We begin by assessing the current state of cannabis
chemotaxonomic research, elaborate on how our proposed
Registry will inform commercial research, medical research, and
consumer knowledge necessary for making
informed consumption decisions.
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The Current State of Cannabis Phytochemical Analysis Effective
policy reflects authoritative knowledge about the reality it
addresses. At this stage, authoritative
scientific knowledge of cannabis – medical, social and
biological – is behind the curve, and this presents a major
challenge for producing effective policy.
The 1961 Single Convention on Narcotic Drugs along with two
other treaties restricted scientific establishments
in the USA from studying Cannabis without approval of the DEA.
Here, under schedule I, Cannabis currently is
classified as if there is no current accepted medical use, which
has deeply undermined the potential to explore
or define the medical value. The consequence has been that the
public has taken on their own uncontrolled
clinical trial, and become the experts on the medical utility of
the plant.
To better understand the medicinal value of botanical medicines,
it is necessary to look beyond the common
macronutrients of protein content, fats, carbohydrate, and focus
on the secondary metabolites that are
responsible for the human/plant biochemical interaction. The two
primary constituents, delta9-THC and
Cannabidiol (CBD) have gained most of the notoriety for
conspicuous effects of Cannabis, and yet there are close
cousins of cannabinoids as well as other classes of compounds
that all work synergistically with THC and CBD to
provide the quality of the experience.
For comparison, there can be a “Nutrition Facts” equivalent for
botanicals - Cannabis specifically - as depicted
in Figure 1. A partial phytochemical breakdown for Cannabis,
(here analyzed by GCMS) is profiled from a research
paper. However, a standard phytochemical profile that could be
used to document how growing conditions may
alter secondary plant metabolite expression, and how
(specifically) the terpenes affect the biological impact on
the broader human sensory experience has yet been allowed the
same importance as nutrition facts for junk
food. For instance, limonene is reputed to “mellow” the
psychoactivity of THC, and beta-myrcene may actually
be responsible for the “couch-lock” effect of varieties that are
marketed as “indicas”. Pinene may be responsible
for the “head” effect of sativas and linalool for elevating
mood. No one has yet to publish any data on these
topics due to the restrictions on formally conducting these
studies, and limitations of the current labs to collect
academic-quality data.
Figure 1: A Nutrition Facts label and the GC quantitative data
of the strain "white widow"
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The Scientific Basis for a Cannabis Varietal Registry (CVR) The
enthusiasm behind our recommendation is rooted in the works of Dr.
Arno Hazekamp5 with Dr. Justin
Fischedick6 et al.
In their 2010 study Metabolic fingerprinting of Cannabis sativa
L.7, the authors emphasize the “urgency to define
the criteria necessary for the chemotaxonomic classification of
medicinal cannabis for drug standardization and
clinical research purposes,” while demonstrating clear
qualitative and quantitative chemotaxonomic
differentiation between cannabis varietals using Principal
Component Analysis (PCA) – a method of algorithmic
multivariate analysis.
In their 2011 study Cannabis – from cultivar to chemovar8, the
authors assert that for “a clearer understanding
of medicinal properties of the Cannabis plant, a better
classification system, based on a range of potentially
active constituents, is needed” while again demonstrating the
methods of multivariate analysis as clearly useful
in defining variously-sourced cannabis samples into distinct
chemovar groups.
What this means:
It means that, provided an adequate sample population, the
science supports the development of a classification
system for cannabis based on the metabolic similarities and
relationships between varietals. Simply put, we can
fingerprint cannabis strains and categorize them into types
based on their constituent makeup. The missing
component has been an adequate sample population of cultivators
and varietals, and this is the opportunity
presented to us in I-502.
We assert that it is our responsibility to capture and make
freely available - for science and the interests of all
constituents - the new learning to be found in the opportunities
presented us that are so unique to these
moments alone.
Figure 2: A PCA scatter diagram illustrating the clustering of
cannabis varietals by metabolic similarities
5 Principal Scientist, Bedrocan BV, P.O. Box 2009, 9640CA
Veendam, The Netherlands 6 Division of Pharmacognosy, Section
Metabolomics, Institute of Biology, Leiden University, Leiden, The
Netherlands 7 2010, Metabolic fingerprinting of Cannabis sativa L.,
cannabinoids and terpenoids for chemotaxonomic and drug
standardization purposes. Justin Thomas Fischedick, Arno Hazekamp,
Tjalling Erkelens, Young Hae Choi, Rob Verpoorte. 8 Cannabis - from
cultivar to chemovar. A. Hazekamp and J. T. Fischedick
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The CVR Will Significantly Inform Commercial Research The
exponential advances in cannabis breeding and cultivation practices
in the last two decades have resulted
in the introduction of highly differentiated strains as well as
the exponential increase in potency of cannabis
products. All of these are contributions of the largely
unregulated medical cannabis industry, and have all been
achieved almost entirely without the benefit of science.
Breeders and producers have instead relied on logic,
experience and trial-and-error in achieving desired outcomes in
both cultivation methods and phenotype
development.
Today – in this period before the advent of producer brands -
strain selection and tactile contact remain the
patient’s sole reference points at retail, and the relevance of
varietals will anything but diminish in the consumer
market.
This dawn of the commercial cannabis industry will see the
advent of commercial cannabis product research
and development of white-market proportions, and the CRV is
precisely the data required to inform this
research. Armed with complete metabolic profiles and a knowledge
of terpenes and other currently unanalyzed
constituents, commercial research will be optimally informed to
achieve desired outcomes.
The Cannabis Varietal Registry will inform:
The development of new, commercially relevant products
Product continuity, year over year (standardization)
The breeding of commercially differentiated strains
The advancement of cultivation practices to specific end
The CVR Will Significantly Inform Medical Research Although
Washington State currently has both a medical and a legal
regulatory framework, we recognize that
the absorption of medical policy by legal Cannabis policy
presents the likelihood that legal cannabis consumers
will make medical use of commercial Cannabis.
Plants are complex mixtures of many classes of phytochemicals –
many of which are biologically active. It is
widely assumed that different Cannabis strains (also known as
cultivar, varietal or phenotypes) have unique
medical relevance. But to be informed by a twenty-something
bud-tender that a certain strain will “improve
memory” and “treat kidney conditions” challenges the guidance of
FDA regulation of herbal and dietary
supplements. However, the patient anecdotes have fueled the
urban legends regarding strains that are on the
market. Strains labeled by the same name may not have closely
similar phytochemical fingerprints, and until we
collect the data, it is unknown how accurate a consumer may
reproduce an effect, and how retail spaces can
“frame” varieties, when supplying and dispensing products being
called by the same name, but may or may not
have any phytochemical resemblance.
In short, the academic knowledge that can inspire and guide both
commercial and medical platforms are NOT
currently sufficient for informing commercial or medical
consumption.
A significant milestone would be met with the collection and
analysis of quantitative data of the phytochemical
fingerprints of Cannabis varieties across a population of
producers.
The CRV richly informs the needs of medical science for:
Pharmaceutical standardization and Quality control
Our understand the effective contribution of active
constituents
Determining how strains can be bred for specific therapeutic
purpose potential
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The CVR Will Richly Inform Current and Potential Cannabis
Consumers Washington voters made consumer safety - in every regard
- the highest administrative priority tasked to the
WSLCB. The CVR will make a significant contribution to this
Washington State priority.
We assert that this objective cannot be over-informed.
Figure 3: A CVR-enabled labeling scenario: The consumer’s
understanding of cannabis is already extensive – as demonstrated in
the online conversation - and they will increasingly require access
to comprehensive product information
While there may be a dearth of hard science on the topic, that
isn’t reflected in the dimensions of the public
conversation. Cannabis strains are the conversational
focal-point of a massive on-line interchange of information
and the shared experiences of cannabis users. Taken in
aggregate, this represents more than just an enormous
conversation about weed. This in fact is a treasure trove of
patient- and consumer- inspired research matter
that has evolved its own taxonomy, based (almost) entirely on
the subjective human experience with very little
contribution from science except in the broadest of strokes. So,
while the extent of the cannabis taxonomy to
describe strains by type is extremely limited, there are over
700 known strains, and millions of people talking
about them, and beyond this it’s just out of control.
But understand that collectively, this is the consumer and
patient conversation, the where and how people gain
and share information on cannabis today, and the conversation is
strains, and its relevance to us cannot be
underestimated.
Figure 4: There are many popular online destinations focused on
information and conversation about cannabis strains
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Online behaviors exhibit patterns, and there are certain
absolutes that can indeed be foreseen, and one of them
is this: If you were to publish a comprehensive and
freely-available database of cannabis cultivars as we describe
– even just the raw quantitative chromatography data we’ve shown
you - you would ignite a phenomenon at
the intersection of the social/human experience and
science/discovery and our goal of the optimally-informed
consumer, defined as consumers with complete access to
information to the full extent of their individual
interests. And of course it is commonly accepted that there is
an inverse relationship between a consumer’s
knowledge of a product and adverse behaviors exhibited with that
product. The very point of these sites is the
dissemination of information on cannabis, and every one of these
would instantly tap into your database,
integrate it with their curated social histories, and in a
single stroke you would elevate the conversation by a
massive margin – almost without trying. The Wikipedia pages for
each of these compounds would light up and
the conversation would leap forward with new learning. That’s
not hyperbole; we believe publishing this dataset
is an essential public service and a social responsibility.
This is an example of what we mean, though, when we say this
information is important and needs to be made
aggregate and needs to be made free, and an opportunity lost if
ignored.
Conclusion For the first time in more than four decades of
polling on the issue, the Pew Research Center in April of this
year
showed that a majority of Americans favor legalizing the use of
marijuana. A tipping point has been reached,
and it is certain that as states move forward with the
liberalization of marijuana laws, increasingly they will look
to Washington for regulatory guidance and example.
We believe that our proposal for the Cannabis Varietal Registry,
if adopted, will be a clear demonstration of
leadership and visionary example in the formation of an
enlightened regulatory framework for commercial
cannabis, and set Washington as an example of authority and
wisdom in establishing these goals.
In summary, we propose that the State assign an independent
organization that will oversee the formation and
management of a Washington State Cannabis Varietal Registry,
from which a database of chemotaxonomic
profiles of all phenotypes taken to market by Washington Growers
will be maintained. From this data and that
produced by recurrent crop testing, the state’s assignee will
create a cannabis classification system and
methodology, and will make public without fee all work products
derived for the benefit of all future research.
The state’s assignee shall provide these services on a
non-profit basis, and be maintained by and responsible to
the Washington Cannabis Industry. The assignee shall work in
service to the People of Washington, thus that
every example of a given variety bearing the Washington Tax
Stamp shall be of the highest possible order, of
uniform genotype and potential, and conformant to the
expectations of an optimally-informed consumer.