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Member Blog: Novel Foods Applications Stalled?

The UK CBD market had an estimated value of £300 million in 2020 and by the end of 2022 estimates had doubled that figure. This goes to show that CBD being deemed a “novel” food in January 2019 has had little impact on market growth and if predictions are right will exceed £1 billion by 2025. With the FSA’s March 2021 deadline long behind us and having made submissions by the deadline, many companies will be feeling comfortable. However, it’s worth remembering that the authorization process is still on-going, so while products that are part of a validated application are allowed to remain on the market they are still not authorized as novel foods. And now with the FSA conducting market research to aid in their risk assessment of consumer CBD products, some concerning data has been published.

The FSA commissioned Fera Science Ltd to carry out a survey to obtain a brief overview of current CBD products on sale in England and Wales in order to help FSA’s risk assessment of CBD products. The products selected covered, oils, sprays and edibles (including drinks). The study collected various data on the products. This included testing for CBD content, cannabinoid profiles, heavy metals, pesticides, residual solvents, Polycyclic Aromatic Hydrocarbons (PAHs) & mycotoxins. A summary of the results are shown below:

  • Heavy metals (cadmium, mercury & lead) and arsenic were not detected in the majority of samples, meaning levels were below the limits of quantification of the method. Seven samples contained lead, four samples arsenic and two samples contained cadmium. Mercury was not found in any sample. A definitive statement as to whether products exceed maximum levels cannot be made due to uncertainty as to whether products would be classified as a food (i.e. oil) or a food supplement. 
  • A  low incidence of low levels of mycotoxins, with Fusarium mycotoxins found more frequently than aflatoxins and ochratoxin A, mostly at the methods reporting limit. Three samples were found to contain ochratoxin A at the methods reporting limit.
  • A total of seven pesticide residues were found across all of the products (each product was tested for over 400 pesticides). There are no specific Maximum Residue Limits (MRL) for CBD products.
  • One oil product was found to have PAHs above the regulated levels, if classed as a product for direct consumption. If classed as a food supplement the PAHs were within regulated levels.
  • Three samples contained residual solvents. One product was over the MRL.
  • Most products contained CBD close to the declared value. Two oils had substantially different levels than that declared (one higher and one lower). CBD was not detected in one of the drink products.  These are potentially non-compliant with compositional and standards requirements.
  • Delta 9-THC was detected in 87 % (26) of the samples analysed. Of these 40% (12) were found to have THC+ (the total sum of illicit cannabinoids in the product) above the 1mg threshold.

Although Fera only tested a small number of products, the fact that such a large percentage of products were found to have issues is concerning to say the least. It throws into question how many other products currently on the market that are part of a validated NF application, but aren’t up to spec.

The next question is, are you 100% sure that your current market offerings meet their product specifications? If not then there’s no time like the present to take a closer look at your products and their manufacturing process. It’s also important to remember that if you do need to make changes then these changes need to be updated in your current regulatory filings.

If you would like to discuss this further, please reach out to us at info@arcuscompliance.com.

Member Blog: Condensate Recapture for Cannabis Cultivation Facilities – Making Informed Decisions to Save Resources and Improve Efficiency

By Taylor Robinson – R&D Manager and Chief Chemist, Silver Bullet Water Treatment & Kyle Lisabeth – Director of Horticulture Business Development, Silver Bullet Water Treatment

Condensate capture for reuse is an intriguing new application within the controlled environment horticulture space. Addressing both environmental impacts and regulatory requirements, capturing and reusing condensate has many attractive benefits. However, several key questions have appeared surrounding the topic of condensate water capture and reuse applications that have slowed its adaptation in many facilities. In this article, we discuss common questions and concerns associated with condensate reuse and how each may be addressed with adequate, customized treatment processes.

Condensate water is generated by a number of processes within a controlled environment agriculture facility. Most commonly, dehumidification and HVAC systems are the primary sources of condensate water. The source of water and collection system plays a significant role in condensate water quality and associated concerns when considering reuse.

Why is collecting and reusing condensate water a good option?

  1. Recycling available water streams reduces the amount of fresh water required and offsets associated costs.
  2. Recycling minimizes discharges and waste. Coming regulations will require extensive discharge limits.
  3. With adequate monitoring and treatment, risks may be greatly reduced, maximizing benefit.

Contamination – Don’t Let One Bad Apple Ruin the Bunch

In general, condensate water is low in Total Dissolved Solids (TDS)/Conductivity and is generally very clean. pH is typically low as carbon dioxide readily absorbs into solution (pH 5.5-6.5 range). Contaminates are easily introduced based on what the water contacts during collection and distribution. Volatile Organic Compounds (VOCs) and other organics can be absorbed and provide “food” for microbial proliferation – especially if the condensate is pooled and stored for extended periods. Metals leaching from dehumidification equipment and/or from dust/air pollutants also may accumulate. Identifying and managing emerging contaminates is crucial to successfully mitigate risk and maximize value when reusing condensate water.  

Microbes and Organics

By themselves, most organics potentially found in condensate water pose little threat. However, organic (carbon-based) pesticides, foliar sprays, etc. have the potential to accumulate in exposed condensate water and could lead to downstream issues. Organics also provide a potential carbon source for various microbial populations to proliferate. This can create biosecurity challenges, plant disease and challenge existing water treatment processes. Microbes are ubiquitous in nature and although pathogens are presumed to make up less than 1% of the known microbial kingdom, contamination remains a threat. Airborne bacteria, viruses and fungal spores can be introduced to a condensate water system through its condenser plates. Microbial proliferation and the formation of biofilms on wetted surfaces downstream of dehumidification equipment can result in elevated levels of total and pathogenic microbes.

Heavy Metals

Heavy metals including lead, zinc, aluminum, and copper may be a concern if leaching from dehumidification equipment occurs. Soldered joints in copper tubing, for example, may introduce lead to condensate water. In that case, mechanical joints/brazed joints would be preferred. Aluminum, copper, and zinc may be stripped directly from metal surfaces as part of generalized corrosion. Even at relatively low levels, some metals, dissolved contaminates and other corrosion byproducts can bioaccumulate in plants resulting in compounded issues, including phytotoxic effects.

Water Treatment & Management

In many situations, the use of recaptured condensate water is a viable option to supplement make-up water demand and reduce waste discharge. Treatment prior to reuse is recommended to condition the condensate water to ensure water system stability over time and to prevent potential treatment and operational challenges that could otherwise arise. 

Available treatment processes include Advanced Oxidation Process (AOP) gas and UV for disinfection, adsorptive media for dissolved organics and various other filtration processes for metals and other contaminate removal. The extent and type of treatment varies based on specific water challenges and end goals. 

Baseline and routine subsequent water testing and monitoring is key to maintain a proactive approach to water management. Integrating smart water management programs limits waste, improves logistics, saves money, protects the environment and allows for current and emerging regulatory compliance. Equally important is choosing the right technical partner to help develop and implement your smart water management program.


Taylor Robinson is the Research & Development Manager and Chief Chemist for Silver Bullet Water Treatment with expertise in molecular and cell biology, general water chemistry, microbiology, and industrial (oil and gas) water treatment and reuse processes/chemistries. For the past 4 years, Taylor has led, conceptualized, organized, and completed numerous Silver Bullet research and development projects related to water treatment for the livestock, cooling water, horticulture, aquaculture and data center industries. Taylor joined Silver Bullet in 2016 and has been a key contributor to the advancements in the company’s technology and research base.

With over 15 years’ experience, Kyle Lisabeth has been focused on improving water management programs across multiple industries, with a central focus of treating water for reuse applications.  Kyle attended the University of Texas – Austin, and upon graduation with a BS in Biology and Environmental Sciences, gained years of international water management experience in both North and South America. Since establishing Silver Bullet’s Horticulture Division, Kyle has exponentially grown the business unit’s install base and cultivated a nationally known water treatment brand for many controlled environment agriculture applications, including cannabis.

Member Blog: The Most Important Things to Consider When Purchasing Bulk or Wholesale Hemp Derived Phytocannabinoids

by Ryan Lewis, Entourage Nutritional Distributors

Folium Biosciences hemp farms are some of the largest in the USA. Location: La Junta, CO.
Folium Biosciences hemp farms are some of the largest in the USA. Location: La Junta, CO.

Hemp, more than any other plant on Earth, is unique in its ability to literally suck the heavy metals and toxic waste out of the environment. Hemp is even being used in phytoremediation at Chernobyl in Russia. What does this mean to consumers of hemp products? Knowing as much information as possible about your hemp is crucial to understanding its legality, limitations, and effectiveness.

Hemp from China, for example, contains some of the most dangerous heavy metals in the world. According to a 2011 study of Chinese hemp strains, the plant was able to absorb dangerously high levels of the heavy metal cadmium without detriment to the plant itself. Cadmium (Cd) is an extremely toxic industrial and environmental pollutant classified as a human carcinogen. 

See the study here:
Cadmium Tolerance and Bioaccumulation of 18 Hemp Accessions

The 5 most important things to consider when purchasing bulk or wholesale phytocannabinoid rich hemp oil products high in cannabidiol (CBD) are:

  1. Was the hemp grown in accordance with section 7606 of the US Farm Bill? The head of the DEA recently stated that section 7606 Farm Bill compliant hemp is safe from the DEA.***
  2. What is the heavy metals and residual solvent content of the hemp oil? Residual solvents and heavy metals can negatively influence the health benefits of the oil.
  3. Besides CBD, what other cannabinoids and terpenoids are present in the extract? A full spectrum profile of synergistic compounds has been shown to be more effective than an extract with only cannabidiol.
  4. Was the hemp grown using clones or seeds? Clones provide a much more consistent end product. With seeds, you never truly know what is going to grow.
  5. Can your supplier provide you with a consistent and reliable product? What good is the product if you cannot get it the exact same way every time and when you need it?

Considering the fact that many people are relying on CBD for their health and wellness, ensuring that your hemp oil is the highest quality is vital to its effectiveness. Prior to purchasing bulk or wholesale CBD oil, make sure you know where your hemp was grown and processed. Ask yourself this question before purchasing imported Chinese or European hemp oil: Would you feed your child milk imported from cows located in China or Eastern Europe? Didn’t think so.

***EDITOR’S NOTE: Federal policy toward hemp-derived CBD products with respect to Section 7606 is currently subject to substantial debate. The USDA’s website states, “[S]ection 7606 did not alter the approval process for new drug applications or any other authorities of the FDA, nor does it alter the requirements of the Controlled Substances Act that apply to the manufacture, distribution, and dispensing of drug products containing controlled substances.”


ryanlewisRyan Lewis is the VP and Head of Global Sales for Folium Biosciences of Colorado Springs, CO. Folium Biosciences is the largest vertically integrated producer, manufacturer, and distributor of hemp derived phytocannabinoids in the U.S. Folium, along with their exclusive distributor, Entourage Nutritional Distributors, supplies section 7606 US Farm bill compliant hemp derived phytocannabinoids to some of the leading brands and companies in the world. Ryan graduated with high honors from Brown University and attended Pepperdine University Law School and Business School.

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