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Hemp Production – Keeping THC Levels Low

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Estoy de Acuerdo / I agree

Leo Stefanile, Margaret Bloomquist, and Zeke Overbaugh showing differences in root development of two hemp varieties.
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Hemp Production in North Carolina is new and changing rapidly. There is a massive shortage of research-based info regarding the basic agronomic recommendations but we are making progress. Because of the great interest in hemp from our farmers, industry, community leaders, and potential consumers of hemp products I will summarize what I have learned from listening to numerous people working with this crop.

Hemp can be grown for seed, fiber, or flower (oil extracts). In 2018, North Carolina had 6133 licensed acres, 394 licensed growers, and 1.6 million square feet in licensed greenhouse space. The majority of production is focused on growing hemp for flower, primarily the CBD market. CBD, or cannabidiol, is one of over 100 cannabinoids identified in hemp plants. Another cannabinoid is THC, tetrahydrocannabinol, which is the psychoactive ingredient in cannabis that gives a ‘high’ effect. The amount of THC in a cannabis plant determines whether it is hemp or whether it is marijuana. If the THC content is 0.3% or less, it is hemp. If the THC content is greater than 0.3% it is marijuana.

Female hemp flower. Most (but not all) hemp cultivars are dioecious, meaning male and female flowers are found on separate plants. Hemp growers interested in CBD production want female plants. Photo by Debbie Roos. See full article here.

Licensed growers of hemp in NC are required to contact the North Carolina Department of Agriculture & Consumer Services (NCDA&CS) at the initiation of flowering ([email protected]). Growers must report when plants are flowering and, thus, are ready to be tested for THC. Someone from NCDA&CS will visit the site and sample hemp 3-5 weeks into flowering. They will take the top 3-5 inches of the plant (NCDA&CS is sensitive to the value of biomass and they are working to minimize the total amount of biomass removed) and if you have multiple varieties you will need multiple tests. The grower must pay for all testing ($59 for the first test). If the level of THC is above 0.3% you will have two options – destroy your crop or pay for a re-test of the THC ($149 for the re-test).

Growers need to be aware that plant stresses (drought, flooding, excessive nutrients, not enough nutrients, heat, cold, etc) can result in THC spikes. According to Paul Adams with theNCDA&CS, in 2017, the NCDA&CS processed 135 hemp samples and 14 came back above 0.3% THC. In 2018 they processed 400 hemp samples and 38 came back above 0.3% THC. About 10% of hemp fields are ‘going hot’ – lingo used to describe a THC spike. This is a serious risk to hemp producers and there is currently no crop insurance to mitigate this risk.

We don’t have solid data on the causes of THC spikes but here are some considerations. While excess nitrogen is often blamed for THC spikes, Dr. Angela Post, NC State University Small Grains Specialist, disagrees with this. In one research trial that Dr. Post conducted, nitrogen was applied at rates of 50, 100, 150, 200, 250, and 300 lbs per acre. While there was no advantage at putting out more than 100 lbs of nitrogen per acre there was no spike in THC. In fact, from just this first year of preliminary data, Dr. Post did not see any relationship between nitrogen and THC or CBD. In fact, Dr. Post wonders if nitrogen deficiencies could result in plant stress, thus causing a THC spike. From just this first year of data the nitrogen recommendation would be 100 lbs of N per acre. However, Dr. Edminsten cautions that this is just one season of data. If he were growing hemp right now he would lean towards a higher nitrogen rate (120 lb/N per acre).

Certainly, variety selection will play a role in THC content of the hemp varieties. We are still gathering information for growers regarding variety performance in NC but there is a listing of how some varieties have performed in Kentucky, including which of those varieties are of concern for THC spikes.

Take a look at this article for more information on prices for hemp floral biomass:

The information regarding hemp is changing quickly so keep visiting these resources and stay tuned.

Detection of cannabinoids in hair after cosmetic application of hemp oil

All data generated or analyzed during this study are included in this published article.

Abstract

The detection of cannabis constituents and metabolites in hair is an established procedure to provide evidence of exposure to cannabis. We present the first known evidence to suggest that applying hemp oil to hair, as cosmetic treatment, may result in the incorporation of Δ 9 -tetrahydrocannabinol (THC), cannabinol (CBN), cannabidiol (CBD) and in one instance, the metabolite 11-hydroxy-Δ 9 -tetrahydrocannabinol (THC-OH). 10 volunteers treated their head hair daily with commercially available hemp oil for a period of 6 weeks. Head hair samples were collected before and after the application period. Hair samples were washed with methanol and subjected to clean up via liquid/liquid and solid phase extraction procedures, and then GC-MS/MS for the analysis of THC, CBN, CBD, THC-OH and THC-COOH. Application of hemp oil to hair resulted in the incorporation of one or more cannabis constituents in 89% of volunteers, and 33% of the group tested positive for the three major constituents, THC, CBN and CBD. One volunteer showed low levels of the metabolite THC-OH. We suggest that cosmetic use of hemp oil should be recorded when sampling head hair for analysis, and that the interpretative value of cannabinoid hair measurements from people reporting application of hemp oil is treated with caution in both criminology and public health.

Introduction

Cannabis Sativa is a plant species of Cannabis. In addition to its recreational use as a drug of abuse, the plant has widespread alternative uses including the production of food, cosmetics (hemp), textiles and medicinal applications 1 . When toxicology laboratories are required to investigate past exposure to cannabis, analysis of hair can provide powerful evidence. The compounds usually targeted for hair analysis to identify cannabis exposure are: Δ(9)-tetrahydrocannabinol (THC), the main active compound of cannabis, the metabolite [11-nor-Δ(9)-tetrahydrocannabinol-9-carboxylic acid (THC-COOH)] and two cannabinoids (cannabinol (CBN) and cannabidiol (CBD)) 2 . Typically passage of these cannabinoids into the hair includes passive diffusion from blood, diffusion from sweat/sebum or external contamination. One of the key questions to be addressed when interpreting the results of cannabinoid hair analysis is that of proof of consumption. Are the results sufficiently clear to suggest cannabis was consumed, or could the results actually be the result of passive exposure to cannabis smoke, or other mechanisms? Passive exposure is defined by an individual being in an environment that is exposed to drugs, an important public health problem. Cannabis smoke can be inhaled or absorbed into the hair by persons other than the intended smoker/user 3 . Researchers have evaluated second-hand cannabis smoke exposure and the corresponding levels of cannabinoids in biological samples 3 , 4 . Herrmann et al. discovered that in unventilated, confined conditions cannabinoid detection was above threshold and higher concentrations of THC and THC-COOH were found predominantly in the blood, urine and hair 4 . THC and THC-COOH have lower incorporation rates in hair in comparison to other bodily matrices. The low presence of THC may be explained by its weak affinity to melanin while the acidic nature of hair may be the reason for the absence of THC-COOH 5 . Along with the levels of cannabis constituents detected in passive exposure, analysis has been conducted to understand what physiological impact exposure has 3 . Past research has shown evidence of increased heart rate and minor impairments in coordination and memory 4 , 6 , 7 . Identification of THC/CBN/CBD in hair suggests exposure to cannabis, which could be due to low level or infrequent use of cannabis or historic or passive exposure. However, some argue that the presence of cannabinoids in hair, especially THC is indicative of repeated or chronic exposure 5 , 8 . The distinction between external contamination and consumption can be difficult for cannabinoid hair analysis 9 , and the implication of a positive test result can have significant consequences for the individual involved. THC-COOH is only formed inside the body, and the presence of this gives unequivocal proof of consumption when detected in hair samples. The metabolite has never been discovered in cannabis smoke ruling out environmental contamination 10 . With hair analysis, THC-COOH is detectable at very low concentrations. The drawbacks for detection from this biological matrix are the requirement for expensive instrumentation and sample preparation can be a more time-consuming process when compared to urine 11 . Routine laboratory screening of hair for cannabis varies and includes the detection of cannabinoids and/or THC-COOH 8 . Hemp is a variety of Cannabis Sativa and is closely related to Cannabis with the difference being in the percentage of THC 12 . Hemp is grown for industrial use and found in food, lotions, medicines, clothing and construction materials. Hemp oil is extracted by pressing the seeds from the female hemp plant 13 . The legalisation of hemp has caused controversy. This is because research has shown that the use or consumption of hemp products could have the potential to impact on drug testing for cannabis 14 .

Hemp oil products are advertised in health shops for their good source of omega fatty acids 15 . Bosy et al. 16 assessed whether oral consumption of hemp oil would negatively affect existing drug screening protocols. Various oils were screened (THC content of bottled oils was 36.0, 117.5, 36.4, 45.7, 21.0, 11.5 mg/g) and administered to volunteers and their urine measured for metabolite levels. GC-MS analysis determined the amount of THC-COOH in each participant’s urine to be below the confirmation cut-off within a 48 hour cessation period. Similarly to hemp oil, hemp foods are classified as ‘natural foods’ and are commercially available. Leson et al. showed that daily consumption of hemp food can lead to the presence of THC and THC-COOH in urine, but these compounds were below the confirmation thresholds 17 . These authors 16 , 17 suggest that hemp food and oil products do contain cannabinoids but in very low concentrations, and that ingestion of such products should not be deemed as a concern in drug testing. The Cannabis plant has been used in the production of cosmetics through the use of hemp oil and cannabis extracts 18 . An evaluation of Cannabio® shampoo revealed levels of THC, CBD and CBN, three constituents that indicate cannabis exposure 19 . However, normal hygiene practice using the cosmetic produced no positive results in hair. Extreme use could generate positive results for CBN and CBD but not the primary constituent, THC.

Hemp oil is marketed as an effective cosmetic treatment for hair, with claims that direct application of the oil to hair has moisturizing benefits, can aid hair growth, may protect the hair and aid in damage repair, and the oil may add shine to the hair. These claims are unsubstantiated but there is a substantial number of online retailers selling various hemp oil based products intended for direct application to head hair. The composition of these products range from pure hemp oil, to hemp oil included at a relatively low concentration into shampoos and other hair treatments.

In this paper we investigate direct hemp oil application to head hair and the implications on resulting cannabinoid measurements.

Results

Cannabinoid concentrations pre and post hemp oil application

Head hair samples were collected from volunteers as described in Methods, and analysed before and after the six week period of hemp oil administration. Results are displayed in Table  1 .

In This Section

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DOT "CBD" Notice

DOT OFFICE OF DRUG AND ALCOHOL POLICY AND COMPLIANCE NOTICE

The Agricultural Improvement Act of 2018, Pub. L. 115-334, (Farm Bill) removed hemp from the definition of marijuana under the Controlled Substances Act. Under the Farm Bill, hemp-derived products containing a concentration of up to 0.3% tetrahydrocannabinol (THC) are not controlled substances. THC is the primary psychoactive component of marijuana. Any product, including “Cannabidiol” (CBD) products, with a concentration of more than 0.3% THC remains classified as marijuana, a Schedule I drug under the Controlled Substances Act.

We have had inquiries about whether the Department of Transportation-regulated safety-sensitive employees can use CBD products. Safety-sensitive employees who are subject to drug testing specified under 49 CFR part 40 (Part 40) include: pilots, school bus drivers, truck drivers, train engineers, transit vehicle operators, aircraft maintenance personnel, fire-armed transit security personnel, ship captains, and pipeline emergency response personnel, among others.

It is important for all employers and safety-sensitive employees to know:

  1. The Department of Transportation requires testing for marijuana and not CBD.
  2. The labeling of many CBD products may be misleading because the products could contain higher levels of THC than what the product label states. The Food and Drug Administration (FDA) does not currently certify the levels of THC in CBD products, so there is no Federal oversight to ensure that the labels are accurate. The FDA has cautioned the public that: “Consumers should beware purchasing and using any [CBD] products.” The FDA has stated: “It is currently illegal to market CBD by adding it to a food or labeling it as a dietary supplement.”* Also, the FDA has issued several warning letters to companies because their products contained more CBD than indicated on the product label. **[i]
  3. The Department of Transportation’s Drug and Alcohol Testing Regulation, Part 40, does not authorize the use of Schedule I drugs, including marijuana, for any reason. Furthermore, CBD use is not a legitimate medical explanation for a laboratory-confirmed marijuana positive result. Therefore, Medical Review Officers will verify a drug test confirmed at the appropriate cutoffs as positive, even if an employee claims they only used a CBD product.

It remains unacceptable for any safety-sensitive employee subject to the Department of Transportation’s drug testing regulations to use marijuana. Since the use of CBD products could lead to a positive drug test result, Department of Transportation-regulated safety-sensitive employees should exercise caution when considering whether to use CBD products.

The contents of this document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies. This policy and compliance notice is not legally binding in its own right and will not be relied upon by the Department as a separate basis for affirmative enforcement action or other administrative penalty. Conformity with this policy and compliance notice is voluntary only and nonconformity will not affect rights and obligations under existing statutes and regulations. Safety-sensitive employees must continue to comply with the underlying regulatory requirements for drug testing, specified at 49 CFR part 40.