As the California Department of Pesticide Regulation (CDPR) prepares to share its draft regulations regarding the use of pesticides and fertilizers on cannabis later this month, there is concern about the fungicide myclobutanil causing toxicity in cannabis and cannabis edibles. Scientific research shows that myclobutanil is incredibly dangerous in smokable cannabis, however it is also permitted by the federal government and approved for human consumption when present in small amounts.
It is entirely possible that the CDPR will follow suit of other recreational states like Colorado, Washington and Oregon by banning the use of myclobutanil in cannabis cultivation. Federal regulations from the Environmental Protection Agency (EPA), U.S. Food and Drug Administration (FDA) and the Federal Register allow for the use of myclobutanil for various dietary and non-dietary crops. Myclobutanil, when absorbed via the most common route, through consumption of foods it is presently on, is metabolized by gastrointestinal enzymes and the liver prior to entering the bloodstream.
The fungicide myclobutanil is sold under the name Eagle 20 or Nova 40 and is used to eliminate powdery mildew and black rot on agriculture. Dr. Jeffrey C. Raber is the Co-Founder and Chief Visionary Officer of The Werc Shop, which is a certified laboratory for cannabis testing services. Dr. Raber provided CULTURE with more insight into the potential dangers of using myclobutanil on cannabis. “What we know is that if you heat myclobutanil via combustion (not so sure about the extent of that via vaporization), it decomposes to form cyanide,” Dr. Raber said. “That’s certainly nothing anyone should ever inhale!”
We know that when smoking cannabis, the plant matter must be heated in order to activate cannabinoids like THC. The THCA in cannabis begins to decarboxylate, turn into THC, at approximately 220 degrees Fahrenheit after around 30-45 minutes of exposure. Although full decarboxylation may require more time to occur, the integrity of both cannabinoids and terpenoids are compromised if you use temperatures over 300 degrees Fahrenheit.
Myclobutanil begins its decomposition after its reached its “boiling point” at 401 degrees Fahrenheit, and begins to produce hydrogen cyanide.
However, since myclobutanil is permitted for use on various food items, there seems to be some maneuverability for the cannabis industry, specifically in the cannabis edibles market. Most cannabis edible manufacturing does not reach a temperature of 401 degrees and therefore would not reach the boiling point to produce hydrogen cyanide.
If myclobutanil is allowed to be used in cannabis edibles that do not exceed temperature or set parts per million (ppm) limits for safe presence, then the industry would remain competitive with other commercial agricultural sectors. With California primed to be the largest cannabis market on the planet, it could be argued that a decision to allow fungicides like myclobutanil in the realm of cannabis edibles, could open up doors to a highly competitive market.
The EPA is primarily responsible for controlling which pesticides and fungicides are permitted in the United States. Currently, federal regulations allow for myclobutanil to be used in the cultivation of various fruits trees, nut trees, vine fruit, mint and vegetables. Additionally, myclobutanil is routinely found in soybeans, hops, milk, eggs and meats. Acceptable levels of myclobutanil vary between different food items and are outlined in the Code of Federal Regulations. The general tolerances for myclobutanil include: 9 ppm in cilantro leaves and leafy greens, 0.5 ppm in apples, 0.02 ppm in eggs, 1 ppm in grapes, 0.1 ppm in almonds and 0.25 ppm in soybean seeds.
Experts like Dr. Raber are hopeful as the cannabis industry waits to see what regulations will be proposed for cannabis products. “We’re not sure what may be permitted on edible products, the draft regulations only come out this month.”
California advocates, entrepreneurs and experts wait patiently to see what the CDPR will decide on in developing the standards for pesticide and fungicide use for cannabis and cannabis edibles.