Passing the Test, part 4: The Reformers


Despite the challenges AZ’s oddly written medical marijuana program created for Desert Valley Testing and Delta Verde Labs, the companies adapted to the ecosystem and thrived, even though, at any time, their facilities could have been raided and their employees charged with possession with intent to distribute.

Before the passage of SB1494 this year, AMMA said nothing about testing of cannabis nor the legal rights and responsibilities of those who did the testing. Still AZ’s MMJ program continued to expand. The patient count rose to be the 3rd highest in the nation.

Soon AZ marijuana production was being measured by the ton. None of it tested. By late 2016, a deadly fungal pneumonia outbreak in Northern California had been traced back to moldy marijuana sold to HIV patients with compromised immune systems.

The One and Only

Meanwhile as state after state adopted their own medical marijuana programs with testing built in from the beginning, Arizona continued to resist the call to protect its patients. By the end of 2018, it was clear that Arizona’s medical marijuana program was the one and only state in the nation that did not test the medical marijuana sold to patients.

Michigan, Rhode Island and Montana all came online last year, leaving Arizona as the sole state not protecting patient safety,” says Lezli Engelking, founder of FOCUS (Foundation of Cannabis Unified Standards). And it might have stayed that way if not for the work of two labs.

Ryan Treacy, founder of Mesa-based C4 Labs pushed for years to find legislators willing to put their reputations on the line for the good of AZ’s MMJ patients. His first break didn’t come until Treacy’s chief scientist of the time, Dr. Hope Jones started working with Sen Sonny Borrelli to craft the testing provisions of his 2017 hemp bill.

Then, last year, as George Griffeth was preparing to launch his new testing company, Level One Labs, the two started working together. For years, patient health concerns were largely ignored. But with Griffeth and Treacy doggedly throwing themselves into the battle, soon AZ MMJ testing movement became a force to be reckoned with.

C4 Labs

1930 S Alma School Rd, Suite D206, Mesa, Arizona 85210480-219-6460

In 2014, Ryan Treacy was a successful executive-level businessman when his boss insulted him one final time. “In the corporate world, when they want to roll out something new that is going to make things worse for the customer, they send out these talking points to teach you how to lie to the public. And it just wears on me as a professional to be told to lie.”

Giving up his 15yr position as executive general manager for Applebee’s was not an easy choice. “Luckily, or unluckily, I had a truly awful boss, who drove me crazy and gave me very little appreciation. The final straw was him handing me those talking points and ordering me to lie to the public for him. Not only did it drive me out of the corporate world, it has been also a powerful lesson of the kind of boss I want to never become.”

So Treacy began looking for his exit strategy. A cannabis enthusiast himself, Treacy was already interested in AZ’s new cannabis industry. “Once I saw that the medical end was really real and decided I was done with working for crappy people and being controlled by the stigma, I started a market analysis to identify the opportunities.”

An Ideal Opportunity

He studied the emerging AZ cannabis market, looking for voids to fill. Faced with the host of obstacles involved with getting in on the cultivation/dispensary end, Treacy quickly identified the startling lack of quality assurance in the program. At first, he was hoping to only become an ancillary player, but the limited number of testing labs in the state made it seem like the ideal opportunity.

“It was crazy to me nobody knew what was in their medication. I would call dispensaries, and everyone was saying they tested, but what they meant was they had tested once, and it was probably just potency and it was probably last year some time. It was totally unacceptable. But it was also the opportunity I was looking for.”

The hard charging Treacy founded C4 in 2014, within just a few months of Desert Valley Testing and Delta Verde Labs in a medical marijuana market that wildly under-educated and unrealistic in their expectations. “We were hemorrhaging money for the whole first year. We received a lot of pressure back then for not just going with the flow.”

“Back then most people in the business did not like the idea of testing because they had only encountered some of those shady testers from back in the day. But we were like the reed that wouldn’t bend. It almost broke us, but, luckily, enough brands came around and respected the science,” Treacy explained.

“Brands Came Around and Respected the Science”

When he started, C4 had a tiny office space, two machines and 2 scientists. By 2018, Treacy’s fortunes had taken a decided turn for the better. That year Ryan Treacy won industry website, Cashinbis’ Person, Company, and Entrepreneur of the Year Awards and was featured in Dope Magazine. Nowadays the C4 labs fill a 2500 square lab and employs a dozen workers who receive a full-benefits package for their work. His lab staff also participates in the continuing education development  sending his staff to  ASU Masters courses in biochemistry program.

Since day one, Treacy’s right hand man has been Aaron Hicks, who does the internal verifications on all C4 projects. “He has 25yrs of analytical chemistry and the last ten specifically in cannabis testing. Around the office Hicks’ nickname is “Swiss,” as in he’s like a Swiss Army Knife and can develop a tool for anything,” Treacy laughs. Treacy takes great pride in his staff.  Another, Dr Hope Jones, catapulted from his lab to become an internationally in-demand cannabis consultant and expert witness.

Dr Hope Jones, formerly with C4, worked w Sen Sonny Borrelli to create testing rules for hemp which helped launch legislative interest in MMJ testing.

Unlike DVT, at C4 all the staff are patients. Treacy has avoided partnering with any dispensaries in exchange for the protection from their licenses. “If we’re going to claim to be an independent lab, we need to be independent!” Treacy insists.

The lab keeps a white board posted on the wall showing how many grams of samples they have on hand at any given time and how many grams their combined patient allotment will allow them to possess. “We never go higher than 60% of our allotment totals,” Treacy says reassuringly.

No More Bro Science

As part of the push to continuously improve testing in the state, C4 is one of the labs pursuing lab certification from the International Organization for Standardization, aka ISO. “We’re about 100 days from Iso accreditation, and already ISO compliant when it comes to our equipment and protocols.”

Treacy is so certain that ISO is the way to go for the state, he pushed to have ISO accreditation as a requirement for all AZ cannabis labs as part of the new testing bill. “It needs to be a requirement so we can get past this era of pretender labs shaming the whole field by practicing ‘bro science.’”

“At first everybody was obsessed with THC percentages and literally nothing else. Eventually they started getting interested in terpene profiles also, but less than 20% of my customers were doing any health and safety testing. Still, it’s under 5% who go for the full battery of tests.”

Treacy understands the cost burden dispensaries and their cultivators will take on to establish a fully tested market. Currently it can cost upwards of $350 to get a complete testing package, but as the state requirements take effect and the volume of tested cannabis increases, Treacy, like all of the labs, is preparing to purchase additional equipment, but it won’t be an easy lift. Some testing equipment costs as much as $350,000.00 for a single LC Triple Quad.

Chemist Zach Hanes looks over the top of a GC FID’s multiple wires and tubes.

Not an Easy Lift

Treacy prides himself on C4’s client and customer service. “We’re in the role of educator, teaching people about cannabis and what they need to understand to protect their health.” It was Treacy’s customers who first alerted him to the health and safety issues in the industry by the buying patterns of the tests they were ordering.

C4’s customer base is mostly dispensary cultivation facilities. Treacy estimates about 85% of his customers are in the industry, with caregivers making up about 10% of his business and patients themselves rounding out the total. C4 offers free testing for any veterans, pediatrics, terminally ill, or first responder-patients who are worried about their medication.

Treacy consults with patients to help identify strains with the most beneficial terpene profiles for their specific conditions. “It helps some patients achieve an almost pharmaceutical level of accurate dosing.” Given the costs of labor, supplies and equipment, Treacy spends over $2000 a month on his free patient testing program.

A Special Relationship with the Patient Community

C4 also has a special relationship with testing advocates in the patient community. For the past 4yrs, C4 has served as the official lab for Jim Morrison’s Errl Cup events. “This most recent competition was the worse. Seven out of every ten flower entries were testing positive for high amounts of yeast and mold. The fact that companies think they can get away with selling these kinds of products to the unsuspecting public drives me crazy. It’s basically consumer fraud.”

Treacy looks at the passage of SB1494 as one of his proudest accomplishments. “I guess I could have tried to just keep my head down and go with the flow, but never been the kind of guy I am.” Treacy first approached AZ-NORML in 2015 to try to establish testing in the AMMA, but at that point the issue had no traction.

After a few sessions of fighting in the background and getting steamrolled at the Capitol with their testing efforts, in late 2018, Treacy, along with George Griffeth, the owner of Level One Labs, decided it was time for the lab industry to step up its game and play politics like the big boys. First C4 joined the ADA to demonstrate they were not intending to be a challenge to the industry.

Next working with Griffeth, Treacy helped found the Arizona Cannabis Lab Association to organize the testing industry and develop a unified voice. It’s a move Treacy is particularly proud of, “Bringing ACLA into the discussion is a huge step forward. Having the labs working together makes it better for all concerned. It’s an opportunity to get it right.”

“Since we started out with an unregulated market, we’ve had to build slowly according to what the market can bear,” Treacy acknowledges. “Making change in an unmandated state is a long grind. Very rarely do you find a win-win solution for everyone involved. This is something I will be proud of for a long time to come.”

Level One Labs

1525 N Granite Reef Rd Suite 11, Scottsdale, AZ 85257, (480) 867-1520

As SB1494 battled its way through nine stakeholder meetings and seemingly endless modifications, no one watched the legislative action any closer than George Griffeth of Level One Labs, one of the valley’s newest cannabis testing facilities. “By the time we were done, 1494 was a truly amazing bill. A testing bill, a rural dispensaries bill, a card cost reduction bill, it has it all,” he grins.

In 2017, Griffeth, now “a recovering litigator,” and longtime cannabis supporter, was hating his 8-5 job as in-house counsel for a medical transportation company. “When I went into law, I thought I was going to helping people, but in the end, I was only helping multinational corporations.” Meanwhile George’s son and best buddy, Conner had moved to Colorado to work in the cannabis industry. George even joined the Colorado Bar Association in preparation for moving from the Arcadia area of Scottsdale that he loved so much.

However, Conner’s experience in the CO cannabis world had turned decidedly sobering. Hired by a major cannabis cultivation company, Conner worked as the head grower’s assistant and things weren’t going well. Their products kept failing to pass the testing standards. “For three months, we could not produce a single plant that passed the safety standards due to the conditions in the cultivation site. It was the company’s own fault. Before long it triggered my ethical responses and I just had to quit.”

“The Work We Do Does Help the Public”

As George examined the Colorado cannabis scene, he quickly realized it was already over-saturated. Same with Nevada. However, in AZ, the limited number of testing labs provided an opportunity and Conner’s experience in CO showed how important testing could be. “Working in this lab space, I know the work we do does help the public.”

The Griffeths hadn’t intended to change AZ marijuana laws when they got started, but the idea of working in an unmandated, unprotected market with no safe harbor to even do their jobs was too much. “Hats off to those brave pioneers like DVT, Delta Verde and C4!” George exclaims.

“But,” he went on, “our tagline of ‘quality robust science’ could only be achieved with the legal support of DHS. We couldn’t do quality robust science unless DHS mandated testing. And AZ’s 200,000 patients were demanding it, dying for it, literally.”

Having watched the struggles SB1420 faced in 2018, George knew the labs needed to step up their political game and reached out to the other labs to rally support. Almost immediately Griffeth connected to Ryan Treacy of C4. They saw the need for an association of Arizona’s testing facilities if the cannabis labs were to ever get protective legislation passed testers. “We kept watching and waiting for the legislature to do the right thing. Eventually we realized we needed to have more political power if we seriously wanted them to act.”

“I understand why the legislators were resistant. Between the federal prohibition, the party divide and the stigma all hounding cannabis, their objections had to be dismantled one brick at a time,” Griffeth laments. “Besides sometimes good legislation takes a couple years to build. SB1494 succeeds because it was built on the shoulders of SB1420.

Crowded stakeholder meeting at AZ House.
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The Griffeths hope that the DHS testing advisory board will take a centrist approach to the testing. “Look at the states that have faced problems, it comes from overly restrictive testing expectations. Like Jim Clark of Delta Verde Labs says, ‘You could come up with standards and protocols for testing for moon dust, but do you really need to?’” he laughs. “I just hope that whatever science is suggests to Dr. Krist (Kara Krist, current director of DHS) is centrist and doesn’t create the artificial choke points that have sprung up in other state programs.”

Based in south Scottsdale, Level One opened for business in February of this year. The lab is now equipped with all the high dollar equipment and bells and whistles of any top-flight testing company: GCMS, HPLC, qPCR and another whole host of equipment known by confusing initials.

Currently they test for 12 cannabinoids and 41 terpenes. Samples are weighed on an extremely precise balance beam scale in a glass case to reduce wind interference. Like Desert Valley Testing, Level One, to reduce vibrations, the scales are on set on marble tables weighing as much as 600lbs.

The Grossest Testing Story

Level One takes the prize for the grossest testing story, told by lab co-owner, Conner Griffeth. “So, this one lady comes in with a box of infused truffles. They came in a four-pack and when she opened the package, without even thinking she popped the first two in her mouth right away. They tasted nasty, so she went to look at the box, she accidentally dropped a third one. It hit the ground and broke open and inside, instead of nougat, it was filled with fibrous mold—Aspergillus.”


Blue lights inside Level One’s microbiology room.

Part One: The Long Road to Safety

Part Two: Basic Primer on Testing and its Many Incomprehensible Terms

Part Three: The Pioneers (Desert Valley Testing & Delta Verde Labs)

Stay Tuned for Part Five, The Up and Comers (KB Labs and Pure Labs).

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