Dear cannabis community,
We are writing to you in hopes that the intelligent minds of this industry can once more come together to help resolve a common issue that is known to effect many us, particularly those of us in distillation.
Currently, California Code of Regulations, Title 17 of Cannabis Manufacturing Licensing §40223. Ethanol Extractions (a) states that “Ethanol used for extractions or for post-extraction processing shall be food- grade”. This regulation inadvertently prohibits the use of ethanol which has been denatured with heptane. Solvents with the chemical makeup of: Ethanol: 95%, n-Heptane: 4.5%, Water: 0.5% are routinely sold to the cannabis industry as “High Purity Extraction Grade Ethanol for Cannabis and Hemp Extraction”. Because this particular solvent of interest contains heptane, it is no longer considered food-grade, thus deemed unusable. For the distillation community, the problem lies here. Although heptane is not considered food-grade, even at percentages used for denaturing, these solvents that are commonly used for extraction are fractionally distilled and separated from the product during the distillation process, leaving zero remaining residual solvents. Many hydrocarbon solvents, such as heptane, are allowed to be used during post extraction processes but not during extraction (under a Type 6 license), even though the solvent could potentially be touching the same product which can be once again distilled of all residuals.
The California Department of Public Health and Safety is currently issuing Ceased and Desist orders for violations of such practices. The ramifications of such circumstances include destroying product which has been completely refined, distilled, and accurately analyzed and tested by a state licensed cannabis analytical laboratory, as well as disposing of all ethanol denatured with heptane used for processing.
It is up to this community and this industry to advocate for the education of these processes and defend our rights to conduct the same chemical processing procedures seen in other industries. We are asking for help in fighting unfair regulations that hinder safe chemical procedures which are otherwise recognized as standards. If you are willing to help us and the community in this fight please help by writing a scientifically correct letter that supports the safe and regulated use of such practices that we can use as support. Every letter can help and is appreciated.
Santa Cruz, California