The “Action Levels” for cannabis pesticide residues in Oregon are based on a single 2015 technical report from the Oregon Health Authority (OHA), comprised of a “Working Group” of non-medical experts assembled by OHA from across state agencies, laboratories, and industry.
The absence of any kind of medical expertise in this group, or in any Cannabis pesticide regulatory activity since seems negligent at best and places millions of people in Oregon at ongoing daily risk for lifelong harm. Here’s the original report:
Here are the individuals and their organizations listed in the report as responsible for the creation of Oregon’s current pesticide residue standards:
Members of the Working Group
- David G. Farrer, Ph.D. – Public Health Toxicologist, Oregon Health Authority (author of the technical report)
- Brian Boling – Laboratory Program Manager, Oregon Department of Environmental Quality
- Theodore R. Bunch, Jr. – Pesticide Analytical and Response Center Coordination Leader, Oregon Department of Agriculture
- Keith Crosby – Technical Director, Synergistic Pesticide Lab
- Ric Cuchetto – Known as “The Cannabis Chemist”
- Camille Holladay – Lab Director, Synergistic Pesticide Lab
- Mowgli Holmes, Ph.D. – Phylos Bioscience and Cannabis Safety Institute
- Rose Kachadoorian – Oregon Department of Agriculture
- Jeremy L. Sackett – Cascadia Labs, Cannabis Safety Institute, and Oregon Cannabis Association
- Bethany Sherman – Oregon Growers Analytical and Cannabis Safety Institute
- Shannon Swantek – Oregon Environmental Laboratory Accreditation Program, Public Health Division, Oregon Health Authority
- Rodger B. Voelker, Ph.D. – Lab Director, Oregon Growers Analytical
These individuals, all well-qualified professionals but none with any medical credentials in any field (that I can find), were appointed by OHA, an agency well-populated with medically-credentialed professionals who were apparently never involved, to shape Oregon’s cannabis testing regulations, including the development of pesticide action levels and analyte lists.
So, without any documented reference to any published scientific or medical literature on the effects of pesticide exposure, either through inhalation of by any other “mode of action”, this “Working Group” went through the process of deciding which pesticides in what concentrations would be allowed on Oregon cannabis. From that point on, these standards have ruled what Oregon smokers and vapers are inhaling.
While there hasn’t been any review, medical or otherwise, of these standards since they were set, there have been several important opportunities for medical involvement since the original working group established Oregon’s cannabis pesticide action levels. Let’s see if anyone managed to change anything.
Regulatory Updates and Ongoing Oversight
- Biennial Review of Pesticide Standards The Oregon Health Authority (OHA) is required to review and update the list of pesticide analytes and action levels at least every two years. This is supposed to ensure that the standards remain aligned with current toxicological data and industry practices. Although OHA has many medically qualified people on staff, I can find no evidence that any medically qualified people have been involved in any of these reviews, nor have any of these biannual reviews made any reference to the pesticide and human health toxicology findings published in the scientific and medical literature that has evolved since 2015.
- Oregon Liquor and Cannabis Commission (OLCC) Rule Changes The OLCC approved new cannabis and hemp regulations that took effect in 2022. These updates aimed to improve product safety and streamline oversight, including testing protocols and lab accreditation. I can find no evidence that any of the Action Levels set in 2015 have been reviewed by any medically qualified individuals considering current established medical knowledge regarding pesticide exposure and health consequences.
- Oregon Department of Agriculture (ODA) Cannabis Pesticide Guide List The ODA maintains and regularly updates a guide list of pesticide products that may be legally used on cannabis. This list is reviewed annually. The most recent update was in July 2025. There is no mention in the documentation of any reviewers of this list being medically qualified individuals, nor is there any reference to current established medical knowledge regarding pesticide exposure and health consequences.
- Legislative Action and Oversight Oregon’s legislature has passed multiple bills affecting cannabis regulation, including HB 2931 (2023), which established a State Reference Lab to support consistent testing standards across licensed labs. This lab could play a role in refining pesticide testing methodologies and validating results. I cannot find any evidence of the involvement of medically qualified individuals in the establishment or operations of this lab.
Working Group Continuity?
While the original “Working Group” hasn’t formally reconvened according to public records, many of its members or their affiliated organizations, like the Cannabis Safety Institute, Cascadia Labs, and ODA, individually and together continue to influence policy and technical standards through advisory roles, public comment, and collaboration with state agencies. Many are on LinkedIn, and a review of their profiles also reveals no medical qualifications and with one minor exception no activity related to pesticides and human health – and absolutely none related to current medical or scientific knowledge regarding pesticide inhalation toxicology.
Even in the most recent 2025 OLCC technical report, which reviews pesticide and potency testing across Oregon’s cannabis market, the contributors are again primarily from the Oregon Liquor and Cannabis Commission (OLCC), Oregon Department of Agriculture (ODA), and Oregon Health Authority (OHA), and none are identified as medical professionals.
What Could The Working Group Have Known About Pesticide Exposure in 2015?
By 2015, the health effects of pesticide exposure were already the subject of a large and diverse body of scientific literature, especially in occupational and environmental health contexts. There had been no studies on the health effects of chronic low-level inhalation of multiple pesticides which is the unique route of exposure for all cannabis smokers and vapers. Here’s what the “Working Group” experts had access to at the time:
Existing Medical Science Before 2015
Scientific knowledge by 2015 consistently linked chronic pesticide exposure to a range of health conditions, with some associations being stronger for specific chemical classes. There were warning signs all over the place. There was also institutional awareness of specific populations at exposure risk, because OHA has tracked and published data on cannabis use in Oregon since the Medical Marijuana Act passed in 1998.
- Neurological disorders including Parkinson’s and Alzheimer’s: Epidemiological studies demonstrated an excess incidence of Parkinson’s disease among agricultural workers exposed to pesticides. Pesticide poisoning was also associated with brain disorders like Alzheimer’s.
- Developmental neurotoxicity: Studies confirmed the biological plausibility of developmental neurotoxicity, particularly from organophosphate insecticides like chlorpyrifos. Some cohort studies showed links between prenatal exposure and impaired motor skills or behavioral traits associated with autism spectrum disorders in children. (Thousands of Oregon children are born every year to smoking/vaping parents.)
- Cancer: Specific malignancies: Studies identified increased risks of certain hematologic malignancies, prostate cancer, non-Hodgkin lymphoma, and multiple myeloma among heavily exposed populations.
- Children’s brain cancer: Research prior to 2015 also showed that exposure before, during, or after pregnancy could increase the risk of childhood brain cancer.
- Probable carcinogenicity: In 2015, the International Agency for Research on Cancer classified glyphosate as a probable human carcinogen, based on evidence from animal models and some human studies.
- Endocrine disruption: Research showed that certain pesticides could interfere with hormone function, leading to developmental delays, birth defects, and reproductive issues. This was of special concern for highly vulnerable populations, including infants and children.
- Respiratory and reproductive issues: Chronic pesticide exposure was associated with increased respiratory problems and decreased fertility.
- Multiple exposure routes: By 2015, it was understood that pesticide chemicals could enter the body through direct contact (skin, eyes), ingestion (contaminated food or water), and inhalation (mist, dust).
- High-risk populations: Research highlighted the heightened vulnerability of certain groups.
- Agricultural workers and handlers were particularly at risk due to high occupational exposure.
- Children were more susceptible due to their physiology and behavior.
- Vulnerable communities: Some research in Latin America documented significant health effects among farmworkers and children exposed to organophosphates and other pesticides.
- Biomonitoring: Urine and other matrices were used in biomonitoring to measure pesticide metabolites and assess exposure, providing a more comprehensive view than relying solely on exposure history.
- Regulatory and safety standards in 2015
- By 2015, the body of evidence had prompted regulatory responses to improve safety for workers and the public.
- Worker Protection Standard (WPS) updates: In November 2015, the U.S. Environmental Protection Agency (EPA) finalized revisions to the WPS to strengthen protections for agricultural workers and handlers through improved training, notification, safety information, and personal protective equipment.
- Consideration for children: The U.S. Food Quality Protection Act (FQPA) of 1996 had already mandated that the EPA consider the unique risks to infants and children when setting pesticide tolerance levels in food, a direct result of earlier scientific findings.
- In summary, by 2015, scientific understanding of pesticide exposure had grown considerably, shifting from a focus on acute poisoning to a comprehensive assessment of chronic, low-level health risks. The medical community had identified links to neurological disorders, multiple types of cancer, endocrine disruption, and other serious illnesses, leading to more stringent regulations and a greater awareness of occupational and childhood vulnerabilities.
So while the data on pesticides and human health available to the working group, if it had been reviewed, was extensive, it was also heterogeneous and sometimes inconclusive, especially for low-dose, long-term exposure effects. The Working Group’s task was complicated by the fact that there has been no research at all on the health effects of tobacco product pesticide inhalation since the 1970s. That all made setting precise “no effect” thresholds challenging, although there is also no record of any consideration by the Working Group, or OHA, or the State of Oregon, of the creation of a “pesticide-free” category for Cannabis standards.
So while experts in 2015 had access to robust general & pesticide-specific toxicological data, they were working with limited cannabis-specific regulatory frameworks and no federal guidance. A review of the meeting records shows that their decisions were based on extrapolations from EPA and USDA food crop standards and multi-agency occupational exposure data, always taking a cautious approach due to the legal and scientific uncertainties.
Why This Matters
Pesticide risk assessments by EPA, FDA and others, are almost universally based on intermittent single pesticide oral/ingestion toxic-level exposure data, not continual low-level multiple pesticide inhalation exposure data. As noted in a Cannabis Safety Institute white paper, inhalation involves pyrolysis products with unknown toxicities, and bypasses first-pass metabolism, potentially increasing systemic exposure. Further, pyrolysis creates a dry distillation environment where the pesticide chemicals interact and evolve. Finally, pyrolysis is only one of the processes that contribute hazardous elements to the smoke stream, and is not involved at all in vaping. Safety considerations appear to have been seriously under appreciated.
These distinctions are critical, yet it appears that no medical expertise in chronic or metabolic diseases, neurological diseases, developmental diseases, respiratory toxicology or pulmonology has been formally or publicly integrated into Oregon’s Cannabis pesticide regulatory process.
I’ll leave it to others to decide how much risk this has created for Oregon smokers and vapers, and especially for the children of any who have smoked or vaped cannabis since 2015, and whether the top bureaucrats at these state agencies ought to be held personally accountable for what they either knew or ought to have known about the absence of medical consultation in their standards-setting process.
To back up my initial conclusions on the absence of medical involvement, I did a search of public comment records from the Oregon Liquor and Cannabis Commission (OLCC) and the Oregon Health Authority (OHA). I wanted to see if there is any record of medical professional concern or involvement through public comment. Here’s what I found:
What’s Current and Available Online
- OLCC Technical Reports and Rulemaking Documents The OLCC’s 2025 Technical Report includes acknowledgments and contributors but does not list public comments or medical professionals involved in pesticide standard-setting.
- Legislative Hearings and Task Force Records The Oregon Legislature’s HB 3000 Task Force presentation outlines interagency collaboration between OLCC, OHA, and ODA, but again, no mention of medical professionals in public comment or advisory roles.
- OLCC Data Portal The OLCC Data Portal provides access to licensing and compliance data, but not public comment archives.
Still No Sign of Medical Involvement
So far, there’s no documented evidence that licensed medical professionals have submitted public comments or been formally consulted in the development of pesticide action levels for cannabis. The process remains dominated by regulatory scientists, chemists, and industry stakeholders. You can check public comments for yourself:
https://www.oregon.gov/olcc/pages/public-records-request.aspx
https://www.oregon.gov/oha/pages/public-records-request.aspx
There is an apparently a complete absence of anyone with medical expertise involved with a massive public health threat – over 1.2 million people age 12 and over use Marijuana daily in Oregon. There is no legitimate reason why Oregon doesn’t have a “Pesticide-Free” classification for Cannabis that would allow citizens to make an informed choice about the safety and long-term health impact of what the state permits them to consume. There’s also no good reason not to list the test results for every batch from every grower on a public website.
As a final backup to all this, today I’m submitting the following Public Records request to both OLCC and OHA.
Subject: Public Records Request – Medical Professional Involvement in Cannabis Pesticide Standards
To: Records Officers OHA/OLCC
Date: August 25, 2025
Dear Records Officer,
Pursuant to Oregon’s Public Records Law (ORS 192.311 to 192.478), I am requesting access to all public records in any form and from any source related to or demonstrating the involvement of licensed medical professionals in the researching or documentation, development, review, or public comment process concerning pesticide residue standards for cannabis and cannabis products in Oregon.
Specifically, I am seeking:
- Records of public comments between October 1, 2015 and August 25, 2025, made in person or submitted by individuals or organizations internal or external to OHA or ODA who possess any recognized medical credentials (e.g., MD, DO, MPH, PharmD, or equivalent) regarding pesticides and human health, cannabis pesticide action levels, or pesticide analyte lists.
- Meeting minutes, correspondence, or advisory group rosters that include participation by any qualified medical professionals external or internal to OHA or ODA in the rulemaking or technical review process for cannabis pesticide standards.
- Any internal communications or memoranda referencing consultation with medical professionals external to OHA or ODA on the health impacts of exposure to or inhalation of single or multiple pesticide residues in cannabis products.
If these records are available electronically, I would prefer to receive them in digital format.
If fees apply, please inform me of the estimated cost before fulfilling this request.
Thank you for your compliance, and assistance. I look forward to your timely response.
Sincerely,
Bill Drake
panaceachronicles 