Important Information for all Medical Marijuana Dispensaries, Growers, and Patients
Advanced Nutrients – The Med Deception
Recently (June 2010) Advanced Nutrients made this announcement via PR Newswire (www.prnewswire.com).
“SEATTLE, June 3 /PRNewswire/ — In a landmark decision, Oregon regulators have given first-ever official US approval to a brand of medical marijuana hydroponics nutrients.
Oregon and most other states have regulatory agencies that examine fertilizers and hydroponics plant supplements to determine the legitimacy, ingredients and effectiveness of plant growth products.
Advanced Nutrients co-founder Michael Straumietis welcomes the news that Oregon’s government proffered formal approval for an Advanced Nutrients formula designed for a specific strain of medical marijuana.
“Regulatory approval is a breakthrough for the medical marijuana community,” Straumietis explains. “For the first time, government regulators have examined and affirmed the use of crop-specific medical marijuana hydroponics nutrients.”
Until Straumietis asked regulators to evaluate the medical marijuana effectiveness and safety of Advanced Nutrients hydroponics formulas, regulators nationwide had apparently never considered how hydroponics nutrients specifically affect medical marijuana crops.
”It hasn’t been part of the discussion, until now,” Straumietis explains. “For example, when fertilizer regulators evaluate fertilizers that have labels claiming to produce larger tomatoes, they require specific efficacy data proving those claims. Now Oregon regulators have opened the door for formal evaluation of hydroponics nutrients and medical marijuana growth, quality and yield.”
Oregon medical marijuana patients, cultivators, doctors and advocates applauded the regulatory decision, citing their long-held concern that regulators were not looking at how hydroponics nutrients interact with medical marijuana.
“Advanced Nutrients and the medical marijuana community give kudos to Oregon regulators for being the first state regulators to evaluate the science of medical marijuana and hydroponics nutrients,” Straumietis says. “Our community is looking for similar action from regulators in other medical marijuana states.”
It was big news. According to Advanced Nutrients they had scored an industry coup. US agricultural regulators were now working with arguably the shadiest company in the hydroponics industry to boost illicit crop yields or, at least this is what Advanced Nutrients would have you believe.
A Letter to Advanced Nutrients from The Oregon Department of Agriculture
“June 17, 2010
Oregon Department of Agriculture
635 Capitol Street NE
Salem, OR 97301-2532
Sent by Certified Mail
NOTICE OF NONCOMPLIANCE
A recent Advanced Nutrients PR release titled, “Hydroponics Nutrients for Medical Marijuana Gain Government Approval” …
As I explained in a letter of February 23, 2010, to Advanced Nutrients, “labeling” means any printed or verbal representation used to promote the sale of any fertilizer, agricultural mineral, agricultural amendment or lime product. Labeling includes, but is not limited to: sales presentations, brochures, posters, websites, printed advertisements, radio and television advertisements [ORS 633.311 (14)]. Press releases are a form of labeling.
Oregon statute [ORS 633.366(2)(a)] considers a product mislabeled if the label or labelling is “false, misleading or deceptive.” Using Webster’s Third New International Dictionary as a guide, a claim is misleading if it, “lead in a wrong direction or into a mistaken action or belief.” Further, in identifying “mislead” as a synonym to “deceive” the dictionary states that “mislead” “indicates a causing to fall into error of some sort, intentionally or not.” Products with labels or labeling using terms or claims that may mislead a consumer are mislabeled, and prohibited under Oregon law.
1) This press release states, ” .. . Oregon regulators have given first-ever official US approval to a brand of medical marijuana hydroponics nutrients …
The online version of the Merriam-Webster Dictionary defines approve as “to have or express a favorable opinion of.” Product registration means a product has met the minimum requirements for sale or distribution in Oregon. No opinion, favorable or otherwise, is expressed or implied. This statement, which applies to the entire Advanced Nutrients brand, is false and misleading.
2) This press release states, ” . . . Oregon regulators have given first-ever official US approval to a brand of medical marijuana hydroponics nutrients … ” In fact, Oregon has registered two Advanced Nutrients products with label claims stating the product is for the production of medical marijuana. Individual products are registered for sale or distribution , not brands. This claim, which applies to the entire Advanced Nutrients brand, is misleading.
3) The press release stated, “Until Straumietis asked regulators to evaluate the medical marijuana effectiveness and safety of Advanced Nutrients hydroponics formulas, regulators nationwide had apparently never considered how hydroponics nutrients specifically affect medical marijuana crops.”
To date, Oregon has not received a request from Mr. Straumietis to “evaluate the
medical marijuana effectiveness and safety of Advanced Nutrients hydroponics
formulas …. ” This labeling claim is false, and all “Advanced Nutrients hydroponic
formulas” may be considered mislabeled.
4) This press release stated, “Until Straumietis asked regulators to evaluate the medical marijuana effectiveness and safety of Advanced Nutrients hydroponics formulas , regulators nationwide had apparently never considered how hydroponics nutrients specifically affect medical marijuana crops.”
This claim, that a state agency, which might be considered as an independent evaluator, has evaluated and approved the safety of these products to produce medical marijuana is false. This claim is also particularly disturbing, as it appears to be targeted to mislead a particularly vulnerable population, medical patients who have turned to medical marijuana in hope of some relief of their symptoms.
The claim that Oregon, the state referred to in the PR release, has evaluated the effectiveness and safety of Advanced Nutrients hydroponics for use in the production of medical marijuana is false and misleading, and all “Advanced Nutrients hydroponic formulas” may be considered mislabeled…..”
Fertilizer Program Specialist”
I’ll post a lot more material shortly regarding the business practices of Advanced Nutrients so keep an eye on www.manicbotanix.com for further updates. In the meantime (to shorten a long story)…
Advanced Nutrients and the Oregon Department of Agriculture (the facts)
At present (October 2010) the ‘Oregon Department of Agriculture’ has issued Advanced Nutrients with five counts of stop sale violation, fifteen counts of selling unregistered products and eighteen counts of mislabeling. In addition, actions for sample deficiencies are in progress.
Prior to this, during the course of 2010 (Jan – Aug) Advanced Nutrients has been issued with numerous violation notices/penalties by the Oregon Department of Agriculture.
E.g. (Excerpts from FOIA material)
“Advanced Nutrients 0-15-40 Big Bud
On April 29, 2009 the Department found this product being offered for sale or
distribution at Northern Light and Garden in Beaverton, Oregon. Subsequent analysis found it was deficient in magnesium (Mg), L-Arginine, L-Aspartic Acid, L-Glycine, LHistidine, L-Isoleucine, L-Leucine, L-Phenylalanine, L-Proline, L–Tyrosine, and L-Valine:
Claimed on Label
|Total Nitrogen||none claimed||0.944|
|Alanine – Total||0.3||0.348|
|Ammonia – Total||none claimed||0.225|
|Arginine – Total||0.8||0.194|
|Glycine – Total||0.7||0.146|
|Histidine – Total||0.4||0.132|
|Isoleucine – Total||1.1||0.475|
|Leucine – Total||0.9||0.747|
|Lysine – Total||0.2||0.624|
|Proline – Total||0.7||0.394|
|Serine – Total||0.4||0.381|
|Threonine – Total||0.3||0.504|
|Tyrosine – Total||1.3||0.209|
|Valine – Total||1.1||0.413|
…These deficiencies constituted false, misleading or deceptive label information, and the label did not accurately reflect the composition of the product, which was thus mislabeled in violation of ORS 633.366(1 )(a)…. “
Results of Analysis – Heavy Metals (Big Bud)
Results Submitted to Support Product Registration
|Arsenic (As)||EPA 3050B, 6010B||16.2 ppm||0.8 ppm|
|Cadmium (Cd)||EPA 3050B, 6010B||< 5 ppm||< 0.1 ppm|
|Mercury (Hg)||EPA 7471A||< 0.2 ppm||< 0.001 ppm|
|Lead (Pb)||EPA 3050B, 6010B||10.7 ppm||<0.5 ppm|
|Nickel (Ni)||EPA 3050B, 6010B||< 5 ppm||0.6 ppm|
Author’s note: Looking at the ‘Results of Analysis – Heavy Metals (Big Bud)’, the HM (Heavy Metal) content found in Big Bud during independent tests is far higher than is stated by Advanced Nutrients. It is important to note that I make a recommendation in ‘contaminants in cannabis’ (www.integralhydro.com/ advancednutrients), stating that Med dispensaries and/or growers should independently test fertilizers and not take manufacturer listings as fact. This is just one example of why I make this recommendation (there are many more). Further, the results of the HM tests indicate relatively contaminated synthetic fertilizers and/or organic components were used in production.
May – July 2010
“On July 12 2010, the Oregon Department of Agriculture (Department) conducted a marketplace inspection at Northern Light & Garden (9290 SW Beaverton-Hillsdale Hwy, Beaverton, OR 97005). During this inspection, the product(s) listed on the attached form were placed under an Oregon statewide Stop Sale, Use, or Removal. Order (SSURO).
The Department hereby instructs Advanced Nutrients and/or its agents to immediately cease all sales, offers of sale, or distribution of the product(s) listed on the attached forms into or within Oregon, by any type of business transaction or other method.
…It is a violation of Oregon Revised Statutes (ORS) 633.366(a) to sell, offer for sale, or distribute a fertilizer, agricultural amendment, agricultural mineral, or lime product that is mislabeled under ORS 633.321.
It is a violation of ORS 633.366(1)(e) to sell, offer for sale, or distribute unregistered fertilizer, agricultural amendment, agricultural mineral, or lime products in the State of Oregon.”
Products Listed in violation Jan – Aug 2010
Advanced Nutrients, 0-2-4 Bud Ignitor (unregistered)
Advanced Nutrients, Tarantula (unregistered)
Advanced Nutrients, Voodoo Juice (mislabeled)
Advanced Nutrients, Piranha (mislabeled)
Advanced Nutrients, 0-0-1 Tarantula (mislabeled)
5-0-1 Micro (unregistered)
Bud Factor X (mislabeled)
1-5-4 Overdrive (mislabeled)
0-2-4 Big Bud (liquid) (unregistered)
0-0-13 Rhino Skin (unregistered)
4.8-1.8-4.3 Mother Earth Super Tea Grow (unregistered)
50-1.50-2.0 Mother Earth Super Tea Bloom (unregistered)
Grandma Energy’s F-1 (mislabeled)
1.5-1.5-1.5 Grandma Energy’s Sensational Seaweed (unregistered)
Grandma Energy’s H-2 (mislabeled)
0-0-0.5 Organic B (unregistered)
2-1-6 Grow (unregistered)
B-52 (no grade, no guaranteed analysis) (unregistered)
3-1 -3 Organic Iguana Juice Grow (unregistered)
Dr. Hornby Voodoo Juice Microbial Rhizosphere (unregistered)
Bud Candy (unregistered)
Juicy Roots (unregistered)
0-0-13 Rhino Skin (unregistered)
2-0-0 SensiCal Mg Calcium and Magnesium Bloom (unregistered)
Sensi Grow (unregistered)
Sensi Bloom (unregistered)
Keep in mind that at present – in addition to these violations – the ‘Oregon Department of Agriculture’ has issued Advanced Nutrients with a further five counts of stop sale violation, fifteen counts of selling unregistered products, and eighteen counts of mislabeling. Actions for sample deficiencies are also in progress.
What is clear is that Advanced Nutrients have no regard for consumer protection policies and regularly engage in misleading and deceptive marketing. In this case they have lowered the bar even further and utilized commercially depraved tactics in order to deceive consumers.
What is most worrying is that Advanced Nutrients have used two credible entities (PR Newswire and the Oregon Department of Agriculture) to support and amplify the deception. This form of parasitic marketing is likely to influence med growers, users and dispensaries re medical marijuana growing practices (something that Advanced Nutrients are all too aware of). One is also left wondering whether my earlier article (Hydro Hype 1) on Advanced Nutrients, their phosphorous myth, and ‘Contaminants in Cannabis’, published in Feb 2010 on www.integralhydro.com might not have inspired this latest outburst of grotesquely distorted marketing (I.e. parasitic marketing times three).
Further, as one Oregon Department of Agriculture representative put it “This claim is also particularly disturbing, as it appears to be targeted to mislead a particularly vulnerable population, medical patients who have turned to medical marijuana in hope of some relief of their symptoms.”
Author’s Note: If you enjoyed and learned something from this article (and others) please give the site or pages you enjoyed a plug on forums (particularly if the information may help to educate others).