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E-Liquid Testing is a critical part of what we MUST do as a responsible members and E-Liquid Manufacturers in this industry. It is our responsibility to do everything that we can to ensure that the products that we provide to the Canadian Consumer is as safe as possible. We would hope that was a shared principle among all Electronic Cigarette businesses and E-Liquid Manufacturers in Canada but, unfortunately, that is not yet the case. For that reason, we wish to fully disclose our E-Liquid Testing practices and protocols so that you can be more confident and comfortable with your knowledge and ability to make an informed decision with as much information as possible.
As a member of the Electronic Cigarette Trade Association (ECTA) of Canada, we are required to send a minimum of three (3) E-Liquid Samples of various flavours and nicotine concentrations for testing at least once every six months. As a manufacturer, we always send more than three as we believe that we are the first line of defense in (and in direct control of) making our E-Liquids as safe as possible based on what is known "today". The laboratory that we use for our testing is accredited by Health Canada, Enthalpy Labs, located in Durham, North Carolina (USA). This laboratory was chosen for several reasons. A few of which are:
- Accredited by Health Canada
- Work with AEMSA so they are familiar with our needs
- Work closely with Dr. Konstantinos Farsalinos, M.D. on E-Cigarette Research
- Perform specific Electronic Cigarette research and lab studies for researchers internationally.
Upon receipt of our test results we review each sample and take any actions that are needed. As a member of ECTA, our results are also forwarded to a third party for audit and historical purposes. The third party auditor reviews the results, deems pass or fail for each sample and follows-up on actions taken for any issues that may have been identified in the results.
Testing Procedures / Protocols
Since this is a relatively new industry, testing procedures and protocols are evolving and expected to change as we learn more going forward. Ultimately, as a Tobacco Harm Reduction tool, we want to make these products as safe as possible and it will take the cooperation of all who touch this industry, from the Flavouring Manufacturer to the E-Liquid Manufacturer to the Retailer to the Consumer. We all play a part in our success or failure.
Currently, we are performing tests for the following:
The MDL is specifically important when performing E-Liquid Testing. For example, in the case of Diacetyl... If you are not familiar with Diacetyl, 2,3-pentanedione and/or 2,3-Butanedione they are basically compounds that contain certain ketones that have been linked, though the evidence is not conclusive, to the disease known as "Popcorn Lung".
The Occupational Safety and Health Administration (OSHA) has not set any "safe exposure limits" for inhalation of Diacetyl.
Because of this, ECTA has adapted a standard of non-detection for these elements. However, they have also adapted a temporary "pass" (with prescribed action) for a couple of lower detection levels for both Pentanedione and Diacetyl:
- Non-Detection of Pentanedione and Diacetyl is the ECTA standard to which all members must strive to achieve
- < 22 µg/ml (Diacetyl) and < 45 µg/ml (Acetyl Propionyl) no disclosure - This is a "caution" threshold, though while recommended, is not required for disclosure. Members are required to work towards removing the cause of the compound. Levels in this range are most often attributed to cross-contamination.
- < 100 µg/ml disclosure - This "caution" threshold requires disclosure to consumers if the eliquid remains on the market, and a plan to replace the flavorant with an alternative. Disclosure is required on a website (if applicable), in a Retail Location (if applicable), and optionally on the label of the product (pending stock level depletion)
- > 100 µg/ml (ppm) indicates a "FAIL" - This is above the upper limit and beyond ECTA standards. If an E-Liquid result shows higher than this level the member must immediately stop sale of that product and either discontinue or return the product to their shelves only after the E-Liquid is reformulated and re-tested to show that it has been corrected.
Also, we position Electronic Cigarettes as a Tobacco Harm Reduction tool, so our goal should be to eliminate as many harmful aspects as possible. Tobacco Cigarettes contain Diacetyl in concentrations of 250+ ppm. Therefore, whatever testing protocol is used should be expected to test to well below that level. Unfortunately, some GC/MS test results that we know of are only detecting to 0.1% (1000 ppm). That's 4 times the level found in a single tobacco cigarette. So what would that test even prove?
If you are using GC/MS testing, be certain to check and understand the lower detection limit for what you are attempting to detect.
The testing protocol that we are using is what they call HPLC/UV Analysis. HPLC/UV testing has a very low minimum detection levels for Diacetyl and Pentanedione. For that reason, you can have confidence that we DO know "what is in the E-Liquid". There is still more to learn and our testing protocols will be adjusted as needed.
The Test Result Reports are anywhere from 20-40 pages in length and are extremely detailed. Except for a few of the summary pages, they are quite complicated to understand if you are not of "that" background. Even after having long and detailed conversations with Enthalpy about the results, we still do not fully understand all of the content.
We have included excerpts of the pages containing the most relevant points. If you wish to obtain a copy of the full report, we can provide it to those enquiring, understanding the following:
- The Report is our property and not public domain
- The Report and it's content is being provided to you for personal use only
- You may not modify and/or re-distribute the report without our expressed written consent
- A conversation with us must take place to go through the report and answer any questions
- As stated above, we may not have all of the answers to any questions you may have
- We may refuse to provide any report if we believe your motives are unclear
- It may take several days for us to schedule time to send and review the report with you
Tests have been performed on the following:
- Feb 22 2017 : 0117-507 Enthalpy Analytical
Havana Cream - passed
Trent Severn Healy - passed
- May 13 2016: 0616-522 Enthalpy Analytical
Top Guns - passed
Trent Severn Crowe Bay - passed
Strawnana - passed
5 Star - passed
- Dec 12 2015 : 1115-597 : Enthalpy Analytical
Punch - passed
Twisted Lemonade - passed
Bottom of the Box - passed
- May 26 2015 : 0515-557 : Enthalpy Analytical
Pink Poison - passed
Pom Springs - passed
Bluenana - passed
Tropicolada - passed
- November 10th 2014 : 1214-120 : Enthalpy Analytical
Banana Mallow - passed
Sweet Bean Buzz - passed
Raspberry Pinto - passed
Mango Tango - passed
Swingin' Apple - passed (then reformulated - use of new flavour - retest )
- October 17th 2014 : 1014-178 & 1014-179 : Enthalpy Analytical
Crantastic - passed
Polar Vortex - passed
Peach Raspberry Medley - passed
Fantasia - passed
Grapeshifter - passed
- May 16th, 2014 : 0514-131 : Enthalpy Analytical
Red Leaf - passed
Chicka Chew - passed (discontinued Jan/16)
Swingin’ Apple - passed