New medical marijuana testing regulations -- which match current requirements for retail marijuana -- go into effect July 1 in Colorado. The rules include medical marijuana, concentrates and medical marijuana-infused products.
The new rules require testing for microbials (E. coli, salmonella and total yeast and mold) for flower, infused products and concentrates. Also, solvent-based medical marijuana concentrates must be tested for residual solvents. Products are also visually inspected for mold and filth.
The new regulations also determine THC potency for medical marijuana-infused products meant to be homogenous. The product will fail potency testing if 10 percent of the infused portion contains more than 20 percent of the product’s total THC content. The THC tested cannot vary more than plus or minus 15 percent.
Potency testing must include concentration levels of THC, THCA, CBD, CBDA and CBN. Initially, a cultivator must submit four samples of each strain for potency one week apart, then a new sample to be tested again at least once every six months after.
Validation of process testing for contaminants is required annually, in which every harvest from at least four to six weeks (depending on the product) is tested. If the production process passes, testing is not required until the following year.
A production batch of medical marijuana is only exempt from testing (except solvent testing) as long as the entire batch is being used to make medical marijuana-infused products, which are then tested.
If a product fails, the producer submits three additional batches for testing within 30 days. If one of those batches fails, the operation must re-validate its testing for contaminants. Failed products could be required to be quarantined, or destroyed if failed for either contaminant or potency testing.
The full rules are available online here. The regulations on test criteria begin at section M712, and the details of the testing program begin at M1500.
The new mandated testing is more stringent than the previous rules, but it will provide some consistency in medical marijuana products, says David Cunic, CEO of Pazoo, Inc., a medical cannabis testing lab.
“We want to ensure that the end user gets the safest, most consistent product possible,” says Cunic. “I think it’s great for the industry. I think it’s showing the rest of the country that this commodity, this drug needs to be taken on a more serious level.”
The cost of testing could be a strain for smaller grow operations that haven’t had to test yet, says Luke Mason, president of Aurum Labs in Durango, Colo., but medical edible dosages will be significantly improved with more quality control in the production process that comes with required testing.
Growers could feel the pressure of testing, but shouldn’t expect it to stop coming, says Cunic.
“If the growers are upset with the rules and regulations getting tighter and stricter, it’s going to happen no matter what,” he says. “If it doesn’t happen now, it’ll happen six months from now, next year. And some of the growers are very happy with the tighter rules because they feel they make a great product.”
Mandatory testing will be phased in over time, starting with flower potency, says Mason. CBT was unable to confirm whether all testing is mandatory effective July 1 or implemented at a later date. The labs are all “working to be ahead of the curve when medical testing comes online in regards to staffing and instrumentation capacity,” he says, adding that it’s difficult to predict that capacity since the official dates for mandatory medical testing are still up in the air.
Initial rounds of proficiency testing in Colorado show the licensed and certified labs are proficient in testing flower potency, and working with the Colorado Department of Public Health and Environment to develop testing protocols for other products, says Mason.
But a mandate is necessary to bring medication to one standard, says Cunic, who is also a physical therapist.
“When you take your Advil or Aleve, you want it to work every single time,” he says. ”If we’re truly going to use this as a medication, as professionals, you need to have consistency.”
