Cannabis may not pose any health dangers, but its contaminates do. If the products contain
bacterial and fungal pathogens, the result may be serious and even cause fatal infections, especially
if used by individuals with impaired immune systems. Laboratory testing and analysis is the cornerstone
of all medical and recreational cannabis legislation. This is why California has been in the forefront of
having rules in place to protect the public’s health by determining what
potencies and residuals must be tested in a lab.
The testing requirements and standards are the same for both medical and recreational cannabis and cannabis products. The
regulations necessitate that mandatory testing must be conducted on all cannabis and cannabis products harvested or
manufactured on or after their phase-in dates. In essence, cannabis and cannabis products cannot be released for retail sale,
or transferred or sold to a retailer if a representative sample of the substance has not undergone and passed all the mandatory
testing. Acceptable limits of chemicals and microbial contamination and testing requirements vary from compound to compound
and based on product type.
Substances That Must Be Tested For
As of January, 1st 2018, products are required to undergo mandatory testing for the following:
- Foreign materials
- Microbial impurities, including total yeast mold count, total aerobic microbial count, Aspergillus spp.,
P. aeruginosa, s. aureus, ochratoxin A, or aflatoxin B1, B2, G1, or G2 at levels that are lesser of either the
most current version of the State Department of Public Health or American Herbal Pharmacopoeia monograph.
- Heavy metals
- Residual solvents and processing chemicals
- Residual pesticides
- Moisture content and water activity
- If tested, homogeneity
- If tested, terpenoids
Additional requirements are added on July 1st, 2018, and the final mandatory requirements
will be produced on or after December 31st, 2018. Testing of batches can only be conducted by a licensed testing laboratory.
Requirements for Testing Labs
Legislators in California refer to each sample batch as a lot and Section 19344 of Bill 266
highlights that labs must report on factors of the lot and provide supporting data.
- Labs must be third-party and independent. This implies that those who hold a license for a cannabis
testing lab are not allowed to have any other license. This is imperative in avoiding any conflict of interest between clients and labs.
- Cannabis Labs must hold both a state license and a local permit and are regulated by the Bureau of Cannabis Control.
- To be deemed technically competent and get a full annual license, labs will be required to achieve ISO 17025 accreditation,
but the state generally offers a 180-day provisional license while they work on their ISO accreditation.
- Testing laboratories have to collect 0.5% of the cannabis batch for testing but must only collect samples that are less than 10 pounds.
- Laboratory technicians have to wear hair nets, safety goggles, and other sanitary gear in addition to using sanitized tools to collect
samples for testing. The gear and tools should be changed between each batch. The sampling area should be free of contaminants.
- The lab must also check that the batch is within the specified appearance and odor.
- Laboratories are required to maintain detailed plans for a chain of custody for storage, samples, and employee training,
and those plans must be made available to the bureau if requested.
- Testing labs must report whether the samples have more than allowed amounts of impurities such as Salmonella, pesticides
such as acephate, heavy metals such as arsenic, residual solvents such as butane, and mold that averages 5% of the sample by weight and more.
- Labs must report in milligrams the concentration of Cannabidiol (CBD), Cannabigerol (CBG), Tetrahydrocannabinolic Acid (THCA),
Tetrahydrocannabinol (THC), Cannabinol (CBN), and Cannabidiolic Acid (CBDA). If samples don’t vary from the stated CBD or THC levels by more than 15%,
they are considered to have passed the test.
- Cannabis testing labs are also required to record the condition under which the sample is transported and stored.
Can Distributors Take Their Own Samples?
No. Distributors of cannabis are not allowed to select samples that they will bring to the facility. Instead, they are legally required to facilitate
compliance testing. This means that they must cooperate with a licensed testing lab who must make a visit to their facility and carry out the
compliance sampling process. The lab sampler must be given access to the entire batch and will have the choice to take two representative
samples of the batch that is a primary sample and a field duplicate. The lab will then test both samples but the client will only receive data for
the primary samples. The samples will be approximately the same number of units for prepackaged goods and the same weight for the cannabis flower.