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Compliance is Science

Compliance in Colorado – Retail Marijuana Testing          

On October 31st, 2014, new Retail Marijuana Testing requirements and regulations were introduced in the State of Colorado.  In order to better ensure safe, consistent products, Retail Marijuana facilities must ensure that samples are taken from at least 10% of harvest batches produced on an annual basis.   All samples must be submitted to a Retail Testing Facility for contaminate testing.  At present there are six certified Testing Facilities in the State of Colorado.https://www.colorado.gov/pacific/sites/default/files/Labs.pdf

To ensure State regulatory compliance, each licensee and testing facility must adhere to the following types of testing:

Potency Analysis

This test includes the cannabinoids potency profile, terpinoids, THC% and more.  Typical testing results on flower/bud THC vary from 12% to 28%, with the average around 17-20%.  For edibles, each batch must be tested to ensure established limits are met.  Most potency testing utilizes Ultra-High Performance Liquid Chromatography (UPLC) to test and analyze known cannabinoids.

Microbial Screening

This test includes bacterial & fungus review of marijuana products, including all water and food-based concentrates.  Common microbials tested are STEC, salmonella and various types of fungi.

Residual Solvents & Metals Testing

This testing looks for solvents (butanes, propane, heptanes, benzene, hexane and others) as well as metals (arsenic, cadmium, lead and mercury) with max limits on parts per million (ppm).  If proper extraction methods are not utilized, solvents within the flower, concentrates or edibles pose a serious health risk to consumers.

Pesticide and Contaminate Testing

These tests identify the use of a banned pesticide, chemical and other contaminates, including mold, mildew and filth.

If Retail Marijuana, Retail Marijuana Concentrate or Retail Marijuana Product has failed a contaminate test, then the testing facility must notify the Retail Establishment that submitted the sample, as well as report the failure in the Marijuana Inventory Tracking System, known as METRC.

Infused Edibles Limits

The new rules also address the amount of activated THC product that may be in a single serving.  The new limit is 10mg of active THC.  Products with more than one serving must be easily identified.  As infused edibles can have later on-set effects, serving limits were imposed.

Summary

Testing in Colorado is now required for all product manufacturers.  As the industry expands, testing will be crucial to State-level compliance.  Failure to adhere to testing requirements is a risk few licensees can afford to take.

About the Author

Steve Owens is the owner of Adherence Corp, a regulatory compliance and consulting company.  He has an International MBA and more than 15 years of management consulting experience. Steve can be reached at [email protected].

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