What is wrong with voluntary compliance, particularly since chemical analysis or other quantitative approaches obviously are not suitable, workable, or effective (for anyone seeking to avoid pesticide detection)? Seems a total waste of resources. Isn’t voluntary compliance how it works throughout the agricultural business, with farmers trusted, presumed, not to violate laws and apply unapproved pesticides? But I also question why mandatory testing is needed. Are CO legal consumers actually demanding this funky 13 pesticides testing? Is this testing PR effort led by testing labs.? Who else would want or see benefits from such a funky regulatory scheme – not growers or consumers? Will the number of pesticides tested increase forever as more pesticide analytical methods are validated? And particularly, is there actual need, risk, such as documented harm or even just theoretical exposures to toxic levels, from legally-manufactured CO cannabis products? Have any actual quantitative assessments of the risks been done concerning the regulated pesticides cannabis consumption by smoking, vaping and ingestion? Are there any cost vs. benefit studies? If spotting illicit pesticide use is actually needed, wouldn’t other options be more much more effective, simpler and cheaper? For example, why not have a ‘whistleblower’-type reward system for employees or anyone reporting unapproved pesticide applications, much as federal law/FDA has implemented with pharmaceutical manufacturing? If this is good enough for prescription pharmaceuticals, wouldn’t it work with cannabis production? Reply
“What is wrong with voluntary compliance…” Because the manufacturers can’t be trusted. If you have the choice between a failed crop or spraying Eagle 20, without regulation, everyone will choose the later. “Are CO legal consumers actually demanding this funky 13 pesticides testing?” There’s nothing “funky” about these pesticides. They are bad for you. Consumers want clean and safe products. We all have an expectation that when we buy our food, it is going to be safe for us to eat. Having clean marijuana is no different. Not only are they bad for you, they aren’t too great for the environment and animals, e.g., Bee Colony collapse. Imidacloprid is a neonicotinoid for example. “Who else would want or see benefits from such a funky regulatory scheme…” The workers benefit from regulation. Federal Pesticide Worker Protection Standard (WPS). https://www.epa.gov/pesticide-worker-safety/agricultural-worker-protection-standard-wps “Is this testing PR effort led by testing labs.?” From what I know, the rules were developed by the Marijuana Enforcement Division and the CDPHE. A Pesticide Working group was formed that consisted of licensees, lawyers, labs, consumer advocacy groups and all worked together with the State on these regulations. “Will the number of pesticides tested increase forever as more pesticide analytical methods are validated?” The Colorado Department of Agriculture has a larger list of banned pesticides that the MED and the working group whittled down to 13. “is there actual need, risk, such as documented harm or even just theoretical exposures to toxic levels, from legally-manufactured CO cannabis products?” Not yet. These studies take years to complete. “…why not have a ‘whistleblower’-type reward system for employees or anyone reporting unapproved pesticide applications,…” There is. https://www.colorado.gov/pacific/enforcement/med-information-referral-form Reply