Labeling & Testing for Medical Cannabis
Anyone who has been following the cannabis industry in California has seen the chaos that has ensued since its legalization in 2016. From pesticides, to pulling product off of shelves for not meeting the law, to a huge recall, it hasn't been a pleasant experience for producers or consumers in the state.
California was once thought to be the state that would set the standard for the cannabis industry. Up until now, most people would disagree with that. However, I think that California actually took a lot of bumps and bruises in order for everyone else to learn what NOT to do. For example, DON'T legalize and then later decide what the regulations should be. Put the structure in place first.
The Bureau of Cannabis Control's latest recall for products tested by Sequoia Analytical Labs is actually a result of getting things RIGHT. California has enacted surprise inspections that appear to be thorough enough that they discovered this lab was falsifying results. This should put other states on notice and will hopefully ensure that surprise inspections are built into every local program.
As of January 1, 2019 all phases of implementation are complete. Therefore, all product on retail shelves should now be fully tested and in compliance with California's newly combined medical and recreational cannabis law called MAUCRSA.
What is on the label?
- Warning statements
- Net weight (dried flower)
- Cultivation source & date
- Type of cannabis or cannabis product
- Date of manufacturing & packaging
- Cannabinoid content & quantity
- Unique identifier
How is product quality ensured?
- Every batch is tested for cannabinoid potency (THC, THCA, CBD, CBDA, CBG, CBN), terpenoid potency, residual solvents, foreign material, microbials, residual solvents, pesticides, mycotoxins, heavy metals, and water activity
- Product must be destroyed if any testing fails
- State performs random quality assurance reviews (inspections)
Strengths
- Testing laboratories must be accredited to ISO 17025
- Significant oversight and control of labeling and testing
- Surprise inspections already in place and proven to be effective
Flaws
- No testing information on the label
- Phase-in approach used for test requirements allows potential for some “bad” product to be sold prior to full implementation
Source: https://www.bcc.ca.gov/law_regs/readopt_text_final.pdf