Labeling & Testing for Medical Cannabis
This past Friday, I attended the Policy Summit at the National Cannabis Festival. The purpose of the summit is to bring light and awareness to the problematic policies across the country. The event was enlightening - especially the panel related to policies concerning victims of the war on drugs. People of color have been incarcerated at levels that are astronomical compared to to majority yet with legalization, it seems to also be the majority that is benefiting the most. The panel discussed opportunities for jurisdictions to elevate communities of color, give priority to those with prior convictions, and even discussed expungement of records due to the acceptance of what was once thought to be heinous. As a black woman, although I specialize in quality and compliance, I also find that I need to speak up for the community that I represent.
During this panel discussion they also mentioned the very unique laws that Washington D.C. has related to cannabis. Although it is quasi-legal, there is no exchanging of money for cannabis. It can be "gifted" - preventing anyone from truly capitalizing on the legalization. Medical cannabis, however, can be purchased from dispensaries with a medical marijuana card.
Although the state has had a heavy focus on medical cannabis since about 2009, they really haven't implement appropriate quality controls for cannabis products. There is currently a draft regulation that will significantly increase the amount of product testing required and control of laboratories, but until then, this is how it stands today:
What is on the label?
- Name of cultivation center & dispensary
- Cannabinoid profile including THC level
- Ingredients list
- List of chemical additives including pesticides, herbicides, and fertilizers
- Physician name
- Dispensing date
- Patient name & card #
- Warning statement
How is product quality ensured?
- During the licensing process, facilities must disclose a product safety and labeling plan
- Testing is required (but not defined)
- Department performs announced and unannounced inspections
- D.C. makes up for lack of testing by requiring all chemical additives be listed on label
- Department does not define how often inspections are performed
- Testing is required but there is no definition around what contaminants must be tested for, if each batch must be tested, or what the contaminant limits are
- Testing laboratories must be registered but there are no other requirements for labs and they are not required to be certified
- Terpenes are not included on the label