As many of our readers may be aware, the Denver Department of Environmental Health (DEH) issued a bulletin last week regarding CBD products. CBD has been the center of a great deal of controversy, and pundits from across the country have shared varying opinions as to the legal status of CBD. As a result of uncertainty, operators in Denver and across Colorado have approached CBD with a wide range of approaches. Because DEH has now provided guidance on the matter, it’s important to understand how this guidance might impact your business.
If you haven’t already, take a moment to read the memo issued by DEH (only one page!). It appears DEH is concerned that unregulated CBD may not only pose a potential issue to public health, but may also be evidence of illegal transportation of CBD. In other words, DEH has indicated CBD products manufactured outside of Colorado are disallowed in Denver. Moreover, DEH has indicated it may request any of the following information for both manufacturers and retailers of CBD products:
- Manufacturer name and address
- Manufacturer proof of license, registration, inspection, or review of processing from a state or local Colorado authority
- SOPs for the production of the subject product(s)
- List of all ingredients and/or additives used for production and information to substantiate their safe source
- Product labeling
- Quality control procedures for verifying the product formulation and absence of contaminants such as pesticides
- Additional information as needed
If you manufacture or sell CBD products in Denver, it is imperative you have this type of documentation prepared in the event of a DEH inspection. Complia customers are encouraged to capture this documentation in Complia so that it is readily available for inspection. Most importantly, ensure your products were manufactured in Colorado.
DEH has a reputation as the regulatory “canary in the coal mine” so to speak. They were the first agency in Colorado to address the pesticide issue and now it appears CBD is the next item in their crosshairs. As you might remember, many businesses suffered tremendous blows as a result of DEH’s involvement in pesticide regulation, so it is important to take this memo seriously.
Yours in Compliance,