As many of you already know, the MED recently issued Industry Bulletin 18-07. This industry bulletin focuses on pesticide testing, a topic that has received quite a bit of attention for several years now. After countless recalls and years spent wrangling with the rules and regulations, mandatory pesticide testing has finally arrived in Colorado.
Per the Bulletin, mandatory pesticide testing begins on August 1 for all flower and trim in both the medical and adult use markets (pesticide testing is not yet required for other product types). This specifically applies to any harvest batch created on or after August 1. Batches created prior to August 1 are not subject to pesticide testing requirements.
The MED specifically indicates that licensees can start testing prior to August 1 if they want to get a jump start on Process Validation. As a reminder, R 1501 B 1 reads (emphasis added): “A Retail Marijuana Cultivation Facilities cultivation process shall be deemed validated for Contaminant testing if every Harvest Batch that it produced during at least a six-week period but no longer than a 12-week period passed all contaminant tests required by Paragraph (C) of this Rule.” Furthermore, the referenced Paragraph (C) includes pesticides. As a result, it is our interpretation that if a licensee wants to become process validated, it must restart the validation cycle for all contaminants (as opposed to maintaining separate validation cycles for unique categories of contaminants).
If you’re a cultivator, now is your last chance to ensure your facility is crystal clean. Keep in mind that the detection limits for some pesticides is as low as 0.01 ppm! Additionally, we recommend checking with your lab to ensure they are ready for the influx of testing demand that is coming.
For MIPs that rely on plant material that comes out of 3rd party OPCs, we recommend that you check with your OPC sources and ensure they are ready and have clean product. It might also make sense to develop some backup relationships in case things don’t go according to plan.
If you’re confused by these new requirements or could benefit from a system that tracks testing requirements for you, drop us a line at firstname.lastname@example.org. We wish all of our readers the best as this transition takes place.
Yours in Compliance,