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What to Know About California's Testing Requirements

 

The Bureau of Cannabis Control (BCC) has, on several occasions, released guidelines regarding required cannabis testing. This means that if you are legally operating a cannabis business, you need to adhere to these guidelines in order to meet state requirements. Per the BCC’s guidelines, there are three categories that cannabis and cannabis products fall under: inhalable cannabis, inhalable cannabis products, and other cannabis and cannabis products.


Cannabis Operator Responsibility


It is every responsible commercial cannabis business operator’s duty to ensure that all their cannabis and cannabis products are tested, and, if sold, have passed these tests. Cultivators must have their product tested through their distribution partners, and retailers must ensure the products they are selling to the public have passed all quality control tests. Providing the patients and customers with safe, effective, potent, and high-quality cannabis and cannabis products should be every operator’s number one priority. Lifting the stigma of cannabis can be done with responsible cultivation, manufacturing, distribution, sale and administration of safe and effective cannabis and cannabis products.


Roll Out Dates


Since the roll out date for all legal cannabis facilities and business was January 1, 2018, the BCC provided three phases for various test types that all cannabis and cannabis products must undergo. The first phase covers all cannabis and cannabis products that were harvested and manufactured beginning January 1, 2018. The second phase began on July 1, 2018, and the third phase will begin on December 31, 2018. The third phase will require that all three cannabis and cannabis product categories to undergo the comprehensive battery of tests in order to comply with state regulations.

As we come to the end of 2018, please make sure you are compliant with the BCC testing regulations. Since annual state licenses will be the focus of the BCC activity in 2019, we expect  little to no changes to their existing testing requirements.


Testing Types


To recap, the comprehensive battery of cannabis and cannabis product test types have been spread out over three phases as follows:

Phase I: January 1, 2018
Cannabinoids Testing
Moisture Content Testing
Category II Residual Solvents and Processing Chemicals Testing
Category I Residual Pesticides Testing
Microbial Impurities Testing (A. fumigatus, A. flavus, A. niger, and A. terreus)
Microbial Impurities Testing (Escherichia coli and Salmonella spp.)
Homogeneity Testing of Edible Cannabis Products

Phase II: July 1, 2018
Category I Residual Solvents and Processing Chemicals Testing
Category II Residual Pesticides Testing
Foreign Material Testing

Phase III: December 31, 2018
Terpenoids Testing
Mycotoxins Testing
Heavy Metals Testing
Water Activity Testing of Solid or Semi-Solid Edibles

Inhalable Cannabis


January 1, 2018July 1, 2018December 31, 2018​Cannabinoids Testing​Category II Residual Pesticides TestingTerpenoids TestingMoisture Content TestingValueMycotoxins TestingCategory I Residual Pesticides Testing​Foreign Material TestingHeavy Metals Testing​Microbial Impurities Testing​Water Activity Testing of Solid or Semi-Solid Edibles

Inhalable Cannabis Products


January 1, 2018July 1, 2018​December 31, 2018 

Cannabinoids Testing
Category I Residual Solvents and Processing Chemicals Testing
​Terpenoids Testing​Category II Residual Solvents and Processing Chemicals Testing
Category II Residual Pesticides Testing
Mycotoxins TestingCategory I Residual Pesticides Testing
Foreign Material Testing
Heavy Metals TestingMicrobial Impurities TestingMicrobial Impurities Testing (Escherichia coli and Salmonella spp.)

Other Cannabis and Cannabis Products


January 1, 2018July 1, 2018December 31, 2018Cannabinoids TestingCategory I Residual Solvents and Processing Chemicals TestingTerpenoids TestingCategory II Residual Solvents and Processing Chemicals Testing​Category II Residual Pesticides TestingMycotoxins Testing​Category I Residual Pesticides Testing​Foreign Material TestingHeavy Metals TestingMicrobial Impurities Testing (Escherichia coli and Salmonella spp.)Water Activity Testing of Solid and Semi-Solid EdiblesHomogeneity Testing of Edible Cannabis Products


Failed tests


If your cannabis and/or cannabis products fail to pass the required testing and cannot be remedied, then, according to State Regulations, the entire batch must be destroyed. This obviously has an impact on your bottom line: cutting losses means implementing industry best practices. We recommend you continually engage the services of testing laboratories at fundamentally significant steps in the cultivation and manufacturing process. This could potentially save your cannabis and cannabis products from failing tests and destruction.


Compliance Assistance


If you are a commercial cannabis operator and need assistance and/or guidance with compliance, contact a team member today. Part of every operator’s responsibility is to meet state regulations and incorporate best industry practices into your operations.



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