MMFLA Update: Required MarijuanaTesting Points

[Guest Josh_Colton]

The purpose of this bulletin is to inform the public and potential medical marihuana licensees of the Bureau of Medical Marihuana Regulation’s intentions regarding testing of marihuana and marihuana-infused products. This bulletin is only for advisory purposes and is subject to change. The Bureau intends to require testing of marihuana and marihuana-infused products at the following two points in the supply chain:

• After harvest: Harvested marihuana must pass required tests before it is transferred from a grower to a processor or a provisioning center.
• After processing: Marihuana and marihuana-infused products in their final state must pass required tests before they are transferred from a processor to a provisioning center.

Facilities may choose to test their products at additional points in the supply chain. More information regarding marihuana testing:

• The test results will be recorded in the statewide monitoring system by the licensed safety compliance facility
• The grower or processor that provided the test sample will be able to view the testing results in the statewide monitoring system once they have been recorded
• A caregiver may choose to have his or her product tested by a licensed safety compliance facility, but those tests will not be recorded or tracked in the statewide monitoring system.

Licensed provisioning centers can sell or transfer marihuana to a registered qualifying patient or registered primary caregiver only after it has been tested and bears the label required for retail sale.

http://www.michigan.gov/documents/lara/BMMR_Advisory_Bulletin_Testing_602773_7.pdf

 

[mishigami bear]

And an armored car to deliver the sample to the testing laboratory...

And an armored car to deliver the flower to the edible manufacturer...

And an armored car to deliver the edible to the testing laboratory...

And an armored car to deliver finished product to the dispensary...

[Restorium2]

That business model is so top heavy that no one with an understanding of the real business of cannabis in Michigan would even pretend it will make a profit and survive in the long run.

They need to study up on light runnin' lean manufacturing with low overhead and very few employees. Farm to market to table.

People need a deal or they just turn their backs. It's a hard lesson to learn if you barge in without real knowledge.  

They deserve to fail after they put all those restrictions in place just to take advantage of the Michigan Cannabis Consumer. Sucks to suck ....

[mibrains]

LARA Releases Advisory Bulletin Regarding Testing of Marihuana and Marihuana-Infused Products

Media Contact: LARA Communications 517-373-9280
Email: mediainfo@michigan.gov

October 5, 2017 – The Dept. of Licensing and Regulatory Affairs (LARA) released an advisory bulletin today to inform and advise prospective medical marihuana licensees concerning the Bureau of Medical Marihuana Regulation’s (BMMR) intentions regarding the testing of marihuana and marihuana-infused products. The bulletin is for advisory purposes only and is subject to change.

BMMR announced that there will be two points in the statewide monitoring system that licensees will be required to have the product tested: after harvest and after processing.

Harvested marihuana must pass state-required testing before it can be transported from a grower facility to either a processing facility or a provisioning center. Marihuana and marihuana-infused products must also be tested in their final state before they are transferred from a processor facility to a provisioning center. Licensees may choose to test their products at other times in addition to those required by the state.

Licensed safety compliance facilities will record the results in the statewide monitoring system. Once the results are entered, the grower or the processor that provided the sample will be able to view the results in the statewide monitoring system. Provisioning centers may only sell or transfer marihuana or marihuana-infused products to qualifying registered patients or registered primary caregivers after it has been tested and the state label required for retail sale has been affixed.

If a caregiver – under the 2008 Michigan Medical Marihuana Act – chooses to have his or her product tested by a licensed safety compliance facility, those results will not be recorded in the statewide monitoring system.

This bulletin does not constitute legal advice and is subject to change. It is intended to be advisory only, in anticipation of LARA’s promulgation of emergency rules consistent with statutory requirements. Potential licensees are encouraged to seek legal counsel to ensure their licensure applications and operations comply with the Medical Marihuana Facilities Licensing Act and associated administrative rules.

For more information on BMMR, please visit: www.michigan.gov/bmmr

For more information about LARA, please visit www.michigan.gov/lara
Follow us on Twitter www.twitter.com/michiganLARA
“Like” us on Facebook or find us on YouTube www.youtube.com/michiganLARA

[mishigami bear]

Does it state what percentage of a crop or an edible needs to be tested? You can't test every individual bud or piece of candy. 

[Restorium2]

Oregon For Example:

 

Testing marijuana for pesticides: How we did it

Updated on June 17, 2017 at 8:13 AMPosted on June 17, 2017 at 7:00 AM

Cannabis product testing for pesticides

 

 

 

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Gallery: Cannabis product testing for pesticides

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113 shares

By Noelle Crombie

ncrombie@oregonian.com

The Oregonian/OregonLive

In March, two reporters for The Oregonian/OregonLive bought 10 extracts from three recreational marijuana stores in Portland. The following month, we bought an additional five extracts from three more stores.

 

Contaminated marijuana still reaching consumers in Oregon

Though the state has authority to do random tests on marijuana sold at shops, regulators so far haven't done that. The Oregonian/OregonLive decided to conduct a spot check to see if Oregon's pesticide rules have led to clean cannabis.

 

Why extracts? Sold as oils or solids known as wax and shatter, extracts are susceptible to contamination because pesticides tend to concentrate during production. The manufacturing process involves extracting tetrahydrocannabinol, or THC, and other cannabinoids from the plant's leaves and flowers.

Extracts also are increasingly popular products often consumed with portable vaporizer pens. While dried marijuana flowers typically contain 10 to 25 percent THC, marijuana concentrates can have up to 80 percent THC, the psychoactive component that gives consumers a high. 

Getting marijuana to market: The state requires that every batch of marijuana extracts and a third of flowers headed to recreational stores be tested for the presence of 59 pesticides and for potency. Producers and processors determine the size of a batch - typically 2 pounds for extract producers; larger batches mean more test samples.

The state, for example, requires a dozen test samples from a 2-pound batch of cannabis extract. A 10-pound batch translates into 20 test samples. All must come back clean before the whole batch can move into the market. One contaminated sample and the batch gets retested.

The state recently introduced a rule that allows processors to remove contaminants from tainted extracts as long as all marijuana used to make the extract passed pesticide testing. New rules also allow the state to consider removing contaminants from flowers tainted with two pesticides known to pose a low risk to human health. Generally, those compounds dissipate with time and exposure. 

Once the batch passes, the product can move into the retail market. Extracts sell in individual half-gram or 1-gram packages, so a 2-pound batch would yield 900 to 1,800 packages.

Test results: The Oregonian/OregonLive requested - and received - the original lab reports for each extract from the shops. These detailed reports are provided to stores by growers and processors to show that their products have met the state testing requirements. Product labels list the lab and the test date.

Round one tests: We delivered 10 extracts in their original, unopened packaging to ChemHistory, a state-accredited marijuana lab in Milwaukie. ChemHistory technicians, wearing gloves, split the 1-gram products into two samples. They put about a half-gram of each extract into containers that we then delivered to Pacific Agricultural Laboratory in Sherwood.

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Why Pacific Agricultural Laboratory and ChemHistory? We picked Pacific Agricultural Laboratory because it specializes in pesticide residue analysis in water, soil, and plant tissues, like fruits and vegetables. The company tests crops for producers, packers and exporters who often must demonstrate to grocery chains and foreign countries that their goods meet residual pesticide standards. The lab is not accredited to test cannabis but holds an internationally recognized accreditation to test for pesticide residue. ChemHistory is one of eight marijuana labs that is state-accredited to test for pesticides.

Results: Both labs independently found pesticides in three of the extracts at levels that exceed what the state allows. The remaining seven extracts met state pesticide standards, both labs found.

Round two tests: In April, we decided to see how the failed three extracts would fare in another round of tests so we found products marketed under the same brand names and strains with the same batch information as the initial purchase. We also bought two additional extracts from marijuana companies that were included in the first round. We bought the extracts at licensed marijuana stores in Portland and this time commissioned only Pacific Agricultural Laboratory to perform the tests.

Results: Pacific Agricultural Laboratory's analysis found four of the five extracts met state pesticide standards. The lab detected multiple pesticides on one of the extracts that failed the first round. The two other extracts that had failed in the first round were among those that passed this time.

Cost: We paid ChemHistory $1,500 to analyze the extracts in the first round. We paid a total of $2,120 for Pacific Agricultural Laboratory to test the extracts in both rounds.

Expert opinion: We consulted with Vincent Remcho, an Oregon State University chemistry professor. Remcho is an expert in analytical chemistry. We described to him how we bought the products, transported them in their original packaging to a lab and watched while the lab split each extract into two samples and then transported those portions to the second lab.

"What you have described to me is a pretty standard procedure when you want a sample to be analyzed by multiple laboratories," he said.

During the first round of testing, Pacific Agricultural Laboratory didn't test the extracts immediately; they waited until ChemHistory was finished with its work.

We asked Remcho to review Pacific Agricultural Laboratory's description of its storage methods for the products. He characterized their protocol as "a thorough description of standard, proper procedure"