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2018 Testing Guide

2018 Testing Guide for Marijuana Cultivation (403 & 403R)

Mandated Harvest Batch Testing in 2018:

*NEW* Sample-Size Requirements for Harvest Batch Testing {Rule (R)1504}:

ONE TAG for all tests now! Starting Jan 1st you will need to randomly sample multiple 0.5g samples from each harvest batch, and combine them as ONE SAMPLE to submit for ALL testing. Note: Harvest Batches should be strain-specific, i.e. the MED will no longer allow combined batch micro tests—there will now be one set of tests per strain per harvest batch. How much do you need to send in now? It depends on how large your harvest batch is. See below for MED requirements.

• If your harvest batch is…

Getting Process Validation in 2018 {Rule (R)1501}:

POTENCY: Each strain that a facility cultivates must be tested 4 times, each test a minimum of a week apart

MICRO: Per Facility—valid for one year unless a facility changes processes. Every harvest batch produced between a 6-12 week period must pass micro contaminant testing (must be at least 6 harvest batches)

 

Minimum Required Testing After Getting Process Validated {Rule (R)1501}:

POTENCY: Each strain must be tested ONCE every 3 months (quarterly) after process validation

MICRO: One Harvest Batch must be tested every 30 days to maintain Process Validation

• Process Validation verification test samples have the same sample-size requirements as above—submit the full amount for each strain

• If the Process Validation Verification Test Samples Fail:

∙ Submit 2 new samples for retest—BOTH must pass
∙ Must retest 3 additional harvest batch samples within 30 days after failure to maintain validation

 

2018 Testing Guide for MIPs—Concentrates (404 & 404R)

Mandated Concentrate Testing in 2018:

*NEW* Sample-Size Requirements for Production Batch Testing {Rule (R)1504}:

ONE TAG for all tests now!  Starting Jan 1st you will need to randomly sample multiple 0.5g samples from each production batch, and combine them as ONE SAMPLE to submit for ALL testing. Note: Concentrates need to be submitted in METRC as weight-based packages, i.e. grams or Oz, not “each”. How much do you need to send in? It depends on how large your production batch is. See below for MED requirements.

•  If your batch is…

 

Getting Process Validation in 2018 {Rule (R)1501}:

POTENCY: Per item—valid for one year unless the facility changes production processes for that item. Every production batch produced for each specific concentrate being validated must pass all potency testing during a 4-8 week period (must be at least four test batches)

RSA or MICRO: Per Facility—is valid for one year unless a facility changes processes. Every production batch produced between a 4-8 week period must pass residual solvent contaminant testing (must be at least 4 production batches)

 

Minimum Required Testing After Getting Process Validated {Rule (R)1501}:

RSA or MICRO: Each production batch must be tested once every 30 days to maintain Process Validation

•   Process Validation verification test samples have the same sample-size requirements as above—submit the full amount for each batch

•   If Process Validation Verification Test Samples Fail:

∙   Submit 2 new samples for retest—BOTH must pass
∙   Must retest the next 3 batches produced within 30 days after failure to keep process validation

 

2018 Testing Guide for MIPs—Edibles (404 & 404R)

Mandated Edible Testing in 2018:

NEW Sample-Size Requirements for Production Batch Testing {Rule (R)1504}:

ONE TAG for all tests now! Edibles need to be packaged for sale when sent in for testing and submitted in METRC for testing as count-based, i.e. “1 each” would be “1 bottle of tablets”, not “1 tablet”, etc. How much do you need to send in? It depends on how large each production batch is. See below for MED requirements.

•     If your production batch is… 

Getting Process Validation in 2018 {Rule (R)1503}:

POTENCY & HOMOGENEITY: Per item—valid for one year unless the facility changes processing for that item. Every production batch produced for each particular type of edible being validated must pass all potency and homogeneity testing during a 4-8 week period (must be at least four test batches).

MICRO: Per Facility—is valid for one year unless a facility changes processes. Every production batch produced between a 4-8 week period must pass residual solvent contaminant testing (must be at least 4 production batches)

 

Minimum Required Testing After Getting Process Validated {Rule (R)1501 & (R)1503}:

POTENCY/ HOMOGENEITY & MICRO: Each item must be tested once every 3 months

•   Process Validation verification test samples have the same sample-size requirements as above—submit the full amount required for each batch

•   If Process Validation Verification Test Samples Fail:

∙   Submit 2 new samples for retest—BOTH must pass
∙   Must retest the next 3 batches produced within 30 days after failure to keep process validation

 

For more information, contact us

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Cannabis Testing Updates

There is a lot changing in Cannabis testing in 2018 and PhytaTech is here to support your testing needs.

 

Here is a direct link to the MED Adopted rules for both Retail and Medical Marijuana.

 

Of note, significant changes to the Residual Solvent Contamination test include new solvents and new regulatory limits, mycotoxin testing language is included, pesticide testing of flowers/trim is mentioned, and Residual Solvent Contamination testing and Microbial contamination testing of medical marijuana products will soon be enacted. The MED will send industry bulletins when Mycotoxins, Pesticides and Medical Marijuana Microbial testing will become mandatory.  Medical RSA mandate begins 01.01.2018.

 

New Residual Solvent Limits Are (Effective 01.01.2018):

 

Acetone < 1,000 ppm

Butanes (n-butane and iso-butane) < 1,000 ppm

Ethanol < 1,000 ppm (For inhaled products only)

Heptanes < 1,000 ppm

Isopropyl Alcohol < 1,000 ppm

Propane < 1,000 ppm

Benzene < 2 ppm

Toluene < 180 ppm

Pentane < 1,000 ppm

Hexane < 60 ppm

Total Xylenes (m, p, o-xylenes) < 430 ppm

 

New Pesticide limits are (not effective until MED industry bulletin published):

 

Abamectin (Avermectins: B1a & B1b) < 70 ppb

Azoxystrobin < 20 ppb

Bifenzate < 20 ppb

Etoxazole < 10 ppb

Imazalil < 40 ppb

Imidacloprid < 20 ppb

Malathion < 50 ppb

Myclobutanil < 40 ppb

Permethrin (isomeric mix) < 40 ppb

Spinosad (Mixture of A & D) < 60 ppb

Spiromesifen < 30 ppb

Spirotetramat < 20 ppb

Tebuconazole < 10 ppb

 

New mycotoxin limits are (not effective until MED industry bulletin published):

Aflatoxins (B1, B2, G1, and G2) < 20 ppb (Sum of all)

Ochratoxin A < 20 ppb

 

Remember test batches are to be 4 to 14.5 grams based on the size of your batch and you will need to submit these in one container, already homogenized. There is also rolling testing required after you receive process validation so make sure to submit samples to stay compliant!

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Sustainable and Environmentally Friendly Practices in the Cannabis Industry

Reduce, Reuse, Recycle. In sticking with an ever-present theme of being on the cutting edge of everything, there is increasing interest in more sustainable and environmentally friendly practices in the cannabis industry, as there should be.  There are new approaches and resources emerging everyday to help reduce organic waste and create alternative solutions to compliant packaging which can generate a huge amount of plastic waste. To emphasize the importance of sustainability, Denver Environmental Health has created a Cannabis Sustainability group (link below).

 

Here at PhytaTech we are taking steps to be conscious of the impact we are making on our planet. Some of the small steps we have taken recently include switching to recycled paper towels as well as biodegradable nitrile gloves (they are cheaper than the regular nitrile gloves we were using and they are the color green!). We also recycle over 2 cubic yards of recyclables every 2 weeks! We would like to encourage our clients to take whatever steps they can to reduce waste without breaking the bank.

 

We feel that one area this could be achieved is in the way you package samples to be sent to the lab. This also helps us with storage space as we are required to retain samples in a secure storage for at least 3 months past their manifest date. Below are photo examples of some ways to submit samples that would reduce both plastic waste and storage space. If possible, see if you can source biodegradable plastic bags/containers where you can. Also, feel free to make sure we give you back your child proof bags or boxes that you bring your samples in. These go right into the recycling waste stream as we don’t normally have the need for outgoing packaging materials.

 

Here are some other resources to help guide you in becoming a truly green business! As always, give us a call with any questions or other suggestions/resources to help you with your sustainability goals:

 

Denver Environmental Health Cannabis Sustainability Website  

A Lab Manager’s Guide to Sustainable Lab Practices from the publication, Lab Manager

Biodegradable nitrile gloves

 

I encourage you all to look into other resources that are more relevant and tailored to your particular business needs such as the recent article in Marijuana Venture Magazine (December 2017) about using Bokashi, a completely natural way to reduce, reuse and recycle organic waste by a method of acidic anaerobic fermentation.

 

Some of these may seem like small steps but if everyone takes a few small steps, in time, together we can make a very big impact! 

 

Remember, we can have a profitable industry as well as do our part to save the environment. If you have any sampling or packaging questions, call or email today!

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Regulatory News

PhytaTechSM is certified by the CO MED & CDPHE for Potency Testing, Residual Solvent Testing and Microbial Contamination Testing.

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