MJBizMag April 2022 - 43

MEASURED VARIETY
Even under the best circumstances, it
is impossible that all batches of flower,
edibles, etc., test the same at different
labs or that the milligrams of THC on
a label will match what's inside to the
nearest thousandth. And that's OK.
Other industries also allot for
measurement variations, provided
they're reasonable, Vaillencourt noted.
He said in pharmaceuticals, range
tolerances of 2% and 5% are common.
For example, an ibuprofen tablet
labeled as having 400 milligrams might
actually have 397 milligrams.
" We've identified what that
reasonableness is, " Vaillencourt said.
" Ranges are your best friend. "
MANY PRODUCTS,
MANY LOCATIONS
The sheer number of cannabis
products and inputs makes
implementing standards difficult.
In the product realm, there is not
only flower but also a large variety of
concentrates, edibles and beverages
containing inputs that interact
differently with cannabinoids, as well
as a wide variety of topicals, tinctures,
suppositories and other products.
" For every different product type,
you need different (testing) methods, "
Vaillencourt said. " For as many new
and creative products
that the industry is trying
to come up with, we will
likely need a unique
method to some degree for
each one. "
Kate Rimmer, a
research chemist at the
Maryland-based National
Institute of Standards and
Technology (NIST), noted
that it is common for
states to have different standards for
different products.
" For example, different states
Kate Rimmer
Cannabis Batch Testing (Certificates of Analysis as of Oct. 22, 2021)
Certificates of Analysis
244,948
Tested Batches
244,948
Tested Batches
By Category
Flower
Inhalable (cartridges, waxes, etc.)
Other (edibles, tinctures, topicals, etc.)
Total
Reasons For Failure*
Pesticides
Label Claims
Microbial Impurities
Heavy Metals
Residual Solvents
Water Activity
Cannabinoids
Moisture
Foreign Material
Homogeneity
Mycotoxins
Total
*Batches can fail for multiple categories
Source: California Department of Cannabis Control
of the regulations that
we can, " Rimmer said.
CHANGE
APPROACH
While harmonizing
standards will
advance quality
control, it will also
be important for the
industry to rethink
have different regulations about the
pesticides that can be in foods. We try
to provide the tools that encompass all
how it approaches testing more
generally, Vaillencourt said.
" Part of the issue is that we take this
ass-backwards approach. ... In the food
or pharmaceutical industry, we say:
What are you putting in your product? "
Vaillencourt said. " Then we test for it. "
For that approach to effectively
function, Vaillencourt said, regulators
would need to require that cannabis
businesses maintain a list of all
ingredients and raw materials-as well
as their origins.
Vaillencourt said such a tracking
system might have prevented the 2019
vape crisis.
" No state was saying, 'Test for
vitamin E acetate.' That wasn't a risk
factor that anybody identified. So it
wasn't that people were hiding things.
We just didn't think to test for it, "
Vaillencourt explained. " That's how we
ended up with a big crisis. "
mjbizdaily.com | April 2022 43
Tested
Batches
112,963
97,190
34,795
244,948
Failed Batches
9,171
Failed Batches
By Category
4,076
3,333
1,762
9,171
Failed Batches By Category
2,907
2,379
1,876
1,187
463
176
161
71
45
36
12
9,313
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MJBizMag April 2022

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