By Nick Mosely
If you’re an I-502 producer or processor, you’re going to need laboratory testing. A LOT of laboratory testing. It’s not a question of how much you want — you need at least one test per five pounds of flower or 15 pounds of trim, as well as for every batch of concentrate, tincture, beverage or edible. It means that a Tier 1 producer might need 100 tests per year or more. A Tier 3 producer could need 1,500 or more. This amounts to significantly more testing than most growers in the medical market purchase.
How you integrate this step into your process has direct impact on how your product enters the market. Your investment in testing means you’ll want to feel confident that you’re getting what you’ve paid for.
Smart producers will get familiar with the requirements of I-502 so that their product will be in stores first and consistently. Here are a few points to consider as you prepare your product.
Timing: Timing of the test is critically important, as you cannot sell or even move your product without testing results. The official test result you report to the tracking database should be from a sample taken after processing is complete, and when the lot/batch is ready for packaging. A 48-hour minimum incubation is required to get microbial results, which the law demands, so count on at least that duration.
Prior to sale, the Washington State Liquor Control Board requires the product be packaged and stored while awaiting transport with a 24-hour notice given to them. Pickup of the test sample, on the other hand, requires no advance notice to the tracking database, if you report to the board that you’re storing the samples within 24 hours after the lab sample is taken, then you could be ready to sell as soon as test results are returned.
Prep: The Liquor Control Board requires you to test after processing is complete, and when the lot/batch is ready for packaging. If it hasn’t been trimmed and cured well it won’t test as well, so don’t test it until it’s done. Keep in mind that 15 percent or higher moisture content is a “failed” test. The Liquor Control Board will let you dry the lot further and retest, but it’s better to save yourself the time and headache. The better you cure the product, the more flattering the test results. Removing the sample, then packaging the entire lot immediately is the best and most honest way to optimize results; it’s really in your interest to do so.
Flower and trim from healthy plants are unlikely to fail the lab test you purchase. Cases of mites or mildew do increase your chances of failure, but their effect on the quality of the product is probably a bigger concern to you. E. coli, Salmonella or Aspergillus detection would cause the lot to fail, but these are unlikely contaminants. E. coli and Salmonella contaminants usually come from manure. Aspergillus is a mold often found on corn, but not known to target cannabis. The best way to avoid mold is to keep the humidity down. Keeping soil off the buds and washing your hands before handling product are obviously good practices.
There are pesticides that could cause your lot to fail, but you aren’t required to purchase the test to detect them. The Liquor Control Board reserves the right to test any of your products for anything they like at any time. Be smart about how you apply chemicals and refer to the Pesticide Information Center online for more information.
Concentrates: Concentrates are held under the additional scrutiny of residual solvent levels. Only the hydrocarbons propane, butane and heptane are allowed, and are limited to half of a percent by weight or 5,000 parts per million.
Ethanol is likely to be added to this list. Other permissible solvents – CO2, VG, PG, natural fats and oils – are allowed at any concentration, but must be food grade. If you fail a test for residual solvents, the Liquor Control Board might let you purge your product again and retest. Remember that you can test your product more than once during its production. If you have a new process and you’re not sure your purge is complete, you can get an additional sample tested prior to the official test and it won’t cause you to fail regardless of the result.
Results: When the lab you’ve contracted to test your samples returns your results, you need at minimum an acknowledgment that the laboratory has submitted results to the tracking database and has designated the product “Class A.”
You will also need the concentrations of THC-9, THC-A, CBD, and total cannabinoids. You can get those values from the tracking database, but you’d do better to ask the lab to provide that information in a format that is convenient for you.
Every package you sell must be labeled with this information listed and more. The test results are the last piece of information you need to make compliant labels for your packages, so be ready to integrate these values into your labeling process.
Nick Mosely is co-founder and operator of Confidence Analytics, a Washington-based Cannabis testing laboratory established specifically for I-502 testing compliance.