A technician in the Wadsworth Center labels cannabis sample vials in preparation for the autosampler
“ Much more than dry flower testing ”
The problems for state laboratories stem from both legal constraints and their limited , collective experience with cannabis testing . “ So much of this issue is anecdotal ; it would be good to have some hard data ,” said Julianne Nassif , MS , APHL ’ s environmental health director . Nassif noted that , in the absence of federal guidance and regulations , “ states have had to figure this out on their own and they have very different approaches .”
The issue is further complicated by the grassroots origin ( no pun intended ) of virtually all state cannabis laws , which tend to be based on voter initiatives crafted by pro-cannabis groups . For example , the 2010 ballot initiative legalizing medical marijuana in Arizona was silent on matters pertaining to public health . Thus , The Grand Canyon State has no product testing requirements , and no state entity has regulatory authority over the private labs offering cannabis-testing services , such as potency analysis .
Patients have a right to have access to medicine of
“ known purity and quality .
Of six state PHLs surveyed for this article , only one , New York ’ s Wadsworth Center , performs routine cannabis testing , and only for medical marijuana , as nonmedical “ adult use ” is illegal in New York . Two others — the Colorado Department of Public Health & Environment ( CDPHE ) laboratory and the Massachusetts Department of Public Health ( MDPH )— provide oversight and guidance to commercial cannabis-testing laboratories in their states . And the remaining three — the Alaska State Public Health Laboratories , Arizona Department of Health Services Laboratory and the Washington State Department of Health Public Health Laboratories — perform no cannabis testing and have no oversight of their states ’ cannabis industries .
Dave Verbrugge , manager of analytical toxicology at the state PHL in Alaska — which legalized “ adult use ” in 2014 — said he would like the state to have “ a technical presence ” overseeing private laboratories that perform required quality control testing for Alaska ’ s cannabis growers and processors . That responsibility lies with the Alaska Marijuana Control Board in the state department of commerce . So far , the health agency has received no cannabis tax revenue to support laboratory oversight and neither the PHL nor the state food safety laboratory ( housed in a separate agency ) has volunteered to bring up a cannabis-testing program .
Said Verbrugge , “ Neither one of us really has capacity . Plus , we felt it wasn ’ t a good fit for the PHL to be testing marijuana plants for an intoxicating agent and certifying that .”
Marijuana ’ s status as a Schedule I narcotic was also an issue : “ At least half of our funding is federal . I definitely had some concerns about the potential for changes in the [ federal ] administration and enforcement of federal grant requirements regarding a drug-free workplace .” Although the US Drug Enforcement Agency ( DEA ) registers qualifying analytical laboratories to work with controlled substances , Verbrugge said it is unclear “ whether testing marijuana for recreational use would be a violation of a DEA license .”
Of course , even without the DEA looking over scientists ’ shoulders , any marijuana testing program requires analytical methods . And a ripple effect of the federal stance on cannabis has been a lack of laboratory guidance from any US government agency , other than a CDC protocol developed to monitor children ’ s exposure to secondhand cannabis smoke .
This void is being filled by both nongovernmental organizations and the state laboratories tasked with cannabis oversight .
The first cannabis-specific guidance document published in the United States — Cannabis Inflorescence , Cannabis spp ., Standards of Identity , Analysis and Quality Control — is a monograph released in 2013 by the American Herbal Pharmacopoeia , a nonprofit organization that promotes “ the responsible use of herbal medicines .” Jahan Marcu , PhD , one of more than 30 contributors to the monograph , said it is “ intensely peer-reviewed ” and cited in the cannabis laws of 19 states , including California .
Last May , APHL released its own cannabis document , Guidance for State Medical Cannabis Testing Programs , developed by a committee of experts drawn from PHLs , academia and the private sector . It cites some of the same source material as the American Herbal Pharmacopoeia monograph . However , this guidance is geared toward governmental testing programs and covers , among other things , product sampling , microbial and heavy metal testing , toxicity scoring , risk assessment and criteria for determining acceptable risk .
A few states , including Massachusetts and New York , have developed their own methods , either created de novo or based on existing testing protocols for foods , drugs and other consumer products . MDPH , for example , has
LAB MATTERS Spring 2017
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