New Oregon cannabis testing requirements for recreational and medical cannabis will take effect on March 1st, 2023. In 2022, the state introduced mycotoxin testing and announced that heavy metal testing and microbial testing would roll out in 2023. Now, that time has come but very few laboratories are fully prepared.
Heavy Metal Testing for Oregon Cannabis
Cannabis plants readily take up heavy metals from the environment. Researchers have noted that cannabis is a great plant for bioremediation that cleans up the soil. However good that could be for the environment, this also means that consumers could be at risk of using contaminated commercial cannabis plants.
Oregon Liquor and Cannabis Commission‘s (OLCC) new rules for heavy metal testing are OAR 333-007-0415. As of March 1st, 2023, every production batch of recreational and medical cannabis must be tested for arsenic, cadmium, lead, and mercury. Action levels for these metals range from 0.1 ug/g for mercury to 0.2 ug/g for the other heavy metals. If a batch contains heavy metals at or above the action limits, it must be destroyed and cannot be remediated.
Microbiological Testing for Oregon Cannabis
OLCC’s new rules for microbial testing are OAR 333-007-0390. The microbiological contaminants of concern are pathogenic Aspergillus flavus, A. fumigatus, A. niger and A. terreus, Shiga toxin-producing Escherichia coli and Salmonella species. Presence of these species will result in a test failure.
Remediation via sterilization will be an option if a batch of cannabis fails microbiological testing. The most common method of cannabis sterilization is Gamma and Beta radiation. These methods are commonly used in Canada, but are not as common in the US where this type of testing has not historically been required.
Infused Pre-Roll and Hemp Testing Updates
Another new requirement for Oregon cannabis testing is specific to infused pre-rolls. The state is now requiring that finished products be tested for residual solvents. In a January 3rd call with laboratories, OLCC also made clarifications about howe pre-rolls are to be weighed during testing.
OLCC is also cracking down on hemp testing. While the state has long required hemp products to be tested the same as marijuana, it was not required to be reported to METRC. This resulted in most hemp producers disregarding the requirement for full compliance testing. Laboratories are already seeing an increase in compliance testing for hemp and CBD products now that the state is requiring METRC reporting for hemp.
Are Oregon Cannabis Labs Ready for New Cannabis Testing Requirements?
While heavy metals testing requirements are long overdue, performing the test requires the use of dangerous chemical reagents so few labs in Oregon are equipped to perform heavy metal testing. A recent bulletin notes that only Rose City Labs and Columbia Labs are currently accredited to perform heavy metal testing for cannabis. These are also the only Oregon cannabis labs that can perform new microbial testing. Rose City Labs is also the first to be accredited for psilocybin testing.
Cannabis producers will still be allowed to test with other labs for potency, pesticides, mycotoxin, and residual solvents. Those labs will either need to sub-contract microbiological and heavy metal testing, or the producer will need to submit samples separately until more labs get accredited.