Colorado’s diverse cannabis industry is currently facing regulatory updates with the Marijuana Enforcement Division (MED). The organization is introducing substantial changes to a testing program now named Reduced Testing Allowance (RTA). Formerly recognized as Process Validation, this is an optional program for cultivators and licensed facilities to optimize testing practices and streamline safer operations. 

The new rule changes from the program are related to current RTA-approved companies in the program, as well as companies interested in an RTA certification. 

Let’s dive into the details of Colorado’s new RTA Rule Changes and break down their implications for cannabis processors and operators.

How the Reduced Testing Allowance (RTA) Unlocks Operational Efficiency

The Reduced Testing Allowance (RTA) program, previously known as Process Validation, is the process of collecting and evaluating test samples that represent the final product of the Harvest or Production Batch. These new rules present game-changing new factors for Colorado cannabis testing.

  • Achieving RTA Certification can create business efficiencies by reducing the frequency at which Harvest or Production Batches must be tested.
  • Reduced Testing Allowance (RTA) certification allows licensed cannabis operations in Colorado to conduct a series of lab tests to demonstrate that their processes yield products that produce clean lab results. 

(For instance, if a licensee tests all of its output and only obtains passing lab results over a specified period, the licensee may be eligible to validate its process).

  • Once this RTA process is complete, the operation is exempt from certain testing requirements for one year. This significantly reduces lab testing costs while eliminating the manpower required to collect/deliver samples and aggregate data.
  • Cultivation facilities stand to gain reduced testing privileges if every harvest batch produced during a six to twelve-week period successfully passes all contaminant tests.
  • A critical requirement is to maintain uniformity in cultivation and processing methods across all harvested flower to be eligible for reduced testing.

The advantages of reduced testing are evident, offering operational efficiency and significant cost savings. By demonstrating consistent clean lab results over a specified period, cannabis operators can streamline their testing processes, reduce testing frequency, and subsequently minimize lab testing costs.

Understanding the new RTA Rules for Colorado Cannabis

Reduced Testing Allowance now serves the same purpose for cultivators and facilitators but includes more elements to become certified.

  • A Regulated Marijuana Cultivation Facility’s cultivation process may achieve a Reduced Testing Allowance for contaminant testing if every Harvest Batch that it produced during at least a six-week period (minimum 42 days) but no longer than a 12-week period (maximum 84 days) passed all contaminant tests required by Paragraph (C) of this Rule. 
  • This must include at least six Test Batches. The period begins from the date of the creation of the first Harvest Batch that passed reduced testing allowance testing. 
  • A Regulated Cultivation Facility must cultivate and process all Harvest Batches the same way, including the same growing media, lighting, pesticides, and drying, trimming, and packaging procedures to be eligible to obtain and maintain a Reduced Testing Allowance.

The New HACCP Plan (Hazard Analysis and Critical Control Point) 

Another pivotal addition to the RTA Rule Changes is the mandatory implementation of a Hazard Analysis and Critical Control Point (HACCP) System. 

Effective July 1, 2024, Cultivation Facilities aiming for Reduced Testing Allowance certification or maintaining status must adopt this intensive plan, as outlined in ASTM D8250-19. 

The HACCP Plan involves a meticulous examination of various elements, ensuring that each product type aligns with the defined standards. 

To navigate through this intricate process, Willow Scientific, a reputable Denver-based microbial consulting service, provides expertise and support. Implementing the HACCP System not only signifies compliance with the updated regulations but also reinforces the commitment to producing safe and high-quality cannabis products.

RTA’s Internal Audit

Another significant facet of the RTA Rule Changes is the introduction of an internal compliance audit, effective July 1, 2024. 

  • Cultivation Facilities are now mandated to conduct this internal audit, with the expectation of achieving a passing score of at least 80%. 
  • The MED will supply a standard audit checklist in early 2024, guiding facilities through the process.

Comprehensive records of the internal audit must be diligently maintained for one year. This addition serves as a proactive measure to ensure ongoing compliance with regulatory standards. 

The RTA’s new internal audit acts as a tool for facilities to assess their substantial compliance with the evolving rule requirements.

Key Dates to Remember for Colorado Cannabis Operators

To successfully navigate the new RTA rules, cannabis operators should save these key dates: 

  • January 8, 2024: Licensees interested in RTA must submit an attestation form and pay the RTA Certification fee. This early deadline ensures a proactive approach to compliance.
  • January 31, 2024 (Extended to Feb 29th): Licensees achieving RTA status before January 8, 2024, have until February 29th to submit the required fee and attestation. The extension provides a grace period for those already engaged in the RTA program.
  • July 1, 2024: A pivotal date marking the full implementation of RTA Rule Changes. Cultivation Facilities aiming for a Reduced Testing Allowance for microbial contaminant testing must have a HACCP System in place and conduct an internal audit to assess substantial compliance, achieving a passing score of at least 80%.

Getting Ready for RTA Compliance with Willow Scientific

Willow Industries understands the complexity new RTA rules bring, which is why we offer an RTA Readiness Guide that will allow you and your cannabis operator to be prepared and fit for this new rollout of regulations. 

The RTA Readiness Guide, and more Colorado cannabis testing resources, are included through the Willow Scientific Microbial Analysis & Consulting Services. From the Internal Audit application to strategizing a HACCP plan, Willow’s microbial consulting services help companies navigate through the intricacies of regulation change. 

Backed by decades of experience and scientific research, Willow’s team of scientists are experts in ASTM/HACCP plans and motivated to help you operate with SOP and GMP standards.

Colorado’s RTA Rule Changes signify a transformative phase for cannabis processors and operators. While they may pose challenges and hurdles for you and your cannabis operation, it’s an opportunity for more operational optimization, cost reduction, and enhanced product quality. 

Embracing and adhering to these changes will provide more cannabis operators with more proactive measures, ensuring not only compliance but also the production of safe, high-quality cannabis products. 
If your cannabis operation is interested in being a part of this voluntary cannabis program in Colorado, get in touch with Willow Industries and learn how our microbial consulting services or cannabis decontamination technology can help.