Understanding Michigan Marijuana Testing Requirements
Michigan instated required contaminant and potency testing for medical marijuana in 2018, and now that adult-use laws have gone into effect starting in December 2019, large volumes of product sold in Michigan are subject to the challenges of testing. This blog post will provide an overview of Michigan contaminant testing and the key requirements all growers and processors should know.
When Michigan’s Marijuana Regulatory Agency (MRA) implemented testing in 2018, the requirements mirrored many of those existing elsewhere. Michigan contaminant testing examines levels of microbials, mycotoxins, moisture content, foreign materials, pesticides and other chemical residues, residual solvents, and heavy metals. Testing also measures potency levels of THC, THCA, CBD, and CBDA, in addition to terpene analysis.
But Michigan has set itself apart by implementing vaping tests in response to medical issues that emerged in 2019 attributed to the use of marijuana-infused vape cartridges. The Centers for Disease Control and Prevention (CDC) deemed the lung disease caused by vape use as EVALI.
A week before adult-use sales began in the state, the MRA announced emergency rules that implemented vape testing requirements. About 1.5% of the vape cartridges that had already passed testing faced retesting, according to a Detroit Free Press report.
Testing for vape cartridges aims to monitor levels of Vitamin E acetate, a dietary supplement that is safe to ingest but potentially toxic when inhaled. Vitamin E acetate was found in the vape cartridges that caused medical issues, and even death, in consumers. Though the vast majority of these vape cartridges came from the black market, state regulators still introduced the requirement out of caution to avoid more cases of EVALI. Consequently, the state has recalled numerous products from dispensary shelves due to the excessive presence of Vitamin E acetate since the required retesting.
Despite the addition of vape cartridges, the requirements for contaminant and potency testing in Michigan remain straightforward, and cultivators and manufacturers can put themselves at an advantage by familiarizing themselves with these laws and ensuring they are taking steps to pass testing.
Basics of Michigan Cannabis Testing
Whether product passes a contaminant test depends on the threshold for a particular contaminant. The MRA bases its contaminant thresholds on a study called “Cannabis Inflorescence: Standards of Identity, Analysis, and Quality Control Monograph” published by the American Herbal Pharmacopoeia. The document can be purchased online, but the state also outlines the specific contaminant thresholds, in addition to other helpful testing information, here.
Based on the American Herbal Pharmacopoeia standard, Michigan regulators set the maximum number of colony forming units (CFUs) of yeast and mold microbes at 10,000 CFUs. This means product passes testing if a lab determines the CFU count is below 10,000, and it fails if found above that number.
Cultivators and processors must submit product samples that amount to a minimum volume of 0.5% of the harvested batch. For concentrate and infused product, the lab chosen for testing determines the required sample amount. If the lab determines all required tests have been passed, the results are recorded in METRC, the state’s designated tracking system, and product can be packaged for sale.
Batches that fail testing are quarantined, and the grower or processor is given a chance to remediate the product.
Failed Marijuana Testing Remediation
Product that fails for microbials, mycotoxins, moisture content, foreign materials, residual solvents, and heavy metals can be remediated, which means decontaminating the product so excessive contaminant levels fall below the legal threshold. The law states that failed pesticide testing cannot be remediated. Any product that cannot be remediated must be destroyed.
Remediated product must pass two retests after an initial failure to be approved for sale by the MRA. Depending on the type of contaminant that resulted in a failed test, cultivators and manufacturers have few options for remediation. One solution is to process failed flower into concentrate, but this reduces the wholesale value of the product.
The other option is using cannabis remediation technology, like a WillowPure system. Our ozone-based systems decontaminate product without harming the plant or affect its wholesale value. Ozone gas effectively reduces microbials and mycotoxins without adverse effects because the gas breaks down into oxygen after treatment, meaning no residual gas remains on the product. This is the only solution for remediating product without processing it into concentrate or using other methods that harm the essential characteristics of the plant.
Implementing WillowPure decontamination technology is the simplest way to combine compliance and quality into one process. Clean cannabis not only passes testing, but also remains fresh for longer – an aspect of quality that few cultivators fully address. Contact a Willow Industries sales representative today to learn more about how ozone treatment can be an effective solution for cannabis decontamination and remediation needs.