Included in the administrative order: producers “shall disclose if the Marijuana batch was subjected to a sanitization treatment or … remediated”
It will take some time to gauge the effectiveness of the steps being taken by the new Massachusetts Cannabis Control Commission executive director, but with help and advisory from commissioners and staff members, he’s definitely making changes.
In the agency’s latest administrative order “Requiring Licensees to Upload Certificates of Analysis in Metrc,” ED Travis Ahern addressed at least two big issues dogging the commission—the integrity and uniformity of required laboratory testing, and the related topic of product remediation and sanitation, as in methods that some companies use to bring weed within the acceptable limits for certain contaminants.
As has been noted by innumerable industry stakeholders, despite its robust regulations and the punishing demands that licensees endure, the CCC has lacked consistent underlying protocols around lab testing. As a result, headlines about potency and mold evaluations have moved to the forefront over the past year, with the issue being closely watched by everyone from business owners to consumers. That’s in part due to a major lawsuit between Independent Testing Labs (ITLs), as well as a February “health and safety advisory” which provided more questions than answers.
In the CCC’s latest attempt to course correct, this month Ahern issued Administrative Order No. 5 “to ensure transparent and consistent reporting of compliance test results for Marijuana and Marijuana Products sold or otherwise marketed to Patients and Consumers consistent with its statutory mandate.” Specifically, the order “requires all licensed ITLs to upload all certificates of analysis (‘COA’) to Metrc’s Seed-to-Sale System of Record,” along with record of “the Protocol for the Sampling and Analysis of Finished Marijuana Products and Marijuana Products for Marijuana Establishments, Medical Marijuana Treatment Centers, and Colocated Marijuana Operations and associated exhibits.”
With a record of the “analytical method utilized for each test,” it will be possible for both the CCC as well as researchers (and journalists and everyone else) to clean statewide data sets, standardize results, and detect problems and patterns. Other specifics outlined in the order address the subcontracting of lab tests, and requiring companies to acknowledge methods they use to prepare products for testing. Details include:
For purposes of this Administrative Order, a “sanitization treatment” shall mean a treatment of a Marijuana batch, conducted prior to compliance testing, that is intended to minimize microbiological contaminants in Marijuana and Marijuana Products.
MEs and MTCs shall disclose to the ITL if the Marijuana batch was subjected to a sanitization treatment or if the Marijuana batch was remediated prior to reanalysis, and what method was used.
ITLs shall indicate on the COA whether the source Marijuana batch was subjected to a sanitization treatment or if the Marijuana batch was remediated prior to reanalysis, as well as the method used.
“ITLs shall begin simultaneously reporting results and uploading COAs to Metrc, the Commission’s seed-to-sale system of record within sixty (60) days after the effective date of this Administrative Order, until its recission or amendment.” The order is scheduled to take effect on June 16, 2025.
