We’d like to take this opportunity to remind you that new rules regarding cannabis testing will be effective on January 1, 2021.
Highlights for SC Labs Oregon Clients
- Kief must be tested for THC, CBD, pesticides, and water activity (unless the flower/trim used to make the kief has already been tested for water activity).
- CBD will now be included in the Relative Percent Difference (RPD) pass/fail criteria for extracts and concentrates as well as products. Our certificate of analysis (COA) will include an indication of Pass/Fail just below the THC status on Page 2.
- All pesticide tests are considered Compliance tests. Labs are required to enter a Pass/Fail in Metrc for every pesticide test.
With a comprehensive list of changes going into effect, we are providing links to the full regulations, a summary of the changes (below), and a few of the more important points we want to call out (right). We strongly encourage you to access the following links to review the rules that go into effect January 1, 2021.
- Marijuana Concentration Limits and Testing; Oregon Administrative Rules; Oregon Health Authority, Public Health Division Chapter 333, Division 7
- Recreational Marijuana Program Compliance Education Bulletin CE2020-07, Oregon Liquor Control Commission (OLCC), December 29, 2020 – This bulletin addresses additional rules relating to labelling, processing, and inhalable products, if applicable.
Summary of the Oregon Medical Marijuana Program (OMMP) Information Bulletin 2020-05
Subject: New Division 7 & 64 Rules Effective January 1, 2021
The Oregon Health Authority, Oregon Medical Marijuana Program (OMMP) is responsible for the Cannabis testing rules that apply to both the medical and retail market. Any marijuana item intended to be sold at a dispensary or retail shop must have been sampled and tested according to the testing rules found in division 7 and 64.
The OMMP has adopted permanent administrative rules, effective January 1, 2021, that make changes to the testing rules. Changes made clarify testing requirements and also clarify standards that cannabis laboratories are required to follow.
This bulletin only provides a summary of the major rule changes. The full rule text may be found on the OMMP’s rules webpage at www.healthoregon.org/ommprules.
An overview of the testing requirements may be found at www.healthoregon.org/ommprules.
Kief Testing Requirements 333-007-0320(6), 333-007-0330(7) and 333-007-0420
Licensed OLCC producers that are permitted under OAR 845-025-2020 to produce kief must test every process lot of kief intended for use by a consumer for pesticides, water activity, and THC and CBD concentration.
If the producer will transfer the kief for use by a processor in making a cannabinoid product then every process lot must be tested for pesticides and water activity.
If the marijuana used to make kief is tested for water activity prior to the kief being made, then the kief will not be required to be tested for water activity.
As a reminder, usable marijuana used to make a concentrate or extract that does not include a sterilization method must be tested for water activity/moisture content.
Standards for THC and CBD Compliance Testing 333-007-0430
Testing requirements for CBD were amended to match THC homogeneity requirements. Pre-control study, the amount of CBD between samples taken from a process lot of a cannabinoid concentrate, extract or product must not exceed 20% RSD. Post-control study compliance testing fails if the RPD between CBD results exceeds 15%, except for cannabinoid products that contain less than 5 mg CBD per unit of sale and concentrates or extract that contain less than 5 mg CBD per gram.
Control Studies 333-007-0440
Changes made to this section better align with information that is collected by Metrc. This change assists the OLCC with approving control studies.
The rule was also amended so that a control study on a CBD-containing product can fail if the product is not sufficiently homogeneous for CBD.
Kief produced by a producer may be submitted for a control study approval if the kief was made using a standard operating procedure.
Failed Test Samples 333-007-0450
A clarification was made to state that if a batch of marijuana or usable marijuana fails water activity or moisture content testing it may be made into a cannabinoid concentrate or extract if the processing method effectively sterilizes the batch.
Quality Control and Research and Development Testing 333-007-0500
A pesticide test on any marijuana item is considered to be a compliance test.
A registrant or licensee must comply with the testing rules found in division 7 at all times. This means that a person working for a registrant or licensee is not able to misrepresent a sample for testing as a personal test when it is not.
Questions / Information
For questions or assistance implementing the considerations in this bulletin, contact your SC Labs Support Representative. Excellent service and support are always our top priority. If there is anything that we can do to improve your service experience, please contact us at (503) 272-8830, or via email at firstname.lastname@example.org.
SC Labs is broadly distributing this bulletin in order to bring to the attention of users of the affected SC Labs tests. SC Labs recommends that all users determine the applicability of this information to their individual situations and take appropriate action. SC Labs does not warrant that this information is necessarily accurate or complete. SC Labs shall not be liable for technical or editorial errors or omissions contained herein.