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LARA Updates Marijuana Guidelines for Active Ingredients, Safety Tests, and Remediation Protocols
Media Contact: LARA Communications 517-335-LARA (5272)
February 4, 2019 – Today, the Bureau of Marijuana Regulation (BMR) updated multiple bulletins related to safety tests, approved/banned active ingredients, and updated remediation methods.
“Since the inception of our program, we have been listening to input from medical marijuana stakeholders and have been looking at best practices from other states,” said BMR Director Andrew Brisbo. “The changes announced today are a direct result of the input we have received from those in the industry. We are confident that these new standards will continue to keep medical marijuana products safe for Michigan’s patients while allowing businesses to run efficiently.”
Highlights from the changes announced today:
- In a Safety Compliance Facility bulletin, BMR changed banned chemical residue active ingredient detection limits to action limits. Instead of any detection of pesticides resulting in a failure, the new chemical residue standard allows a sample to pass if the detection is at or below the limit. This change was brought about by industry feedback and reduces the possibility of very minute environmental contaminants resulting in failed marijuana tests. It also brings Michigan in line with other states’ regulations.
- Since there are currently no federally recognized and published action limits or tolerances for marijuana in 40 CFR part 180, subpart C, or the federal insecticide fungicide, and rodenticide act, 7 USC 136 to 136y; the department published its own list. This list will be continually evaluated and updated based on available scientific and industry information. If the federal government adds marijuana to 40 CFR part 180, subpart C, or the federal insecticide fungicide, and rodenticide act, 7 USC 136 to 136y, LARA will adopt these standards.
- Based on industry feedback, BMR added an additional species of Aspergillus, Aspergillus terreus (fungus), for required testing and added homogeneity to the testing chart as a testing requirement for marijuana-infused products.
- In a bulletin published for licensed growers, BMR added five new, low-risk, approved chemicals to be used in the cultivation of marijuana:
- Ammonium Nonanoate
- Gliocladium catenulatum Strain J1446
- Hydrogen Peroxide
- Peroxyacetic Acid
- Sodium Carbonate Peroxyhydrate
- In a bulletin regarding banned chemical active ingredients, BMR clarified that any product with a value that exceeds the action limit will result in a failed test for chemical residue.
- In multiple bulletins, BMR removed METRC item categories and now only include examples of marijuana-infused product types. This was done after receiving feedback from stakeholders. METRC categories of marijuana products will now only be found in METRC’s Michigan Supplemental Guide available to licensees within METRC. METRC is the statewide seed-to-sale monitoring system.
- In a retesting and remediation bulletin, BMR published an expanded remediation protocol which addresses testing failures for pests and metals. If initial product testing of product fails for pests or metals, the processor can remediate the product with departmental approval. The product will then need full compliance testing to prove contaminants have been removed. There are four scenarios in which the product must be destroyed for failed tests:
- Final test for chemical residue
- Marijuana product is in final package
- Final failed test for microbials on marijuana-infused products
- If one or both retests fail
- A new LARA Tips bulletin directed towards licensed processors further explained testing requirements and the suggested manner of tagging packages in METRC.
The seven updated bulletins can be found here:
- Department Banned Chemical Active Ingredients
- Safety Compliance Facility Sampling and Testing Information
- Department Approved Active Ingredients for Growers
- Maximum THC Levels for Marijuana-Infused Products
- Purchasing Limits
- Retesting and Remediation
- Testing Requirements for Production Products and Package RFID Tags