We're proud to announce that 374 Labs completed its final state inspection and received a certificate to operate, news of which dovetailed nicely with progress made at the fifth Nevada State Independent Laboratory Advisory Committee (ILAC) meeting. During the meeting, pesticide as well as terpene and cannabinoid policies were clarified, allowing labs to move forward toward being able to approve product for sale. Key points from the ILAC meeting included:
What happened: The Division held a Q&A session on the pesticide policy issued on 5/4/2015. The policy rejected the 1 part per million residue limit recommendation from the previous ILAC meeting, returning to requirements in the regulations calling for limits set at: "the most stringent acceptable standard for an approved pesticide chemical residue in any food item as set forth in Subpart C of 40 C.F.R. Part 180." The Division also removed several compounds from the original list, including Azadirachtin (Neem Oil), which are not found in Subpart C. At the request of cultivators, the Division will review whether Neem Oil and other compounds found on Subpart D of 40 C.F.R. Part 180 will be allowed for use. Subpart D includes compounds with exempted tolerances that: "involve no hazard to the public health." It is expected that those compounds will be allowed.
The Division will also review section 4.8 of the pesticide policy, at the request of the ILAC, to ensure that retests are done using split samples that are collected at the same time as the original sample and tested by the same lab as the original sample. This ensures that retesting procedures will follow good laboratory practices.
What it means for MMEs:
Labs: Need to ensure equipment and testing procedures are in accordance with the final policy. Achieving compliance will require both gas and liquid chromatography equipment coupled with mass spectrometry.
Cultivators: Can move forward using minimum risk pesticides (formerly 25b), but should avoid compounds found on on Subpart C, as the limits are so low that they create an effective ban. Also, Subpart D compounds (like Neem Oil) should be avoided until the state issues its final decision.
Cost: Testing cost could increase substantially based on the additional chemicals, equipment and/or expertise needed to satisfy the stringent pesticide policies.
Sample Size: Labs will require a larger sample size, including amounts needed for retesting.
Cannabinoids and Terpenes
What happened: The committee recommended a list of cannabinoids and terpenes, that labs will be required to test for. Once reviewed by the Division, a final policy notice will be issued.
What it means for MMEs: MMEs using specific terpene and cannabinoid formulations in their products will need to ensure that labs are capable of testing for those compounds, so that products can be effectively labeled. 374 Labs plans to include additional cannabinoids and terpenes as part of its standard testing suite, and is open to add other compounds based on MME and patient needs. 374 Labs will initially test for:
- Caryophyllene oxide