Three issues dominated discussion at the December 2 ILAC meeting in Carson City: Potency testing/labeling, issuance of a formal residual solvents policy, and proposed requirements for extract testing.
The ILAC committee made a motion to require all labs to report potency values on an "as received" basis, meaning that labs may no longer use a dry weight basis to report values. This was proposed so that test results reflect the water content of flower at the time of testing, thereby more accurately specifying potency of product that patients will receive at dispensaries. While this "as received" reporting approach typically results in a lower reported percentage of cannabinoid content by weight, it will allow patients to more accurately dose and administer their medication.
The committee also pushed through a measure to require uniform reporting and labeling of potency results across the state. In the current environment, MMEs pick and choose THC label values in an uncoordinated manner that is often dependent on the way in which specific labs report product THC content on their Certificate of Analysis (COA). This usually results in dispensary selection of either the highest value present on the COA, or selection of a combination of values, making it impossible for patients to compare product labels. The example below illustrates the means by which identical results can be manipulated to give inflated THC levels:
(Total Potential THC Formula= (%THCA*0.877)+ %THC )
The proposed ILAC motion will allow COA reporting of individual cannabinoids only, thereby precluding “Total”-type calculations to be reported. Labeling products with "Total THC" values would no longer be permitted. This will put the onus on dispensaries to educate patients as to what each value means for potency, which in turn depends on how the patient intends to use the product.
Residual Solvents Testing
The Division released the Residual Solvents policy at the meeting. The approved solvents established by the state are butane, isobutane, heptanes, and propane. All solvents must be 99% purity or higher. The limits set by the state are as follows:
SubstanceAcceptable LimitsProduct to be Tested
Approved Solvents FOR ALL SOLVENT BASED CONCENTRATES
Butanes<500 Parts Per Million (PPM)
Heptanes<500 Parts Per Million (PPM)
Propane<500 Parts Per Million (PPM)
A link to the complete policy can be found here:
As has been the topic of discussion in many states around the country, extraction processes often concentrate contaminants such as pesticides and metals in the final extract. In order to provide patients with safer product and to avoid unnecessary testing, or "double dipping", the ILAC committee proposed moving the full testing requirements for (flower and trim destined for extraction) to the final extracted product. The Division indicated this would not likely be an issue changed by policy, but would rather require a more time-consuming and arduous change to statute.