You’ve grown some beautiful cannabis and now Health Canada requires you to test it to sell it in the market – here’s what you should know.
Analytical
testing of cannabis is a regulatory requirement under the Health Canada Cannabis
Act and Regulations but what does that mean? How do you know what to test for? How do you determine if your test results are
acceptable, and your cannabis passes the test?
Great questions!
Under
“Good Production Practices”, Part 5 of the Cannabis Regulations,
sections 89 to 92 outline what testing is required to meet regulatory
requirements:
- Testing
for phytocannabinoids; and
- Testing
for contaminants.
Testing
for phytocannabinoids, or cannabinoids, is to determine the cannabinoid
content of your cannabis – the THC and CBD you hear so much about. This includes a breakdown of the total
cannabinoid content into individual cannabinoids (cannabinoid profiling) and
how much of each cannabinoid is present (cannabinoid potency).
Testing for contaminants is broken down into microbial-type contaminants and chemical-type contaminants.
- Microbial testing determines the presence or absence of microbials such as E. coli and Salmonella spp. and the colony-forming units (cfu) of Total Combined Yeast and Moulds, Bile-tolerant Gram-negative Bacteria, and Total Aerobic Microbial Count.
- Chemical contaminant testing determines the presence or absence and potency of potentially harmful heavy metals, such as Arsenic, Cadmium, Lead, and Mercury. As well as the presence or absence and potency of harmful mycotoxins, such as Aflatoxins B1, G1, B2 and G2. Other chemical contaminants include testing for residues of pest control products (also known as pesticides) meaning it is also necessary to determine whether pesticide active ingredients are present or absent, and if present, the concentration of the pesticide active ingredient.
Seems so simple, right? Unfortunately not all things are as easy as they seem. “Cannabis Product”, Part 6 of the Cannabis Regulations, section 93 outlines how to determine if your results are passable:
- Microbial and chemical contaminant limits are acceptable so long as it meets limits accepted by one of the authorized publications outlining these limits as referred to in Schedule B of the Food and Drug Act. This list of publications includes the European Pharmacopeia and the US Pharmacopeia, for example. The task of choosing an acceptable publication to follow for limits can be a bit daunting, as you also must keep in mind the intended use (for example, inhalation) for your cannabis product.
- When it comes to pesticides, Health Canada has established their own limits for residues as identified and described under the Pest Control Products Act. A comprehensive list of 96 pesticides and the limit for each can be found in the Health Canada guidance document “Mandatory Cannabis Testing for Pesticide Active Ingredients”. The Cannabis Regulations also states that the more stringent limit applies to generally accepted tolerance limits in relation to residues of pest control products. Which further breakdown to any pesticide result that exceeds an acceptable residue limit must be reported to Health Canada.
While testing your cannabis may seem very complex, it is a necessary chore to ensure regulatory requirements are met. Our experts at BloomLabs are well versed in the necessary regulatory testing, as well as the interpretation of the test results, so don't hesitate to reach out and inquire about all that we have to offer!
Posted by: Michelle Shearer