I am responding to David's email below with my formal written comments on the testing proposal for Maine's Medical Cannabis Program. Here are my thoughts:
- I believe that some degree of testing should be required for all products sold by commercial operators (caregiver storefronts, dispensaries and potentially 'commercial' style caregiver delivery services).
- I agree that all products sold through retail dispensaries or retail caregiver storefront avenues should be tested.
- To my knowledge there are some larger commercial caregivers that distribute into the market via delivery service direct to patients or through wholesale to other caregivers/dispensaries. I would be in favor of expanding the 'commercial operator' definition to include any caregiver cultivating within the canopy sizes of 200-500 sqft or by plant count cultivating between 12-30 plants. If you are a caregiver cultivating within 200-500 sqft of canopy OR over 12 plants without a retail storefront, I would be in favor of requiring all harvested cannabis flower and concentrates produced under that caregiver's license be tested prior to wholesale transaction or delivery direct to the patient. That test result in my opinion would be sufficient for the source batches all the way through final sale - as to not require the receiving dispensary/caregiver retail storefront to retest the batch.
- I support testing only harvested cannabis, in its final form that would be available to sell for patients.
- I am not in support of testing requirements for cannabis trim, or oil that are transferred in bulk form between licensed cultivators and manufacturing facilities. I only support testing requirements for the final cannabis products created from cannabis trim or concentrates.
- Analytes for testing: I am in agreement with most of the analytes listed in the Testing Proposal, I would further suggest adding pesticides as a required testing analyte to Flower, Concentrates and Edibles. For flower, I would suggest not requiring Water Activity and Moisture content. I personally think pesticides should also be a required analyte to test for in the adult use market.
- With all of this said, I am concerned that the existing testing infrastructure in the State of Maine could and would become overwhelmed with the volume of tests that could potentially result from required testing in the Medical Cannabis program. With that said, I would suggest and be comfortable with a phased approach and roll out with medical testing, perhaps starting with randomized testing, and/or only requiring dispensaries and caregiver storefronts to required to test at the onset.
Please let me know if you have any questions.