How Colorado is Pioneering Hemp Testing
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Once again, Colorado is showing the way when it comes to regulating cannabis – but not the recreational kind this time.
On July 1 of this year, Colorado’s Department of Public Health and Environment (CDPHE) began requiring all hemp foods, hemp dietary supplements, and hemp cosmetics sold in the state to display how much THC they contain. The days of relying on vague “may contain traces of THC” labels were over. Now, all companies producing such goods must have them tested for THC to the milligram.
And that isn’t the only new rule. The CDPHE is also requiring all hemp foods and cosmetics to be tested for a host of microbials, including Salmonella, Shiga-toxin producing E.coli, yeast and molds, and mycotoxins such as aflatoxin B1. And, effective from October 1 this year, all such hemp products must be tested for 106 pesticides, too.
It’s a substantial list of new tests – far more than recreational cannabis products are required to undergo in the same state. But at least it’ll keep the many cannabis labs in Colorado nice and busy for the next few years, right? Well, maybe in time. But for now, only two labs in the whole state have been licensed to carry out these new tests: Botanacor Laboratories in Denver and Aurum Labs in Durango.
Analytical Cannabis caught up with the team at Botanacor – the first lab to be certified – to learn what it takes to carry out these new tests and why they’re necessary.
“[The new tests] are sort of in line with what Canada’s doing and a little bit of what California is doing, but maybe with the action limits of Oregon,” says Lisa Stemmer, senior director of marketing at Botanacor. “And so it’s a sort of a mash up of what’s already out there.”
But just because the new rules resemble what’s been trialed in other regions, doesn’t mean that the Botanacor team were completely ready to carry them out. A lot of time was still needed for method development.
“And the [Colorado] laboratories said, ‘Hey, wait a minute. This is great – awesome that we’re doing this – but it takes time to get instrumentation, and validation, and all of the things to make the testing accurate. Can we have a little bit of more a little bit more time?’ And they [the CDPHE] said yes,” Stemmer adds.
With this extra time, the team at Botanacor managed to expand their inventory of instruments.
“We have purchased additional triple quads to do the pesticide list,” Stemmer says. “And we’ve increased the number of HPLCs [High-performance liquid chromatography machines] for the potency. It’s been a couple months in the works, but we’re ready.”
These new instruments then needed to be tested and validated to ensure they could detect the new list of analytes within the famously complex cannabis matrix.
“We validated all of our analytes, such as mycotoxins, pesticides, and residual solvents in cannabis and cannabis-derived matrices, rather than adopting general test methods that were developed for non-cannabis products (grapes, lettuce, etc.),” Mike Branvold, Botanacor’s president, tells Analytical Cannabis.
“Validating on the proper matrices takes into account the complex chemistry of the plant, which provides a more accurate result that is trusted by regulators. What may work for ‘simple’ matrices won’t work for complex matrices that contain these extensive chemical properties found in cannabis.”
It may have been a lot of work, but Branvold and his team validated their instruments in record time. As of early-August 2021, they were still ahead of the competition.
“We were the first and we still are only the only CDPHE laboratory that’s been certified because it takes a lot of effort to do it,” Stemmer adds. “We were fast and we reacted quickly. And that’s really the reason why we’re the only ones. Are we always going to be the only ones? Of course not.”
The future of hemp testing
“Colorado in the cannabis industry – we were the canary in the coal mine, right?” Stemmer says.
“We took the initiative, we legalized first. And I think Colorado’s still in that mindset of, ‘Let’s be the first to start to align ourselves with [what] the FDA is [planning].’ This starts to align Colorado with what might be happening on a federal level, as well as, ‘Let’s start to make the products that are coming out of Colorado safer for consumers.’”
The Centennial State may be leading the hemp testing vanguard for now (with Botanacor at the front), but if the new regulations go down well, it shouldn’t be alone for long. Several other states are already mulling over stricter tests for hemp products.
“I think it’s just the beginning, to be honest,” Stemmer says. “I think there’s other states starting to put together their own regulations. There’s movement in North Carolina, Florida, New York, California.”
“There’s no other industry that has begged so hard for regulation – begged,” she adds.
But while many in the hemp testing sector welcome further oversight, these regulations don’t always end up uniform. In Colorado, for instance, despite the increased scrutiny regarding hemp food additives and cosmetics, the testing requirements for smokeable hemp products and hemp pet foods remain unchanged.
“The CDPHE does not rule over that type of product [smokeable hemp],” Stemmer explains. “So they couldn’t make a rule about it anyway.”
And these are just some testing differences within the same state. When it comes to the US as a whole, it seems things are only going to get more complicated.
“It’s starting to get very patchwork,” says Stemmer. “And it’s going to be very difficult for many product manufacturers and concentrate manufacturers to figure things out. ‘OK, so I want to make something in Colorado, but I want to sell it in Florida, like what do I have to test now? And where do I test?’ I think it’s going to get super complicated.”
“What I would like to see is a national panel, so everybody does the same thing,” she adds. “There are new test methods that are coming out for Aspergillus and listeria and things that weren't required on the Colorado panel, but we’re seeing other states are now starting to require them. There might even be a requirement in New York for botulism. So it’s important for Botanacor, in order for us to serve as our customers, to keep ahead of what each state is now doing, not just Colorado.”
This article originally appeared in Analytical Cannabis' Advances in Cannabis Testing eBook in September 2021.