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On August 21st, 2020, the Drug Enforcement Agency dropped its rules for implementation of the Agricultural Improvement Act of 2018 (AKA 2018 Farm Bill).  As expected, this set of rules carries some large implications for the cannabis industry, particularly for the production of CBD.  
In this analysis, we simplify the rules set forth, offer some key analysis, and present our official comments to the DEA. 

Considering the importance and impact these rules will have, we spent a considerable amount of time diving into these regulations and supplementary guidelines that were published on January 15th, 2021.  The USDA seems to address some of the comments and concerns brought up during the comment period following the publication of their interim rules. 

This is a long document because we wanted it to be as thorough as possible. We've included links to the Federal Register publication and supplementary guidelines put forward by the USDA. 

We had the privilege of sharing some of our research and analysis on the dangers, potential issues, various testing methods, current and future testing methodologies, and potential technological advancements for testing and analyzing microbial contaminants in CBD products

Ace Conlon, CPO/ CMO of Pan-X Corp. and Founder of Nimbus Adaptogenics and Josh Smith, Founder and Chief Scientist of Telic Labs come together to discuss the scope and impact of testing on cannabis-infused consumer packaged goods. This webcast was hosted by Cassandra Murray, Executive Recruiter of CLM Careers.

In the last two years there have been several high-profile illnesses in cannabis users, notably the e-cigarette, or vaping, product-use associated lung injury (EVALI), and heavy metal poisoning in California and Michigan. While these are undeniably deserving of attention, they have led to a focus on chemical contaminants and causes of illness, rather than microbial ones. With an estimated combined market of over $10B in retail sales this year, it’s not a matter of if, but when will the cannabis industry have its first major microbial or food-borne outbreak and product recall. Are we as an industry doing enough to catch it before it happens? Are we even looking for the right things? If processors and growers are already complaining about high testing costs and being shut down by state governments for selling products that have failed previous testing, how do we convince the industry to embrace new testing requirements? Josh Smith, Founder & Chief Scientist of Telic Labs presented his talk back in April at the Analytical Cannabis Online Expo 2020.

Speaking at the Analytical Cannabis Expo East Online 2020 in October, Josh Smith, Founder & Chief Scientist of Telic Labs, presented his talk on microbial testing of cannabis. Microbial Testing requirements vary in the US from state to state and the type of cannabis your crop or product is derived from. From overly generic such as “total aerobic” to using DNA based methods to test for E. coli O157:H7 and even all the way to …. nothing at all. Why do these tests matter, what do they actually tell you and how did the states decide on them? In the end, do they make sense? When a major problem with the cannabis industry is a resurgence of the black market and compliance costs for legal products, it’s worth reviewing these kinds of requirements and asking if we have picked the right monitoring tests to make these products safe for consumption.

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