Protect public health - adopt science based testing standards

In the absence of statewide standards for product testing local governments have taken the lead, or worse, products are sold and consumed with no quality assurance whatsoever. Mandatory, universal testing is one of the most important elements of regulation going forward. The state should draw on the experience of the various local testing requirements and develop robust, science based regulations that protect public safety with the least possible added cost. Specifically, it is critical to not repeat the mistakes made by the notoriously flawed plate count approach to microbial testing.

To: Lori Ajax, Chief Bureau of Cannabis Control

Dear Lori:

We write today to express our strong support for the approach outlined in sections 5316 (microbiological impurities) and 5325 (filth and foreign material) from the Proposed Regulations for Medical Cannabis Testing Regulations.

Standing in stark contrast to the plate count based approach, the draft regulations (and specifically the sections cited above) are science based and will protect public health without failing products unnecessarily or adding unnecessary costs to testing requirements. We firmly oppose any suggestion that the state adopt a plate count based approach to microbes, including bacteria, yeast and mold.

As you and your staff work against the clock to finalize the emergency regulations which will be the foundation for regulated cannabis marketplace in California we strongly encourage you to keep the sections cited above intact.

Adopting a plate count approach to microbe testing will reduce the number of labs that are ready to serve the market on January 1, 2018 and will not provide a public health benefit.

Respectfully,

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