MED Orders Special Testing

Special Microbial Contaminant Testing - Yeast and Mold

The Colorado Marijuana Enforcement Division (MED) has ordered a special microbial contaminant testing alert.  The alert affects all Retail Marijuana Cultivation (RMC) Licensees, and Retail Marijuana Manufacturing Facilities (RMPMF).  The alert was posted through a January 30, 2017 industry bulletin.   This action is being taken due to new data regarding the effectiveness of 3M Total Yeast and Mold Petrifilms in Marijuana.   To see the complete bulletin, click on the hyperlink at the end of this article.

Special Microbial Contaminant Testing

The MED is requiring all Retail Marijuana Cultivators and Product Manufacturers, who have obtained process validation, to submit a single Test Batch for total yeast and mold.

The test batch must be submitted prior to ANY transfer of retail marijuana, or retail marijuana product, out of their licensed facilities.   Test batches must be submitted before March 1, 2017 for any transfers that are scheduled during the month of February 2017.  Those retail marijuana cultivators and manufacturers who will not transfer product during the month of February must submit a test batch in any subsequent month.

If a single test batch passes for total yeast and mold, the process validation remains effective.  If the single test batch fails however, the licensee must adhere to the rules for failed contaminant revalidation.  These may be found in MED Rule R 1501(F)(2).  The licensee must also comply to the procedures identified in MED Rule R 1507(B) for contaminated product and failed test results.

We applaud the MED’s special test action.  These tests are being ordered in the interest of public health and safety.  That is, or should be, the number one priority of each and every marijuana business owner.  It is something every customer expects and deserves.

At Cannabis Regulatory Solutions, we provide more than just exceptional responsible vendor program training.  We seek to provide our clients with valuable services long after the training is complete.  Contact us should you need help navigating and interpreting this special microbial contaminant testing bulletin, or any other MED, or CDPHE rule or regulation.

Useful MED Links:

https://www.colorado.gov/pacific/sites/default/files/17-01%20Industry%20Bulletin%2017-01%20Micro%20Contaminant.pdf

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Author: Ren Gobris

Ren has over 30 years of experience working as a leader in international manufacturing, supply chain management, and security systems solutions with special focus on regulatory affairs. In October 2015 Ren founded and is now the owner of Cannabis Regulatory Solutions, headquartered in Estes Park, CO. Its mission is to provide exceptional regulatory compliance training, consulting, and cost-effective business support systems to the dynamic and fast growing medical and recreational marijuana industries.

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