On March 21, 2019, WSLCB released conceptual rules regarding the proposal of new quality assurance testing and product requirements. While the proposed changes are well-intentioned, based on our experience in the industry as a certified testing lab and the collective experience of our employees at Treeline Analytics, we feel that the proposed regulations miss the mark in a number of ways.

Below, we outline our recommendations for more effective pesticide testing.

The Future of Pesticide Testing

The protection of public health could be achieved most efficiently (both financially and practically) by the random sampling of producer/processors at the farm level along with the random sampling of packaged product.

Required testing of all intermediate and final products is unnecessary and will impose an undo financial burden on producer/processors. We recommend that the WSLCB follow similar testing methods and guidelines used by USDA and FDA, with random sampling of producers and farms. Samples would include but are not limited to soil, plants, hydroponic system, and spraying equipment. These tests would effectively detect banned pesticides at the source. To ensure the safety of cannabis available to the consumer, we recommend that random samples of product packaged for sale be sampled prior to shipment from producer/processors to detect pesticides in excess of allowable levels.

Additionally, the WSLCB should establish a voluntary testing protocol for pesticides (with associated official label) to encourage producer/processors to have their product tested. This would also provide incentive for labs to become certified for pesticide testing and provide added value to producer/processors. Data from a voluntary testing program would generate scientific information for the validation and standardization of the testing of cannabis. This program would also provide crucial economic data for small business impact analysis.

Problems with Pesticide Analysis

The overall accuracy of all tests performed by certified labs is contingent on a truly representative QA sample being collected by the producer/processor. As supported by the WA State Department of Ecology, QA sampling protocols are inadequate and should be clarified with increased stringency for sample collection. We recommend that sampling be performed by State agencies (LCB, WSDA, WDoE), with the next best option being third party sampling, followed by producer/processor sampling.

We are also concerned about the current state of research on pesticides in cannabis. Additional studies must be conducted to determine standardized sampling and testing methods and scientifically valid allowable levels of pesticides.

Stick with us while we follow the progress of the regulations surrounding cannabis pesticide testing in Washington State and read our ideas on how to improve proposed WA pesticide testing here.