Important Documents Released
Pesticide Use and Testing Document
The Insanely long Group 19 List from SB447 that must be tested for now
25B List
***Plea for action and attendance
This is a plea to come to these Independent Lab Advisory Committee meetings to speak up for patients by keeping the cost of testing down and pushing things along. As a cultivation, production, or dispensary MME, the cost of these regulations affects your bottom line either from hundreds of thousands of dollars a year to easily over a million a year. Your opinion of disapproval during public comment will influence this process reducing costs and removing excessive regulation. Your input to the Division about what they can change during the “revision” period will be invaluable.
“Revision Period” - late 2015 - early 2016 The Division of Public and Behavior Health can change 453A to benefit patients and MMEs.
***Pesticide Use and Testing Document Presentation
You will fail your test if their is a spike in your test from using an unauthorized pesticide or you are over your level. Retesting is now done by the NV department of agriculture and the MME must pay them. Current sample size of up to 12 grams per 5 pound batch will make this difficult to analyze, so they may have to increase this in the future. Division may open changes during revision period such as changing batch sizes to 10 pounds. (This is something I have continued to ask the Division at ILAC meetings and through email to bring the cost of testing down. This is one of the ways we can chip away at testing costs.) Laura Freed stated that the Division will accept recommendations from MMEs to make changes during the “Revision” period of time such as changing batches to 10 pounds for sampling. You need to meet with your individual MME teams and write that list to make changes during the “Revision” period to bring down costs for patients and help protect our industry. Feel free to send me that list and I will submit it on your behalf as part of the ILAC committee if you are not comfortable sending yourself.
***Cost of testing Group 19 list
When asking fellow committee members who work in or own labs to testify to the cost of testing this Group 19 list, they did not want to say or give a range. Just that it would be over $1,500. When stated on multiple occasions to the Division that this list would push the cost of testing up to $4,000 per 5 pounds, I did not hear any disagreement from the labs either on the committee or via public comment.
***Department of Agriculture
The Department of Agriculture stated that the Group 19 list was ridiculous and asked if it could chop it down and the response was no from the Division and that it would have to be settled in a court of law. The question is who has the authority here - I do not think it was the legislature's intention to ruin the industry with this long list and I hope that the Division or Department of Agriculture can knock this list in half. The Department of Agriculture stated MMEs do not have to get a “pesticide applicator” license from them to apply pesticides. You must post label at site of application, when you use a pesticide. Pesticide must be labeled for “Indoor / Greenhouse” use or you can not use it. They stated they will not provide list of pesticides to use or tolerance limits.
***Proficiency Testing
This happens once a year for labs and they pick up the cost.
***Edibles Dosage
We will talk about this again at the next ILAC meeting. My statement below was read and please provide input if you believe I am in error or wrong.
***Edibles ILAC Recommendation
I would like to recommend that each edibles product be no more than 100 milligrams with the option that each serving being wrapped individually or demarcated in increments of 10 or fewer milligrams of activated THC or the total product be no more than 100 miligrams with servings suggested on product label and the option to not be individually wrapped in 10mg serving size. These could include products such as chocolates, candies, cookies, and brownies.
The purpose of this is to protect patients, especially first time consumers in Nevada.
However, because certain patients need speciality doses beyond 100 mg, I believe an exception should be made for cannabis capsules, topicals, tinctures, suppositories, and applicator RSO oils to be as high as 200 mg in the total product with no limits on it being wrapped individually or demarcated into increments of 10 or fewer milligrams of activated THC.
Disclaimer: I am not an attorney and I would suggest you talk with your attorney for advice and guidance. These are only opinions which you may choose to ignore or seek further guidance on. I am one member of the ILAC committee and my opinion does not represent other members of the committee's opinion or the state of Nevada or any of its agencies.
