Jason Sturtsman, Healthcare Options For Patients Enterprises (HOPE), Cultivation & Processing & WECAN, Wellness Education Cannabis Advocates of Nevada.
This Thursday the Independent Laboratory Advisory Committee (ILAC) will be meeting to further regulate cannabis labs in the state of Nevada set forth by NAC 453A.666. Just ignore the last ominous 3 digits or maybe stress how important this is for MMEs and patients.
The first ILAC meeting is set to take place on Thursday, January 29, 2015 from 10:00 a.m. to 12:30 p.m. Meeting locations are as follows:
Division of Public and Behavioral Health
Southern Nevada Adult Mental Health Services
1650 Community College Drive
Rawson Neal Training Room B-193
Las Vegas, NV 89146
I would like to assure minimal regulation of the labs to reduce costs that will add a burden to the patients. However, I would like to make sure that the patients have safe and tested medicine with hopefully all three important points of “Quality” “Speed” and “Cost” of the cannabis testing being what is reasonable to protect consumers.
Some important points that I have come upon myself and with consultation with various MMEs seem to be the following:
1. There may be residual heavy metals left over after R/O filtration from city water and we may have made some of our lab testing requirements in this area too restrictive. Currently heavy metal acceptance is 1 part per billion per administrative code. This range must be changed to be in a range more common in the food and medical industry and less burdensome and restrictive.
2. If cultivation and processing facilities do not let labs know the fertilizers used in their product, the labs must open their window of analysis and risk accuracy in their testing.
3. There is a faster way to test for molds called “PCR” that can have 24 hour turnaround but the test specified now would take many days to conduct, which would pass an undue cost burden to patients and increase the amount of time it takes to get product to patients.
4. For a lab to use a new methodology a cumbersome amount of proof must be provided to the state to show validity and it would take months to show the validity of this new process. We must make it easier for labs to use new methodologies without adding burdensome costs and time to it with the patients paying more for the medicine as a result.
5. The committee must define solvent levels in production product that is not unreasonable but not burdensome to MME facilities.
6. There needs to be standardization between labs with a standardized sample sent out at certain intervals to check the validity of the results within a certain range among all labs.
7. After a product has been tested, a set amount of time needs to be determined how good the testing results will be for. If something has sat in storage for a period of time, depending on the type of product, it will degrade and test results will not be valid.
8. Labs must have the right to test any medicine from Nevada cannabis patient cardholders who continue to cultivate cannabis; and since we have full reciprocity, any patient within Nevada that would like their medicine tested.
9. Labs must have standardization to how they take their samples from products. Instead of facilities bringing products to labs, which may taint the sample, labs must go to the facility and acquire the sample. Depending on where they take the sample from the product can result in overinflated and underinflated results. For example, if a lab take the top cola of a cannabis plant and avoids as much of the stems of the plant as possible, then you will have inflated results. Other states have perfected or standardized this, so I would like more information about how other states have moved to standardize this important part of lab testing to keep results consistent.
Please contact me and let’s meet and talk more about how I can make sure your voice is heard with regards to regulating the labs to make sure we keep costs low for patients and also provide quality tested cannabis products for consumers.
Jason Sturtsman
Healthcare Options For Patients Enterprises
Wellness Education Cannabis Advocates of Nevada (WECAN)
Board of Directors
Wecan702.org
702-325-9923
JasonS@wecan702.org
