The lack of randomness in the MED’s new random testing program

Last week the Marijuana Enforcement Division (MED) finally announced their plans for a random testing program. After months of pressuring the MED to implement what the legislature directed in 2015, you’d think this would be cause to celebrate. Unfortunately, this new program is seriously lacking in randomness.

“Beginning this week, MED will begin selection of licensed businesses and establishments for random testing sample collection, as well as the Harvest or Production Batch from which a Test Batch Sample will be collected. MED Staff will put the selected batch on hold in Metrc® and may be present at the business or establishment during sample collection. Once the sample is collected, the licensee is responsible for submitting the sample, via Metrc®, to a testing facility certified to conduct the type of test requested.”

cannabisSo let me get this straight…

The MED will “randomly” select businesses to submit to secondary testing of product, but it’s up to the business to select the sample to send in for testing and choose what lab to send it to.

So it’s not “random” like walking into a store, pulling something off the shelf and sending it in for testing.

With process validation in place, this random testing scheme should catch anything that isn’t adhering to the validated procedure, but will it? With the business in charge of deciding what samples are submitted and what lab does the testing, there are ample opportunities and incentives to get around the system.

Oh, you didn’t know about process validation?

Process validation allows marijuana businesses to test a certain number of times and if they get consistent results, their process is validated. They don’t have to continue testing for a year until it’s time to renew their validation. This means that, when it comes to assurances of potency and cleanliness, the consumer could be relying on test results from months before. This random testing program should push businesses to follow procedures and remain in compliance even after process validation, assuring the accuracy of product claims, but will it?

Under this new random testing program, it’s up to the business to decide what sample gets submitted. Not a third-party sampler. Not the MED. The business decides. How hard would it be to manipulate the samples to get the desired results?

It’s up to the business to decide what lab to use. They’ll likely choose the same lab they used for process validation. In this highly competitive market, what lab is going to willingly rat out a customer they rely on for revenue? Even the most discerning lab would be hard pressed to ignore the incentive to fudge the numbers a little.

This new random testing program is a step in the right direction, but it’s only a step. Real oversight to protect consumers will require taking the sampling and testing decision out of the hands of the business and bringing in third-party sampling and blind testing. Otherwise, this system is seriously lacking in the necessary checks and balances.

Read the bulletin from the MED here: ib-16-16-random-testing-12282016

— Rx MaryJane (Teri Robnett)


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Categories: Colorado, Labs and Testing

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