LII:Past, Present, and Future of Cannabis Laboratory Testing and Regulation in the United States/Final thoughts and resources

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This last section of the guide provides closing thoughts to tie together what was previously discussed. It also provides a directory of cannabis testing, standards, etc. resources for readers wanting to learn more.

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This guide has attempted to provide insight into various aspects of the current status of laboratory testing of cannabis in the U.S. By extension, it has required a closer look at many non-testing or tangentially related aspects of cannabis, including history, regulations, standards, methods, equipment, and software. The guide has also attempted to look at the potential future of testing, a more difficult feat that has required inspection of—and speculation on—a mix of statistics and politics, as well as government and social policy and how they may all affect the future of cannabis testing. We learned that many point fingers at the U.S. federal government for being responsible for several cannabis-related issues, including lack of clear government support for cannabis research, lack of standardization of testing and analysis methods for said research, and wavering policy that remains inconsistent at best. At root is the fact that the federal government maintains cannabis (and its constituents) as a Schedule I drug, by extension declaring that it has no respectable medical use. This and related decisions have slowed down the academic study of cannabis (at least in the U.S.), including its analysis, quality testing, and research and use as a medical treatment. The development, implementation, and reassessment of cultivation and testing standards and methods have largely been piecemeal; additionally, those efforts have been enacted in an environment where, despite the legal status in a state, fear that the federal government will inevitably intervene slows progress even further.

Despite these barriers, the speed at which U.S. states have adopted some form of legalization of cannabis has pushed scientists and researchers to collaborate and improve standards and methods. Necessity continues to be the mother of invention, driving those in the industry to adapt or perish in a difficult, inconsistent market. State officials are teaming up at industry conferences and sharing ideas. Non-profit organizations are joining forces with major standards agencies to expand and improve good laboratory practices. Researchers—whether on their own or with the help of others internationally—are learning more about the various cannabinoids and their interaction with terpenes, driving new insight into potential therapeutic remedies. Overall public perception about marijuana consumption and use is gradually shifting towards a positive light, even when so little is still understood about the long-term ramifications of its use. Commercial interests are taking notice, and so are international treaty makers. All of this adds up to forward momentum in the cannabis industry, with warts and all.

Many factors will affect the future of cannabis regulation, testing, and research; in the process, we're certain to see both ups and downs as political and social climates continue to change. However, as marijuana consumption and hemp-based manufacturing methods continue to see expanded support, consumers and manufacturers, as well as all those involved in between, will always clamor for a safer product that is "as advertised." Laboratory analysis will play an important role in that effort, whether it's in the medical research lab, the quality control lab, or the manufacturer's lab. It will be imperative for all interested parties to further work together to ensure methods are sound and standardized in a realistic and beneficial way to ensure that in the end consumers will get the best possible product available.


6.2.1 Key reading

  • Goldman, S.; Bramante, J.; Vrdoljak, G. et al. "The analytical landscape of cannabis compliance testing". Journal of Liquid Chromatography & Related Technologies 44 (9–10): 403–20. doi:10.1080/10826076.2021.1996390. 


6.2.2 Reference material


Law and regulation


Standards and guidance


Testing


New York State Department of Health:



Accreditation and certification





Below are the major scientific conferences and trade shows for cannabis.


Associations, organizations, and interest groups

Global and national

Table 1. Global and national entities
Entity Description from website
Agricultural Genomics Foundation "non-profit organization that aims to understand the biology of new and emerging crops with industrial and medical value such as Cannabis and educate the public about the scientific findings"
American Cannabis Nurses Association "national organization dedicated to expanding the knowledge base of endo-cannabinoid therapeutics among nurses"
American Chemical Society, Cannabis Chemistry Subdivision "to be recognized as the leading chemistry authority on the safe & beneficial processing, extraction, and purity analysis of cannabis products"
American Herbal Products Association "national trade association and voice of the herbal products industry"
American Oil Chemists Society "advances the science and technology of oils, fats, proteins, surfactants, and related materials, enriching the lives of people everywhere"
American Trade Association for Cannabis & Hemp "a 501(c)(6) trade organization ... founded to promote the expansion, protection, and preservation of businesses engaged in the legal trade of industrial, medical, and recreational cannabis and hemp based products"
Americans for Safe Access "national member-based organization of patients, medical professionals, scientists and concerned citizens promoting safe and legal access to cannabis for therapeutic use and research"
Association of Cannabinoid Specialists "ensures the highest standards in the practice of cannabis medicine, safeguards patient care with clinical best practices, and interfaces with other stakeholders in the cannabis community"
Cannabis Council of Canada "national organization of Canada’s licensed producers of Cannabis under Health Canada’s federal Cannabis Act"
Cannabis Horticultural Association "an authoritative and first choice for people seeking to learn how to cultivate clean, high grade cannabis through the objective information and education on sustainable and regenerative management practices"
Cannabis Marketing Association "to bring a positive perception to, and authentic understanding of, cannabis and its consumers around the world"
Cannabis Science Interest (CSI) Group part of the National Institute on Drug Abuse, "aims to promote discussion and knowledge dissemination about cutting edge scientific findings as well as changes in policy and legal status of cannabis, in order to generate innovative ideas for NIDA's research portfolio and dissemination/outreach strategies for all audiences"
Center for the Study of Cannabis and Social Policy "to promote public and private efforts to use cannabis legalization to end the war on drugs, or 'prohibition'"
Doctors for Cannabis Regulation "a non-profit organization dedicated to advocacy for the legalization, taxation and—above all—the effective regulation of marijuana in the United States"
European Cannabis Association "offer support in the areas of consulting and development of standards for the production of medicinal cannabis"
European Medicinal Cannabis Association "to advance patient access to medicinal cannabis treatments, and improve the health outcomes of patients across Europe"
Foundation of Cannabis Unified Standards "to protect public health, consumer safety, and safeguard the environment by promoting integrity in the cannabis industry"
Hemp Industries Association "a non-profit trade association representing more than one-thousand (1,000) supporters, farmers and business members serving the hemp industries since 1994"
International Association for Cannabinoid Medicines "to advance knowledge on cannabis, cannabinoids, the endocannabinoid system, and related topics especially with regard to their therapeutic potential"
International Cannabinoid Research Society "to (1) foster cannabinoid research; (2) promote the exchange of scientific information and perspectives about Cannabis, the cannabinoids, and endocannabinoids through the organization of scientific meetings; (3) serve as a source of reliable information regarding the chemistry, pharmacology, therapeutic uses, toxicology and the behavioral, psychological, and social effects of cannabis and its constituents"
International Cannabis Bar Association "to educate and connect with other cannabis industry lawyers for the purpose of providing excellent, ethical, and advanced legal assistance to this growing industry"
International Cannabis Farmers Association "a broad group of cannabis farmers, scientists, and stakeholders working together to promote the unique quality and ecological benefits of traditionally farmed cannabis and cannabis-derived products while preserving the heritage of traditional farming communities"
International Institute for Cannabinoids "a multi-national cooperation in the field of cannabinoid research ... [that] achieves its goals through the implementation of research, development, analysis, education, training, counseling, monitoring, publishing, informing, raising awareness, proposing expert opinions or standpoints, offering expert advice and similar"
Medical Cannabis Institute, The "provides online medical education for healthcare professionals who want to learn about medical cannabis and its potential clinical application"
Medical Cannabis Society "to foster a model medical cannabis industry in the United States through education and leadership"
Minority Cannabis Business Association "501(c)(6) not-for-profit business league created to serve the specific needs of minority cannabis entrepreneurs, workers, and patients/consumers"
Multidisciplinary Association for Psychedelic Studies "a 501(c)(3) non-profit research and educational organization that develops medical, legal, and cultural contexts for people to benefit from the careful uses of psychedelics and marijuana"
National Association of Cannabis Businesses "a self-governing community, focused on differentiating themselves to regulators, the public and others brands or competitors as the most legitimate, professional and trustworthy businesses in the industry"
National Cannabis Industry Association "working together to defend the responsible cannabis industry and create more opportunities for small businesses in our sector"
National Cannabis Risk Management Association "to offer innovative risk management services that will enable our members to thrive from seed to consumer in the emerging cannabis industry"
National Hemp Association "to support the growth and development of all aspects of the industrial hemp industry"
NORML "to move public opinion sufficiently to legalize the responsible use of marijuana by adults, and to serve as an advocate for consumers to assure they have access to high quality marijuana that is safe, convenient and affordable"
Patients Out of Time "a non-profit 501c3 corporation of the Commonwealth of Virginia that provides education to all disciplines of health care professionals; their specialty and professional organizations; the legal profession; and the public at large, about medical cannabis (marijuana)"
Project CBD "to create a world where cannabis empowers people to take an active role in their health"
Smart Approaches to Marijuana "an alliance of organizations and individuals dedicated to a health-first approach to marijuana policy"
Society of Cannabis Clinicians "a 5013 non-profit organization dedicated to educating physicians about the medical use of cannabis"
Transnational Institute, The "to strengthen international social movements with rigorous research, reliable information, sound analysis and constructive proposals that advance progressive, democratic policy change and common solutions to global problems"
U.S. Cannabis Council "to build a future of legal access to cannabis delivered through an equitable and values-driven industry by advancing federal cannabis legalization and promoting restorative justice for communities harmed by cannabis prohibition"
Veterans Cannabis Project "to improving US military veterans’ quality of life through the opportunity of cannabis"
Women Grow "a for-profit entity that serves as a catalyst for women to influence and succeed in the cannabis industry as the end of marijuana prohibition occurs on a national scale"

Regional

Table 2. Regional entities
Entity Region/locality served Description from website
Alaska Marijuana Industry Association Alaska to "promote and advocate for a vibrant and reasonably regulated Alaska-based marijuana industry"
Arkansas Cannabis Industry Association Arkansas "a 501(c)(6) cannabis industry trade association advocating for laws, regulations and public policies that foster a healthy, professional and accountable medical cannabis industry in our state"; the Arkansas Medical Marijuana Association merged with it in December 2018
California Cannabis Industry Association California "to promote the growth of a responsible and legitimate cannabis industry and work for a favorable social, economic, and legal environment for our industry in the state of California"
Cannabis Business Association of Illinois Illinois "a non-profit statewide association that represents member cannabis businesses licensed by the state of Illinois"; formerly the Medical Cannabis Alliance of Illinois
Cannabis Trade Council Colorado "to help the cannabis industry to grow and flourish through self-regulation while keeping the needs of the patient foremost"
Colorado Cannabis Chamber of Commerce Colorado "a nonprofit chamber of cannabis businesses that focuses on policies at the state and local levels of government"
Colorado Leads Colorado "a pro-business alliance created to help educate the general public about the economic and community benefits of a safe, regulated medical and recreational cannabis industry"
Delaware Cannabis Advocacy Network Delaware "to build and support a network of business owners, professionals and grassroots activists advocating to legalize cannabis in the First State"
Florida for Care Florida "a non-profit 501C(4) founded in 2014 to advocate for the implementation of a strong, well-regulated, medical marijuana system under Amendment 2"
Hawaiʻi Cannabis Industry Association Hawaii "nurtures the legal cannabis industry’s long-term success by advancing the adoption of sound public policies and promoting awareness and understanding of the regulated cannabis industry’s contributions to Hawaiʻi’s wellbeing"
Las Vegas Medical Marijuana Association Nevada "a chamber of commerce for medical marijuana, organized to promote the medical marijuana industry in Nevada"
Marijuana Industry Group Colorado "to advance appropriate legislation, regulation and implementation of Colorado’s licensing and regulatory program"
Marijuana Industry Trade Association Arizona "professionals, entrepreneurs, educators, and advocates united to build a strong and sustainable future for the cannabis industry in Arizona"
Maryland Cannabis Industry Association Maryland "a professional trade association advocating for laws, regulations and public policies that foster a healthy, professional and accountable medical cannabis industry in our state"
Maryland Cannabis Policy Coalition Maryland to improve honest dialogue, remove criminal penalties for possession, and ensure proper regulation and taxation of cannabis sales in Maryland, among other goals
Maryland Medical Dispensary Association Maryland "a professional trade association advocating for laws, regulations and public policies that foster a healthy, professional and secure medical cannabis industry in our state"
Maryland Wholesale Medical Cannabis Trade Association Maryland "promotes the responsible advancement of the medical cannabis industry in Maryland by fostering a favorable social, economic and legal climate"
Massachusetts Cannabis Business Association Massachusetts "advocates on behalf of our members to remove barriers, fight stigma, and bring cannabis into the mainstream of the Massachusetts economy"
Massachusetts Medical Marijuana Dispensers' Association Massachusetts "to provide guidelines, best practices, vendor support, government regulation compliance and up to date research and knowledge about our industry"
Medical Cannabis Coalition of Hawaii Hawaii "an independent community driven effort to support medical cannabis patients and caregivers in Hawai‘i"
Missouri Cannabis Industry Association Missouri "to promote and shape the legalization of cannabis in Missouri to ensure that the benefits and opportunities created by legalization will do the most good for the most people"
Medical Marijuana Business Association of Florida Florida "to protect and promote a rational and compassionate approach to Florida’s emerging medical marijuana regulatory framework, serve as a responsible business resource for policy makers, support and grow business opportunities for the emerging medical marijuana industry"
Medical Marijuana Caregivers of Maine Maine "a Maine trade association dedicated to the support and promotion of safe access to medical marijuana"
Michigan Cannabis Industry Association Michigan "advocates for a favorable policy environment in which cannabis can thrive"
Michigan Cannabis Manufacturers Association Michigan "Dedicated to providing safe, tested cannabis products to Michigan consumers in a regulated market"
Michigan Medical Marijuana Association Michigan not particularly clear on the website what their mission is
Missouri Medical Cannabis Trade Association Missouri "an association of business owners and professionals proactively working together to build a successful, safe, compliant medical cannabis industry"
Montana Cannabis Industry Association Montana "a safe, functional, responsible and accountable program that meets the needs of patients, communities, and providers"
MS Cannabis Trade Association Mississippi "to serve the diverse interests of the cannabis market from plant-touching to ancillary businesses, including, cultivation, processing, quality testing, manufacturing, retail, delivery, insurance, packaging, and various supporting services"
Nevada Cannabis Association Nevada "dedicated to developing and promoting best practices among Nevada cannabis businesses as well as supporting the efforts of cannabis establishments to provide high quality, safe cannabis to Nevada’s consumers"
New Jersey Cannabis Industry Association New Jersey "to promote sensible policy, responsible growth and development of New Jersey’s cannabis industry"
New York Medical Cannabis Industry Association New York "to protect and serve the patients in New York’s medical cannabis program while working collaboratively to establish a responsible, inclusive and competitive adult-use cannabis program"
Ohio Cannabis Association Ohio "promotes a responsible expansion of the industry in order to best serve every resident of Ohio"
Oklahoma Cannabis Industry Association Oklahoma "the establishment of an innovative, industry-leading cannabis industry in Oklahoma built upon industry collaboration, community partnerships, enhanced market development and analysis, and a robust presence at our policy making institutions"
Oregon Cannabis Association Oregon "a diverse group of cultivators, processors, retailers, entrepreneurs, and allied businesses ... [dedicated] to help one another thrive through networking events, educational workshops, and political representation"
Oregon Retailers of Cannabis Association Oregon "a member supported non-profit trade association that lobbies and advocates on behalf of the cannabis industry and our members"
Texas Cannabis Industry Association Texas "promotes and works to ensure the favorable social, economic and legal environment necessary for a legitimate and responsible cannabis industry in Texas"
United Cannabis Business Association California "shape the regulated cannabis industry through our political efforts, while creating a network and community for the licensed industry"
Washington CannabBusiness Association Washington (state) "to advocate on behalf of our member companies in the legislative, regulatory, legal and public policy arenas"
Washington Sun and Craft Association Washington (state) "to advance and protect the interests of sun and craft cannabis growers through the development of rule and law that supports an economically and environmentally sustainable cannabis industry"


Consultancy and support services

The following entities are known to provide consulting and support services of various types to cannabis testing labs (as well as cultivators, dispensaries, etc.):


Licensed cultivators

This information is based largely on state-supplied resources and is up-to-date as of February 28, 2020.

Canada

Canada's cultivators are licensed by the federal government. The country has 43 cultivation licenses, which can be viewed on their licensed cultivators, processors, and sellers page. A variety of fees are applied to applicants, including application fees, security clearance fees, import/export fees, and annual regulatory fees. Consult the country's Cannabis Fees Order Guide for details.


United States

Alaska:

The state boasts 95 Limited and 117 Standard Marijuana Cultivation Facilities. The state differentiates a "limited" facility as one with 500 square feet or less of grow operation space, whereas "standard" facilities have no such limitation.[1] To review the entire list of 200+ cultivation facilities, go to https://www.commerce.alaska.gov/web/amco/ and look for the link "Licenses and Applications by Status."

Licensing fees for limited are $1,000, and $5,000 for standard.[2]


Arizona:

The government ties cultivation to dispensaries. However, Arizona state law prohibits making public a list of dispensaries, so the state's cultivators/dispensaries are not publicly known.[3]


Arkansas:

The five cultivation facilities for Arkansas are[4]:

  • Bold Team, LLC (Cotton Plant)
  • Delta Medical Cannabis Co. (Newport)
  • Natural State Medicinals Cultivation, LLC (White Hall)
  • Natural State Wellness Enterprises, LLC (Newport)
  • Osage Creek Cultivation, LLC (Berryville)

As of January 19, 2020, four of the five were up and running, with Delta Medical awaiting final inspections.[5]

The five facilities were licensed after paying a $100,000 license fee and a $500,000 performance bond.[6]


California:

The state of California has approximately more than 2,100 unique cannabis adult-use and medicinal-use cultivators of provisional and annual status. As of January 1, 2019, the state no longer has the authority to issue temporary licenses, though normal adult-use and medicinal-use cultivation licenses can still be applied for.[7] To review the entire list of more than 850 unique cultivation businesses (note: some companies have more than one license), go to https://aca6.accela.com/CALCANNABIS/Cap/CapHome.aspx?module=Licenses, select the license type, then select "Active" from the License Status. (Active licenses won't be older than January 1, 2018.)

Application and license fees vary depending on facility type. Consult the FAQ's "How much do application/license fees cost?" for the latest regulatory text indicating these fees.


Colorado:

The state has more than 360 unique medical-use and more than 600 unique adult-use cultivators. To review the two lists in their entirety, go to https://www.colorado.gov/pacific/enforcement/med-licensed-facilities and select the PDF or Excel file labeled "Cultivations" under each column.

Cultivation application and license fees vary based upon operation size. The base fee for everyone is Tier 1 (1 – 1,800 plants) - $1,500.00.[8]

For cultivators who wish to expand their operations, the following is paid in addition to the Tier 1 fee[8]:

  • Tier 2 (1,801 – 3,600 plants) - $1,000.00
  • Tier 3 (3,601 – 6,000 plants) - $2,000.00
  • Tier 4 (6,001 – 10,200 plants) - $4,000.00
  • Tier 5 (10,201 – 13,800 plants) - $6,000.00
  • Each additional tier of 3,600 plants over Tier 5 - $1,000.00


Connecticut:

According to Connecticut's license lookup for medical marijuana producers, the four entities are licensed to cultivate in the state:

The state is not currently accepting new applications. However, the application fees for licenses were $25,000 for the initial applications, a $75,000 registration fee, and a $75,000 renewal fee.[9]


Delaware:

The state's cultivation facilities are vertically integrated with its dispensaries, i.e., dispensaries are also cultivators. The three entities operating cultivation centers in Delaware are[10][11]:

These compassion centers pay a $40,000 license fee ever two years.[12]

The state is not currently accepting new applications.


District of Columbia:

The District of Columbia allows eight cultivators to operate[13]:

The state is not currently accepting new applications.


Florida:

The state's cultivation is vertically integrated with it its other cannabis functions, and "medical marijuana treatment centers are the only businesses allowed to grow, process or sell medical marijuana in Florida."[14] However, vertical integration may be removed as a requirement in 2020, though that progress has stalled.[15] The state currently has 14 medical marijuana treatment centers[14]:

The state is not currently accepting new applications. Its application fee was reported to be $60,830.[17]


Hawaii:

The state of Hawaii allows for eight entities to grow and distribute medical marijuana, with each entity able to have two production centers and two dispensaries. Each production center is limited to a maximum of 5,000 cannabis plants. Those eight entities are[18]:

The state is not currently accepting new applications. It's application fee was $5,000, initial license fee $75,000, and license renewal fee $50,000.[19]


Illinois:

Illinois law allows up to 22 cultivation centers to be established in the state, with the intent being to create a center in each police district. The current cultivation centers are (some entities have centers in more than one district)[20][21]:

The state is not currently accepting new applications. Fees associated with a cultivation center include a $25,000 application fee, a $200,000 first-year license fee, and a $100,000 annual license fee afterwards.[22]


Louisiana:

Difficulties meeting laboratory testing requirements and acquisitions involving a grow operation have slowed down the progress of getting the state's growing operations started.[23][24] Two growing operations are coming online in 2019, however.[25] Those operations are[25][24]:


Maine:

Cultivation and manufacturing is vertically integrated with dispensaries. The state currently allows for eight such facilities, which are run by five entities[26]:

Applications don't currently appear to be accepted. Registration fees were $12,000, and a moving fee of $4,000 was also required.[27]


Maryland:

The state does not require vertical integration among its growers, dispensaries, and producers, but many growers may also be integrated with dispensaries, etc. Maryland currently has 14 licensed growers[28]:

The state opened the application process again for growers and processors, with applications being accepted from March 25 to May 24, 2019. (Seeking to add four new growers and 10 new processors.) The state requires a $2,000 application fee[29] and a $250,000 two-year license fee.[30] As of February 2020, the announcement of the new approved growers and processors was delayed due to an investigation into the fairness of the approval process.[31]


Massachusetts:

The state does not require vertical integration among its growers, dispensaries, and producers, but many growers may also be integrated with dispensaries, etc. Massachusetts currently has 26 licensed cultivators[32]:

Application and license fees vary based on how many plants are to be grown in the cultivation facility. Refer to the Cannabis Control Commission's guidance document "Guidance for Application and License Fees" for details.


Michigan:

The state does not require vertical integration among its growers, dispensaries, and producers, but many growers may also be integrated with dispensaries, etc. Michigan currently has 87 licensed cultivators[33]:

The state charges $6,000 for an application fee, as well as a "regulatory assessment" fee, which is not clear in cost (varies from $10,000 to $66,000).[34]


Minnesota:

The state has chosen two companies to cultivate for its medical cannabis program[35]:

Further applications are not being accepted at this time. A $20,000 application fee was due for anyone who applied.[36]


Missouri:

After the first wave of approvals in December 2019, the state has 36 unique businesses licensed to cultivate cannabis in the state. To view the list of cultivation facilities, go the licensed facilities page for the state and download the related Excel sheet.

Licensing application fees were $10,000.[37] Applications for cultivation, testing, manufacturing, and dispensary facilities are currently not being accepted.


Montana:

The medical marijuana program in the state is in a bit of disarray. As Michigan-based New Leaf Cannabis Consulting puts it[38]:

Voters re-approved medical cannabis in the state in Nov. 2016. Dispensaries were supposed to not open until June 2017, but a Montana court ruled that they may reopen immediately. Montana used to have an established medical cannabis dispensary program, but a court ruling upholding a severe state law dismantled the dispensaries, by limiting the maximum number of patients to 3; that portion of the law is now repealed.

As of mid-July 2019, the program had finally bounced back to a patient base similar to pre-2011 levels.[39] The state's language is a bit confusing, but it appears that "Providers" are cultivators, and if that is the case, the state currently has 270 licenses issued for cultivators. Visit the state's program website and click on "Licensed Providers in Complia."


Nevada:

The current number and details of the state's licensed cultivators are unknown. Per an inquiry and a form letter emailed from the Marijuana Enforcement Division of Nevada, "the state is only permitted to release information on open dispensaries," and does not release information on current licensed cultivators. However, a list of provisional certificates awarded in November 2014 can still be found on their site, though many of the names are redacted due to confidentiality laws in the state.

Licensing fees for cultivation facilities differ based on product. Recreational marijuana cultivation has an initial $30,000 licensing fee, with renewal costs at $10,000. Medical marijuana cultivation has an initial $3,000 license, with renewal costs at $1,000.[40]


New Hampshire:

The state vertically integrates cultivation and dispensation of medical cannabis into alternative treatment centers, with the state currently allowing for five locations run by three entities[41]:

The state doesn't appear to be accepting new applications, and it's not clear what fees applicants had to pay.


New Jersey:

The state vertically integrates cultivation and dispensation of medical cannabis into alternative treatment centers, with the state currently allowing for nine locations run by seven entities[42]:

An application period occurred in July 2018 to grant six more licenses. In December 2018, six additional providers were invited to proceed with the application process, though in February 2019 five appeals were filed by rejected applicants and an existing alternative treatment center in regards to the selected six. Due to the litigation, only one those six providers—Rise—has become fully licensed and operational.[43][44][45] As of February 2020, more lawsuits have delayed final approvals even further, with no clear conclusion in site.[45]


New Mexico:

New Mexico vertically integrates cultivation and distribution. The state calls such licensed entities "licensed non-profit producers" (LNPPs), of which 107 locations are operational.[46] (Go here to see the full list.)

The state is not accepting additional applications at this time. Initial application fee was $10,000, with a license fee of "thirty thousand dollars ($30,000) for the first 150 cannabis plants to be possessed by the non-profit producer, and ten thousand dollars ($10,000) for each additional quantity of 50 plants thereafter to be possessed, up to a maximum collective total of 450 cannabis plants."[47]


New York:

The state vertically integrates cultivation and dispensation of medical cannabis into registered organizations. Each registered organization can have one cultivation facility and up to four dispensaries. Those organizations are[48]:

Applications are not currently being accepted. Applications fee was $10,000, licensing fee $200,000.[49]


North Dakota:

The state approved two cultivation sites in 2018 for its medical marijuana program[50]:

Additional cultivation applications don't appear to be accepted. An initial $5,000 application fee was required, and a $110,000 certification fee for a two-year license.[51]


Ohio:

The state of Ohio approved 30 total cultivator licenses, 17 for Level I and 13 for Level II. They are[52]:

The state is not currently accepting applications. Application fees were $20,000 for Level I and $2,000 for Level II cultivators, with initial license fees of $180,000 and $18,000 respectively, and annual renewal fees of $200,000 and $20,000 respectively. (Level I permitted to 25,000 square feet initially, Level II to 3,000 square feet initially.)[52]


Oklahoma:

In April 2019, the state released a document containing 118 pages of cannabis cultivators for its medical marijuana program. Consult the "List of Licensed Businesses" to view the entire list. Application/license fee is $2,500 annually.[54]


Oregon

Oregon boasts 1,162 recreational cannabis cultivation licenses across its program. (Medical cannabis growers are designated by an Oregon Medical Marijuana Program.[55]) To view the list of cultivators, go here and choose the PDF or Excel document titled "Approved Marijuana Licenses."

Application fee is $250, license fee varies depending license type ($100–$5,750).[56]


Pennsylvania:

The state initially introduced 12 grower-processor licenses with Phase I of its program.[57] In 2018, the state issued 13 additional permits to grower-processors[58], taking the total to the allowed-for 25. They are:

Applications are currently not being accepted. Prior applicants paid a $10,000 application fee and $200,000 permit fee.[58]


Rhode Island:

The state has given licenses to 52 cultivators, with 21 additional licenses pending final licensing inspection. Consult the state's approval page for the full list. The application process is currently closed. Prior applicants were required to pay a $5,000 application fee. Annual license fees vary based upon the class (grow operation size) license: Micro at $5,000, Class A at $20,000, Class B at $35,000, Class C at $50,000, and Class D at $80,000.[60]


Utah:

The state handed out eight of its 10 cultivator licenses in 2019. See the state's cannabis program site for details. Those eight cultivators are:

Applications are currently not being accepted by the state. The original application fee was $2,500, with an additional $51.50 for a background check. Approved licensees pay $100,000 for the first-year license.[61]


Vermont:

Vermont vertically integrates cultivation and distribution and refers to licensed entities as "dispensaries." The state has issued five dispensary registration certificates[62]:

The state has said it plans on opening the application process to a sixth dispensary once patient count reaches 7000 (which could happen in 2020).[62] Application fees were $2,500 and license fees set at $20,000. Annual renewal fee is $30,000.[63]


Washington:

The state has more than 1,050 active production licenses issued. To view the entire list, go here, export the list, and sort out the production facilities. The state is not accepting new applications at this time. Application fees were $250, with an annual $1,480 annual license fee for producers.[64]


West Virginia:

  • The state is still working on developing its medical cannabis program due to unanticipated delays[65], particularly with finding banking solutions for the program.[66] The Bureau for Public Health indicates that it plans on issuing no more than 10 permits for cultivators. The initial application fee will be $5,000 and the permit fee $50,000.[67] The application period should open sometime in 2019.[66] The state ceased accepting application for cultivators on February 18, 2020.[65]


Testing labs and pricing info

Canada

Flag of Canada.png

The following are licensed cannabis testing labs, as reported by Health Canada.[68] Note that some of these laboratories are not stand-alone laboratories accepting samples but rather in-house labs testing for R&D or manufacturing programs.


Alberta


British Columbia


Manitoba


New Brunswick


Newfoundland

  • None


Nova Scotia


Ontario


Prince Edward Island


Quebec


Saskatchewan


Yukon

  • None


United States

Flag of the United States.png

The prevalence of testing laboratories in any given state depends on a few factors: legalization status, state laws regarding testing, and strictness of regulations. Labs typically appear as stand-alone, third-party entities. Though not common, some testing laboratories are located within dispensaries (e.g., Champlain Valley Dispensary in Vermont[69]) and treatment centers (e.g., Sanctuary ATC in New Hampshire.[70]).

The following are known active cannabis testing labs (those currently in the licensing process are not included):


Alabama

As of July 2022, the state is still in the process of finalizing rules and regulations for its program.


Alaska


Arizona:


Arkansas:


California:


Colorado:


Connecticut:


Delaware:


District of Columbia:

D.C. is still seeking a lab to take on testing as of mid-2021.[74]


Florida:


Georgia:

As of July 2022, the Georgia Access to Medical Cannabis Commission (GMCC) has not yet opened up applications for laboratory testing licenses.[75]


Hawaii:


Illinois:


Iowa:

The state requires cannabidiol product manufacturers for its medical cannabidiol program test the products at two different stages of production.[76] However, it's not clear if any external labs are licensed to test the state's cannabidiol products.


Louisiana:

Due to an absence of independent testing labs, the Louisiana Department of Agriculture was testing, as of October 2018[77] The Department of Agriculture was jointly working with the LSU AgCenter's Agricultural Chemistry Department to test for the state's fledgling medical marijuana program.[78]

In July 2022, news broke that the state had amended medical marijuana statute to allow The University of Louisiana's Monroe School of Pharmacy "to provide lab testing services for purity and potency to the state’s medical cannabis industry," with an engineering and construction phase for the associated facility beginning in early 2023.[79]


Maine:


Maryland:


Massachusetts:


Michigan:


Minnesota:

Not clear; independent labs must be approved by Commissioner of Health.[80] Two labs—Aspen Research Corporation and Legend Technical Services, Inc.—were approved to do testing in 2015, but neither lists those services on their website.[81] The state explains how to apply to become an approved laboratory, but no corresponding list of approved labs can be found on the site.


Mississippi:

As of July 2022, the Mississippi medical cannabis program is young, and there are no entities approved as a "Testing Facility" yet on the medical cannabis establishment list.[82]


Missouri:

Medical marijuana passed in November 2018.[83] In late December 2019, Missouri announced a list of 10 labs that were approved for medical marijuana testing.[84] As of July 2022, eight labs are currently approved to operate in MO:


Montana:


Nevada:


New Hampshire:

The state mandates testing, but it's not clear which independent laboratories are approved to do so. Alternative treatment centers may be responsible for own testing. Nelson Analytical, LLC may be licensed to test cannabis in New Hampshire, but it's not clear.


New Jersey:

For the medicinal Cannabis program, independent laboratories are able to test for the program, but a list of labs for medicinal Cannabis can not be found on the Cannabis Regulatory Commission's site. As of July 2022, a list of four testing laboratories show as being approved for a testing license[85]:


New Mexico:

As of August 2022, the State of New Mexico indicates that a list of currently licensed cannabis testing labs, for some reason, is only available "with an Inspection of Public Records (IPRA) request," found here. (Citation: e-mail correspondence.) It's not clear why cultivators, etc. are listed publicly but laboratories are not. Prior to this, Scepter Lab, LLC and Scientific Base Solutions Laboratories, LLC were suspected of being licensed, but it's not clear if they still are.


New York:

"The Department's Wadsworth Center Laboratory will perform initial testing and analysis of final medical marijuana products until independent laboratories receive certification from the New York State Environmental Laboratory Approval Program (ELAP)."[86] The state is accepting comments about laboratory testing regulations until August 15, 2022.[87] Presumably once accepted, applications will be accepted for independent testing labs.


North Carolina:

Some labs in North Carolina, like Avazyme, Inc., are registered with the U.S. Drug Enforcement Administration to test hemp. See the USDA page for more.


North Dakota:

The state mandates that its compassion centers must test cannabis in-house or have it done by a contracted facility.[88] Keystone State Testing, LLC DBA Dakota State Testing was originally selected by the state for testing in May 2018.[89] However, by late 2020 or early 2021, the North Dakota location was removed from the Keystone State Testing website. A news article from The Dickinson Press in October 2021 casually indicated that Adams Independent Testing, LLC was testing medical marijuana for the state.[90] It's not clear when this transition occurred.


Ohio:


Oklahoma:


Oregon


Pennsylvania:


Rhode Island:


South Dakota:

As of August 2022, the state lists only Cannabis Chem Lab, LLC as the primary testing laboratory, noting also that the South Dakota Public Health Laboratory in Pierre is available but only for "for confirmatory and law enforcement testing."[91]


Texas:

As of August 2022, the state's medical cannabis program is quite limited in scope.[92][93] It appears the three approved suppliers may be doing their own testing in-house, e.g., as with Texas Original.[94]


Utah:

In November 2019, the application process for laboratories opened up.[95] As of August 2022, the Utah Department of Health & Human Services states that the "Utah Department of Agriculture and Food has one licensed Independent Cannabis Testing Facility located in Utah County."[95] The Department of Agriculture and Food reveals this lab to be Aromatic Plant Research Center, LLC.[96]


Vermont:


Washington:


West Virginia:

Draft legislation originally stated the Bureau for Public Health will be responsible for approving testing laboratories.[97] An update to its "Growers/Processors/Dispensaries/Laboratories" FAQ was made in February 2020[98], and the application period for such businesses was set to close on February 18, 2020.[98]

As of August 2022, it's not clear how many laboratories have been approved. No formal list of labs can be found on the state site, and according to law, "an approved laboratory may not advertise, market, or otherwise promote its medical cannabis testing services to the general public,"[99] making it difficult to locate them. A single press release was found, however, indicating Analabs, Inc. of Crab Orchard, WV was approved by the state in March 2021.[100]


Mexico

Flag of Mexico.png

Recreational cannabis was potentially going to be legalized in Mexico in 2019.[101][102] However, the push to legalize was stalled until April 30, 2020, and the possibility it would get pushed back further was real.[103] Expectations were that legalization maybe be limited to medical applications, according to statements by President Andrés Manuel López Obrador.[104]

Though the Mexico Supreme Court struck down laws that would prohibit the use of recreational Cannabis products in June 2021[105], the government has not put in place a legal framework as of August 2022, leaving some of Mexico's farmers to forge ahead without official government approval.[106]


 
 
 
 

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  2. ↑ Alcohol and Marijuana Control Office. "Marijuana License Application". Alaska Department of Commerce, Community, and Economic Development. https://www.commerce.alaska.gov/web/amco/MarijuanaLicenseApplication.aspx. Retrieved 25 April 2019. 
  3. ↑ Arizona Department of Health Services. "DI31: Can I get a list of the dispensaries?". FAQs - Dispensary. Government of Arizona. https://www.azdhs.gov/licensing/medical-marijuana/index.php#faqs-dispensary. Retrieved 25 April 2019. 
  4. ↑ Field, H. (21 January 2019). "Building underway at all medical marijuana cultivation sites in Arkansas". Arkansas Democrat Gazette. https://www.arkansasonline.com/news/2019/jan/21/building-underway-all-cannabis-cultivation-sites/. Retrieved 25 April 2019. 
  5. ↑ Field, H. (19 January 2020). "Lagging Arkansas medical-marijuana operations put on notice: Open or risk losing permits". Arkansas Democrat Gazette. https://www.arkansasonline.com/news/2020/jan/19/clock-ticking-on-state-cannabis-license-1/. Retrieved 28 February 2020. 
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  7. ↑ CalCannabis Cultivation Licensing (7 January 2019). "Notice Regarding Temporary Cannabis Cultivation License Applications". California Cannabis Portal. Government of California. https://cannabis.ca.gov/2019/01/08/notice-regarding-temporary-cannabis-cultivation-license-applications/. Retrieved 25 April 2019. 
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  53. ↑ Byer, K. (21 December 2018). "Canton cannabis growers in jeopardy of losing licenses". Akron Beacon Journal. https://www.ohio.com/news/20181221/canton-cannabis-growers-in-jeopardy-of-losing-licenses/1. Retrieved 27 April 2019. 
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  66. ↑ 66.0 66.1 Fidura, F. (10 April 2019). "West Virginia Medical Marijuana Banking Bill Signed Into Law". DispensaryPermits.com. http://news.dispensarypermits.com/west-virginia-medical-marijuana-banking-bill-signed-into-law. Retrieved 28 April 2019. 
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  82. ↑ "Establishment Registry: Registered Mississippi Medical Cannabis Establishments". Mississippi State Department of Health. 5 July 2022. https://msdh.ms.gov/msdhsite/_static/30,0,425,1005.html. Retrieved 08 July 2022. 
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  86. ↑ "Frequently Asked Questions". New York State Medical Marijuana Program. New York State Department of Health. March 2016. https://www.health.ny.gov/regulations/medical_marijuana/faq.htm. Retrieved 24 February 2017. 
  87. ↑ Office of Cannabis Management. "Marihuana Regulation and Taxation Act (MRTA)". State of New York. https://cannabis.ny.gov/marihuana-regulation-and-taxation-act-mrta. Retrieved 30 July 2022. 
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  89. ↑ "North Dakota chooses medical marijuana laboratory company". The Associated Press. 21 May 2018. https://www.apnews.com/397eab5555e84454af2833c2763ba481. Retrieved 27 November 2018. 
  90. ↑ Schmidt, H. (10 October 2021). "Fargo lab keeps 'Wild West' of hemp and marijuana industry in line". The Dickinson Press. https://www.thedickinsonpress.com/business/fargo-lab-keeps-wild-west-of-hemp-and-marijuana-industry-in-line. Retrieved 30 July 2022. 
  91. ↑ "Certified Establishments". South Dakota Department of Health. https://medcannabis.sd.gov/Establishments/CertifiedEstablishments.aspx#Testing. Retrieved 03 August 2022. 
  92. ↑ Miller, S.R. (13 February 2020). "Texas Cannabis Market Restrictions Stunt Growth". New Cannabis Ventures. https://www.newcannabisventures.com/texas-cannabis-market-restrictions-stunt-growth/. Retrieved 08 July 2022. 
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Citation information for this chapter

Chapters: 6. Final thoughts and 7. Resources

Title: Past, Present, and Future of Cannabis Laboratory Testing and Regulation in the United States

Edition: Third edition

Author for citation: Shawn E. Douglas

License for content: Creative Commons Attribution-ShareAlike 4.0 International

Publication date: March 2020


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