In response to recalls of cannabis products related to the use of unauthorized pesticides, Health Canada announced in February that they would begin conducting random product testing.
They now say that, to date, they have conducted unannounced inspections of seven licensed producers of cannabis, collecting 43 random samples. According to Maryse Durette, Senior Media Relations Advisor for Health Canada, these samples included cannabis plants, dried cannabis, cannabis oil and pest control products at the facilities.
“The product samples have been drawn from current and past production lots,” Durette told Lift News, “which licensed producers are required to retain for a minimum of one year after the date of last sale. Health Canada is in the process of testing these products to ensure that only authorized pest control products are used during the production of medical cannabis. All licensed producers, including any newly licensed producers, are subject to random testing at any point in time.”
Durette also says that Health Canada has added special “terms and conditions” to Organigram and Mettrum that require testing of every product lot. In a communication with Lift in early March, André Gagnon, Media Relations Officer for Health Canada, said they were satisfied with Mettrum and OrganiGram’s response to these issues.
“Both Organigram and Mettrum have adopted a series of corrective measures to ensure that no unauthorized pesticides are used in any future production of cannabis at their site,” writes Durette. “These corrective measures include revising their internal procedures, adding video monitoring within their sites and ensuring supervision of product preparation. In addition, the companies have adopted an expanded testing regime whereby all products are tested for unauthorized pesticides, and this testing is now a condition of their Health Canada license. “
Neither OrganiGram nor Mettrum were able to account for how pesticides made their way onto the cannabis products they sold.
While there are more than 20 labs able to test cannabis products in Canada, only a handful are able to handle pesticide testing. There are potentially hundreds of pesticides that can be used on cannabis, which poses a challenge for testing facilities and the regulators monitoring the product. Laboratories need to know what pesticides they are even looking for, and a full array of hundreds can be financially prohibitive, as well as consume a lot of product.
Durette also notes that Health Canada issued an information bulletin in February and hosted a technical briefing with producers to remind them of these rules.
In February 2017, Health Canada issued an information bulletin and hosted a technical briefing with all licensed producers to remind them of the pest control product requirements and their legal obligations under the ACMPR and the Pest Control Products Act (PCPA).
“Additional compliance education and information is also being provided to all licenced producers during their regularly scheduled inspection. This includes factsheets on effective pest control management approaches, and additional information to support licenced producers as they review and ensure they have adequate controls and safeguards in their facilities to reduce the risk of the use of unauthorized pest control products. This information has also been provided to any newly licensed producers authorized by Health Canada in March and April 2017.”
One other issue that has reportedly arisen with some licensed producers in the wake of concerns with pesticide use is a restriction of foliar feeding, the process of applying nutrients directly to the leaves of the plant. Health Canada states that this is disallowed under the ACMPR.
According to Durette; “Recently, Health Canada has received a number of questions from licensed producers requesting clarification as to what fertilizers may be used in the production of medical cannabis, and how they may be applied. The Department has confirmed that fertilizers and supplements can be applied to plants via their roots, provided that the fertilizers and supplements are used as labeled, and are not applied as a foliar spray. Section 18 of the ACMPR specifies that marijuana must not be sold or provided with any additives. Foliar sprays are not permitted to be used in the production of medical cannabis, as the use of a foliar spray is considered an additive under the regulations.”
This point, however, is disputed by some within the industry. Expect to hear more on this issue from Lift News on the coming weeks.