JUST IN: Massachusetts CCC to require all operators to disclose use of remediation prior to testing. Testing labs must now also upload detailed COA’s, with method-specific overview to METRC.

By: Grant Smith-Ellis
Date 4/10/25
Time: 11:30am ET

A new order from the Massachusetts CCC, to be voted on later Thursday, requires all testing lab who conduct testing on products to upload a certificate of analysis, and detail the type of testing used for those results by method (PCR, plating, qPCR, etc.). Furthermore, all operators must now disclose if they use any remediation, or similar procedure, on their products prior to testing.

Testing lab operators must also detail the specific Standard Operating Procedure (SOP) for the testing used by the lab that provided the COA in question.

This is a good change that is driving at the heart of how testing labs manipulate total yeast and mold results to help wealthy clients.

Read the CCC’s proposed administrative order here (subject to final vote by the Commissioners later this afternoon) - https://drive.google.com/file/d/1cS06vln6oblEiYrVaWu-IINIzARbQXxH/view?usp=sharing

"The Commission, acting through its Executive Director, hereby ORDERS & follows: This Administrative Order require: all licensed Independent Testing Laboratories (ITL’s)to upload all certificate: of analysis: (COA's) to METRC Seed-to-Sale System of Record for all testing performed on behalf of Marijuana Establishments ( MEs) and Medical Marijuana Treatment Centers ( MTCs ) on compliance with this Order:

1. ITLs shall begin simultaneously reporting results and uploading COAs to Metrc; the Commission 5 seed-to-sale system of record within sixty (60) days after the effective date of this Administrative Order; .

2. ITLs shall report the measured concentration for each analyte detected during the course of Marijuana or Marijuana Product testing On the COA and in the Commission’s seed-to- sale System off record.

3. ITLs shall identify the analytical method utilized for each test and reference to the ITL 6 applicable written operating procedure outlining the method (Le Lab SOP #); and as a description of the method shall include (E.g. HPLC; LC-MS, etc ) as well as the name of the ITL agent that oversaw the analysis (1e , "Analyst ) The method, Lab SOF, and analyst shall be reported in the COA accompanying the reported results for each compliance test category.”

5. For purposes of this Administrative Order; a "kill-step" shall mean treatment of a Marijuana batch conducted prior to compliance testing that is intended to significantly minimize microbiological contaminants in Marijuana and Marijuana Products

6. ME and MTCs shall disclose to the ITL if the Marijuana batch was subjected to a kill- step and what method was ua2d. ITLs shall indicate on the COA whether the source Marijuana batch was remediated of subjected to & kill-step; as well as the method used.

8. Failure to comply with the above conditions may result in disciplinary; action against Licensees and its agents up to and including fine; suspension and or revocation of license or registration.