The Vermont Agency of Agriculture, Food and Markets (AAFM) adopted rules establishing Vermont Hemp compliance standards and expectations for:
- Record keeping
- Reporting
- Labeling
- Verify cannabinoid label guarantees potency within 20% accuracy
- Lab Testing
- Established contaminant limits for crops and products
- Develop potency and contaminant lab testing protocols
- Mandate lab testing for contaminants (pesticides, solvents, heavy metals, mycotoxins, and bacterial and fungal contaminants)
- Lab testing must be third party
That’s all still pretty general, though, and many folks might wonder about the specifics of what products need to be tested, and what the tests are looking for. So here’s a deeper dive into testing details.
Trimmed, smokable flower needs to be tested for:
- Potency (percentage of THC, CBD, and other cannabinoids)
- Moisture or water activity (to assure safe storage)
- Microbials (total aerobic bacteria, total combined yeast and mold, and mycotoxins)
- Heavy Metals (see Note 1)
- Pesticides (testing not required if Certified Organic)
Harvest lots (hemp biomass-turned into CBD supplements) need to be tested for:
- Potency
- Moisture (for dry weight calculation)
- Heavy Metals (see Note 5)
- Pesticides (if not Certified Organic)
Concentrates (liquids, solids such as oils, hashish, shatter, and kief) need testing for:
- Potency
- Microbials (total aerobic bacteria, total combined yeast and mold, and mycotoxins)
- Heavy metals
- Pesticides
- Residual Solvents (if solvent based extraction is used)
Products & Infused Products (tinctures, salves, edibles, drinks) need testing for:
- Potency
- Prior compliance with lab testing/Certificate of Analysis (COA) for ALL other tests ALREADY completed.
The Vermont hemp program compliance standards also states that it does “include enforcement provisions,” and on December 24 2020, the Hemp Program started conducting record inspections.
Inspections begin with a phone call followed by an email, and use online inspection forms to gather information (total number of harvest lots, harvest lot yields, total number of process lots, results of contaminant testing and more).
This new format is a way for the Hemp Program to collect important industry data, gauge registrant’s knowledge of the Vermont Hemp Rules and allow the program to offer compliance assistance, as necessary.
Full panel lab testing is the only way to help ensure consumers have access to clean cannabis, and the only way to ensure hemp-based businesses are compliant with the Vermont Hemp program mandates.
Unfortunately, with over 500 hemp farms, and a small staff, it’s likely only a small percentage of farms will be contacted for inspection. The reality is that not many Vermont companies I’ve worked with or looked into are transparent and/or have adequate lab testing, and frequently, Vermont hemp products are NOT in compliance with full panel lab testing, especially for smokable flowers.
So, it’s important for cannabis consumers to champion their own health and safety by looking out for the quality of the products they’re purchasing. Look on the company’s website for lab testing to see what they’re testing for. It’s not enough to just test for how much CBD a product contains, you need to know about both potency and contamination.
If full panel testing results aren’t available, ask your grower or vendor why. And depending on their answer, here’s how you might respond:
- It’s too expensive.
- You can respond by asking, “Are you valuing patients over profits?”
- I didn’t know they needed them.
- You can respond by saying, “Now you do. And here’s what you need to look for…”
If the absence of testing seems like it comes from a lack of ethics, then you shouldn’t be supporting those growers and product-makers.
Remember, full panel lab testing is the only way to help ensure consumers have access to clean cannabis, and the only way to ensure hemp-based businesses are compliant with the Vermont Hemp program mandates.
NurseGrown has been committed to full panel lab testing since day one, and we will continue to honor that commitment and champion clean cannabis because you deserve the best products to help you maintain your health and well being.
For more Information, check out these articles on:
- The power of the cannabis plant
- What third party lab testing is
- Why lab testing is so important for the safety and health of consumers
Also, here’s a graphic with more details about testing and compliance:
Note 1: Harvest lot testing is sufficient to show compliance.
Note 2: Trim flower or hemp concentrate testing is sufficient to show compliance.
Note 3: Residual solvents are tested whenever solvent based extraction techniques are used.
Note 4: A hemp product or hemp-infused product process lot complies when a COA demonstrates that the product meets the acceptable potency level or the processor’s formulation demonstrates compliance with the acceptable potency level.
Note 5: Testing for heavy metals is required whenever the hemp crop land was used for orchard crops or any land use other than farming as defined in the Required Agricultural Practices Rule, unless a recent soils test demonstrates that the heavy metals are within the authorized action limits for soils.
Note 6: No pesticide testing required if the crop is certified organic or Clean Green Certified.
Note 7: Testing for other contaminants is necessary when the Agency of Natural Resources has approved biosolids applications to the hemp crop land.