An advisory issued today by Michigan’s Department of Licensing and Regulatory Affairs (LARA) provides additional guidance toward businesses in or hoping to become part of Michigan’s medical marijuana business economy. The advisory provides a brief set of rules regarding the testing of cannabis products, and when in the supply chain those tests are to be performed.
Currently in Michigan commercially-sold cannabis is typically tested when it is ready to leave the place where it was grown; if that cannabis is used to create products like foodstuffs, topical ointments or concentrated medicines those products are tested prior to distribution to patients.
The LARA memo embraces this pattern of testing and will require it in Michigan’s new cannabis economy, created by the passage of the Medical Marihuana Facilities Licensing Act (MMFLA) in 2016. The rules for the MMFLA are being crafted now; this memo is just one of several issued recently which have provided guidance to potential applicants for licenses in the new state-regulated business environment.
Michigan’s current medical marijuana market is unregulated at the state level and there are no requirements for testing of products, although many businesses and caregivers choose to use testing even without a legal requirement. Under the new MMFLA program all cannabis grown, processed and sold by licensees must be tested at these stated times.
The memo from LARA reminds growers and distributors that they are able to test their cannabis at safety compliance facilities as desired, in addition to the specified times. Caregivers, who are not required to test cannabis under the original MMMA program or the new MMFLA system, are also able to submit samples for testing.
From the memo:
Licensed safety compliance facilities will record the results in the statewide monitoring system. Once the results are entered, the grower or the processor that provided the sample