DCR issues new guidance on reanalysis of cannabis products that fail mandatory testing

The Missouri Division of Cannabis Regulation (DCR) released a new guidance document on November 4, 2024, detailing the process for the reanalysis of cannabis products that fail mandatory testing. This guidance clarifies the steps licensees must follow under regulation 19 CSR 100-1.110(10)(B)2.A.

According to the DCR’s latest guidelines, if a cannabis product fails its initial mandatory tests, licensees have the option to reanalyze the product. However, they must initiate the reanalysis within three months from the date of the initial test failure. The DCR requires licensees to notify the agency within 15 days of the test failure if they intend to pursue reanalysis.

The reanalysis must be performed using the original sample collected from the source lot, ensuring consistency in the testing process. If the original mandatory sample is insufficient, the testing licensee is allowed to resample the source lot to complete the reanalysis. This step can only be undertaken by the testing licensee who conducted the initial analysis or by another designated testing licensee.

When reanalysis is performed, partial test results can be uploaded into Missouri’s statewide track and trace system, which helps maintain a detailed record of the testing phases. If the reanalyzed sample passes, it is then subject to a second round of mandatory testing by a testing licensee that did not conduct the initial analysis or reanalysis. This final test must cover all mandatory analytes, including checks for foreign matter.

Products that pass both the reanalysis and subsequent mandatory testing are then recorded with the results from the last test conducted. These results are used for all regulatory and compliance purposes as outlined in 19 CSR 100-1.120.

The DCR encourages all licensees to contact their compliance officers or the Testing and Research Unit at TestingandResearchUnit@health.mo.gov for further inquiries or clarifications regarding the reanalysis process and compliance with regulatory requirements. This guidance aims to ensure the safety and integrity of cannabis products within the state, reflecting the DCR’s ongoing commitment to upholding public health and safety standards in the cannabis industry.