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Oregon Cannabis Testing and Aspergillus: May You Live in Interesting Times

On February 16, I blogged on the new Oregon cannabis testing requirements that were scheduled to take effect (and did take effect) on March 1. I published that particular post for two reasons. First, I anticipated a bunch of failed tests. Second, I felt that the Oregon Health Authority (OHA) and Oregon Liquor and Cannabis Commission (OLCC) could have done a better job messaging the new testing requirements. (Note: OHA put out an email blast shortly after my piece published. Hey guys!)

In the last few weeks, tests results have been rolling in and it hasn’t been pretty; but it hasn’t been a total fiasco, either. I say this based on recent calls and emails I’ve received from affected clients, as well as conferral with OLCC. Let’s break this down in Q&A format.

Where are the new testing rules and where are people tripping?

The new rules are woven into OAR 333-007-0300 et seq. which covers “Marijuana and Hemp Testing.” (See also OHA’s page with various resources here). The OAR sections that took hold on March 1 center on testing requirements for 1) heavy metals and 2) microbiological contaminants. People are tripping on the latter, and specifically on testing for

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