As the cannabis market continues to evolve and mature, so too do approaches to cannabis operations. For example, when it comes to regulatory compliance for mold and other pathogens, a current, popular strategy among cannabis cultivators is to roll the dice and send untreated product to the lab in hopes that it passes microbial testing.

However, any product that fails microbial testing must be remediated, a process that is negatively perceived by consumers, who view remediated cannabis as inherently flawed. Some states, such as Pennsylvania, have banned this remediation approach altogether because of the risks associated with moldy product unintentionally getting to market. If flower in Pennsylvania fails microbial testing, growers may choose to have it re-tested without remediating it. If it fails again, the flower must be thrown out, or in specific circumstances, may be used to create topical products only.[1]

Remediation Doesn’t Need to Be Reactive

To avoid these issues, many operators are changing their approach to meeting regulatory compliance. Instead of reactively remediating failed flower, they’re incorporating a microbial contamination control solution into their Standard Operating Procedures (SOPs) before sending their product out for testing. This proactive approach is similar to the milk industry, which pasteurizes all milk prior to sale out of an abundance of caution. For cannabis operators, this strategy avoids failing tests, reduces the added expense of retesting, and ensures a predictable, safe product hits the shelves.

With rescheduling in the US on the horizon, there is now an even more compelling reason to proactively incorporate a microbial control solution versus reacting with remediation. The FDA and USDA will soon gain access to states’ medical marijuana programs, in turn bringing the industry one step closer to the eventual federal oversight of recreational cannabis markets.

The reactive approach to regulatory compliance through remediation runs in opposition to how the FDA and USDA currently regulate manufacturers and protect consumer safety. When the federal government does decide to regulate cannabis, it’s likely they’ll approach it like any other agricultural commodity or medical product and will require cultivators to treat their flower for mold and pathogens before sending it out for testing.

If cultivators want to prepare for the future of the cannabis market, they must adjust their approach to regulatory compliance and embrace a proactive decontamination strategy.

Microbial Contamination Control Solutions

There are several microbial contamination control solutions available to cannabis cultivators, though not all are ideal when considering what federal oversight may entail, including labeling requirements and organic certification.

With this looming federal oversight in mind, microbial control solutions that use ionizing radiation to treat mold and pathogens should be avoided. Ionizing radiation can change the molecular structure of the flower, as well as its moisture and terpene content. Because of this, products treated with ionizing radiation may become subject to specific labeling requirements, like adding the Radura—the international symbol for radiation—to their packaging.

That molecular change also means any product treated with ionizing radiation is not eligible for USDA Organic status, a label that could become available to cannabis once it’s rescheduled to Schedule III.

Ionizing Radiation Microbial Control Solutions:

• Gamma radiation
• E-beam radiation
• X-ray radiation

Non-Ionizing Radiation Microbial Control Solutions

Non-ionizing radiation, on the other hand, does not alter the molecular structure of what it’s treating, making it the front-running microbial control solution for cannabis cultivators. The most readily available and reliable non-ionizing solution for cannabis cultivators is Radio Frequency (RF).

RF has been used to treat nuts and dates for decades and has already been approved by federal authorities for USDA Organic operations.

The Benefits of Being Proactive With Radio Frequency

Incorporating an RF microbial control solution into your SOPs now is the fastest and easiest way to efficiently run your business and start preparing for federal change.

The Ziel RFX and APEX 7 are the industry’s only non-ionizing solutions that boast a 99.9% regulatory compliance pass rate. Operators who use them are set up for success in a few ways:

• RF is already approved for USDA Organic operations, so when that certification becomes available to the cannabis industry, cultivators who use the machine and meet the rest of the National Organic Program (NOP) requirements will be eligible for the USDA Organic label.
• Ziel’s RF technology has been EU GMP validated, a requirement for all processors seeking to bring product to market in Europe. Additionally, using RF enables processors to more easily sell in Germany, Europe's largest and fastest-growing market, which has a restrictive stance on the use of ionizing radiation.
• Both the Ziel RFX and APEX 7 can be set up on-site without building modifications and be working within a week.
• Both machines can decontaminate 160 pounds of raw cannabis flower per eight-hour shift.
• RF technology does not alter the molecular structure of the flower, so brands with a health-conscious customer base can continue to provide their consumers with a clean product.

“We’ve already seen cultivators in states like New Mexico, where the only pathogen tested for is Aspergillus, adding the Ziel RFX to their SOPs to prepare for change at the federal—and even state—level,” Ziel CEO and Co-Founder, Arthur de Cordova, noted recently. “The same thing is happening in Mississippi, where cultivators are preparing as the state makes moves to expand their testing requirements from only E-coli and Aspergillus to a full panel similar to Colorado’s. State programs are making changes as the federal reschedule draws nearer.”

Start Preparing Now

The cannabis industry is changing across the world. Standard testing procedures are in the industry’s future not just at the federal level, but also at the global level as cross-border trade increases, especially throughout Europe.

Operators must start preparing for a more regulated and standardized industry if they want to survive these changes, and that starts with reframing their attitude toward remediation. It’s no longer about reactively killing mold—it’s about proactively ensuring your product hits the market shelves.

To future-proof your business with the Ziel RFX or APEX 7, get in touch with Ziel today.