In January’s package of federal recommendations to improve the Cannabis Act’s micro-class regulations for BC craft farmers and processors, the Co-op identified a need to address concerns about microbial testing limits for dried cannabis. The new testing limits are specific to the intended use of the cannabis or cannabis containing the products (oral, inhaled, topical, etc.), and are meant to reflect the differences in risk associated with a particular route of consumption (ingested vs inhaled). These new limits will take effect on March 31, 2021 after a grace period has expired. Since then, Health Canada released a statement to “clarify” their approach. Here are the highlights:

  • Health Canada has received questions about the use of oral microbial limits for herbal medicines for smoked/vaped dried cannabis products and whether limits such as those found in the European Pharmacopeia section 5.1.8 would be considered appropriate.

  • Health Canada has concluded that oral limits for dried cannabis products, such as those found in Ph. Eur. 5.1.8, are acceptable.

  • This requirement remains unchanged since the implementation of the Marihuana for Medical Purposes Regulations in 2014 (now repealed).

  • If Health Canada becomes aware of information that oral limits don’t mitigate the risk posed by micro-organisms in dried cannabis that is smoked or vaped, they may review this position.