Missouri cannabis regulators publish new information and FAQs regarding reference lab and testing

Missouri’s Division of Cannabis Regulation is revising routine cannabis sampling procedures following industry feedback, with anticipated changes including advance notices to licensees along sampling routes, according to newly published FAQs.

The FAQs also explain how the state’s cannabis reference lab compares laboratory results, supports investigations, and uses confirmatory testing before recalls arising from routine sampling.

DCR said the procedural revisions incorporate feedback from industry and testing partner meetings.

“For example, advance notices are expected to be issued to licensees along the sampling route, and laboratories will receive notification after sampling to allow for retention choices,” the FAQs explain.

Existing sampling processes have been available to licensees, and updated procedures will be posted on DCR’s website when revisions are complete.

The information is available on DCR’s Facility FAQs webpage.

DCR acknowledged that cannabis testing results can vary because of differences in equipment, methods, and analyst techniques. The division said it supports secondary or confirmatory testing when appropriate.

“For example, DCR’s process for routine sampling has always included confirmatory testing, and recalls have only been issued after multiple confirmations by the Reference Lab and a testing facility chosen by the licensee whose product failed a test,” DCR states in the FAQs.

DCR also cited its authority under 19 CSR 100-1.020(3)(G)1 to immediately suspend all or part of a facility’s operations, including placing products on administrative hold, when the department identifies a credible and imminent threat to public safety.

The reference lab’s work supports DCR’s oversight of regulated cannabis licensees.

“The primary purpose of the Reference Lab is to assist the Division of Cannabis Regulation (DCR) in its oversight of regulated cannabis licensees by conducting independent testing of regulated cannabis to ensure product safety, labeling accuracy, and testing consistency and efficacy,” the document states.

Responsibilities are shared between DCR and the Missouri State Public Health Laboratory, which oversees reference lab activities.

That work includes routine sampling, comparisons among laboratories, and investigative assistance. Sampling and investigative testing check whether products meet testing requirements and match their labels, while laboratory comparisons help identify inconsistencies or weaknesses in testing.

DCR cited 19 CSR 100-1.110(3)(E) as requiring testing licensees to participate in inter-laboratory comparisons by exchanging and testing product samples. The division also cited 19 CSR 100-1.110(12) as authorizing it to require licensees to submit samples to assess product safety, labeling accuracy, and the validity of a testing laboratory’s results.

DCR said it may collect samples when it has reason to believe a product is contaminated or mislabeled, suspects a violation of applicable rules or law, or determines testing would contribute to an investigation. The division said products may be tested by a licensed marijuana testing facility, the Missouri State Public Health Laboratory, or another laboratory authorized to perform the required tests.

The laboratory comparison program has included two rounds with different testing objectives and preparation methods.

“The first round of testing focused on potency analysis of raw bud flower, while the second round involved inoculated bud flower containing a specific species of Aspergillus,” the FAQs explain.

Future rounds will address needs identified at the time, with differing preparation methods and testing requirements.

DCR said routine sampling and laboratory comparisons are intended to strengthen testing consistency across laboratories, product types, and the broader regulated market. The division may reduce the level or frequency of sampling in the future once the performance and reliability of testable analytes, the substances or organisms being tested for, are demonstrated.

Patterns in testing failures could also inform broader regulatory changes, including adjustments to the mandatory testing panel or the thresholds that determine whether a product passes or fails.

“For example, analysis of testing data could indicate a need to update the mandatory testing panel, such as adding or removing analytes or raising or lowering action limits,” the document notes.

Licensees could use their own testing data to identify needed changes in cultivation, packaging, or testing procedures. DCR identified failures associated with post-packaging tests or particular analytes as potential signals that processes need review.

The reference lab’s activities could expand in the future. DCR identified possible work with the attorney general or other entities to test unregulated cannabis products, additional investigative coordination, and research with licensed testing facilities to improve testing panels and standards.

“Activities may shift or expand over time as needed to ensure DCR and the Reference Lab are fulfilling their responsibilities related to cannabis testing oversight,” the FAQs state.

DCR states that the Missouri State Public Health Laboratory is ISO accredited and directs readers to accreditation information through Perry Johnson Laboratory Accreditation Inc. and the Department of Health and Senior Services.

The division said sample collection and transportation activities are recorded in Missouri’s statewide tracking system. The state public health lab updates chain-of-custody, sample receipt, and storage procedures as needed. Its staffing requirements are governed by 42 CFR 493.1441-1495, according to DCR.