On February 7, 2017, following three recalls of medical cannabis related to the use of unauthorized pesticides, Health Canada announced that it would begin a series of unannounced inspections, including random testing of cannabis products from licensed producers to ensure that only registered pesticides are used during the production of cannabis for medical purposes.
As part of a first series of unannounced inspections of seven licensed producers in March, Health Canada collected samples of plant leaves, dried cannabis and cannabis oil (if produced), as well as samples of any products suspected to contain pesticides the inspectors found on site.
On May 1 and 4, Health Canada's Pest Management Regulatory Agency completed laboratory testing of plant leaves from the seven inspected sites. Five of the seven sites (RedeCan, 7Acres, Tweed, Tilray and Broken Coast) showed no sign of contamination in the leaves that were tested. Of the remaining sites, both leaf samples at Hydropothecary tested positive for myclobutanil at low level concentrations of between 0.012 and 0.023 parts per million (ppm), and one leaf sample from plants at Peace Naturals tested positive for piperonyl butoxide at a low level concentration of 0.78 ppm. Myclobutanil is a pesticide that is not authorized for use in cannabis cultivation, while piperonyl butoxide is a synergist that is a substance that is combined with pesticides to increase their effectiveness. Piperonyl butoxide is considered an active ingredient in pesticides, and is not contained in any of the 17 pesticides authorized for use in cannabis cultivation. Testing of dried cannabis and cannabis oil samples taken from the seven licensed producers is ongoing; results are not yet available.
When it announced random testing, Health Canada was clear that it would not hesitate to take additional measures if warranted based on evidence. Health Canada is announcing that it will require all licensed producers to conduct mandatory testing of all cannabis products destined for sale for the presence of unauthorized pesticides. Licensed producers already test cannabis products for microbial and chemical contaminants (such as mould, heavy metals, and bacterial and fungal contamination) as required by the Access to Cannabis for Medical Purposes Regulations. In addition, Health Canada will continue to carry out random testing of product samples collected during its regular and unannounced inspections of licensed producers to help ensure the safety of Canada's medical cannabis supply.
Hydropothecary and Peace Naturals are working to determine through additional testing by independent laboratories which product lots may be affected, will communicate directly with clients who may have received affected product, and have indicated they will undertake voluntary recalls as necessary. Health Canada will keep the general public informed by publishing information in the recalls and safety alerts database. These companies are also undertaking an investigation and will implement any necessary corrective measures, which will be reviewed by Health Canada.
The Access to Cannabis for Medical Purposes Regulations are clear: only the 17 pesticides listed under the Pesticides Act (PCPA) for use on cannabis crops may be used at any point in cannabis production. There are no exceptions to these requirements, and no situations in which using a pesticide that is not authorized under the PCPA for cannabis cultivation would be acceptable.
In the coming weeks, Health Canada will provide guidance to licensed producers on how to implement mandatory testing, including reporting of test results to Health Canada.
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