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Testing Requirements for Medical Marijuana

Part 1 of 4 Part Series



State by state, when rules and regulations are written for medical marijuana one very important area is often overlooked – testing. The need for testing cannabis seems like a no brainer. However, when most states launch their medical marijuana programs the parameters for testing are not always laid out. It often takes additional laws being written to mandate testing. The regulation of pesticides on cannabis, including the difficulty of setting specific residue limits is not the only thing that needs to be considered. Solvent residues, microbes, and heavy metals each pose regulatory challenges of their own. Another hot topic regarding testing is terpenes. It is not mandatory to test for terpenes and from what science is teaching us, we should all be paying close attention to which terpenes are in the cannabis strains we are consuming.

This article is the first in a series focused on the various needs for testing cannabis. Each article will cover the need for testing and why, as well as a call to action so that you can feel educated and empowered to make your voice heard wherever you live. Cannabis consumers are not just healthy adults. In most states, medical marijuana programs are legalized before recreational laws are even considered. This means that consumers consist of all age groups with various types of illnesses and conditions, and everyone is entitled to clean medicine.

The need for testing cannabis seems like a no brainer.

Third party testing is required in all states to show the amount of THC and CBD the marijuana cultivars possess. But, testing for pesticides, terpenes, and anything else varies from state to state. Regulations for testing are vital, and laboratory analysis is the bare minimum for medical cannabis facilities. A medical marijuana treatment center must retain all records of testing, as well as the samples, for a minimum of nine months (depending on the state.) Then, if a sample does not meet the set legal standards, the treatment center must recall all other products from the same batch.

Pesticides are used in the growing of cannabis for pests, insect infestations, mites, and more. Cannabis crops are very expensive, and the fastest and most inexpensive solution for bug problems is often to spray the crops down with chemicals. 33 states now have medical marijuana in the US, and they all have different rules and regulations surrounding pesticides. A major cause for this could be the fact that pesticide use in agriculture is regulated by the U.S. Environmental Protection Agency (EPA) and overseen by state and local governments. But, the federal government considers cannabis an illegal drug.1 Therefore, the EPA has not approved any pesticides for use on the plant, nor has the agency provided any indication of the level of residues on cannabis products—if any—that could be considered safe. 

Each state has had to create new laws and executive orders. Colorado for example, passed Amendment 20 in 2000 legalizing medical marijuana. But, their emergency rules for testing for pesticides took place in 2015 when the Governor issued an executive order directing Colorado state agencies to address the threat to public safety posed by marijuana contaminated by pesticides. By March of 2016, the Colorado Department of Agriculture passed rules and regulations for the Pesticide Applicators Act to apply to cannabis as well.3

Now, 20 years after medical marijuana was legalized, the state of Colorado maintains a very thorough list of which pesticides can be used on growing cannabis. The list is now up to 46 pages.4 Whenever the list is updated, notifications are sent out to all cannabis businesses and anyone registered on the list to receive updates. This streamlined process took years for the state of Colorado to fully develop. This type of list is something every state should implement.  Another example is Washington state. Five years into their recreational cannabis program, they are still working on laws related to pesticides used on recreational cannabis. Currently, their medical cannabis testing requirements for pesticides are simply to detect the general presence of any pesticides prohibited by the Washington State Department of Agriculture.

Regulations for testing are vital.

Florida is an agricultural state. Many crops are exported from the state and many pesticides are already in use for these large scale crops. The difference is—we don’t smoke strawberries or oranges. Some pesticides are deemed safe to be eaten if the produce is thoroughly washed off before eating. We don’t wash our cannabis. Instead we add fire to it when consumed through a pipe or a joint, or we add solvents to it to turn it into concentrates, or we cook with it to become edibles. None of these methods of usage have been studied for the pesticides in question. This can lead to people becoming sick after consumption if the plants are not properly flushed. 

Florida created emergency rule 64ER20 in January 2020 requiring that testing results  be reported accurately to three significant figures as the concentration in milligrams per kilogram, dry-weight for any test reported in parts per million (ppm,) and to three (3) significant figures as the concentration in micrograms per kilogram dry-weight for any test reported in parts per billion (ppb).5 They also provided a list of some 67 agricultural agents used in the growing process and what the testing parameters are for each chemical. This is a great step in the right direction.

Now you may be wondering, “What are they testing for in my state, or how can I make sure we have testing for pesticides?” The first place you can check, is the website your state has created for their medical marijuana program. You can find this by searching “medical marijuana Washington” or whatever state you live in. In Florida, the Department of Health created the OMMU (Office of Medical Marijuana Use) to be the official source of all things cannabis.6 They are responsible for writing and implementing the department’s rules for medical marijuana, overseeing the statewide Medical Marijuana Use Registry, and licensing Florida businesses to cultivate, process, and dispense medical marijuana to qualified patients. 

You can also try reaching out to cannabis organizations currently fighting for your rights as patients, such as Americans for Safe Access. The mission of Americans for Safe Access (ASA) is to ensure safe and legal access to cannabis (marijuana) for therapeutic use and research.7 There are also groups like the National Organization for the Reform of Marijuana Laws (NORML) working towards cannabis legalization as a whole. NORML has chapters in almost every state working towards broadening the conversation surrounding the cannabis plant.8

There are steps you can take to feel empowered and make your voice heard. 

Follow these 4 steps to empowerment…

1. Reach out to your legislators
If you don’t know who they are, that is okay. Our government has made it incredibly easy to find out exactly who represents you at the local, state, and federal levels. By visiting the site and clicking on the tab at the top of the screen that says “Government Agencies and Elected Officials,” you will then see the question pop up that says,
“How do I contact my elected officials?” Simply click on that and away you go.9

Pro-tip: Do your homework before you write a letter to your representative. What does that mean? It means to research them and their opinions of things, especially the issue you are contacting them about. Follow the Ten Commandments of speaking with lawmakers and you will do great.

2. Get involved
Whether you are a keyboard warrior or you are better at walking the halls of your state Capitol or medical cannabis business offices. Become proactive and interactive with your elected officials. Don’t just send emails, try calling their offices too. Remember, if you call, have a plan of what you want to say.

3. Interact digitally
In addition to platforms like Facebook and Instagram increasing the amount of interaction politicians make, Twitter remains the place where most are active daily. Consider making an account to interact and read their opinion on current events. 

4. Attend town hall meetings
Your representatives will hold local Town Hall events where the public is encouraged to attend and voice concerns. You can usually find when and where these events are going to take place on your representative’s website. If you do not see any upcoming events listed, call their office and ask their assistant. They will be happy to provide an engaged citizen with the information.

The Ten Commandments for Speaking with Lawmakers

  1. Thou shalt not lie to thy legislators.
  2. Thou shalt not forget to thank thy legislators for their help.
  3. Thou shalt not ignore thy legislators between sessions. 
  4. Thou shalt not be hypercritical of thy legislator’s voting on any bill.
  5. Thou shalt not hesitate to praise thy legislators publicly for their good works.
  6. Thou shalt not insist thy legislators desert their party on important party policy.
  7. Thou shalt not fail to recognize the importance of thy legislator’s office.
  8. Thou shalt not forget thy legislators too hath problems and sometimes needeth assistance in their day.
  9. Thou shalt not become completely partisan.
  10. Thou shalt not nitpick.

Do your homework on the office you will visit:

  • Familiarize yourself with your representative’s position or votes on relevant issues.
  • It is nice if there is something you can thank them for right from the start.


  • A warm greeting is a great ice breaker.
  • Begin your meeting by thanking your representative for his/her time.
  • Introduce yourself and all members in your group and state why you have requested a
  • meeting or why you are stopping by their office. 
  • Identify your association and no more than three priority issues.

Stay on Message

  • Be professional, but assertive.
  • Be brief. Representatives appreciate it when you get to the point and respect their time.
  • Ask for something; be specific.
  • Never make up information or ‘guess.’
  • It is best to say, “I need to get back to you.” Other than making up an answer.
  • Encourage a conversation. Ask questions of the staff.

Tips for After the Meeting

  • Take notes to help you remember what was accomplished.
  • Find the answers to questions you were unable to answer during your meeting and follow up with them like you said you would.
  • Send a thank you note and other relevant information when you get home/back to your office.


1. Seltenrich, N. Environmental Health Perspectives. April 25, 2019. doi: 10.1289/EHP5265

2.  “Amendment 20 To Colorado’s Constitution” Americans for Safe Access.” 

3.  “Pesticide Use in Cannabis Production” Colorado Department of Agriculture.

4.  “Pesticides allowed for use in cannabis production.” Colorado. 

5.  Florida Department of Health. Emergency Rule for 2020, 64ER20-9.

6.  OMMU, Office of Medical Marijuana, Florida. 

7.   Americans for Safe Access.

8.   NORML (National Organization for the Reform of Marijuana Laws) “How to find a chapter near you.”

9.  “How to contact your elected officials.”


Salute to Cannabis Nurses

Featuring Taylor Hayes



Taylor Hayes is a psychiatric registered nurse with a passion for psychedelic plant medicines that she has used to found the new International Association of Psychedelic Nurses (IAPN).Taylor’s journey to plant medicine use began through her own exposure and the benefits she received. One trip changed the trajectory of her life.

As a college student at Auburn University, Taylor had no idea what she wanted to do in addition to struggling with depression and PTSD for almost a decade. “I had never gotten help before. So I went to counseling services. I thought I would try this out and see what mental healthcare is like. And I received some help there. I was inspired by some of the people who helped me through that time period. It inspired me to want to help people as I recovered from my own depression and PTSD, I wanted to be there to help other people through their struggles, so I chose nursing school and knew I wanted to go into psychiatry since I started. I fell in love with psychiatry and all the psych patients that I have worked with mostly inpatient kids, adults, adolescents, teenagers.”

Taylor’s first exposure to a psychedelic plant was in college, and she didn’t take it with the anticipation that it would have any huge effect. “It was a mushroom, I had a psychedelic experience and it completely changed my life. I went to my psychiatrist and I told him that I didn’t feel like I needed my medications anymore; I didn’t feel depressed; I had made significant lifestyle changes following this one experience: started exercising and eating better and just caring about my life.” With the approval of her psychiatrist, Taylor was able to come off of her medication.

Throughout her journey with plant medicines, Taylor has participated in research studies and expanded her own knowledge through study in South America. “I signed up to be a participant in a psilocybin research study down in Jamaica. […] I kept following plant medicines, it became very important to me. I took a semester off school to go stay at an ayahuasca research center in Peru. I studied in San Pedro with the indigenous healers of Peru. I just had so many life-changing experiences throughout the course of that. It made me want to further study the plants and their applications within Western psychiatry: treating addiction, mental health, depression, PTSD, trauma. I actually learned throughout this journey that a significant portion of western medications originated in the Amazon Rainforest Basin, which means there’s probably countless medicines left to derive from the plants there.” 

As we continue to profile cannabis nurses, GRAM recognizes the power that nurses have. Taylor says, “Nurses have taken the lead as far as self-care in the way of medical cannabis. They’ve started writing standards of care. I think that is because the nursing practice is more pinpointed. Nurses are powerful; they’re the hands of healthcare and the heart of healthcare and they’re a significant portion of the whole body of healthcare. So if nurses get behind plant medicines and there’s no telling what kind of changes could happen.”

In February 2020, Taylor launched IAPN, which currently has about 200 members. They are “Nurses and nursing students who are interested in learning more about psychedelics and the plant medicines and how to fit this into healthcare appropriately and insightfully determining best practices and standards.” The goal is, “Increasing our database of information, increasing our membership, increasing awareness, compiling the research so that we can start putting the research into practice and into best practices for the field.” 

Taylor definitely thinks plant medicines should be legal, accessible, and regulated. “I think people should be able to possess whatever plant. As far as administering or hosting ceremonies, I definitely do think there should be some regulation around that, because it can be unsafe with people who don’t know what they’re doing or aren’t medically trained. If we promote a culture of education and safety around proper use of these plants and medicinal use of these plants, I don’t see why anybody shouldn’t be able to use them.”

In order to allow people to have safe access to psychedelic plant medicines, Taylor has also launched Hope Network Health. In coordination with licensed medical professionals, they work to provide psychedelic plant medicine care in a controlled, legal environment. They are scheduled to have their inaugural psilocybin group healing session in January 2021.

Taylor has a lot of hope for the future of plant medicine. “I am really looking forward to the future of what can be done in this space if we work consciously and with a good intention. There’s lots of potential for a new wave of healing or medicine.”

Psychedelic medicine has the potential to revamp and expand the mental health care system in the U.S. Taylor tells us, “We have a very good system in the U.S. as far as some parts of mental healthcare, but I think that our system can be expanded and improved upon. I’m advocating for an expansion, for adding new substances to medical practice, so that people can have options especially people who have tried the traditional therapy and it’s not working, now perhaps they can have access to a breakthrough therapy psilocybin or MDMA. There’s such high demand for healthcare workers because there’s so many sick people. If we can get better medicines perhaps we can improve our healthcare system, see fewer patients, less personnel on staff, less stress in everyway on the system itself, less stress on society in general, if we could get mental healthcare under control, our opiate and alcohol addictions under control, you might see less DUIs, less domestic violence, all these things are related to each other so if we have better medicine options, I think we would have a much happier and more productive country altogether. I want to see our country well.”

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Election 2020 Plant Medicine Results

Here at GRAM, we look forward to the changes coming in 2021!



2020 was a major year for plant medicine. Voters in red and blue states voted for changes in state law about cannabis for recreational and medical use. In every state that cannabis was on the ballot in November, it passed!

Cannabis Legalized for Adult Recreational Use

Arizona Proposition 207

Montana Initiative 190

South Dakota Amendment A

New Jersey Question 1

Cannabis Legalized for Medical Use

Mississippi Initiative 65

South Dakota Measure 26

Other Plant Medicine Election Results

Oregon Legalized Psilocybin- Measure 109

Washington D.C. Initiative 81

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Year of the Nurse

Featuring Eloise Theisen



Eloise Theisen is the president of the American Cannabis Nurses’ Association (ACNA). She has been a nurse for 20 years and a cannabis nurse for six years. With the focus on healthcare workers during the pandemic of COVID-19, GRAM felt talking to a cannabis nurse about COVID-19 issues would benefit our readers.

The number one challenge across the country is rapid change and uncertainty. This uncertainty is no different for the cannabis industry. “One of the challenges we’re seeing in the industry right now are these rapid changes that are coming out around deeming cannabis as an essential business in some states and not others; requiring adult-use states to now only supply cannabis to medical patients again. I think we’re seeing the industry–as a whole–is in jeopardy in terms of being able to sustain and weather this storm because of the fact we don’t qualify for any of the business stimulus relief at the federal level because we’re federally illegal still. So we have all these challenges as an industry that I am concerned about how, eventually, the ripple effect comes to patients. If manufacturers can’t weather this storm, if dispensaries and growers can’t weather this storm, who’s going to be there for patients when we start to come out of this?” Eloise said. 

A challenge for healthcare providers is providing the opportunity for cannabis as an alternative to opioids. Eloise said, “The way that the laws are set up, you have to go in and physically get your prescription refilled. And with all the practices trying to limit patients coming in, some of these chronic pain patients on opioid prescriptions are having a hard time getting their prescriptions refilled. So it’s a good time to explore cannabis as a medicine, as either an alternative to their pain medication or something they can use in conjunction, which may allow them to spare some of the dosages.”

Eloise highlighted the extreme variations happening across the healthcare industry that she sees through ACNA. “What we’re seeing right now is there are hotspots in need of healthcare professionals, but outside of that, we’re seeing layoffs, furloughs, and places closing down because the ERs aren’t at capacity or the hospitals aren’t at capacity. So there’s a real interesting extreme happening in healthcare where we’re either in crisis mode like in New York City, Michigan, Chicago, or you’re getting laid off.” One of the things ACNA is working on is a position statement on post-traumatic stress. Eloise anticipates a “huge increase in that diagnosis from the frontlines, first responders. So we want to get out there and get the states to list PTSD as a qualifying condition because not all states do.”

Eloise addressed the various concerns floating around about using cannabis in these times. “I think a lot of people are nervous about inhaling cannabis right now because there’s been some mixed reports, some clickbait, fear-mongering articles coming out. A lot of those articles, they’re using information based on tobacco studies and not cannabis studies.”

“We do have legitimate research to show that cannabis is effective for things like anxiety, chronic pain, and insomnia, and those are three major conditions or symptoms that people are struggling with right now,” she said. “I would say if you’re new to cannabis, inhalation is not the route you should choose to start until COVID settles in. If you’re a long-term cannabis user and you’re having any respiratory distress or any type of respiratory symptoms like a cough or shortness of breath, you should stop, contact your healthcare provider. Know that there are other options out there.”

It is important to note that cannabis is not a treatment for COVID-19. The ACNA came out with a statement1 addressing cannabis or CBD products being marketed as a cure or treatment for COVID-19. Eloise said, “I think it’s essential for patients to know that the FDA says there’s no coronavirus treatment or cure, and what we know about cannabis and immunity is mixed. So if you’re seeing people making claims about how cannabis or CBD can improve your immune system to fight COVID, you should be suspicious of those claims, and they haven’t been founded in science.”

If you are trying to save money on cannabis or hemp-based CBD products, you are probably sacrificing quality and putting yourself at risk. Eloise said, “Right now, because people have limited income, they may be turning to the grey market to try to save some money, and there’s concern about what’s in those products in terms of mold and pesticides.”

One frustrating aspect of the current environment is that in the race to find a treatment and develop a vaccine for coronavirus, doctors and scientists are basing decisions on extremely small subject groups. “The gold standard of the double-blind, randomized placebo trials, that the healthcare community requires or requests for any type of treatment has been getting a lot of pushback with cannabis, and here we are seeing very small sample sizes with coronavirus and different treatments. And you understand, people are desperate. They’re theorizing how COVID is behaving in the body and what mechanism of action and trying to find the right medication for it. But we see mixed results. Even The New England Journal of Medicine published and basically said there’s not enough evidence to support that hydroxychloroquine and azithromycin are effective treatments for COVID right now.2 Yet we have our current leadership out there promoting this treatment [which has] devastating side effects. It can be toxic to the heart, among other things. It’s this double standard that we’re experiencing right now. I would love to see some leniency or some opportunities open up for cannabis,” Eloise said. “You’re reading about shortages in the hospitals for the different things we need to treat patients, not just with personal protective equipment, but now medication. It’s like if there was ever a time for cannabis, now is it.”

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