MDARD institutes testing requirements for hemp | 2019-09-06


Michigan has instituted emergency guidelines for an emerging crop.

In August, the Division of Agriculture and Rural Improvement implemented testing requirements for industrial hemp. The guidelines are pertaining to the sampling and analytical testing solutions for measuring the concentration of tetrahydrocannabinol (THC) in the crop.

The crop have to not exceed .three% of THC content material on a dry weight basis. When the crop surpasses .three% of THC, it is deemed marijuana. The emergency guidelines cover a range of problems, such as the destruction of industrial hemp plots, test samples, testing facilities and licenses.

According to MDARD, the emergency guidelines apply to all registrants and licensees, and they are as follows:

  • A grower that intends to harvest or destroy an industrial hemp plot shall schedule a test of a sample of the plot by a testing facility.

  • A grower shall submit a representative sample of their plot for testing, which have to contain leaves and pistillate inflorescences.

  • The division have to prescribe sampling procedures and publish the sampling procedures on

  • The testing facility shall test the sample not significantly less than 15 days prior to the intended harvest or destruction date.

  • All samples come to be the home of the division.

  • The testing of industrial hemp have to be completed by the division or by a testing facility.

  • Samples have to be tested in accordance with ASTM International or other nationally or internationally recognized test solutions, or any other validated process authorized by the division.

  • All tests have to be performed post-decarboxylation.

  • Testing performed by a test facility, at a minimum, have to contain quantitative laboratory determination of delta-9 THC concentration on a dry weight basis. 

  • A registrant or licensee or the division might conduct added testing on their industrial hemp, such as cannabidiol and cannabidiol acid levels, foreign matter inspection, pesticides, microbial and mycotoxin screening and chemical residue, fungicides, insecticides, metals screening, residual solvents levels, terpene evaluation and water activity content material. 

  • The testing facility have to offer the grower and the division a certified report stating the final results.

  • A grower shall harvest their compliant plot inside 15 days of getting the final test final results, such as retests. Noncompliant plots have to be destroyed pursuant to the destruction order issued by the division.

  • If the division determines, primarily based on a certified report, that a plot or item is noncompliant, the division shall situation a destruction order.

  • The division shall recognize in the destruction order the plot to be destroyed and the date by which the destruction have to happen.

  • The destruction order might call for a process of destruction and might call for the division oversight of the destruction. 

  • A grower shall comply with a destruction order issued by the division.

  • All registrants and licensees are topic to inspection and sampling by the division at affordable instances to make certain compliance with the act.

  • Failure to comply with an inspection might outcome in the initiation of enforcement proceedings.

  • Either the registrant or licensee or agent of the registrant or licensee shall be present for the inspection and sampling, and they shall offer the division with unrestricted access to all industrial hemp

  • All cannabis material is topic to sampling and testing to confirm the delta-9 THC concentration does not exceed .three% on a dry weight basis. 

  • The division might gather and test person or composite samples of every single range of cannabis from the registrant’s or licensee’s land region.

  • All samples taken by the division have to be representative samples.

  • The expense of testing have to be paid by the registrant or licensee, and the division might annually modify the costs for testing. 

  • The division shall deny any registration or license application or renewal application for any registrant or licensee who has not paid all the costs it is assessed by the division below this rule. 

The guidelines will be in spot for six months, and if important, the time will be extended, according to MDARD.

James DeDecker, director of the Michigan State University Upper Peninsula Study and Extension Center, mentioned the most significant game-changer is if a sample of a grower’s crop is identified to have greater levels of THC, then the grower will have to destroy their complete crop.

An additional concern DeDecker mentioned he has is incorrect sampling. Although there are consequences outlined in the guidelines for registrants and licensees who do not comply with the sampling submission, he fears there could possibly be an situation relating to the initial submission by registrants and licensees.

“There is seriously practically nothing stopping a grower from submitting a sample that was either collected incorrectly or is not representative of the crop they are saying it is representative of,” he mentioned. “As far as integrity in the THC testing procedure right here, I assume there will be a tiny bit of a challenge (recognizing whether or not growers are) submitting their personal sample.”

The procedure is contrary to states like Wisconsin, which demands state inspectors to do on-internet site sampling of hemp fields.

The emergency guidelines comply with the state’s initiation of its Industrial Hemp Ag Pilot System in April. The pilot plan makes it possible for farmers, processors, colleges and universities to develop, cultivate and marketplace Michigan industrial hemp for the 2019 planting season.

The plan is the initial of its sort in the state. Nevertheless, the state also have to incorporate applying an older law.

“All of the regulatory framework that is expected to carry out the 2018 Farm Bill, which is the duty of the U.S. Division of Agriculture, is not in spot however,” mentioned Eric Anderson, field crops educator for Michigan State University’s St. Joseph County Extension Workplace. 

As a outcome, Michigan is applying the 2014 Farm Bill to dictate how the pilot plan operates.

“Michigan’s pilot plan makes it possible for our farmers to discover the production and processing for hemp to figure out whether or not or not this is a financially viable crop for them,” mentioned Gary McDowell, MDARD director. “It also assists pave the way for Michigan growers as we move toward a permanent licensing plan subsequent year to recognize and expand worth-added hemp processing and new marketplace prospects.”

According to MDARD, due to the fact the pilot plan was launched for the 2019 planting season, there have been more than 541 hemp grower registrations that cover more than 32,243 acres, and an added 389 processor-handler licenses have been issued.

Anderson mentioned the grower license only makes it possible for the grower to develop hemp. They can’t harvest or sell the crop. He mentioned the processor-handler license permits the licensee to procedure, shop, ship and sell, but if they would like to develop the crop, they also will have to get a grower license.

Hemp has more than 50,000 unique utilizes, such as clothes, handbags, footwear, ropes, canvas, tarps, soaps, shampoos, lotions, cosmetics, hemp seed oil, paper and a lot more, per MDARD.

Now that hemp is legalized at the national level, Anderson mentioned it makes it possible for for the state to develop the crop as an alternative of importing it from other nations. There are 3 key motives growers and processors use the crop. 

Anderson mentioned it is applied for fiber, seeds or CBD, but the pilot plan only makes it possible for for investigation purposes. Nevertheless, since the crop was planted so late since of climate, the time in which applications have been accepted and the licenses have been authorized, the harvest date will be pushed back, hampering some components of the investigation work.

Anderson mentioned the crop generally is planted in late April to May perhaps, but since of the unique situations, the crops have been planted in June and July. He mentioned it generally requires about 120 days prior to the crop is prepared for harvest, based on the intended use.

“Harvest the flower, prior to the plant is pollinated and the seeds get started developing, for CBD,” he mentioned. “Harvest the seeds when 70% of the crop is prepared to have mature seed harvested and the fiber from the stem of the plant thereafter.”


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