The Agricultural Improvement Act of 2018 (2018 Farm Bill) sets the stage for products containing hemp cannabidiol (CBD) to come to market. These CBD products include oils, edibles, beverages, topicals and other health products.
The Federal Food, Drug, and Cosmetic Act (FDCA) gives broad authority to the U.S. Food and Drug Administration (FDA). Essentially the FDA guarantees the safety and effectiveness of drugs (including animal drugs), devices (including veterinary devices), and food supply.
Inherently, the FDA requires certain food lab and environmental testing to help determine safety. They take enforcement action as appropriate when food quality is inadequate or unsafe. For example, they monitor and take action case-by-case if metals in food, cosmetics, pet food and animal feed are determined hazardous.
Among other things the FDCA allows the FDA to approve new drugs. Accordingly, the FDA ensures that companies can only market products that have been approved as such and regulates advertising for prescription drugs.
Specifically, section 408 of the FDCA authorizes the Environmental Protection Agency (EPA) to set limits on the concentration of pesticides in foods. Pesticide-sprayed crops can leave residue on plant produce/products causing potential adverse health problems. Thus the FDA addresses effects of pesticides on food plants and products.
The EPA determines allowable tolerance levels in food items for each different pesticide. Then, it is up to the FDA and U.S. Department of Agriculture (USDA) to enforce those levels.
Primarily, due to lack of scientific information on the safety of CBD products, the FDA has not yet determined whether they can be marketed lawfully. Alternatively, the FDA warns a number of companies are violating the FDCA by prematurely marketing and mislabeling CBD products.
The FDA asserts it is illegal to sell CBD products with unproven claims or applications. Many claim their CBD products prevent, treat or cure a variety of diseases in humans or animals and also market as dietary supplements.
At the same time, the FDA seems to indicate that CBD ingredients can be used in cosmetics. That is, if labeled appropriately and are free of other toxic substances.
So far, the FDA approves only one CBD product, a prescription drug called Epidiolex. This medication treats epilepsy and seizures linked with three rare and severe neurological diseases.
An international standard exists for the competence of testing and calibration of testing labs. This standard, ISO/IEC 17025, was created by the International Organization for Standardization/International Electrotechnical Commission. In most countries, it is the certification that most testing labs must hold in order to be deemed technically proficient.
The ISO accreditation requires on-sight inspection of laboratory facilities, equipment and staff credentials. It endorses the performance of all individual tests and protocols used. It verifies any procedure used is reliable, traceable (what steps taken) and fully justified.
KJ Scientific Independent Testing Labs (KJ SCI-ITL) is accredited ISO/IEC 17025. We affirm that all our analytical work is conducted professionally in accordance with all applicable standard laboratory practices using valid methods.
Potentially, contaminants or toxins occur in extracted CBD. These impurities come from soil, the separation process used, product manufacture, transport and storage. However, federal laboratory testing of CBD products is not yet required.
Fundamentally, the public expects safe and high-quality CBD products. So already some state regulations require third-party testing labs to test CBD products to protect the consumer.
Ideally, a testing lab should adequately analyze the CBD oil added to consumer products prior to product infusion.
Each state determines the legal status of CBD as well as regulation of sale and purchase of CBD manufactured products. The state of Texas legalizes CBD and CBD hemp products containing 0.3 percent or less of tetrahydrocannabinol (THC).
Overall, the Texas Department of Agriculture (TDA) holds a federally approved Texas Hemp Plan for their state’s program to commercially grow hemp. Among other things, it defines consumable hemp products as foods, drugs, devices or cosmetics containing industrial hemp or hemp-derived cannabinoids including legal CBD.
The hemp plan requires testing labs to analyze presence and quantity of cannabinoids (ex. CBD, THC). Accordingly, they test for associated residual solvents, heavy metals, pesticides and harmful pathogens i.e., mold, fungi and bacteria.
The plan mandates an ISO/IEC 17025 accredited testing lab to test hemp/hemp derivatives used in consumable hemp products. All independent testing labs are expected to register with the state.
In addition, the TDA provides guidelines for sampling the hemp plant for laboratory testing. The sampling agent as directed cuts the plant underneath the flower from the top one-third of the plant.
KJ SCI-ITL is an official independent (third-party) testing lab registered under TDA hemp regulations (Texas License #: 2020011). In Texas we are one of two laboratories ISO accredited to do all the tests required for hemp and hemp products.
The high performance testing of KJ SCI-ITL meets the most rigorous mandatory California cannabis testing regulations. For example, California tests all cannabis for more than 100 contaminants including 66 pesticides.
Additionally, our diverse experience sets us above most certified labs. We conduct environmental chemical risk assessment and bioaccumulation testing for every industry. Our analysis meets specifications of international industry regulators. For instance, we meet regulations issued by Environmental Protection Agency (EPA), Registration, Evaluation, Authorization and Restrictions of Chemicals (REACH) and European Chemical Agency (ECHA).
We develop and utilize cutting edge in vitro experimental methods that reduce the number of animals, cost and time. We are also among seven labs of Fortune 500 commercial and government organizations in the world that conducted a ring trial to standardize methodology to test chemicals for purposes of human and environmental health.
KJ SCI-ITL is suited to address and customize your CBD testing to meet regulatory compliance. Please contact us to address your specific CBD testing requests.