Health Canada Testing of Cannabis for Medical Purposes for Unauthorized Pest Control Products
To Licensed Producers of Cannabis for Medical Purposes
Recently, two licensed producers of cannabis for medical purposes undertook voluntary recalls of products that contained low levels of unauthorized pest control products, including myclobutanil. Under the Access to Cannabis for Medical Purposes Regulations (ACMPR), licensed producers are permitted to use only the 20 pest control products that are currently approved for use on cannabis under the Pest Control Products Act (PCPA).
Health Canada would like to remind licensed producers of their obligations when it comes to the use of pest control products in the production of cannabis for medical purposes. The following regulatory obligations must be met prior to selling products:
- As per section 18 of the ACMPR, licenced producers are not permitted to use additives in the production of fresh or dried marijuana, or marijuana plants or seeds intended for sale. “An additive means anything other than marihuana but does not include any residue of a pest control product or its components or derivatives unless the amount of the residue exceeds any maximum residue limit specified for the product, component or derivative under section 9 or 10 of the Pest Control Products Act.”
- Licenced producers must also adhere to section 66 of the ACMPR which states that “fresh or dried marihuana or marihuana plants or seeds must not be treated with a pest control product unless the product is registered for use on marihuana under the Pest Control Products Act or is otherwise authorized for use under that Act”.
As such, licensed producers must ensure that no other products, other than the 20 approved pest control products, are applied to fresh or dried marijuana, marijuana plants or seeds, as part of their production practices. Licensed producers are advised that the use of any foliar spray containing, but not limited to, fertilizers, nutrients, or wetting agents applied on fresh or dried marijuana, marijuana plants or seeds is prohibited, as is any other product containing an unauthorized pest control ingredient.
Licensed producers are required to have adequate controls within their facility to ensure that unauthorized pest control products are not used. These controls may include, but are not limited to, restricting access to pest control products, monitoring the application of products to fresh or dried marijuana, marijuana plants or seeds, or testing for unauthorized pesticide use. Licensed producers are encouraged to review and implement an integrated pest management program as part of their Good Production Practices.
In response to recent events, Health Canada will begin conducting random testing of cannabis products produced by licensed producers to provide added assurance to Canadians that they are receiving safe, quality-controlled product. Health Canada will test these products to ensure that only registered pest control products are used during the production of cannabis for medical purposes.
The Pest Management Regulatory Agency (PMRA) maintains a database repository of registered pesticides that are approved for use on marijuana.
As of September 13, 2017, there are 20 registered pesticides approved by PMRA for use on cannabis (marijuana) that is produced commercially indoors. They are:
- Actinovate SP
- Agrotek Ascend Vaporized Sulphur
- Bio-Ceres G WP
- Bioprotec Caf
- Bioprotec Plus
- Botanigard 22 WP
- Botanigard ES
- Doktor Doom Formula 420 Professional Use 3-in-1
- Influence LC
- Kopa Insecticidal Soap
- MilStop Foliar Fungicide
- Neudosan Commercial
- Opal Insecticidal Soap
- Rootshield(R) WP Biological Fungicide
- Rootshield HC Biological Fungicide Wettable Powder
- Vegol Crop Oil
Information and labels for the pesticides approved by the PMRA are available in the Pesticides and Pest Management section of the PMRA website.
If licensed producers have questions or concerns regarding pesticides, or would like approval on the use of particular pesticides, they are encouraged to contact PMRA for information.
Adherence to Good Production Practices
Section 63(1) of the ACMPR prohibits a licensed producer from selling or providing or exporting fresh or dried marijuana, cannabis oil or marijuana plants or seeds unless the Good Production Practices requirements set forth in Subdivision D of the ACMPR have been met. This includes the requirements for use of pesticides.
In the event that an unauthorized pest control product is used on fresh or dried marijuana, or marijuana plants or seeds intended for sale, Health Canada will take applicable enforcement actions. This includes, but is not limited to, the seizure and destruction of the product, recall of products if they are sold to clients, suspension and/or revocation of the licence. Compliance action may also be taken under Pest Control Products Act.
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