CaCOA Submits Technical Comments on DCC's Proposed Pesticide Testing Changes

The California Cannabis Operators Association recently provided detailed feedback to the Department of Cannabis Control (Rulemaking File DCC-2025-03-R) regarding proposed amendments to pesticide residue testing standards.

Public Comment on Proposed Pesticide Regulation Updates_ DCC.pdf

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Our comments demonstrate how industry expertise can help strengthen consumer protection while ensuring regulations remain scientifically sound and practically achievable.

Supporting Consumer Safety Through Smart Regulation

CaCOA supports the Department's efforts to modernize cannabis testing requirements based on emerging science and data. The proposed changes include positive updates, such as clarifying outdated action levels, expanding the pesticide testing panel, and adjusting thresholds where strong safety data justifies the changes.

These improvements align testing standards with what laboratories can realistically measure while maintaining robust consumer protections, precisely the kind of science-based approach the industry needs.

Identifying Critical Implementation Issues

However, our technical review revealed several concerns that could undermine the effectiveness of the regulations. Working with laboratory partners, CaCOA identified key problems requiring attention:

• Missing Real-World Pesticides: The proposed testing panel omits compounds frequently detected in actual products, particularly in vape cartridges. Without including pesticides such as p,p'-DDE, biphenyl, and flutriafol, which appear routinely in expanded screenings, the updated standards miss important consumer safety gaps.

• Impossible Detection Requirements: Some proposed limits fall below what even advanced laboratory instruments can detect. As we explained: “Labs cannot report what they cannot detect. And, if forced to report values they can't actually measure, they may be left to guess.”

• Flawed Consumption Models: Perhaps most problematic, the edibles standards use watermelon consumption as a proxy for cannabis edibles usage. This creates a fundamental flaw: “People don't consume cannabis edibles the way they eat watermelon. Watermelon is mostly water and often eaten in large portions, hundreds of grams at a time. In contrast, cannabis edibles are typically consumed in small, measured doses.”

Beyond technical concerns, CaCOA emphasized the need for realistic implementation timelines. Many proposed changes would require laboratories to overhaul workflows and revalidate methods. Without adequate phase-in periods, testing bottlenecks and supply chain disruptions are likely to occur.

Membership Benefit

This type of regulatory engagement directly benefits our members by ensuring testing standards remain workable while maintaining consumer protections. By identifying potential problems before implementation, CaCOA helps prevent costly disruptions and unnecessary barriers for compliant businesses.

Our members can rely on CaCOA to monitor regulatory developments and provide the technical expertise needed to navigate California's complex cannabis regulatory environment. This is the kind of proactive advocacy that makes membership essential for success in California's cannabis market.

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