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HomeMy WebLinkAbout06/03/2014 06 Audience Participation Distributed at the i l 6 Y �� Overview ,1 Jedidoh 1 1 Key Features of Initiative 502 TO MARIJUANA • It would no longer be a crime for adults 21 and over to possess up to one ounce of marijuana for personal use. 12000 ") 10000 8000 6000 E 4000 I 2000 0 2°°° 2001 2002 2003 2004 2009 Misdemeanor Possessan Arrests 2006 2007 Felony Arrests (Growing, Sales) 2008 2009 2010 • Specially- licensed Washington farmers would be allowed to grow marijuana that could be sold in standalone, marijuana -only package stores operated by private Washington businesses licensed and regulated by the state. Public display, and smoking in bars or other locations where tobacco smoking is prohibited, would not be allowed. Advertising and store locations would be restricted to minimize exposure to people under 21. 502 - Tax Revenue Distribution Youth Drug Prevention Public Health According to the state Health Care ---$68 million Education Office of Financial million $244 million $44 I -502's new 25% marijuana Evaluation and excise tax, combined with • Research retail sales and B &O tax, $5 million would generate more than a half - billion dollars in new Program tax revenue annually. Administration Approximately $182 million $5 million would go to the state general fund, $34 million to Local Budgets local budgets, and $366 $34 million million to health care, education, and prevention. State General Fund $182 million • A new marijuana DUI standard would operate like Washington's alcohol DUI standard to discourage drivers who might be over the limit from getting behind the wheel. Updated 08.10.12 www.newapproachwa.org J i .I YES4 Backgrounder 1-502 Federal Law: Preemption and Dual Sovereignty A NEW APPROACH TO MARIJUANA Initiative 502 is not preempted by federal law. On the other hand, it does not create a legal defense to enforcement of federal marijuana laws. Rather, it represents a well - considered, responsible approach to marijuana regulation that deserves the same policy deference as state medical marijuana laws. Washington is free to try a new approach to our marijuana laws. • Our nation's structure, and the limits placed on federal power by the U.S. Constitution, "allow the States 'great latitude under their police powers to legislate as to the protection of the lives, limbs, health, comfort, and quiet of all persons." "' • The powers reserved to the states by the U.S. Constitution include the power to decide what is criminal and what is not under state law.' • The reservation of powers to the states can foster innovation and positive change: "It is one of the happy incidents of the federal system that a single courageous state may, if its citizens choose, serve as a laboratory; and try novel social and economic experiments without risk to the rest of the country.i "Federal preemption" is a legal doctrine that says that any state law that conflicts with a federal law is preempted, or "trumped" by the federal law. • The Supremacy Clause of the U.S. Constitution says, 'This Constitution, and the Laws of the United States ... shall be the supreme Law of the Land; and the Judges in every State shall be bound thereby; any Thing in the Constitution or Laws of any State to the Contrary notwithstanding." • The "Laws of the United States" are federal laws, like the federal Controlled Substances Act (CSA) that prohibits marijuana. The "Laws of any State" are state laws like Washington's Uniform Controlled Substances Act, which 1 -502 amends. • Sec. 903 of the federal CSA specifically provides that federal drug laws do not preempt state drug laws "unless there is a positive conflict" between the two. A "positive conflict" arises only if the state law requires someone to do something that violates federal law.' 1 Gonzales v. Oregon, 546 U.S. 243, 270 (2006) (internal citations omitted) (striking down a federal rule aimed at undermining Oregon's Death with Dignity law). 2 See, e.g., Gonzales v. Raich, 545 U.S. 1, 42 (2005) (O'Connor, J., dissenting). 3 New State Ice Co. v. Liebmann, 285 U.S. 262, 311 (1932) (Brandeis, J., dissenting). 4 Article VI, Clause 2. s 21 U.S.C. § 801 et seq. 6 RCW 69.50.101 et seq. ' Qualified Patients Ass'n v. City of Anaheim, 187 Cal. App. 4 734, 115 Cal. Rptr. 3d 89 (2010). Updated 07.30.12 www.newapproachwa.org lr.t a._on g NEW APPROACH TO MARIJUANA 1 -502 does not require anyone to do anything that violates federal law. • 1 -502 removes state -law prohibitions against producing, processing, and selling marijuana, subject to licensing and regulation by the Liquor Control Board. It also decriminalizes, under state law, possession of limited amounts of marijuana by persons aged twenty -one and over. It does not attempt to change federal penalties that apply to marijuana. • A state may adopt regulations relating to marijuana that define the parameters of conduct that is permissible under its own laws, and also create licensing systems that allow it to distinguish between people engaged in permissible conduct and those who are breaking the law.' • 1 -502 does not require anyone to produce, process, sell, or possess marijuana — or engage in any other activity that is illegal under federal law. It simply removes state criminal and civil penalties for marijuana - related activities that are conducted in compliance with state law, should a person choose to engage in those activities. "Dual sovereignty" is a legal principle that allows both the states and the federal government to adopt laws relating to marijuana. Each sovereign is free to enforce its own marijuana laws within the individual states — and also to exercise discretion as to how and whether to enforce those laws. • Both Congress and Washington State have adopted laws regarding marijuana. Those laws are inconsistent in a number of areas, like sentencing and the medical use of marijuana. Someone who grows marijuana in Washington is breaking both state and federal law, but the response by law enforcement, and potential sentence one could face, are very different under the two sets of laws. • The federal marijuana laws do not recognize medical use as a defense. However, in 1998, Washington voters passed a medical marijuana law with 59% of the vote. In 2009, the U.S. Department of Justice issued a memorandum to all U.S. Attorneys serving in medical marijuana states that said that, as a policy matter, federal resources should not be expended on the investigation and prosecution of individuals in "clear and unambiguous compliance" with state medical marijuana laws. • Marijuana produced, sold, and taxed under a robust regulatory system would protect public health and safety much better than Washington's current unregulated medical marijuana market and the black market supplying recreational users. Washington voters' decision to move in this direction should receive the same deference as the medical marijuana laws already adopted by sixteen states and Washington, D.C. 8 Initiative Measure No. 502 Ballot Measure Summary; 1 -502, Sec. 19. 9 1 -502 Ballot Measure Summary; 1 -502, Sec. 20. 10 Qualified Patients Ass'n, supra, n.5; County of San Diego, et al., v. San Diego NORML, et al., 165 Cal. App. 4 798, 81 Cal. Rptr. 3d 461, review denied (2008), and cert. denied, 556 U.S. ___, 129 S. Ct. 2380, 173 L. Ed. 2d 1293 (2009). Green (/green) / Society (/society) Sign in 1 Register • _f , • 4 iO J�rr c .o, 000, } :14.i's f 0. Y ti • 41 , • t** Argior 4011 A budtender pours marijuana from a jar at Perennial Holistic Wellness Center medical marijuana dispensary in Los Angeles, California. Photo by David McNew /Getty House blocks feds from going after medical marijuana 05/30/14 12:28 PM 5 save share 14 (http: /i By Amanda Sakuma (/person /amanda - sakuma) For the first time ever, Congress is taking action to protect - not condemn - medical marijuana use. Shortly after midnight Friday, the GOP -led House passed a measure (http: / /www.huffingtonpost. com/ 2014 /05 /30 /dea- medical- marijuana - house- vote_n_5414679.html) that would prohibit the Drug Enforcement Agency from raiding medical marijuana activities in states where it is legal. It gained broad bipartisan support with 170 Democrats and 49 Republicans voting in favor of the bill, with a final 219 -189 tally (http: / /clerk. house .gov /evs /2014/ro11258.xm1). Republican Rep. Dana Rohrabacher of California attached the measure to a routine spending bill. It would block the Justice Department from using federal dollars to interfere with medical marijuana operations that are legal in almost half of states in the country. 'Sortie people are suffering, and if a doctor feels that he needs to prescribe something to alleviate that suffering, it is immoral for this government to get in the way," Rohrabacher said, raising his voice on the House floor Thursday night. "And that's what's happening." The measure still faces several procedural hurdles. The Senate is expected to pass its own funding bill, meaning the amendment would have to survive the reconciliation process in a joint conference. And that's even before it makes it to the president's desk for his signature. The groundbreaking vote mirrors a growing swell of support for marijuana across state legislatures and among the public. For the first time ever, a majority of Americans support Vmsnbc/ majority - americans - want- experiment)legalizing marijuana. Minnesota just became the latest state to green -light medical use ( http: / /minnesota.cbslocal.com /2014/05/29/gov - dayton- signs - medical- marijuana -bill- into -law /) of pot, adding to the 21 other states and the District of Columbia that have similar laws on the books. Meanwhile Washington and Colorado are becoming a testing ground in shaping a market and regulation for recreational pot use while the drug remains illegal under federal law. "Despite this overwhelming shift in public opinion, the federal government continues its hard line of oppression against medical marijuana," Rohrabacher said on the House floor. The feds have already taken small steps toward reconciling the competing state and federal laws. Easing back on the decades -long "war on drugs," Attorney General Eric Holder said the DOJ would stand by the voter - backed initiatives in Washington and Colorado. Holder has also said the administration would be "glad to work with Congress" on whether to declassify marijuana from being considered on the same level as heroin and LSD, a movement that is slowly gaining steam (http://www.thefix.com / content / congressmen- ask- obama- declassify- pot- schedule -i- drug). "It's becoming clearer and clearer that marijuana prohibition's days are numbered," Marijuana Policy Project director Dan Riffle said in a statement (http: / /www.mpp.org /media /press- releases/ congress- votes -to- end - war - on.html). "It's nice to see more members of Congress standing up for their constituents instead of standing in the way of reform." Do you think recreational marijuana will be legal nationwide within the next decade? (/msnbc /do -you- think - recreational- marijuana - will -be- Iegal- nationwide - within- the - next - decade) What do you think? ( http: / /pubads.g.doubleclick.net /gampad /jump? iu= 2620 /msnbc /poll &sz =240x 6/3/2014 Congressmen Ask Obama To Declassify Pot As Schedule I Drug 1 The Fix the THE ANGELS HOUSE Luxurious Recovery of the body, mind & spirit. fi ► Committed, Professional • Luxurious & Comfortable Retreat addiction and recovery, straight up as LALU NOW (714) 471 -4985 • Specialized Comprehensive Program IiIr® HOT TOPICS: Alcoholism Addiction AA Cocaine Heroin Get Your Weekly Email Fix Search ■ Congressmen Ask Obama To Declassify Pot As Schedule 1 Drug MOST POPULAR Spearheaded by Oregon congressman Earl Blumenauer, the letter marks the latest effort 1. AA Critic Lights Another Fire by a growing number of politicians to make more sensible marijuana laws. 2. No Profit In Junkies, New Heroin A bipartisan letter signed by 18 congressmen, 17 Vaccine Ignored Democrats and one Republican is asking President ` r� 3. Film Starring Elle Fanning Shows Obama to drop marijuana as a Schedule 1 drug. Its ' • +' Shocking Reality of Eating Disorders current classification puts it on the same level as 4. Ester Nicholson Talks "Soul heroin and LSD, which makes it impossible for Recovered" doctors to prescribe it. .af" t 5. 35 Steps to Total Demoralization i . ' a The letter was composed by Rep. Earl Blumenauer • r _ '� (D -Ore.) and said that urgent action was required of i . SOBER LIVING MORE on this issue since Obama had recently told the New Yorker that marijuana isn't any more From Steroid /•. Madness to dangerous than alcohol when it comes to "impact ByMcCartonAckerman Bantu Marijuana + on the individual consumer." 02/14/14 - ------- Sacred Bantu 1 Share marijuana was my You said that you don't believe marijuana is any more dangerous than miracle MS healer —it alcohol: a fully legalized substance...Marijuana, however, remains listed got diapers forced o func an b p out p t on me and by y pr rescription in the federal Controlled Substances Act at Schedule I, the strictest steroids. Barack Obama Supports classification. This makes no sense," the letter. "Classifying Marijuana Legalization In marijuana as Schedule I at the federal level perpetuates an unjust and Colorado And Washington 35 Steps to Total Demoralization irrational system. We believe the current system wastes resources and From Cold Turkey to Manorexia White House Drug Official destroys lives, in turn damaging families and communities. Taking Slammed For Refusing To I Don't Believe in God, But I Pray action on this issue is long overdue." Say If Pot Is More Addictive My Name is Steven and I'm Not An Than Meth Alcoholic The letter also requested that marijuana be pushed further down than a Senate Majority Leader Schedule II classification. Schedule I drugs are viewed by the federal Harry Reid Now Supports THE REHAB REVIEW government as having "no currently accepted medical use in the United Medical Marijuana States," while Schedule II are classified as having "a high potential for Congress Hopeful to Smoke Cliffside Malibu abuse which may lead to severe psychological or physical Pot on Capitol Hill dependence." Blumenauer has become a pot advocate as of late; he Rhode Island Lawmakers The "beach house - relaxed" has pushed for tax reform to treat legal marijuana businesses like any Consider Legalizing Pot Cliffside Malibu claims to pro' de an oasis for other businesses and wants federal legislation to clarify the rights of recovenng addicts and alcoholics. And that's Just states to legalize medical marijuana. what you'll get —if you've got the cash. tr, //1' Morningside Last week, Blumenauer - lammed the deputy director of the White House Office of National Drug I// Recovery Control Policy after he refused to say whether pot was more dangerous than meth. Deputy director ', Michael Botticelli acknowledged that "there's relative toxicity related to those drugs," but declined to say For a "rehab near the beach" which was more harmful because he felt the conversation minimizes the harm." experience that isn't quite as costly as similar SoCal competitors, head to this Newport Beach treatment facility. Blumenauer literally threw his hands up in frustration and ranted over what he felt was a vague response. "Being unable to answer something clearly and definitively when there is unquestioned evidence to the contrary, is why young people don't believe the propaganda, why they think it's benign," he said. "If a professional like you can't answer clearly that meth is more dangerous than marijuana — http : / /www.thefixcorr'content/cong ressmen - ask - obama- declassify- pot - schedule -i -drug 1/3 f Washington State `_: Liquor Control Board Washington State Liquor Control Board (WSLCB) Certification Good Laboratory Practice (GLP) Checklist — Version 1.0 ORGANIZATON Document Y N NA Comments Reference 1. The laboratory or the organization of which it is part shall be an entity that can be held legally responsible. 2. The laboratory conducting third -party testing shall have no financial interest in a licensed producer or processor for which testing is being conducted. a. If the laboratory is part of an organization performing activities other than testing and /or calibration, the responsibilities of key personnel in the organization that have an involvement or influence on the testing and /or calibration activities of the laboratory shall be defined in order to identify potential conflicts of interest. 3. The laboratory shall have policies and procedures to ensure the protection of its client's confidential information and proprietary rights, including procedures for protecting the electronic storage and transmission of results. 4. The laboratory is responsible for all costs of initial certification and ongoing site assessments. 5. The laboratory must agree to site assessments every two years to maintain certification. 6. The laboratory must allow WSLCB staff or their representative to conduct physical visits and check 1- 502 related laboratory activities at any time. 7. The laboratory must report all test results directly into WSLCB's traceability system within 24 hours of completion. Labs must also record in the traceability system an acknowledgment of the receipt of samples from producers or processors and verify if any unused portion of the sample was destroyed or returned to the customer. 1 HUMAN RESOURCES Document Y N NA Comments Reference 8. Job Descriptions for Owners and all Employees: key staff 9. Qualifications of Owners and Staff: CVs for staff on file a. Have technical management which has overall responsibility for the technical operations and the provision of the resources needed to ensure the required quality of laboratory operations; b. Documentation that the Scientific Director meets the rule requirement of the WSLCB. c. Chain of command, personnel organization /flow chart, dated and signed by the laboratory director d. Written Documentation of delegation of responsibilities (assigned under rule of Chapter 314 -55 WAC as related to quality assurance testing) to qualified personnel, signed and dated by the laboratory director e. Documentation of employee competency: Prior to independently analyzing samples, testing personnel must demonstrate acceptable performance on precision, accuracy, specificity, reportable ranges, blanks, and unknown challenge samples (proficiency samples or internally generated quality controls). Dated and signed by the laboratory director. f. Designate a quality manager (however named) who, irrespective of other duties and responsibilities, shall have defined responsibility and authority for ensuring that the quality system is implemented and followed; the quality manager shall have direct access to the highest level of management at which decisions are made on laboratory policy or resources. 10. Written and documented system detailing the qualifications of each member of the staff a. The need to require formal qualification or certification of personnel performing certain specialized activities shall be evaluated and implemented where necessary. 11. Standard Operating Procedure Manual that details records of Internal Training Provided by Facility for Staff: (Laboratory Director must approve, sign and date each procedure) a. Instructions on regulatory inspection and preparedness b. Instruction on law enforcement interactions c. Information on U.S. federal laws, regulations, and policies relating to individuals employed in these operations, and the implications of these for such employees. 2 HUMAN RESOURCES Document Y N NA Comments Reference d. Written and documented system of employee Training on Hazards (physical and health) of chemicals in the workplace, including prominent location of MSDS sheets and the use of appropriate PPE. e. Written and documented system on the competency of personnel on how to handle chemical spills and appropriate action; spill kit on site and well - labeled, all personnel know the location and procedure. f. Information on how employees can access medical attention for chemical or other exposures, including follow -up examinations without cost or Toss of pay g. Biosafety and sterile technique training STANDARD OPERATING PROCEDURES Document Y N N/A Comments Reference 12. As appropriate, Laboratory operations covered by procedures shall include but not be limited to the following: a. Environmental, safety and health activities b. Sample shipping and receipt c. Laboratory sample chain of custody and material control d. Notebooks /logbooks e. Sample storage f. Sample preparation g. Sample analysis h. Standard preparation and handling i. Post - analysis sample handling j. Control of standards, reagents and water quality k. Cleaning of glassware i. Waste minimization and disposition 3 STANDARD OPERATING PROCEDURES Document Y N N/A Comments Reference 13. The following information is required for procedures as appropriate to the scope and complexity of the procedures or work requested: a. Scope (e.g. parameters measured, range, matrix, expected precision, and accuracy) b. Unique terminology used c. Summary of method d. Interferences /limitations e. Approaches to address background corrections f. Apparatus and instrumentation g. Reagents and materials h. Hazards and precautions i. Sample preparation j. Apparatus and instrumentation set -up k. Data acquisition system operation I. Calibration and standardization m. Procedural steps n. QC parameters and criteria o. Statistical methods used p. Calculations q. Assignment of uncertainty r. Forms used in the context of the procedure FACILITIES AND EQUIPMENT Document Y N N/A Comments Reference 14. Allocation of Space: adequate for number of personnel and appropriate separation of work areas 15. Arrangement of Space a. Allows for appropriate work flow, sampling, lab space separate from office and break areas; b. Employee bathroom is separate from any laboratory area 16. Adequate eyewash /safety showers /sink 17. Procurement Controls a. The laboratory shall have procedure(s) for the selection and purchasing of services and supplies it uses that affect the quality of the tests and /or calibrations. Procedures shall exist for the purchase, receipt and storage of reagents and laboratory consumable materials relevant for the tests and calibrations. b. The laboratory shall ensure that purchased supplies and reagents and consumable materials that affect the quality of tests and /or calibrations are inspected or otherwise verified as complying with standard specifications or requirements defined in the methods for the tests and /or calibrations concerned. a. Prospective suppliers shall be evaluated and selected on the basis of specified criteria. 4 FACILITIES AND EQUIPMENT Document Y N N/A Comments Reference b. Processes to ensure that approved suppliers continue to provide acceptable items and services shall be established and implemented. c. When there are indications that subcontractors knowingly supplied items or services of substandard quality, this information shall be forwarded to appropriate management for action. 18. Utilities a. Electrical i. outlets: adequate, unobstructed, single use, no multi -plug adaptors ii. no extension cords iii. Ground fault circuit interrupters near wet areas b. Plumbing i. Appropriateness of sink usage: separate for work/personal use; ii. Adequate drainage from sinks, or floor drains iii. Hot and cold running water c. Ventilation i. Areas around solvent use or storage of waste solvent ii. Vented hood for any microbiological analysis – Class II Type A biosafety cabinet d. Vacuum i. appropriate utilities/ traps for prevention of contamination e. Shut -off controls: located outside of the laboratory 19. Waste Disposal: appropriate for the type of waste and compliant with WAC 314 -55 -097 Marijuana waste disposal— Liquids and solids 20. Equipment List a. Equipment and /or systems requiring periodic maintenance shall be identified and records of major equipment shall include: i. Name ii. Serial number or unique identification , iii. Date received and placed in service, iv. Current location, v. Condition at receipt, vi. Manufacturer's instructions, vii. Date of calibration or date of next calibration, viii. Maintenance ix. History of malfunction. 21. Maintenance 5 FACILITIES AND EQUIPMENT Document Y N N/A Comments Reference a. Regular preventive maintenance of equipment demonstration in log book including but not limited to: thermometer calibration, pipette calibrations, analytical balances, and analytical equipment. Documentation of a schedule and reviewed by the laboratory director. b. Documentation of curative maintenance in log book, signed and dated by laboratory director c. Temperature maintenance log book for refrigerators d. Decontamination and cleaning procedures for: i. instruments ii. bench space iii. ventilation hood e. Documentation of adequacy of training of personnel and responsibility for each maintenance task f. The organization shall describe or reference how periodic preventive and corrective maintenance of measurement or test equipment shall be performed to ensure availability and satisfactory performance of the systems. 22. Computer Systems a. Adequate for sample tracking b. Adequate for analytical equipment software c. Software control requirements applicable to both commercial and laboratory developed software shall be developed, documented, and implemented. d. In addition, procedures for software control shall address the security systems for the protection of applicable software. e. For laboratory- developed software, a copy of the original program code shall be: i. Maintained, ii. All changes shall include a description of the change, authorization for the change, iii. Test data that validates the change f. Software shall be acceptance tested when installed, after changes, and periodically during use, as appropriate. g. Testing may consist of performing manual calculations or checking against another software product that has been previously tested, or by analysis of standards. h. The version and manufacturer of the software shall be documented. i. Commercially - available software may be accepted as supplied by the vendor. For vendor supplied instrument control /data analysis software, acceptance testing may be performed by the laboratory. 6 FACILITIES AND EQUIPMENT Document Y N N/A Comments Reference 23. Security a. Written facility security procedures during operating and non - working hours. b. Roles of personnel in security c. SOP for controlled access areas and personnel who can access d. Secured areas for log -in of sample, and for short and Tong -term storage of samples 24. Storage a. Appropriate and adequate for sample storage over time. The laboratory shall monitor, control and record environmental conditions as required by the relevant specifications, methods and procedures or where they influence the quality of the results. Due attention shall be paid, for example, to biological sterility, dust, electromagnetic disturbances, humidity, electrical supply, temperature, and sound and vibration levels, as appropriate to the technical activities concerned. b. Adequate storage of chemical reference standards c. Appropriate Storage of any reagents: fire -proof cabinet, separate cabinet for storage of any acids. d. Appropriate safe and secure storage of documents etc., archiving, retrieval of, maintenance of and security of data for a period of three years. QA PROGRAM and TESTING Document Y N N/A Comments Reference 25. Sampling /Sample Protocols: Written and approved by the laboratory director a. Demonstrate adequacy of the Chain -of- Custody tracking upon receipt of sample including all personnel handling the sample. b. Sampling method (representative of an entire batch), including but not limited to homogenization, weighing, labeling, sample identifier (source, lot), date and tracking. c. Condition of the Sample: Macroscopic and foreign matter inspection — fit for purpose test. Scientifically valid testing methodology: either AHP monograph compliant, other third party validation. d. Failed inspection of product: tracking and reporting e. Return of failed product documentation and tracking f. Disposal of used /unused samples documentation 7 QA PROGRAM and TESTING Document Y N N/A Comments Reference g. Sample preparation, extraction and dilution SOP h. Demonstration of recovery for samples in various matrices (SOPs): i. plant material - flower, ii. edibles (solid and liquid meant to be consumed orally), iii. topical, iv. concentrates 26. Data Protocols a. Calculations for quantification of cannabinoid content in various matrices - SOPs b. Determination of the range for reporting the quantity (LOD /LOQ) data review or generation c. Reporting of Data: Certificates of Analysis (CA)- Clear and Standardized format for consumer reporting d. Documentation that the value reported in the CA is within the range and limitations of the analytical method e. Documentation that qualitative results (those below the LOQ but above the LOD) are reported as "trace ", or with a non - specific (numerical) designation. f. Documentation that the methodology has the specificity for the degree of quantitation reported. Final reports are not quantitative to any tenths or hundredths of a percent. g. Use of appropriate "controls ": documentation of daily use of positive and negative controls that challenge the linearity of the curve; and /or an appropriate "matrix blank" and control with documentation of the performance for each calibration run. 27. Chemical Assay Procedure / Methodology 28. Proficiency: a. Documentation of use of an appropriate internal standard for any quantitative measurements as applicable to the method b. Appropriate reference standards for quantification of analytes, performing and documenting a calibration curve with each analysis c. Demonstration of calibration curve r2 value of no Tess than 0.995 with a minimum of four points within the range. d. Documentation of any proficiency testing as it becomes available. Laboratory director must review, evaluate and report to the WSLCB any result that is outside the stated acceptable margin of error. 29. Method Validation: Scientifically valid testing methodology: either AHP monograph compliant, other third party validation or: 8 QA PROGRAM and TESTING Document Y N N/A Comments Reference 30. Level 11 Validation of Methodology used for quantification of THC, THCA and CBD for total cannabinoid content (if reporting other cannabinoids, the method must also be validated for those compounds): a. Single Lab Validation parameters are demonstrated for GC, HPLC data review i. linearity of reference standards ii. use of daily standard curve; iii. accuracy, iv. precision, v. Recovery (5 determinations not less than 90 %), vi. reproducibility over time within a relative standard deviation of 5 %; b. Dynamic range of the instrumentation: Limits of Quantification (LOQ) and Limits of Detection (LOD) c. Matrix extensions for each type of product tested, data review of recovery for i. solvent -based extract; ii. CO2 extraction or other "hash oil "; iii. extract made with food grade ethanol; iv. extract made with food grade glycerin or propylene glycol; v. infused liquids; vi. infused solids; vii. infused topical preparations; viii. other oils, butter or fats d. Presence of QC samples and recording of daily testing e. Appropriate use of an internal reference standard f. Daily monitoring of the response of the instrument detection system 31. Other Methods a. Microbiological methods fit for purpose: b. Microbial Contaminants within limits of those listed in the most recent AHP monograph and otherwise directed by WSLCB c. Moisture Content Testing fit for purpose. Scientifically valid testing methodology: either AHP monograph compliant, other third party validation. d. Solvent Residuals Testing fit for purpose; Solvent extracted products made with class 3 or other solvents used are not to exceed 0.5% residual solvent by weight or 500 parts per million (PPM) per one gram of solvent based product and are to be tested. e. Any other QA/QC methods is proven to be fit for purpose 32. Laboratory Notebooks a. Legible and in ink (or computerized system) 9 QA PROGRAM and TESTING Document Y N N/A Comments Reference b. Signed and dated c. Changes initialed and dated d. Periodically reviewed and signed by a management representative 33. Preventive /Corrective Action a. The laboratory shall have a process in place to document quality- affecting preventive /corrective actions through resolution. 34. Periodic Management Review a. Laboratory management shall periodically review its quality system and associated procedures to evaluate continued adequacy. This review shall be documented. 10 Center for Laboratory Sciences 2710 North 20th Avenue, Pasco, WA 99301 ' A PARTNERSHIP WITH CBC Tel: (509) 545 -4989 I Fax: (509) 544 -6010 t L aboratory To Support WSLCB in Implementing Initiative 502 and WAC 314 ®55 -102 Jim Conca Kris Kuhl - Klinger Joe Sears The Center for Laboratory Sciences on the campus of Columbia Basin College 509 ®545 ®4989 Iabcertification@columbiabasin.edu 1 Center for Laboratory Sciences 2710 North 20th Avenue, Pasco, WA 99301 A PARTNERSHIP WITH CBC Tel: (509) 545 -4989 I Fax: (509) 544 -6010 �-r P ro p osed Process An r i p; Center for Laboratory Sciences 2710 North 20th Avenue, Pasco, WA 99301 A PARTNERSHIP WITH CBC Tel: (509) 545 -4989 I Fax: (509) 544 -6010 • Laboratory Certification in support of 1 -502 (WAC- 314 -55 -102) Lab begins operations and prepares for On- Site Assessment Yes ° Receive Lab ID ` Complete Provisional Apply and Complete st On -Site Operate Granted? Deliverables Asse No Lab prepares for Ol Site A A Basic Overview of the Initial Certification Process 8 . , - -rte- f Center for Laboratory Sciences 41 • 2710 North 20th Avenue, Pasco, WA 99301 4 --! A PARTNERSHIP WITH CBC Tel (509) 545-4989 I Fax (509) 544-6010 ,Att Laboratory Lab Completes 1-4 Notified of Status, • Lal? N. gtifips ' • Documentation As with and 'w Sti-c of and Returns to ': Prepares for On-Site., Intent to Apply . •CPC-4.5 As5P,-rii.ent , WSLCB : --- ------ ---- ----- , E - Review With WSLCB WSLCB Sends , , .4p.,. Notice to i RrOviSiPri4VNgn 7 . CBC-C15 I , Provisional Recommendation 1 , n i ,, , CBC-CLS . CB-C1S Sgficls • acknowledgement, •i C.,I3g reviews . -,, . A0g9n,S I-Pb JP. PO documentation and issues tiPeciPd. For . schedules -Qn-51,t.q. Assessment Guidance to L.01? • . Initial certification in a bit more detail 9 Center for Laboratory Sciences 2710 North 20th Avenue, Pasco, WA 99301 A PARTNERSHIP WITH CBC Tel: (509) 545 -4989 I Fax: (509) 544 -6010 C onsiderations Imp Provisional vs. Non - Provisional Laboratories • Provisional Laboratory — Operating as a business in Washington State; — Has a QA program in place; — Has the right people and credentials in place; — Has the necessary instrumentation /equipment in place, and — Can demonstrate acceptable performance through a combination of: • Existing accreditations /certifications in 1 -502 specific areas • Documented Demonstration of Capabilities • Documented performance through other accreditations /certifications in relevant technical areas • Demonstration of capabilities through other means A Laboratory designated and accepted as meeting Provisional status can be allowed to proceed with testing provided an initial assessment is scheduled within three months of application. 10 Center for Laboratory Sciences ` . 2710 North 20th Avenue, Pasco, WA 99301 A PARTNERSHIP WITH CBC Tel: (509) 545 -4989 I Fax (509) 544 -6010 Important Considerations - Continued Provisional vs. Non- Provisional Laboratories • Non - Provisional Laboratory — Operating as a business in Washington State; — Has a documented QA program in place; — Has the right people and credentials in place; — Has the necessary instrumentation /equipment in place, but — Cannot demonstrate acceptable performance through a combination of: • Existing accreditations /certifications in 1 -502 specific areas • Documented Demonstration of Capabilities • Documented performance through other accreditations /certifications in relevant technical areas • Demonstration of capabilities through other means A Laboratory designated and accepted as meeting Non - Provisional status will not be allowed to proceed with testing until an On -Site assessment is completed and the Laboratory is determined to be competent to execute the work scope. 11 Center for Laboratory Sciences 2710 North 20th Avenue, Pasco, WA 99301 I A PARTNERSHIP 1 CBC Tel: (509) 545 -4989 I Fax: (509) 544 -6010 oar Important Considerations - Continued Regardless of Provisional /Non - Provisional Status • All Labs must first be considered competent by the WSLCB — Subcontractor provides recommendation regarding overall competency. — The WSLCB determination can include other relevant representatives or agencies in final determination. 12 Center for Laboratory Sciences 2710 North 20th Avenue, Pasco, WA 99301 A PARTNERSHIP WITH CBC Tel: (509) 545 -4989 I Fax: (509) 544 -6010 What a Lab Will Receive? Acceptable Labs will Receive: • An Initial On -Site Assessment Report (completed checklist) and follow -on acceptance of closure on any Findings initiated /completed • A letter signifying certification — and a Field of Testing Summary that supports the certificate. 13 Center for Laboratory Sciences 2710 North 20th Avenue, Pasco, WA 99301 A PARTNERSHIP WITH CBC Tel: (509) 545-4989 I Fax: (509) 544 -6010 Next Steps (Over Time) Following Initial certification Labs will: • Be- required to renew their status annually. — Will use a modification to the Initial Application format. • Be reassessed (On -Site Assessment) every two years. • Be required to demonstrate acceptable, continued performance in order to maintain certification 14status. Note: Continuing Certification is not expected to entail as much time as Initial Certification. Changes will be made as the program continues to mature and more lessons learned are gained. 14 . Center for Laboratory Sciences 2710 North 20th Avenue, Pasco, WA 99301 A PARTNERSHIP WITH CBC Tel: (509) 545 -4989 I Fax: (509) 544 -6010 Anticipated Costs for Certification Washington State will invoice the applying Laboratory • Initial Application: $2,667 (could lead to Provisional Status) • Initial Site Assessment: two people for one day of on -site auditing plus travel and per diem: $3,875 Total initial licensing effort is $2,667 + $3,875 = $6,542 • Annual Renewal Application: $1,667 • Subsequent bi- annual Site Assessments: One person for one day of on -site auditing plus travel and per diem: $2,270 Total subsequent licensing effort is $1,667 and $3,937 alternating every other year 15 Center for Laboratory Sciences 2710 North 20th Avenue, Pasco, WA 99301 R A PARTNERSHIP WITH CBC Tel (509) 545 -4989 I Fax (509) 544 -6010 A Anticipated Costs for Certification 1St Year 2 Year 3rd Year 4th Year $6,542 $1,667 $3,937 $1,667 • If follow up to corrective action response is needed then additional effort will be applied. This is typically 5 hours or less. • If very significant changes occur to the laboratory, personnel or business, an additional site assessment may be required. 16