The Blacklist

Lab Mismanagement

Green Leaf (Oregon – March 2018 to April 2022): A series of inspections occurred from March 2018 through April 2022 regarding Green Leaf, based in Oregon, by the OLCC and OHA.

• The OLCC received complaints regarding Green Leaf knowingly not performing appropriate number of tests for potency (inconclusive), skipping potency tests (inconclusive), testing product that the owner has an ownership stake in (inconclusive), lack of detail for overnight transfer stays of product (warning), and numerous camera failure notifications (warnings). Here are the OLCC reports.

• The OHA launched investigations regarding Green Leaf’s low recovery of pesticides, not reporting un-accredited tests, not performing assessment in quality system matrices and not including the evaluation of blanks, not following homogenization processes (pulling apart the flower buds and removing stems / infused pre-rolls tested using one whole pre-roll for each test instead of from
  the entire sample), using unverified equipment, and using practice PTs. All of the OHA cases were resolved with a Corrective Action Plan (CAP). Here are the OHA reports.

Reference Labs (Oregon – February 2020 to September 2022): The OHA launched investigations regarding Reference Labs’ failure to perform sample duplicates for either the Moisture Analysis or Water Activity method, failure to record the calibration weight set ID on the “Moisture Balance Verification” form (without this information the assessor was unable to determine which weights were used to perform required daily balance checks), improper sealing techniques, lack of procedure for documenting ongoing Demonstration of Capability (DOC)/potency initial calibrations/Laboratory Control Sample (LCS), incompletion of an initial Detection Limit (DL) study for potency, improper spreadsheet formulas that were not locked, and inconsistent use of one method blank for every preparation batch of up to 20 samples. All of the OHA cases were resolved with a Corrective Action Plan (CAP). Here are the reports.

PREE Laboratories (Oregon – July 2020 to May 2022): A series of investigations occurred from July 2020 through May 2022 regarding PREE Laboratories, based in Oregon, by the OLCC and OHA.

• The OLCC received a complaint over an un-manifested transfer of marijuana from PREE Laboratories, based in Oregon. After investigation the error was made by the transportation workers and resolved through a change in PREE’s SOP. Here’s the OLCC report.

• The OHA launched investigations regarding PREE Labs referencing an outdated sampling SOP, not calibrating for and quantitating both the cis- and trans-isomers of Permethrin (a requirement in regulation), spiking Laboratory Control Samples (LCS) after the addition of extraction solvent in batches for pesticide analysis, and freezer temperatures that dropped below acceptable levels.
  All of the OHA cases were resolved with a Corrective Action Plan (CAP). Here are the OHA reports.

Harrens Lab (California – March 2021): California marijuana testing lab regains revoked license via court settlement. (MJ Biz Daily)

ACS Laboratory (Florida – May 2021 to August 2022): 6 inspections occurred from May 2021 through August 2022, the Florida Department of Health found violations and deficiencies for inflation and misreporting, unapproved testing methods, failed proficiency tests, and inspection failures. These cases have amounted to a total of $30,000+ in fines. Here are the reports.

MW Labs (Oregon – August 2021): The OHA launched investigations regarding MW Labs manipulated data in a laboratory control sample during pesticides analysis by manually changing the peak integration parameters when the instrument is stabilizing at the beginning of a run. The OHA also found that MW Labs was not sampling the bottom third of a sample batch to avoid damaging the flower, thereby not randomly sampling the flower. All of the OHA cases were resolved with a Corrective Action Plan (CAP). Here are the reports.

Pure Labs (Arizona – January 2022): Over 7 inspections occurred from October 2020 through January 2022, by the AZDHS of Pure Labs, which all included repeat violations for inventory control and improper testing procedures. Here’s the report.

• Lack of true inventory control procedure with over 5 grams of unaccounted product in one instance (p. 12)

• Inconsistent homogenization process by randomly picking parts of the bud for weighing and illegally trimming all leaves and stems prior to homogenization (p. 14)

• Inappropriate manual data integrations to change percent recovery, change the baseline, and input background noise to produce a response on a signal-to-noise ratio (p. 22-23)

• Repeat failures to have an acceptable proficiency test of each parameter and analyte and to properly calibrate or maintain calibration records for key equipments (p. 15-22)

• Unapproved methods for E.Coli, Salmonella, Aspergillus, and Heavy Metals Testing (p. 21-28)

OnPoint Laboratories (Arizona – February 2022): Arizona regulators fined the OnPoint Laboratories after repeated and intentional violations including, “incomplete records and documentation for inventory, marijuana disposal, maintenance records for equipment, chemical storage, and employee training.” Here’s the report. (MJBizDaily / Cannabis Business Times / PHOENIX 3TV/CBS 5 / Ganjapreneur)

• Every assay does not have work and is noncompliant (p. 13)

• Repeated inconsistent capture of Potency instrument data (p. 15)

• No audit trails of testing instruments and equipment (p. 15)

• Repeat failures to have an acceptable proficiency test of each parameter and analyte (p. 19)

• Repeat failures to use approved and appropriate screening methods for heavy metals, arsenic, pesticides, fungicides, herbicides, mycotoxins, E. coli and salmonella (p. 30-52)

3B Analytical (Oregon – September 2022): The OHA launched investigations regarding 3B Analytical’s inconsistent percent moisture data sheet collection and signature routine, not labeling expiration dates on potency analyses, lack of preparation record for Laboratory Control Sample (LCS), lack of analyzing performance verification standards for water activity analysis batches, and Proficiency Test (PT) sample for moisture analysis analyzed in duplicates. All of the OHA cases were resolved with a Corrective Action Plan (CAP). Here are the reports.

Cannex Nevada LLC (DBA LettuceTest LCC) (Nevada – September 2022): Nevada Cannabis Lab Faces 10-Year Ban for Manipulating Test Results. (Cannabis Business Times)

605 Cannabis (DBA Badlands) (South Dakota – February 2023): South Dakota Medical Cannabis Program (SDMCP) requested a voluntary product recall due to the Badland’s failure to test product and have licenses for edible products, mislabeling, contamination, and lack of inventory tracking. (SDMCP Advisory)

Candid Labs, LLC (DBA Layercake Farms 2, LLC) (Michigan – February 2023): Cannabis Regulatory Agency (CRA) issued formal complaints and announced summary suspensions of the medical and adult-use processor licenses held by Candid Labs due to investigations and formal complaints that demonstrate the safety and health risk of their patrons and employees. (CRA Advisory)

Steep Hill (Massachusetts, New Jersey, Pennsylvania – March 2023): Steep Hill Enters Settlement and Release Agreement Terminating Key Licenses. (Investors Observer / ICYMI Deep Dive of the Week)