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Growers and labs press for testing reform and larger batch sizes; lab-shopping and microbial standards debated

2935426 · April 9, 2025
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Summary

Outdoor farmers and independent testing lab representatives urged changes to testing thresholds, batch sizes and sampling requirements, and warned that current microbial limits and sampling rules are ill-suited to outdoor production and may encourage lab-shopping.

Growers, independent testing laboratories and scientists told the Joint Committee on Cannabis Policy that current testing rules — especially low microbial thresholds and small sample‑batch sizes — are poorly fitted to outdoor cultivation in Massachusetts and are discouraging farming and creating quality control problems.

Outdoor growers argued the state’s total yeast and mold and total aerobic bacteria thresholds are too strict for outdoor-grown flower, that current batch‑testing rules (a representative sample from every 15‑pound batch) are costly and arbitrary, and that a larger representative batch (for example, 40 pounds) would better reflect production realities and reduce costs. "An outdoor road that's full size in Massachusetts ... is supposed to spend up to about $430,000 on soil and water testing every year," testified Kyle Page and other growers who highlighted disproportionate testing costs.

Independent lab testimony: Representatives from independent testing labs and the Institute of Cannabis Science said testing practices and standards need to be evidence‑based and warned about lab‑shopping — businesses seeking labs that will return favorable results. Dr. Dimitrios Pelakoutis of Assured Testing Laboratories and Mike Esposito, a cannabis microbiologist, urged the committee to preserve representative batch sampling and to maintain scientifically justified microbial thresholds to protect public health while adjusting sampling protocols to reflect outdoor production.

Policy trade-offs: Growers asked for batch-size increases, adjusted microbial limits for outdoor-grown flower, and larger representative samples to reduce per-pound testing costs and avoid false positives for naturally present environmental microbes. Lab representatives cautioned that increasing batch sizes or loosening thresholds without clear, science‑based standards could raise the risk of contaminated product reaching consumers and potentially miss localized contamination events.

Committee response: Members asked for empirical evidence and comparative policy examples; growers cited petitions and prior CCC listening sessions and asked the legislature to act where the CCC has not acted. Lab experts offered to provide technical assistance and empirical data for follow-up rulemaking.

Next steps: The committee received testimony and asked for additional technical input. Witnesses requested the legislature either direct the CCC to adopt revised testing standards or commission an independent scientific review.