Pennsylvania Cannabis Testing Overview
COA Requirement:
Required.
All medical marijuana harvest batches, process lots, and infused productsmust be tested by a Department of Health (DOH)-approved laboratory. A Certificate of Analysis (COA) is issued for each lot and must include:
- Cannabinoid profile
- Contaminant results
- Appearance and odor observations
- Compliance status
A COA is required prior to product release or packaging.
Cannabinoid Testing:
Required.
Quantification of the following cannabinoids is mandatory:
- Δ⁹-THC
- THCA
- CBD
- CBDA
- CBC
- CBN
- THCV
- CBDV
- CBG
- Δ⁸-THC
Testing must be performed using validated chromatographic techniques (e.g., HPLC, UHPLC) and must report both neutral and acidic form of cannabinoids where applicable.
Terpene Testing:
Required.
All harvest and process lots must undergo terpene content analysis using GC or LC methods. While specific terpene action limits are not defined, quantitative terpene data must be included in the COA for all product types.
Contaminants Tested For:
Broad screening required.
a. Heavy Metals:
- Arsenic: ≤0.4 ppm
- Cadmium: ≤0.3 ppm
- Lead: ≤1.0 ppm
- Mercury: ≤0.2 ppm
- Chromium and Nickel are not mandated.
b. Pesticides:
- Only pesticides listed in 28 Pa. Code § 1151, Appendix A are permitted.
- Detection of banned compounds (e.g., myclobutanil, DDVP, paclobutrazol) results in automatic failure.
- Action limit: ≤0.1 µg/g
c. Mycotoxins:
- Aflatoxins (B1, B2, G1, G2): ≤20 ppb total; B1 alone must be ≤5 ppb
- Ochratoxin A: ≤20 ppb
d. Microbiological Contaminants:
- Salmonella spp. and E. coli: Must be absent in 1g
- Aspergillus spp., Pseudomonas aeruginosa, and Staphylococcus aureus must be screened in processed products
- Total Aerobic Count: ≤10,000 CFU/g
- Yeast and Mold:
- Flower: ≤10,000 CFU/g
- Bile-tolerant gram-negative bacteria:
- Flower: ≤1,000 CFU/g
- Note: PCR-based testing methods are prohibited; culture-based validation is required.
e. Foreign Material: Products must be visually inspected, and COAs must confirm absence of foreign matter such as:
- Hair
- Insects
- Dirt
- Debris
Visual contamination is considered a fail point.
Contaminants Not Required (But of Concern):
While Pennsylvania has strong testing protocols, the following are not explicitly required:
- Chromium, Nickel, Selenium (heavy metals)
- Explicit limits for total terpene concentrations
- Testing for Listeria monocytogenes, Shigella spp., or Clostridium botulinum
Risk Level:
Low Concern: Pennsylvania has adopted extensive contaminant testing requirements across product types.
House Bill 1024, passed in March 2025 and pending Senate review, would enhance enforcement through:
- Random batch audits
- Laboratory transparency protocols
- Mandatory lab independence from growers and processors
If enacted, these changes would elevate Pennsylvania’s testing integrity to match national best practices.
Moisture and Water Activity:
Water Activity (aw):
- Flower: ≤0.65
Moisture Content:
- Must be within 5–15%
State Cannabis Regulatory Agency:
Pennsylvania Department of Health: Office of Medical Marijuana
Website: https://www.health.pa.gov
Email: RA-DHMedMarijuana@pa.gov
Phone: 1-888-733-5595
Address: 625 Forster St, Harrisburg, PA 17120
References:
Pennsylvania Department of Health, Office of Medical Marijuana. (2018, August 10). Pennsylvania Guidance for Quality Testing and Sampling by Approved Laboratories.
Pennsylvania Department of Health. (March 4, 2023) Chapter 1171. Laboratories
Pennsylvania General Assembly. (2025). House Bill 1024: Cannabis lab reform.