DATE: July 24, 2019

SUBJECT: Hemp Variety THC Testing

TO: 2019 Hemp Permit Holders

FROM: PDA Hemp Program Team

Dear 2019 hemp permit holder:

As Pennsylvania’s hemp growing season is progressing and hemp crops are maturing, it is time for hemp permit holders to plan for the next phase of the season: harvest. Before harvest occurs, testing of hemp plant material for tetrahydrocannabinol (THC) must occur. The PA Department of Agriculture (the Department) will only be visiting a randomly selected percentage of permit holders (approximately 25% of permit holders) to collect hemp variety samples for regulatory testing.

In addition to the sampling that the Department will be conducting for regulatory purposes, all permit holders are responsible for locating a private laboratory for the purpose of testing the floral material of all hemp varieties grown on their farm for percentage THC. The laboratory must supply the Department with a Certificate of Analysis (COA) with the total delta-9 THC % for each hemp variety planted. The laboratory must send the COAs directly to the Department, where they will be reviewed and cleared by the Hemp Program Team. The following information must be included on the COA to identify the growing location:

o Permit Holder’s Name and Address

o Permit Number

o Growing location (Address and field name/location)

o Variety name of the hemp sampled

Certificates of Analysis referencing your permit number and the growing location must be sent by laboratories to:

Cathy Thomas

Bureau of Plant Industry

PA Department of Agriculture

2301 N. Cameron Street

Harrisburg, PA 17110

Since the Department does not have a registration for laboratories which conduct hemp testing, we do not have a directory or listing of approved hemp laboratories. The Department does not require that laboratories conducting THC testing hold a particular certification. (However, certain hemp processors or retailers may have more stringent requirements.) Locating a laboratory to test plant samples is the responsibility of the permit holder. Since permit holder contact information has been posted on the Department’s website, laboratories may already be in the process of reaching out to the permit holders.

The only mandatory testing required by the Department is total delta-9 THC % for each hemp variety planted. While hemp processors or retailers may require additional testing of hemp prior to purchase, such as levels of CBD, heavy metals or pesticides, these tests are not required by the Department.

The testing method used by Pennsylvania analyzes total delta-9 THC %, on a dry weight basis, using a post decarboxylation method. Samples are analyzed by Gas Chromatography-Flame Ionization Detection (GC-FID) which decarboxylates the THC-A, converting it through heating to THC, which goes on to be quantitated by the instrument system. The laboratory that the permit holder uses must test the samples for % total delta-9 THC.

The Department’s hemp sampling occurs 70-80 days after planting. Samples submitted for THC testing shall consist of only female flowers or buds clipped from the terminal points of the plant, with the top 2-3 inches per plant collected with minimal stem material. These must be collected from random sampling points throughout the growing site for the individual variety to obtain a sample representative of the variety to supply between 4-6 oz of plant material to the lab (an average of 50-80 flowers or buds sampled). Samples should be collected in paper bags and stored in a cooler with ice packs to deliver to the laboratory. The private laboratories you select may have further instructions for samples which should be followed.

For permit holders delivering or shipping samples to laboratories, it is recommended to include copies of the hemp permit and any seed/transplant varietal documentation to accompany the samples in case any entity, such as the shipping company or law enforcement, should stop or question the material being transported.

Certificates of Analysis are to be received by the Department prior to movement of harvested hemp from the permit holder’s property/storage location to a processor, handler or retailer. Results that are returned with a THC % of less than 0.3% will be cleared by the Department, and the permit holders may move forward with processing or sales. Results that have been returned with a value of over 0.3% will be subject to a re-sampling and testing at the permit holder’s expense. If the second testing would result in a THC value of over 0.3%, the program will issue control orders to the permit holders for destruction of that variety.

Ultimately, this analysis is a tool that will show that Pennsylvania’s hemp permit holders have produced hemp crops that are in compliance with both state and federal law and can therefore be sold throughout the United States. The Department thanks you for your cooperation.

Sincerely,

The PDA Hemp Program Team:

Cathy Thomas

Sarah Pickel

Dave Scott