Virginia: from processor to patient, what ends up on the label

Step by step: Virginia

1. Step 1: Processor grows the batch (Pharmaceutical processor) Virginia's medical program has five pharmaceutical processors, one per health service area, and each grows, makes and dispenses medical cannabis. Every plant gets a unique identifier at seed or cutting in an electronic seed-to-sale system the CCA prescribes. This is where the processor's name and address and the batch serial number come from.
2. Step 2: Sample made available, batch held (Pharmaceutical processor) The processor must make a sample from every batch available to the lab: for oils at least 0.5% of the units of a homogenized batch, for flower a representative draw from various points in the harvest. From sampling until results, the entire batch is segregated in a secure, cool, dry place, except the samples the lab has removed.
3. Step 3: Independent lab analysis (Independent lab) The lab must be independent: no owner may have a financial interest in a processor, dispensary, certifying practitioner or anyone else who profits from medical cannabis. It needs a Virginia controlled-substances registration and ISO/IEC 17025 accreditation within two years of applying. Flower is tested for microbes, mycotoxins, heavy metals, pesticides, water activity (0.65 at most) and moisture (15% at most), plus total THC, total CBD and a terpene profile; oils are tested for residual solvents instead of water activity and moisture, and report THC, THCA, CBD and CBDA.
4. Step 4: Certificate of analysis (Independent lab) No product may be sold until the lab has finished and handed the processor a certificate of analysis. Pesticides are judged against the strictest federal tolerance for any food. A lab must file any failing result with the CCA's board at the same moment it sends it to the processor.
5. Step 5: Fail: remediate, or turn flower into oil (CCA) A failed batch may be remediated and fully retested, except for pesticides, which can never be remediated. Flower that fails again may be processed into cannabis oil, which must then pass the oil tests. The Cannabis Control Authority registers every product name, and two products may share a name only if their active ingredients test within 15% of each other.
6. Step 6: Package + label (Processor packaging) Every container and layer of packaging shows the CCA's universal symbol, the yellow IICPS triangle (at least 1/4 inch on vape cartridges). The label adds the processor's name and address, registered product name, purpose and instructions, warnings, a serial number tied to the batch, the dates of testing and packaging, expiration, a terpene profile, THC, THCA, CBD and CBDA, and a pass or fail rating for each contaminant test.
7. Step 7: Pharmacist dispenses (Dispensing pharmacist) A pharmacist, or a technician under direct supervision, adds a dispensing label with the patient's name, the certifying practitioner, directions and a dispensing serial number, within a 90-day supply and at most 4 oz of flower per 30 days. Lab results must be available on request to patients, parents, guardians, registered agents and certifying practitioners.