The DHSS Placed Cannabis Products on Administrative Hold
In July 2024, the Department of Health and Senior Services (DHSS) placed marijuana products that present a potential threat to health and safety on administrative hold under 19 CSR 100-1.100(4)(P). While products are on administrative hold, the Missouri Division of Cannabis Regulation (DCR) requires dispensary licensees to take action.
Licensees must separate all affected packages to prevent cross-contamination and cannot move or alter products until further guidance is provided. Affected products include vape cartridges, edibles, infused pre-rolls, and numerous other categories. Products remain on hold until the DHSS determines they are safe, may be remediated, or must be destroyed.
Recently, the DHSS provided clarity on the reasons behind these holds and outlined next steps for handling affected products.
NGWMO, LLC Recall
On August 6, 2024, the DCR issued a product recall for marijuana products sold to dispensary facilities by NGWMO, LLC (License Number: CUL000069). The recalled products were not properly tested before being sold to patients and consumers. Specifically, the marijuana was tested at the unprocessed bud/flower stage instead of the final marijuana product stage required by 19 CSR 100-1.
C&C Manufacturing, LLC Recall
Then, on August 8, 2024, the DCR issued a product recall for marijuana products sold to dispensaries and manufacturing facilities by C&C Manufacturing, LLC (License Number: MAN000105). The recall was prompted by the discovery that these products were not compliantly tracked in the statewide track and trace system (Metrc) as required by 19 CSR 100-1. Consequently, the DCR cannot verify health and safety requirements were met.
Blue Sky Health & Wellness, LLC Recall
Next, on August 30, 2024, the DCR issued a product recall on marijuana products sold to dispensaries and manufacturing facilities by comprehensive manufacturing licensee Blue Sky Health & Wellness, LLC (License Number: MAN000088). Since the recalled products were not compliantly tracked in Metrc as mandated by 19 CSR 100-1, the DCR cannot verify compliance with health and safety requirements.
ClearWater Science, LLC Recall
On September 17, 2024, the DCR issued a product recall on marijuana products mandatory tested by licensed testing facility ClearWater Science (License Number: TES000007). The recalled products were not compliantly mandatory tested as required by 19 CSR 100-1. Therefore, the DCR cannot verify health and safety requirements were met.
Noah’s Arc Foundation MAN97, LLC Recall
Lastly, on November 15, 2024, the DCR issued a product recall on marijuana products sold to dispensary facilities by manufacturing licensee Noah’s Arc Foundation MAN97, LLC (License Number: MAN000097). The recalled marijuana products were not compliantly labeled prior to being sold to patients and consumers. They may contain food coloring ingredients not listed on the compliance label as required by 19 CSR 100-1.120(1)(C)2.A.
What This Means for Patients and Consumers
Patients and consumers who purchased a recalled product are directed to not use it. Any unused products should be discarded or returned to the dispensary where they were purchased. Returned products will not count toward the patient’s purchase limit, and for more information on returns, they should contact the dispensary directly.
If patients and consumers are experiencing life-threatening reactions to marijuana, they should seek medical attention immediately. To report any adverse reactions, they can email CannabisComplaints@health.mo.gov or complete a complaint form.
What This Means for Dispensaries
At this time, facilities cannot move or alter products until further guidance is provided by the DCR. When the DCR gives the green light to begin the destruction process for recalled items, Monarch Waste Co. will be there to help.
We provide licensed cannabis facilities with tailored waste management solutions, ensuring waste is properly managed. Our experts compliantly and conveniently render mixed waste and harder-to-remediate cannabis products, including vape carts, disposable vapes, and gummies, on-site prior to departure.
Dispensaries Practice Sustainable Cannabis Waste Solutions With Monarch
Dispensaries that partner with Monarch Waste Co. are guaranteed compliance with Missouri waste management regulations and ensured that waste is managed in an environmentally responsible manner. Learn more about Monarch’s Disposable Vape Recycling Program and other sustainable cannabis waste services here.
Let us handle the complexities of cannabis waste management so you can focus on running your business. Get in touch with a member of our team to schedule your one-off or recurring pick-up today!