Patients Want More Robust Lab Testing And Easier To Find COAs As GMCC Proposes Rule Changes

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There’s no way to sugar coat it. Many Georgia patients (including us) want better lab testing and more information about the products we’re buying.

The good news is that the Georgia Access to Medical Cannabis Commission (“GMCC”) is proposing several changes that we believe can genuinely improve safety, consistency, and transparency. The GMCC’s proposed updates to Rule Chapter 351‑7 show they’re working to tighten the standards around how our medicine is tested. For patients, this is the backbone of the entire system. If the testing isn’t robust, clear, and easily accessible, nothing else matters.

The proposed changes include several improvements that directly benefit patients. They also leave out a few critical pieces that Georgia needs if it wants a testing program that matches the science and protects people who rely on this medicine every day.

What the GMCC is getting right

One of the most important changes is the push for clearer, more controlled sample collection. The new language spells out how samples must be portioned, homogenized, and stored before testing. That matters because a batch can look clean on paper while possibly hiding contamination or uneven potency in the parts that never get tested. When labs test a properly homogenized sample, patients get results that actually reflect what they are buying.

The GMCC is also adding water activity as a required analyte. Water activity is a simple measurement that predicts whether mold can grow. It is one of the most reliable early indicators of microbial risk in flower and certain edibles. States with mature testing programs treat water activity as a core safety test because it helps prevent contamination before it starts. For patients with respiratory conditions or compromised immune systems, this is not a minor detail. It is a meaningful layer of protection.

Another positive change is the requirement that labs only test controlled samples of the product in its final packaged form. This closes the door on cherry‑picked samples that do not represent the full batch. Patients deserve results that match the product they actually take home.

The proposed updates to the Certificate of Analysis (“COA”) rules are also a win. The GMCC wants contaminant standards to be product specific, which means inhalable products will have stricter limits than tinctures or topicals. Every COA will need a batch number, which is essential for recalls and patient complaints. And labs will no longer be able to quietly edit a COA after it has been issued. Any change will require Commission approval. That protects patients from retroactive potency changes or contamination results being “fixed” after the fact.

We’re hopeful as we think the GMCC’s proposed changes show they’re paying attention to how testing works in real life, not just on paper. That is a win for patients even if we think they need to go further.

Where the GMCC should go further

Even with the proposed improvements, Georgia’s testing rules would still lag behind best practices used in other regulated markets and scientific standards from organizations like AOAC and ASTM. The science is clear in our opinion about what needs to be added.

Terpene testing is absolutely necessary. Right now, terpene testing is optional. So we’re left with a mixed bag of info. Some products have terpene testing results. Others don’t. This simply isn’t fair for patients. Terpenes are not mere flavor notes. In our personal experience, they can meaningfully shape how cannabis can feel, how long it lasts, and how we respond to it. A patient trying to manage something specific such as nausea, sleep, appetite, or anxiety needs more information. Terpenes can also help clinicians and patients understand why one product works differently from another, even when the cannabinoid numbers look similar. Georgia should require terpene testing for all inhalable and oral products and report actual quantitative values, not vague descriptors.

The second missing piece is remediation disclosure. The proposed rules never mention remediation, even though it is common in regulated markets. Remediation happens when a batch fails testing and is treated to remove contaminants. It might be re‑extracted, distilled, or processed to reduce microbial load or residual solvents. Remediation is not inherently bad, but patients deserve to know when it happens. A COA should clearly state whether a batch failed its first test, what contaminant was out of spec, and what treatment was used before retesting. This is basic transparency from our perspective.

Georgia already requires testing for microbiological contaminants and mycotoxins, but the rules do not spell out a detailed, product‑specific panel the way some other states do. We believe the GMCC should strengthen and modernize these requirements.

The pesticide rules need the same updating in our opinion. Georgia requires pesticide testing with defined limits, but the state has room to publish and expand a modern, comprehensive pesticide panel that reflects real‑world cultivation. Publishing a named pesticide panel and clear action limits would bring Georgia in line with national best practices.

At the end of the day, Georgia’s medical cannabis patients deserve medicine that is safe, consistent, and transparently tested. The GMCC’s proposed changes move the state in the right direction, but the science is clear in our opinion about what still needs to be added. Mandatory terpene testing, remediation disclosure, stronger microbial and mycotoxin standards, a modern pesticide panel, and modern, product‑specific heavy metal and solvent limits (beyond the limits that already exist), clearly communicated on COAs, would bring Georgia closer to the testing standards used in mature medical markets and give patients confidence that their medicine is exactly what the label says it is.

We want to be clear here. We aren’t throwing shade at anyone here. Not the lab doing great work down in Macon or any of the companies working hard to get needed products to patients. We’re proud of what everyone has done already. What we are saying is that we want more required testing, more required disclosures, and we want that information to be super easy to find, access, and read. The patient experience for obtaining a COA should be the same no matter where the patient buys their medical product.