The minimum capital investment in testing equipment needed to satisfy regulations is substantial

To complement licensed testing lab data, we also drew on personal interviews, phone calls, and email exchanges with sales representatives of three large equipment suppliers. Table 3 summarizes capital costs, other one-time expenses, and annual operational and maintenance costs used in our calculations. We report average cost and standard deviation for each estimate. We assume that medium-sized and large labs receive discounted prices on equipment, given the larger scale of their purchases. Based on information provided by equipment suppliers, we expect these discounts to be between 1.5% and 2.5%. Different-sized labs have different capacities based on their scale. We assume that larger labs have made larger capital investments and are better able to optimize processes when supplying a larger volume of testing . On the other hand, small testing labs require less equipment and less capital investment, and operate with low annual costs, but their testing capacities are also low. Table 4 summarizes our estimates of running time for tests, the main consumables used by testing machines, and the expected cost of running a specific test per sample. In addition, we include a range of $80 to $120 per sample to cover general material and labor apparel used while preparing and processing samples. We estimate that in small labs , capital investment in equipment is about $1.1 million; in the medium-sized labs , capital investment in equipment is about $1.8 million; and in large-scale labs , capital investment in equipment is about $2.8 million. These capital costs,grow rack system amortized over a 10-year time span with a 7.5% rate of depreciation and interest, represent less than 15% of total annual expenses.

Annual costs of operating range from $1.4 to $2.2 million for small labs, $2.7 to $3.7 million for medium-sized labs, and $6.2 to $8.1 million for large labs. Consumables are the largest share of total annual costs in large-scale labs, whereas labor is the largest share of costs in small-scale labs. In medium-scale labs, consumables and labor have about equal shares of annual costs. Different-sized labs differ in their capacity and efficiency. The highest possible sampling cost we assume for small labs is about $35 per sample if the distributor is located 156 miles away . On average, costs of collection, handling, and transportation represents a small share of total lab costs per sample. Fig 4 shows the distribution of full testing cost per sample from 1,000 Monte Carlo simulations assuming 49 labs. Variability of the cost per sample within small labs is high, with the highest and lowest cost within that group differing by $463. The difference between the highest and lowest costs in large labs is $88, with a lowest cost per sample of about $273. The average full cost per sample tested is about $313 for large labs, $537 for medium labs, and about $778 for small labs . Large cost differences per test and per batch document the large-scale economies and differences in operational efficiencies across labs of difference sizes. The aggregate amount of cannabis flowing through licensed labs in 2019 remains relatively small relative to the anticipated amounts expected in the future. That means labs that may anticipate growth, operate well below capacity. Substantial scale economies suggest that,grow rack system as the market settles, the smallest labs must either expand to use their capital investment more fully, leave the industry, or provide some specialized services to distributors that are not accounted for in the analysis presented here.

Simply put, the average cost differences shown in Table 6 or the simulated ranges displayed in Fig 4 should not be understood as a long run equilibrium in the cannabis testing laboratory industry.Based on the shares developed based on current information, a few large labs are likely to supply almost half the testing services for cannabis sold through licensed retailers in California, while medium labs will test about 24% of cannabis and small labs about 30% of cannabis. Using these shares and the cost information documented, the weighted average of testing cost from our simulations is about $504 per sample.In 2018, the first year of mandatory testing enforcement, according to official data published by the California Bureau of Cannabis Control and posted publicly on its website, failure rates in California averaged about 5.6% . Failure rates for the first seven months of 2019, the second year of the testing regime, have averaged 4.1%. We assume a 4% failure rate for the current market in California. By comparison, in Washington State, in 2017, the second year after the testing began, 8% of the total samples failed one or more tests. The Colorado Marijuana Enforcement Division reported that during the first six months of 2018, 8.9% of batches of adult-use cannabis failed testing, with infused edibles and microbial tests for flower accounting for the most failures. Batch size significantly affects the per-pound testing cost of cannabis marketed, especially when batch size is smaller than 10 pounds. Fig 5 shows the costs of one pound of cannabis marketed coming from different sizes of batch flowers using 0%, 4%, and 8% rejection rates. As rejection rates increase, the differences between the costs per pound of testing different batch sizes decreases. For example, given a 0% rejection rate, the cost of testing per pound of cannabis marketed from a one-pound batch is about 27 times higher than the cost of a 48-pound batch; on the other hand, given an 8% rejection rate, the cost of testing per pound of cannabis marketed from a one-pound batch size is only seven times higher than the cost from a 48-pound batch size.Table 7 shows costs per pound of cannabis testing itemized into laboratory cost, the value of lost inventory, and the cost of remediating failed batches, given different rejection rates and batch sizes. For small batch sizes, laboratory costs are a higher share of total testing costs than they are for large batch sizes. For a one-pound batch size, the total cost of testing of a pound of cannabis that reaches the market is about $641 when the expected rejection rate is equal to zero. The cost increases to $714 if the expected rejection rate is equivalent to 4%, and to $791 if the expected rejection rate is 8% . The share of laboratory cost from total cost decreases as the rejection rate increases and the value of lost inventory therefore increases.

Under an 8% expected rejection rate, the share of lost inventory is half of the total cost for eight-pound batches .In this paper, we use a simulation model to estimate the costs per pound of mandatory cannabis testing in California. To do this, we make assumptions about the cost structure and estimated the testing capabilities of labs in three different size categories, based on information collected from market participants across the supply chain. For each lab, we estimate testing cost per sample and its share, based on testing capacity, of California’s overall testing supply. We then estimate a weighted average of the cost per sample and translate that value into the cost per pound of cannabis that reaches the market.We use data-based assumptions about expected rejection rates in the first and second round of testing, pre-testing, and the remediation or processing of samples that fail testing. Our simulations rely on information collected from several sources, including direct information from testing labs in California, price quotes from companies that supply testing equipment,rolling flood tables interviews with cannabis testing experts, data on testing outcomes for cannabis and other agricultural products from California and other states, data on pesticide detection in California crops, and data on average wholesale cannabis batch sizes.As lab scale rises, testing capacity rises faster than do input costs, so average costs fall with scale. We find that a large lab has four times the total costs of a small lab but 10 times the testing capacity, in part because large labs are able to use their resources more efficiently. Testing cost per pound of cannabis marketed is particularly sensitive to batch size,rolling flood tables especially for batch sizes under 10 pounds. Testing labs report that batch size varies widely. The maximum batch size allowed in California is 50 pounds, but many batches are smaller than 15 pounds. We assume an eight-pound average batch size in the 2019 California market, but we expect that the average batch size will increase in the future as cultivators become larger and more efficient and take advantage of the opportunity to save on testing costs .Testing itself is costly, but losses inflicted by destroying cannabis that fails testing is a major component of overall costs. Low or zero tolerance levels for pesticide residues are the most demanding requirement, and result in the greatest share of safety compliance testing failures. Cannabis standards are very tight compared to those for food products in California. A significant share of tested samples from California crops have pesticide residues that would be over the tolerance levels established for California cannabis . Some foods that meet pesticide tolerance established by California EPA may be combined with dried cannabis flowers to generate processed cannabis products . Pesticide residues coming from the food inputs may generate detection levels of pesticide over the tolerance levels set by cannabis law and regulation, even if they are otherwise compliant as food products.

Cannabis testing regulation is strict compared to tobacco, another inhalable crop. Tobacco has no pesticide tolerance limits because it is considered to be an inedible crop used for recreational purposes.Cannabis has multiple pathways of intake, such as edibles, inhalable, patches, etc., and also may be prescribed for people with a health condition, searching for alternatives to traditional medicine. Some labs report that when samples barely fail one test, they have a policy of re-testing that sample to reduce the probability of false positives. Some labs have reported up to 10% in variation in test results from the same sample. Some labs indicate that about 25% of samples need to be re-tested to be sure that results are accurate. Such concerns have been widely reported. In July 2018, some producers voluntarily recalled cannabis products after receiving inconsistent results of contaminant residues from different laboratories; and some California labs have also been sanctioned by the Bureau of Cannabis Control for failing state audits on pesticide residue tests. A major issue for legal, taxed and licensed cannabis market is competition with cannabis marketed through untaxed and unlicensed segment. Higher testing costs translate into higher prices in the licensed segment. Safety regulations and testing may improve the perceived safety and quality of cannabis in the licensed segment, thus adding value for some consumers. However, price-sensitive consumers move to the unlicensed segment when licensed cannabis gets too expensive. A useful avenue for further research is to investigate cannabis testing regulations and standards across states to assess implications for consumer and community well being and competition with unlicensed cannabis. Compared with other agricultural and food industries, the licensed cannabis industry in California has relatively little data. Banking is still done in cash, and sources of government financial data are less available for cannabis than they are for other industries. As the licensed cannabis segment develops, we expect that increased access to data on the market for testing services, including on prices, quantities, and batch sizes. Data from tax authorities, the track and-trace system, and the licensing system will then help clarify the costs and implications of mandatory cannabis testing.Assessing the environmental impacts of the cannabis industry in Northern California has been notoriously difficult . The federally illegal status of cannabis has prevented researchers from obtaining funding and authorization to study cultivation practices . Fear of federal enforcement has also driven the industry into one of the most sparsely populated and rugged regions of the state , further limiting opportunities for research. The result has been a shortage of data on cultivation practices and their environmental risks . An improved understanding of cannabis cultivators’ water use practices is a particularly pressing need. Given the propensity of cannabis growers to establish farms in small, upper watersheds, where streams that support salmonids and other sensitive species are vulnerable to de watering , significant concerns have been raised over the potential impacts of diverting surface water for cannabis cultivation.