Pesticide residue requirements for cannabis and hemp products vary widely across jurisdictions. For cannabinoid-containing extracts intended for inhalation, many existing limits are based on laboratory reporting capabilities or policy decisions rather than human health–based toxicological risk assessments.
While state-required testing provides a critical baseline to detect hidden contaminants, “detected” does not automatically mean “dangerous.” Further, a pesticide being absent from a state panel does not mean it is irrelevant to consumer safety. In general, inhalation exposure is considered a higher hazard due to differences in absorption, first-pass metabolism, and sensitive respiratory tissue.
A Task Group within Committee D37 on Cannabis and Hemp at ASTM International is working to address these critical gaps. ASTM International is a standards development organization bringing experts together across sectors to develop consensus standards for product safety and quality. For example, you may recognize ASTM’s name from conformance statements on everyday products such as the “Conforms to ASTM D-4236” statement on crayon boxes, which certifies the evaluation of potential chronic health hazards in art materials.
ASTM Work Item WK96795, New Specification for Risk Levels of Pesticides in Cannabinoid-Containing Extracts Intended for Inhalation, is a standard being developed by this D37 Task Group to establish scientifically defensible, risk-based levels for pesticide residues in inhaled cannabinoid extracts, including extracts derived from both cannabis and hemp.
The proposed specification will provide:
- Numerical risk levels for an initial group of prioritized pesticides;
- A framework for adding pesticides as new compounds are detected or identified as priorities;
- A transparent scientific methodology for deriving and updating the risk levels as toxicological evidence evolves; and
- A resource for regulators, testing laboratories, manufacturers, and other stakeholders seeking inhalation-specific guidance.
Why This Work Matters
Inhalation is a distinct exposure pathway. Setting limits primarily according to what laboratories can detect does not necessarily provide an accurate measure of risk to consumers who inhale cannabinoid products.
The core question is not simply “did we find a pesticide?” Rather, it is “are we looking for the right compounds and interpreting findings based on actual exposure and toxicological risk?”
WK96795 is intended to adapt established risk-assessment principles to the specific circumstances of inhaled cannabinoid-containing extracts. The methodology considers:
- Hazard identification;
- Relevant toxicological endpoints;
- Dose-response assessment;
- Human reference concentrations;
- Inhalation exposure estimates; and
- Uncertainty analysis.
The work builds upon scientific approaches used by international health agencies, existing cannabis regulatory programs, and the tobacco sector while accounting for the characteristics and use patterns of cannabinoid-containing extracts.
Supporting Public Health and Regulatory Consistency
The lack of a harmonized, inhalation-specific approach has contributed to substantially different pesticide requirements across jurisdictions. A pesticide may be prohibited in one market, subject to a numerical limit in another, and not addressed at all in a neighboring jurisdiction. For example, California sets the action level for the pesticide bifenthrin in inhalable cannabis products at 3.0 parts per million, while Oregon’s action level is 0.2 parts per million—a fifteen-fold difference for the exact same chemical and exposure route.
These inconsistencies create challenges for regulators, laboratories, and businesses, and make it difficult to determine whether current requirements consistently protect public health.
A consensus-based ASTM specification can help establish a common scientific foundation for evaluating pesticide residues in inhaled cannabinoid extracts. The goal is not simply to make requirements more uniform. It is to support requirements that are transparent, scientifically justified, protective of consumers, and practically implementable.
Broad Participation Is Essential
Input from toxicologists, regulators, laboratories, industry, public-health professionals, and other stakeholders is essential to developing a scientifically sound standard.
WK96795 is expected to be balloted by the ASTM D37.03 Laboratory Subcommittee this year, and feedback is welcome. Broad participation will help support a practical, evidence-based approach that strengthens consumer protection and regulatory consistency.
To learn more, visit the ASTM WK96795 Work Item page or the ASTM Membership page.
About S3 Collective
The S3 Collective is a 501(c)(3) nonprofit organization committed to advancing the cannabis, hemp, and botanical industries through collaboration, education, and standardization. By assisting in the development of robust standards, fostering open communication channels, and providing scientifically validated resources, S3 Collective empowers stakeholders to make informed decisions that promote public health and safety. S3 Collective is currently the only cannabis-related nonprofit to be a part of the FDA’s Network of Experts.