Effective Date: November 15, 2019

MMCC Expands Compliance Testing and Bans Vitamin E Acetate in Medical
Cannabis Vape Products

Linthicum, MD (November 15, 2019) – The Maryland Medical Cannabis Commission (the
“Commission”) is issuing this bulletin to notify licensed medical cannabis processors and
independent testing laboratories of enhanced testing requirements for medical cannabis vape
cartridges. Effective immediately, medical cannabis vape cartridges, including disposable vape
pens, will require screening for vitamin E acetate as part of mandatory compliance testing prior to
release to a licensed dispensary for sale to patients. The bulletin only applies to medical cannabis
vape products regulated by the Commission.
If any vape product is found to contain vitamin E acetate, the vape product may not be released
for sale to patients. The expanded compliance testing for vitamin E acetate applies to vape products
that have passed previous compliance testing requirements. Vape products currently available for
sale to patients will be placed on administrative hold until expanded compliance testing has been
completed. The Commission is aware that this may result in vape products being temporarily
unavailable to patients. Any disruption to the availability of vape products will likely be limited to
a few days.
The U.S. Centers for Disease Control and Prevention (CDC) has identified vitamin E acetate as a
chemical of concern among individuals with e-cigarette, or vaping product, use associated with
lung injury (EVALI). On November 8, the CDC announced that “laboratory testing of
bronchoalveolar lavage (BAL) fluid samples (fluid samples collected from the lungs) from 29
patients with EVALI submitted to CDC from 10 states found vitamin E acetate in all of the
samples.” The CDC recommends that “until the relationship of vitamin E acetate and lung health
is better understood, vitamin E acetate should not be added to e-cigarette or vaping products.”
This is a preemptive safety measure for medical cannabis patients implemented as a result of the
CDC’s findings. Current licensees have reported to the Commission that they do not manufacture
any vape products using this ingredient.
The Natalie M. LaPrade Technical Authority for Medical Cannabis Testing has been revised to
reflect this change. Further amendments to the testing technical authority may be made, including
prohibiting additional ingredients that may be found to be toxic and not safe for human
consumption. Please direct any questions regarding this bulletin to Lori Dodson,