11/20/2025
I love to keep you updated with any cannabis-related legislation that could impact patient health. The current proposal to change guidelines for cannabis testing regarding terpene content: WSR 22-23-001 rulemaking, or 246-70 rulemaking depending on the entity of consideration. Producers and processors of medical cannabis are not required to test for terpene content, nor to include this information on the label, although they may choose to do so.
Please note that these opinions are my own and in no way reflect the opinion of my employer or any other person.
My experience working with patients is that terpenes are important. Before our current regulated system was in place, I used a system I called “follow your nose” in which I taught patients how to smell different cannabis flower cultivars and select medical flower based on smell. The smell is largely caused by the terpenes in flowers. Smell 10 different cultivars of cannabis and you’ll notice they are different. Although no significant research into medical effects of terpenes exists in a clinically useful way at this time, I suspect we will find that terpenes have useful medical effects and that cannabis is not simply medicinal because of the cannabinoids we are most familiar with (CBD, THC, etc). Having tracked patient cannabis medicine use for 17 years, I am confident that it is not simply the THC/CBD and other cannabinoids that provide the medical benefit. As patients are not simply seeking psychoactivity (THC), it is critical that we consider all other bioactive compounds in this complex plant and their medical effects.
As cannabis medicine has changed significantly in WA state since the time I used “follow your nose” I am personally interested in having the same information available for patients in a more scientific and useful way- testing for terpenes and providing this content on the label. Beyond flower sold in hermetically sealed smell-free packaging, many of my patients now use other products where smelling wouldn’t be particularly helpful for determining terpene content anyway! I currently have patients who are very sensitive to cannabis cultivars and need to carefully track what they use to maximize medical benefit. These patients often need to create their own spreadsheets, and research what terpenes may be present in their medicine to help guide them. It is of particular concern when a product or cultivar that works for the patient is no longer available and we need to find the closest match. A reminder that medical cannabis patients have serious health conditions- changing their medication is no small matter.
The industry in general feels this proposal to be unnecessary, to not be helpful for patients, and to add costs that could force smaller licensees out of the business. If you disagree with this, you have an opportunity to share your opinion please do so. Those of us who are for terpene information are currently outweighed by the industry comments. Each comment counts!
Comments to DOH should be sent to medicalcannabis@doh.wa.gov.
Be sure to place: WSR 22-23-001 rulemaking, or 246-70 rulemaking in the subject line.
If you have questions or want to become more involved with the patient terpene effort you can also contact homegrow2018@gmail.com.
Thank you for your interest in medical cannabis!