Remediating a Failed Cannabis Compliance Test – NY OCM Retesting Guide

I failed a compliance test. How do I remediate and resubmit for retesting under OCM rules?

Remediation & Retest Workflow

  1. Quarantine & notify the Office
    • Immediately place the entire lot on hold.
    • Email compliance@ocm.ny.gov with subject “Failed Lot Remediation – [License #]”.
    • Attach the failed Certificate of Analysis (COA) and outline the root-cause investigation you intend to run.
      • If you do not have this yet, we recommend sending the email without COAs initially to start the process and expedite the overall process. 
    • Provide details of the intended remediation process you will use and information about your vendor if not performing in-house remediation.
    • Wait for acknowledgement before touching the lot (plan on ~2–3 business days). 
  2. Receive OCM instructions
    • OCM will confirm whether remediation is allowed or if destruction is mandatory (e.g., any prohibited-pesticide failure must be destroyed—no remediation permitted). 
    • They may require a specific remediation approach (e.g., further extraction, dilution, or heat treatment).
  3. Execute remediation
    • Follow the approved method exactly.
    • Update your batch record to document:
      • Lot/batch ID, equipment, processing line, and all corrective actions taken. 
    • Keep the product in a clearly marked, locked area until retest results are received.
  4. Prepare the lot for retest
    • If the product is repurposed (new form or batch)
      → assign a new lot/batch number and submit a full compliance panel.
    • If remediation keeps it in the same form
      → submit samples only for the failed analyte group:
      • Microbiology failure
        (Total Yeast & Mold, Total Aerobic, Salmonella, E. coli, Aspergillus) → retest the entire microbiological package.
      • Other failures
        (e.g., Pesticides, Metals) → retest that specific panel.
    • All retesting must go back to the same laboratory that issued the original COA. 
  5. Outcome handling
    • Pass:
      Lab issues an amended COA incorporating all passing data with a note “Remediated Lot”, Updated QR code and provides the new COA to distributors/retailers before release. 
    • Fail again:
      The lot must be destroyed and logged in your inventory tracking system; no second remediation attempt is permitted. 
  6. Record-keeping & traceability
    • Retain all correspondence, revised COAs, destruction logs, and batch records for the life of the license.
    • Ensure your seed-to-sale system reflects every status change (quarantine, remediation, retest, release, or destruction).

 

Key points to remember

  • Only one remediation attempt per lot is allowed.
  • Never ship or transfer a lot while it is on administrative hold.
  • Treat remediation as a GMP activity—use validated equipment, calibrated instruments, and qualified personnel.