DocuSign Envelope ID: 1B28B555-A60A-4327-9A2F-786D02353695

February 21, 2024

Harriet Henry
Manager, Rapid Analytics, LLC
131 Jeff Davis Blvd., Ste. C
Natchez, MS 39120

Via DocuSign: mamie_henry@yahoo.com

Re: Rapid Analytics, LLC

License No. TESL000301

NOTICE OF INTENT TO REVOKE LICENSE NO. TESL000301

Following the emergency suspension of Rapid Analytics, LLC’s license to operate as a medical
cannabis testing facility, License No. TESL000301, on December 20, 2023, an investigation of the
license holder’s medical cannabis testing methods and laboratory practices was conducted by the
Mississippi Medical Cannabis Program between December 21, 2023 and February 9, 2024, which
revealed deviations from 15 Miss. Admin. Code Part 22, Subpart 1 and the standard operating
procedures approved as a condition of Rapid’s licensure award. Because the serious and persistent
nature of the deviations constitute a danger to public health, safety, and welfare, the Mississippi State
Department of Health hereby provides notice of its intent to intent to revoke your establishment’s
license to operate as a medical cannabis testing facility. The Department’s decision is based upon and
supported by regulatory violations uncovered during MMCP’s investigation of Rapid’s conduct,
including but not limited to the following:

 Rapid persistently violated Rule 1.7.7 because it failed to establish and consistently report
cannabinoid Limit of Quantitation (“LOQ”).

 In violation of Rule 1.15.1, Rapid used a test method incapable of detecting pesticides at the
required Limit of Detection. 15 Miss. Admin. Code Pt. 22, Subpart 1, Appendix A.

 Numerous compliance sample results were reported as passing without being tested by Rapid
in violation of Rule 1.10.1.

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 Rapid repeatedly mislabeled COAs as “regulatory compliance testing” that failed to include
analysis for all regulated analytes in violation of Rule 1.10.2.

 In violation of Rules 1.10.2, 1.10.5, 1.10.6 and 1.10.7, Rapid improperly manipulated testing
data and inaccurately reported compliance samples as passing testing for pesticides,
mycotoxins, heavy metals, material solvents and potency that should have been reported as
failed based on regulatory action limits.

 In violation of Rule 1.13.1, Rapid failed to develop and implement a Quality Assurance
program to verify the reliability and validity of the analytical data produced by the cannabis
testing facility.

 Rapid deviated significantly from its approved SOP and method validation for cannabinoid
potency and manipulated sample injection volumes to obtain optimized potency results for the
various product matrix types in violation of Rule 1.13.3.

 In violation of Rule 1.13.4, Rapid implemented alternative testing methods without submitting
the requisite validation report or graded external proficiency test to MSDH for approval. The
review of COAs published by Rapid on various dates in 2023 (e.g., February, October,
November, and December) revealed changes to the reported values associated with the Limit
of Quantitation (“LOQ”) and Limit of Detection (“LOD”) for pesticides, mycotoxins and
residual solvents that were different than those presented in Rapid’s method validation report
for the testing of these analytes. Rapid never submitted a validation report for the alternative
method nor an external proficiency test graded by a third party verifying the method’s accuracy
to MSDH. Rule 1.13.4 mandates that new or altered test methods used by licensed testing
facilities be submitted to the agency for approval within five business days. See 15 Miss. Admin.
Code Pt. 22, R. 1.13.4.7-8. More critically, Rapid also intentionally changed its methodology
to prevent detection of regulated pesticides at levels equal to or above the required action limits.
Rapid further failed to maintain records of deviations from its Standard Operating Procedures.

 In violation of Rule 1.14.1, Rapid failed to adhere to good laboratory practices in the
performance of each test analysis and did not consistently use Quality Control samples.

 Numerous analytical batches1 containing compliance samples tested for pesticides, mycotoxins,
potency, and residual solvents were reported by Rapid in violation of Rule 1.14.5 because the

1
Rule 1.1.2.3 defines Analytical Batch as “a set of no more than twenty samples that are prepared together for
the same type of analysis, are sequentially analyzed using the same instrument calibration curve, and have

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applicable specifications for quality control samples per analytical batch were not adhered to in
Rapid’s testing methods.

 Rapid repeatedly failed to run adequate continuing calibration verification samples for
analytical batches tested for pesticides, mycotoxins, residual solvents, and potency in violation
of Rule 1.14.6.

 Multiple analytical batches of compliance samples tested for pesticides, mycotoxins, potency,
and residual solvents were reported by Rapid in violation of Rule 1.14.7. This was due to one
or more of the following: 1) multiple analytical batches demonstrated Laboratory Control
Samples with percent recovery outside of the required 70% to 130% and results were reported
without remediation; 2) multiple analytical batches demonstrated duplicate Laboratory Control
Samples with Relative Percentage Difference ≥ 30%; 3) multiple analytical batches
demonstrated Matrix Spike Samples with percent recovery outside of the required 70% to 130%
and results were reported without remediation; 4) multiple analytical batches demonstrated
duplicate Matrix Spike Samples with Relative Percentage Difference ≥30%; and/or 4) multiple
analytical batches demonstrated Continuing Calibration Verification samples with percent
recovery outside of the required 70% to 130%.

 The results associated with numerous analytical batches containing compliance samples tested
for pesticides, mycotoxins, residual solvents, and potency were reported by Rapid in violation
of Rules 1.10.7 and 1.14.14. Rapid continued to report pesticide and mycotoxin results despite
systemic and repeated quality control failures.

 In violation of Rules 1.8.1 and 1.14.11, Rapid failed to perform a second retest with a passing
result prior to reporting passing results to commercial cannabis licensees after medical cannabis
and medical cannabis product samples failed required testing by exceeding allowable thresholds
for regulated analytes.

 In violation of Rules 1.16.1 and 1.16.2, Rapid failed to provide any data packages for
compliance tests performed by Rapid during the 2023 calendar year as requested by MSDH in
the Notice of Emergency Suspension issued December 20, 2023.

common analytical quality control requirements.

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 Rapid failed to ensure and document that each cannabis testing facility employee meets the
employee qualifications, including but not limited to an initial and annual demonstrations of
competency in violation of Rules 1.1.12 and 1.1.17.

The testing of medical cannabis is a core component to product safety. Medical cannabis
patients rely on licensed medical cannabis testing facilities to properly test the medical cannabis and
medical cannabis product samples before the items may be sold to a dispensary to ensure what is being
consumed and/or inhaled is safe and free of contaminants that could potentially have negative effects
on the health of patients. Rapid’s violations show an indifference to the safety of those who are intended
to be protected by the very services it is licensed to provide and its failure to comply with applicable
regulations and standards demonstrates a disregard of its duty to protect public welfare and the integrity
of the Mississippi Medical Cannabis Program. Accordingly, and for the reasons stated herein and the
accompanying Report of Findings & Observations, the Department has further determined that the
violations committed by Rapid further warrant monetary penalties as follows:

VIOLATION FINE
Rule 1.15.1 $5,000
Rule 1.10.1 $5,000
Rules 1.10.2, 1.10.5, Per Instance:
1.10.6, & 1.10.7:
 SA155 $5,000
 SA157 $5,000
 SA1140 $5,000
 SA1614 $5,000
 SA1793 $5,000
 SA1821 $5,000
 SA2558 (*308) $5,000
 SA2558 (*314) $5,000
 SA2608 $5,000
 SA2811 $5,000
 SA2814 $5,000
 SA3021 $5,000
 SA3317 $5,000
 SA3366 $5,000

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 SA3398 $5,000
 SA3811 $5,000
 SA3812 $5,000
 SA3918 $5,000
 SA2642 $5,000
 SA2688 $5,000
 SA2689 $5,000
 SA2691 $5,000
 SA2692 $5,000
 SA2693 $5,000
 SA2694 $5,000
 SA2695 $5,000
 SA2696 $5,000
 SA2697 $5,000
 SA2698 $5,000
 SA2699 $5,000
 SA2700 $5,000
 SA2701 $5,000
 SA2702 $5,000
 SA2703 $5,000
 SA2704 $5,000
 SA2705 $5,000
 SA2706 $5,000
 SA2707 $5,000
 SA2708 $5,000
 SA2709 $5,000
 SA2710 $5,000
 SA2711 $5,000
 SA2643 $5,000
 SA2644 $5,000
 SA2645 $5,000
 SA2679 $5,000
 SA2680 $5,000
 SA2681 $5,000
 SA2646 $5,000
 SA2647 $5,000
 SA2678 $5,000
 SA2649 $5,000
 SA2650 $5,000
 SA2651 $5,000
 SA2652 $5,000
 SA2653 $5,000
 SA2654 $5,000
 SA2655 $5,000
 SA2656 $5,000
 SA2657 $5,000
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 SA2727. $5,000
 SA2728 $5,000
 SA2729 $5,000
 SA2730 $5,000
 SA2731 $5,000
 SA2732 $5,000
 SA2733 $5,000
 SA2734 $5,000
 SA2735 $5,000
 SA2736 $5,000
 SA2737 $5,000
 SA2738 $5,000
 SA2739 $5,000
 SA2740 $5,000
 SA2741 $5,000
 SA2742 $5,000
 SA2743 $5,000
 SA2744 $5,000
 SA2745 $5,000
 SA2746 $5,000
 SA2747 $5,000
 SA2748 $5,000
 SA2749 $5,000
 SA2750 $5,000
 SA2751 $5,000
 SA2752 $5,000
 SA2756 $5,000
 SA2757 $5,000
 SA2758 $5,000
 SA2759 $5,000
 SA2761 $5,000
 SA2762 $5,000
 SA2763 $5,000
 SA2764 $5,000
 SA2765 $5,000
 SA2766 $5,000
 SA2767 $5,000
 SA2768 $5,000
 SA2769 $5,000
 SA2770 $5,000
 SA2771 $5,000
 SA2772 $5,000
 SA2773 $5,000
 SA2774 $5,000
 SA2775 $5,000
 SA2776 $5,000
 SA2777 $5,000
 SA2778 $5,000
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 SA2779 $5,000
 SA2780 $5,000
 SA2781 $5,000
 SA2782 $5,000
 SA2783 $5,000
 SA2784 $5,000
 SA2785 $5,000
 SA2786 $5,000
 SA2787 $5,000
 SA8789 $5,000
 SA2790 $5,000
 SA2791 $5,000
 SA2792 $5,000
 SA2793 $5,000
 SA2794 $5,000
 SA2795 $5,000
 SA2796 $5,000
 SA2797 $5,000
 SA2798 $5,000
 SA2799 $5,000
 SA27800 $5,000
 SA27801 $5,000
 SA27802 $5,000
 SA27803 $5,000
 SA27804 $5,000
 SA2864 $5,000
 SA2865 $5,000
 SA2866 $5,000
 SA2905 $5,000
 SA2906 $5,000
Rule 1.13.1 $5,000
Rule 1.13.3 $5,000
Rule 1.13.4 $5,000
Rule 1.2.2 $5,000
Rule 1.14.1 $5,000
Rule 1.14.5 $5,000
Rule 1.14.6 $5,000
Rule 1.14.7 $5,000
Rule1.14.14 $5,000
Rule 1.7.7 $5,000
Rule 1.8.1 $5,000
Rules 1.16.1 & 1.16.2 $5,000
TOTAL $1,000,000.00

Please remit payment for these amounts to the Mississippi Department of Health Medical
Cannabis Program within thirty (30) days of this correspondence.

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Please be advised that pursuant to Miss. Code Ann. § 41-137-47 Rapid Analytics, LLC has the
right to appeal this decision should it so choose, by submitting a written request for administrative
hearing to the Department within twenty (20) days of receipt of this Notice. Otherwise, Rapid Analytic,
LLC’s medical cannabis testing facility license (No. TESL000301) will be revoked effective from and
after March 13, 2024.

Please do not dispose of or destroy any records, video footage, instrument data/files, equipment
or any other evidence related to this administrative action. We anticipate that it will be both
discoverable and admissible in any litigation that may arise out of same.

Should you have any questions, please feel free to contact the Office of Medical Cannabis at
601-206-1540 or via email at MCLicensing@msdh.ms.gov.

Sincerely,
2/21/2024 | 4:42 PM CST

Laura D. Goodson, Esq.

Director, Mississippi Medical Cannabis Program
Mississippi State Department of Health
MSB No. 101250

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