CSQ CERTIFICATION
The CSQ Certification Program and applicable standards were built around ISO/IEC 17067
19 CSR 100-1.100 Facilities Generally
Missouri QMS for Cannabis
Licensees shall implement a quality management system using a published standard, such as those offered by Cannabis Safety and Quality within one year of the date the facility receives department approval to operate. The chosen standard shall be applicable to the licensee’s facility type and be implemented with emphasis on regulatory compliance.
Missouri's Cannabis QMS Rule, in Plain English — and How to Comply
If your facility holds a Missouri cannabis license, state law requires you to implement a quality management system within one year of receiving department approval. This page explains what that means, whether it applies to you, which CSQ standard fits your license, and what certification with Kiwa ASI actually involves.
START HERE
Does Missouri's Cannabis QMS Rule Apply to Me?
Probably yes. Missouri’s QMS rule applies to every cannabis license issued by the state — not just to processors and not just to large facilities. Here is the short version.
WHO IT APPLIES TO
Every Missouri cannabis license
Cultivators, processors (extraction and manufacturing), dispensaries, microbusinesses, transporters, and testing laboratories. There is no carve-out by license type or revenue.
YOUR DEADLINE
One year from DHSS approval
The clock starts on the date your facility receives approval to operate from the Department of Health and Senior Services. Most operators need 6 to 9 months to actually be ready.
IF YOU DON'T COMPLY
Inspection violation, fines, license risk
The Division of Cannabis Regulation can issue notices of violation, fines, license suspension, or revocation for facility-rule failures. The practical risk: failing an inspection and being put on a corrective-action plan you can't meet.
What “QMS using a published standard” actually means
Missouri does not just want SOPs binders. 19 CSR 100-1.100(4)(C) requires a complete quality management system: documented policies, internal audits, a corrective-action process, training records, traceability, and management commitment — all built around a recognized published standard. The regulation names four acceptable standards: ISO, ASTM International, Cannabis Safety and Quality (CSQ), and FOCUS. Of those four, CSQ is the only one written specifically for cannabis operations, which is why most Missouri licensees choose it.
The rule does not explicitly require third-party certification — but a certificate from an accredited body is the cleanest, most defensible proof you have a QMS in place when an inspector asks. CSQ certification through Kiwa ASI is one path; the next sections walk you through whether it’s the right one for your operation.
FIND YOUR PATH
Pick Your License Type and See Exactly What You Need
Each Missouri license maps to one CSQ standard. Pick the card that matches your operation and you'll see the standard, the minimum level for compliance, the typical timeline, and the audit length. Vertically integrated? Use multiple cards.
Cultivator
19 CSR 100-1.160STANDARD
CSQ Cultivation v2.0.0
MINIMUM LEVEL
Level 1
PREP TIME
6–9 months
AUDIT LENGTH
~2 days onsite (initial)
Indoor, outdoor, and greenhouse cultivation — including post-harvest drying, curing, and trimming. Foundation: cGACP (good agricultural and collection practices) plus cGMP. Established cultivators often add Level 2 (HACCP) for hazard control.
Processor — Extraction
19 CSR 100-1.170STANDARD
CSQ Extraction v2.0.0
MINIMUM LEVEL
Level 1
PREP TIME
6–9 months
AUDIT LENGTH
~2 days onsite (initial)
Solvent-based and solvent-free extraction (CO₂, ethanol, hydrocarbon, mechanical). Critical CSQ items to watch: beverage-grade CO₂ (99.5%), food-grade non-denatured ethanol where required, and residual-solvent specs that meet whichever is stricter — Missouri rule or your internal spec.
Processor — Manufacturing
19 CSR 100-1.170STANDARD
CSQ Manufacturing v2.0.0
MINIMUM LEVEL
Level 1
PREP TIME
6–9 months
AUDIT LENGTH
~2 days onsite (initial)
Edibles, beverages, vape cartridges, topicals, and infused pre-rolls. Key cannabis-specific rules: food-grade/GRAS ingredients are not appropriate for inhalable products or infused pre-rolls; allergen declarations are required across formulated, ingestible, and topical products.
Dispensary
19 CSR 100-1.180STANDARD
CSQ Retail v1.0.0
MINIMUM LEVEL
Level 1
PREP TIME
4–6 months
AUDIT LENGTH
~2 days onsite (initial)
Retail medical and adult-use dispensaries. Built on cGHP (good handling practices) — covers inventory, storage, customer-facing controls, and staff training. Yes, the QMS rule applies to dispensaries too.
Dispensary with On-Site Production
Deli-Style RetailSTANDARD
CSQ Deli-Style Retail v1.0.0
MINIMUM LEVEL
Level 1
PREP TIME
5–7 months
AUDIT LENGTH
~2 days onsite (initial)
Dispensaries producing pre-rolls, infused products, or other items on-site for direct retail sale. Adds cGMP coverage on top of retail handling controls.
Microbusiness
19 CSR 100-1.190STANDARD
Cultivation or Manufacturing v2.0.0
MINIMUM LEVEL
Level 1
PREP TIME
5–8 months
AUDIT LENGTH
~2 days onsite (initial)
Microbusiness wholesale facilities (250 flowering plant limit) use the Cultivation standard. Microbusiness manufacturers (pre-rolls, infused pre-rolls) use the Manufacturing standard. The QMS rule applies to microbusinesses.
Standalone Warehousing/Distribution
19 CSR 100-1.140STANDARD
CSQ Warehousing & Distribution v1.0.0
MINIMUM LEVEL
Level 1
PREP TIME
4–6 months
AUDIT LENGTH
~2 days onsite (initial)
Transport and storage operations licensed separately from cultivation, processing, or retail. Built on cGDP (good distribution practices).
Selling Dietary Supplement Products
Add-OnSTANDARD
+ CSQ Dietary Supplement Addendum v2.0.0
MINIMUM LEVEL
Level 2 base + addendum
PREP TIME
+1–2 months
AUDIT LENGTH
+4 hours (Pass/Fail)
Layered on top of any base CSQ standard. Aligns with US 21 CFR 111 and APHA Dietary Supplement Guidelines. Required if any product is classified as a dietary supplement.
Testing Laboratory
19 CSR 100-1.110STANDARD
ISO/IEC 17025 (not CSQ)
MINIMUM LEVEL
N/A
PREP TIME
Varies by lab
AUDIT LENGTH
Per accreditation body
CSQ does not currently issue audit certifications for testing labs — it requires labs to be ISO/IEC 17025 accredited. Missouri-licensed testing labs should pursue ISO 17025 as their published standard under the QMS rule.
MISSOURI REQUIRES VS. CSQ GOES FURTHER
What's a State Rule, and What's a CSQ Best Practice?
This trips up almost every operator at first. Missouri's regulations are the legal floor. CSQ is a published standard that satisfies the floor and adds requirements that aren't in state law. Knowing which is which keeps you from over-buying or under-preparing.
What Missouri requires (the legal floor)
- Implement a QMS using a published standard within 1 year of approval — 19 CSR 100-1.100(4)(C)
- SOPs to keep marijuana free of contaminants — 100-1.100
- Employee training on safety, sanitation, rules, and role-specific duties — 100-1.080
- Mandatory product testing (potency, contaminants, residual solvents, microbial) — 100-1.110
- Compliant packaging, labeling, and product design — 100-1.120
- Statewide track-and-trace and inventory control — 100-1.130
- Compliant transport and storage — 100-1.140
- Secure waste storage and 5-year disposal records — 100-1.150
- License-type-specific requirements — 100-1.160 / .170 / .180 / .190
What CSQ adds (best practice on top)
- A documented internal audit program (Module 1.5)
- A corrective and preventive action (CAPA) system (Module 1.6)
- An annual mock recall (Module 1.8) and verified traceability test
- Cannabinoid and non-cannabinoid waste streams kept completely separated (Module 2A.4 / 2B.4)
- Beverage-grade CO₂ (99.5%) for extraction — medical-grade is not acceptable
- Food-grade, non-denatured ethanol where used as an ingredient
- No lead in irrigation systems; no untreated manure as soil amendment
- Inhalation-grade ingredients for inhalable products (food-grade/GRAS is not sufficient)
- Route-of-administration risk assessments for formulated, inhalable, and topical products
- HACCP team and certified lead (Level 2 only — not a Missouri state requirement)
Quick glossary — the terms that show up in a CSQ audit
QMS
Quality Management System. The full set of policies, procedures, audits, and management practices that run your facility — not just SOPs.
cGMP
Current Good Manufacturing Practices. The baseline rules for facilities that make a product (cultivators, extractors, manufacturers, deli-style retail).
cGHP
Current Good Handling Practices. The retail equivalent — applies to dispensaries.
cGDP
Current Good Distribution Practices. The transport and warehousing equivalent.
cGACP
Current Good Agricultural and Collection Practices. Cultivation-specific foundation, layered with cGMP.
HACCP
Hazard Analysis & Critical Control Points. A formal hazard-control method. Required at CSQ Level 2 — not required by Missouri.
Module / Section
How CSQ organizes its standards. Modules 1, 2, and 3 (CSQMS, GMP/GHP/GDP, operation-specific). Sections are the numbered subsections (e.g., 2A.12.9).
Surveillance audit
The annual (or 6-month, depending on score) check-in audit that keeps your certificate valid between recertifications.
THE AUDIT
What a CSQ Audit Actually Looks Like
A Missouri CSQ audit is an onsite review of your QMS against the standard that fits your license. Here is how scoring, findings, and timing work — followed by the technical mapping table for the people who want it.
Scoring (100-point scale)
How CSQ scores you and what it means for your certificate
| Score | Outcome | Surveillance Cycle |
|---|---|---|
| 80–100 | Certificate issued | Annual surveillance audit |
| 70–79 | Certificate issued | 6-month surveillance audit |
| Below 70 | No certificate | 6-month wait before re-audit |
Findings categories
CRITICAL · –100 POINTS
Auto-fail finding
Regulatory non-compliance, product safety risk, or foundational QMS breakdown. A single Critical finding fails the audit regardless of other scores.
MAJOR · –10 POINTS
Significant gap
Systemic failures or significant deviations from CSQ requirements — not an immediate safety risk but requires corrective action.
MINOR · –1 POINT
Isolated finding
Documentation gap, single-occurrence lapse, or correctable deviation that is not systemic.
Audit timing & certificate validity
What to expect onsite and on the calendar
| Item | Detail |
|---|---|
| Level 1 audit | 1 day onsite + 0.5 day report time |
| Level 2 audit | 1.5 days onsite + 1 day report time |
| Level 3 audit | 2 days onsite + 1 day report time (unannounced window) |
| Initial audit add-on | +1 day for offsite documentation evaluation (all levels) |
| Corrective action window | 30 days to close nonconformities |
| Certificate validity | 1 year + 45 days from audit date |
| Initial certification blackout | No initial certifications scheduled in November or December |
| Provisional certificate | Available for new operations (valid 6 months) |
| Dietary Supplement Addendum | 4-hour minimum · Pass/Fail · separate report within 72 hours |
For consultants, internal compliance leads, and operators who want the section-by-section map between Missouri's regulations and CSQ 2.0:
Missouri 19 CSR 100-1 requirements and corresponding CSQ 2.0 sections
| Missouri Requirement | Citation | CSQ Coverage |
|---|---|---|
| Quality management system | 100-1.100(4)(C) | CSQ Level 1 minimum (Modules 1–3) — Module 1 CSQMS, Module 2A or 2B, Module 3 by operation |
| SOPs for contaminant-free product | 100-1.100 | Section 1.1 + 2A.3 / 2B.3 (Cleaning & Sanitation) + 2A.12 / 2B.11 (Process & Production Controls) |
| Facility construction (smooth, cleanable) | 100-1.100 | Section 2A.1.1 / 2B.1.1 (Facility Construction and Design) |
| Temperature & humidity controls | 100-1.100 | 2A.9.3 / 2B.8 (Temperature-Controlled Storage); 3A.1.1 (Indoor Cultivation); 3B.1.11; 3C.1.9 |
| Environmental condition monitoring | 100-1.100 | Module 2A.8 / 2B.7 (Environmental Monitoring) |
| Employee training (safety, sanitation, role-specific) | 100-1.080 | Section 2A.13 / 2B.12 (Personnel Requirements) — training, hygiene, PPE, handwashing |
| Mandatory product testing (potency, contaminants, solvents, microbial) | 100-1.110 | Section 2A.12.9 / 2B.11.7 (Product Sampling and Testing) |
| Packaging & labeling (child-resistant, cannabinoid content, warnings) | 100-1.120 | Section 2A.12.8 / 2B.11.6 (Product Labeling and Packaging) |
| Inventory control & seed-to-sale tracking | 100-1.130 | Section 2A.10 / 2B.9 (Inventory Management) + Section 1.3 (Regulatory Compliance) |
| Transport & storage | 100-1.140 | Section 2A.9 / 2B.8 (Storage and Distribution) |
| Cultivation: pest management, water quality, harvest, drying | 100-1.160 | Sections 3A.1.5–3A.1.16 (cultivation inputs, IPM, water, harvest, drying/curing) |
| Manufacturing: extraction safety, CO₂ & ethanol grade, residual solvents | 100-1.170 | Sections 3B.1.2–3B.1.9; 3C.1.3, 3C.1.4, 3C.2.5; allergen and inhalation-grade controls |
| Dispensary: product handling, inventory, customer safety, staff training | 100-1.180 | Section 2B.8 + 2B.9 + 2B.11 + 2B.12 + Module 3E |
How to Prepare | A Realistic Path From Approval to Certificate
Plan backwards from your DHSS approval date. Most operators need 6 to 9 months of preparation before they're ready for an initial audit. Here is a sequence that actually works.
01
Confirm your CSQ standard and level
Use the Find-Your-Path section above. Pick the standard that matches your license, decide whether Level 1 is enough or you want Level 2/3, and add the Dietary Supplement Addendum if it applies. Write the answer down — it drives every other step.
02
Run a gap analysis
Compare your current state to the CSQ standard. ASI Training and Consulting, LLC can deliver a structured gap analysis as a separate engagement from the certification body — this is the cheapest way to find out where you are before paying for an audit.
03
Build the QMS documentation
Author or update SOPs for sanitation, process flow, cross-contamination, allergens, environmental monitoring, waste, traceability, and product release. Stand up your CAPA, internal audit, and document control systems.
04
Address the cannabis-specific Critical items
The findings most likely to fail a first audit: CO₂ purity, ethanol grade, lead in irrigation, untreated manure, inhalation-grade ingredients, and route-of-administration risk assessments. Verify these before the auditor arrives.
05
Train your team
Deliver competency-based, role-specific training. Cover Missouri DHSS rules (19 CSR 100-1.080), facility processes, hygiene, PPE, allergen handling, and traceability. Document training records and competency verifications.
06
Run internal audits and a mock recall
Conduct a documented internal audit covering every CSQ section in scope. Run an annual mock recall and verify your traceability and product hold/release procedures. Close any nonconformities through CAPA before the certification audit.
07
Schedule your CSQ audit with Kiwa ASI
Schedule through Kiwa ASI in the CSQ Database. Allow time for the offsite documentation evaluation (1 day) plus the onsite audit (1–2 days depending on level). No initial certifications are scheduled in November or December. Request a quote to start.
Why Missouri Operators Choose Kiwa ASI
Kiwa ASI brings nearly a century of food safety expertise and the global Kiwa network's footprint in 30+ countries to Missouri's cannabis QMS market.
Accredited
ISO/IEC 17065 + CSQ-Licensed
Audits and certificates are issued by ASI Food Safety, LLC — an ISO/IEC 17065-accredited certification body licensed by CSQ.
Expertise
Food-grade rigor for cannabis
Our auditors are credentialed food safety, GMP, and HACCP professionals with cannabis-specific qualifications. Cannabis is being regulated like food. We've been doing food for decades.
Efficiency
Direct scheduling, no surprises
Pre-audit scoping clarifies level, scope, and Module 3 requirements before you're onsite. Audit reports are turned around inside the standard CSQ timeline.
Comprehensive
Training and consulting available
Pre-assessments and gap analyses are delivered by ASI Training and Consulting, LLC, a separate legal entity, kept structurally separate from the certification body to safeguard impartiality under ISO/IEC 17065.
Continuity
Surveillance, recertification, transfer
If you're already CSQ-certified through another body and the relationship isn't working, we accept transfer audits. Continuity matters as much as the initial certificate.
Partnership
Global Kiwa network
Operations in 30+ countries. Useful when a Missouri operator expands into other state markets or builds an international supply chain.
Frequently Asked Questions About Missouri Cannabis QMS & CSQ Certification
Yes. Missouri regulation 19 CSR 100-1.100(4)(C) requires every cannabis licensee to implement a quality management system using a published standard within one year of receiving department approval to operate. The rule applies to all license types — cultivators, processors (manufacturers), dispensaries, microbusinesses, and testing laboratories — and explicitly names ISO, ASTM International, Cannabis Safety and Quality (CSQ), and FOCUS as acceptable published standards.
Non-compliance with 19 CSR 100-1.100(4)(C) is a regulatory violation and can be cited during a Division of Cannabis Regulation (DCR) inspection. Missouri DCR has authority to issue notices of violation, fines, license suspension, and license revocation for failure to meet facility requirements. The specific penalty depends on the inspector's findings and your facility's remediation history. The most practical risk is failing an inspection, having a corrective action plan imposed, and being unable to demonstrate the QMS within the required window. Implementing CSQ — explicitly named in the regulation — is the most defensible documented response.
Yes. CSQ (Cannabis Safety and Quality) is one of four published standards explicitly named in 19 CSR 100-1.100(4)(C). Of the four named options — ISO, ASTM International, CSQ, and FOCUS — CSQ is the only standard purpose-built for cannabis, with modules covering cultivation, extraction, manufacturing, retail, deli-style retail, warehousing & distribution, and dietary supplements.
Cultivators use CSQ Cultivation v2.0.0. Extraction processors use CSQ Extraction v2.0.0. Manufacturing processors (edibles, vapes, topicals, infused pre-rolls) use CSQ Manufacturing v2.0.0. Dispensaries use CSQ Retail v1.0.0. Dispensaries with on-site production use CSQ Deli-Style Retail v1.0.0. Microbusinesses use the standard matching their licensed activity. Standalone warehousing/distribution operators use CSQ Warehousing & Distribution v1.0.0. Operations selling dietary supplement products add the CSQ Dietary Supplement Addendum v2.0.0 on top of a Level 2 base.
The regulation requires implementation of a QMS using a published standard. It does not explicitly mandate third-party certification. However, third-party certification through an accredited certification body — such as Kiwa ASI, an ISO/IEC 17065-accredited and CSQ-licensed certification body — provides the strongest documented evidence of compliance and protects licensees during DCR inspections.
CSQ Level 1 (Modules 1, 2, and 3) is the minimum to satisfy Missouri's QMS mandate for any license type. Level 2 adds HACCP and is recommended for established operations seeking advanced hazard control — note that HACCP is not a Missouri requirement, it is a CSQ Level 2 requirement. Level 3 adds management review, continuous improvement, and an unannounced audit window, and is appropriate for multi-site or premium operators. Operations selling dietary supplement products must hold Level 2 plus the Dietary Supplement Addendum.
Level 1 audits are typically 1 day onsite plus 0.5 days of report time. Level 2 audits are 1.5 days onsite plus 1 day of report time. Level 3 audits are 2 days onsite plus 1 day of report time and are scheduled unannounced within a defined audit window. Initial audits add 1 day for the offsite documentation evaluation regardless of level. The Dietary Supplement Addendum audit is a separate 4-hour minimum review with a Pass/Fail outcome.
There is no single published price because cost depends on six factors: (1) which CSQ standard applies (Cultivation, Extraction, Manufacturing, Retail, Deli-Style Retail, or Warehousing & Distribution); (2) which level you pursue (1, 2, or 3); (3) facility size and complexity; (4) whether this is your initial audit (which adds an offsite documentation evaluation day) or a surveillance audit; (5) whether the Dietary Supplement Addendum applies; and (6) whether you also engage Kiwa ASI's separate consulting entity for a pre-assessment. Most Level 1 initial audits run two onsite days plus an offsite documentation day.
Licensees must implement a QMS using a published standard within one year of the date the facility receives Department of Health and Senior Services (DHSS) approval to operate. The clock starts on the approval date, not the original license issue date. New licensees should begin QMS planning immediately because building documentation, training staff, conducting internal audits, running a mock recall, and scheduling a third-party audit typically takes 6 to 9 months.
Yes. Missouri's QMS mandate in 19 CSR 100-1.100(4)(C) covers all license types — there is no carve-out for dispensaries or microbusinesses. CSQ Retail v1.0.0 is purpose-built for dispensary operations covering cGHP, product handling controls, inventory traceability, and personnel requirements. Microbusinesses use the CSQ standard that matches their licensed activity (Cultivation for grow operations; Manufacturing for pre-rolls and infused pre-rolls).