AOAC CASP Meeting Book
WEDNESDAY, MARCH 16, 2022 1:00PM – 5:00PM
at the
AOAC 2022 MID-YEAR MEETING Gaithersburg MarriottWashingtonian Center Gaithersburg, Maryland, USA
AOAC Mid-Year Meeting Wednesday, March 16, 2022 | 1:00pm – 5:00pm ET
MEETING AGENDA
I. WELCOME, INTRODUCTIONS AND ANNOUNCEMENTS (1:00PM – 1:05PM) David Schmidt, Executive Director, AOAC INTERNATIONAL
II. PROGRAM REVIEW & PROCESS OVERVIEW (1:05PM – 1:20PM) Christopher Dent, Sr. Manager, AOAC Science Programs, AOAC INTERNATIONAL
III. THE CHANGING REGULATORY LANDSCAPE (1:20PM – 1:45PM) Susan Audino, Audino & Associates / AOAC CASP Science Advisor
IV. GUEST SPEAKER: CANNABIS REGULATORS ASSOCIATION (CANNRA) (1:45PM – 2:15PM) Lori Dodson, Sr. Advisor, Maryland Medical Cannabis Commission
V. REPORT FROM THE CANNABIS CHEMISTRY WORKING GROUP: CANNABIS BEVERAGES (2:15PM – 3:15PM) • Heavy Metals, Pesticides: Julie Kowalski, Kowalski Science Support • Cannabinoids, Residual Solvents: Holly Johnson, Chief Science Officer, AHPA
VI. UPDATE ON AOAC PROFICIENCY TESTING PROGRAM (3:30PM – 3:45PM) Shane Flynn, Sr. Director, Laboratory Proficiency Testing Program, AOAC
VII. Update on ALACC Revision (3:45PM – 4:00PM) Susan Audino, Audino & Associates / AOAC CASP Science Advisor
VIII. CANNABIS DRYING GUIDANCE DOCUMENT *(4:00PM – 4:30PM) Holly Johnson, Chief Science Officer, AHPA • Discussion and Vote
IX. REPORT FROM THE MICROBIAL CONTAMINANTS WORKING GROUP (4:30PM – 5:00PM) Julia Bramante, Lead Scientist Cannabis Reference Laboratory, Colorado Department of Public Health & Environment • Discussion and vote on the proposed Cannabis Microbiology Validation Guidelines*
X. ADJOURN (5:00PM) Scott Coates, Sr. Director, AOAC Research Institute, AOAC INTERNATIONAL
02/14/22 Version 4 – Subject to Change Without Notice
Break at 3:15PM
*Item requires a live vote
AOAC INTERNATIONAL – Cannabis Analytical Science Program, March 16, 2022, Presenter Bios
PRESENTER BIOS
JULIA BRAMANTE, COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
Julia Bramante is the Cannabis Reference Laboratory Manager and Lead Scientist at the Colorado Department of Public Health and Environment, in which the lab’s primary focus is conducting in depth method development and validation studies for application to reference methods. Additionally, Julia is the Chair of the AOAC CASP Microbial Contaminants Working Group, Chair of the AOAC CASP Microbial Contaminants Expert Review Panel, and serves on the AOAC CASP Cannabinoids and Chemical Contaminants Expert Review Panels. She also serves as Chair of the
Cannabis Chemistry Subdivision of the Division of Chemical Health and Safety of the American Chemical Society, a position she has held since January of 2019. She is also a member of the AOAC Official Methods Board..
LORI DODSON, MARYLAND MEDICAL CANNABIS COMISSION / CANNRA
Lori Dodson currently serves as a Senior Advisor for the Maryland Medical Cannabis Commission and the Co ‐ Chair for the CANNRA Laboratory Testing Sub ‐ Committee. Over the years, Lori has been actively involved in developing cannabis policy and regulations, specifically in the area of cannabis testing. Prior to coming on board at the commission, Lori served the Maryland Department of Health and Mental Hygiene where she was responsible for regulating and inspecting forensic and clinical laboratories in Maryland. Ms. Dodson has a Masters of Science in
Biomedical Research from the University of Maryland ‐ Baltimore and a Bachelors of Science in Medical Technology from Wichita State University. Lori is married with two very active children and a dog, and loves competing in endurance sports.
AOAC INTERNATIONAL – Cannabis Analytical Science Program, March 16, 2022, Presenter Bios
PRESENTER BIOS HOLLY E. JOHNSON, AMERICAN HERBAL PRODUCTS ASSOCIATION Holly E. Johnson Ph.D., is the Chief Science Officer for the American Herbal Products Association (AHPA). She previously served for three years as Laboratory Director for Alkemist Labs, an ISO 17025 accredited natural products testing lab specializing in botanical dietary supplements. Dr. Johnson took her Ph.D. in Pharmacognosy at the College of Pharmacy, University of Illinois – Chicago (UIC), under renowned Pharmacognosist and
researcher Dr. Norman Farnsworth. Holly was awarded a National Institutes for Health (NIH) Fellowship and trained at the UIC/NIH Center for Botanical Dietary Supplements. She was a Postdoctoral Research Fellow at the Institute for EthnoMedicine studying the etiology of neurodegenerative disease, and also worked for Waters Corporation conducting technical training and regulatory consulting for pharmaceutical and supplements companies. She is currently a Research Associate with the National Tropical Botanical Garden and serves on AOAC working groups, stakeholders’ panels, and expert review panels for Foods and Dietary Supplements. She is a member of the United States Pharmacoepia’s (USP) Medical Cannabis Expert Panel, the Editorial Board of the Journal of AOAC International, and she serves on the Advisory Boards of the American Botanical Council and the American Herbal Pharmacoepia. Holly has over 20 years’ experience working with natural products & botanicals and spent many happy years conducting research on medicinal plants and giving courses at the University of Hawaii.
JULIE KOWALSKI, JKSS LLC Julie Kowalski is a technical consultant primarily serving the cannabis and hemp testing market. She earned her graduate degree in Analytical Chemistry from Pennsylvania State University. Her professional experience includes
troubleshooting, method development and validation for GC, GC ‐ MS, LC, and LC ‐ MS/MS in addition to pesticide residue analysis and chromatography method development. She has previously served as the President of the North American Chemical Residue Workshop, served on AOAC Expert Review Panels, the Cannabis Scientific Task Force for Washington State and is currently chairing the AOAC CASP Chemical Contaminants Working Group.
PROGRAM OVERVIEW AOAC MID-YEAR MEETING
MARCH 16, 2022
MARRIOTT GAITHERSBURG
WASHINGTONIAN CENTER
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Overview & Updates
AOAC Standards Development
Cannabis Analytical Science Program Overview
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• Documents a community’s
• Used to adopt AOAC Official
What are SMPRs?
analytical method needs.
Methods by Expert Review
Panels.
• Very detailed description of the
analytical requirements.
• Published as a standard in the
OMA and in the Journal of AOAC
• Includes method acceptance
International.
requirements.
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On April 8, 2008, PCR Methods for Detection of Bacillus anthracis in Aerosol Collection Filters and/or Liquids, was approved by the Stakeholder Panel on Agent Detection Assays (SPADA). This would become AOAC’s first SMPR.
In 2009, AOAC replaced the terms “acceptance criteria” with “Standard Method Performance Requirements” (SMPR).
History of SMPRs at AOAC
Numerous SMPRs for the Stakeholder Panel on Agent Detection Assays (SPADA) were developed soon after and the format was duplicated for other efforts. Soon, AOAC was producing numerous SMPRs every year.
A standard format was developed and agreed in 2010.
SMPR is now a registered service mark of AOAC
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Basis for method acceptance and approval.
Guidance to method developers for the development of new methods.
Advance the state-of-the-art in a particular direction.
How are SMPRs Used?
Address specific analytical needs.
Allow AOAC to reach a broader community of method developers and users.
Development time = 3 to 6 months.
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Advisory panel explains their needs regarding methods in that specific area and assigns a working group to begin the standards development process.
Working group chair and members develop SMPR through a series of meetings.
SMPR
AOAC staff will post draft SMPRs to the AOAC website.
Development
Collect and compile comments.
Working group chair addresses comments.
Process
Approval process / voting
Staff works with working group chair to prepare SMPR for publication.
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• Chemistry & microbiology • Quantitative & qualitative • Definitions • Evaluation recommendations • Expected results • Informative sections
Appendix F Covers:
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Funding Policy
Objectives
• AOAC does not accept funding from any organization involved in the
• Facilitate a forum where the science of cannabis analysis is discussed with
cultivation, manufacture, distribution or possession of cannabis as
scientific experts.
long as it is federally illegal in the US.
• Facilitate the development and publication of cannabis and hemp-specific
methods and standards.
• AOAC does not advocate for or against the use or legalization of
•
Identify cannabis and hemp reference materials.
cannabis.
• Establish a cannabis and hemp proficiency testing program in accord with
• Our mission is consistent with ensuring public health and food safety
International Standards
by facilitating the development of methods for testing cannabis in
• Provide analytical and laboratory management training
food, feed or other substances of interest to determine the
best available science to promote public health.
• Provide resources and education to regulators responsible for establishing
rules and laws around cannabis and hemp.
• Fund provided by the analytical community consisting of testing
laboratories, technology providers, test kit companies, and other
associations.
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SMPRs Developed: 2017 - 2022
SMPR 2018.011: Identification and
SMPR 2017.001: Quantitation of Cannabinoids in Cannabis Concentrates
SMPR 2017.002: Quantitation of Cannabinoids in Dried Plant Materials
SMPR 2017.019: Quantitation of Cannabinoids in Edible Chocolate
SMPR 2019.001: Detection of Aspergillus in Cannabis and Cannabis Products
Quantitation of Selected Pesticide Residues in Dried Cannabis Materials
SMPR 2019.002: Identification and Quantitation of Selected Residual Solvents in Cannabis Derived Materials
SMPR 2019.003: Quantitation of Cannabinoids in Plant Materials of Hemp (low THC varieties of Cannabis)
SMPR 2020.001: Determination of Heavy Metals in a Variety of Cannabis and Cannabis Derived Products
SMPR 2020.012: Detection of Shiga Toxin Producing Escherichia coli in Cannabis and Cannabis Products
SMPR 2020.013: Mycotoxin Screening Technique in Cannabis Plant Material and Derivatives
SMPR 2022.XXX Cannabinoids in Beverages
SMPR 2022.XXX Heavy Metals in Beverages
SMPR 2021.010: Quantitative Mycotoxins
SMPR 2021.009: Total Yeast and Mold
Find them all at: https://tinyurl.com/caspsmprs
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• AOAC OMA 2018.11 Quantitation of Cannabinoids in Cannabis Dried Plant Materials, Concentrates, and Oils
• AOAC OMA 2018.10 Cannabinoids in Dried Flowers and Oil
• AOAC OMA: Method for the Quantification of Cannabinoids in Edible Chocolate by High-Pressure Liquid Chromatography: Single Laboratory Validation*
• AOAC OMA: Quantitating Cannabinoids in Edible Chocolates Liquid Chromatographic Separation with Photodiode Array Detection*
• AOAC OMA 2021.03: Determination of Heavy Metals in a Variety of Cannabis and Cannabis-Derived Products
• Matrix Extensions of OMA 997.02, OMA 2002.11, and 2018.02* for Total Yeast and Mold in Cannabis
* Publication pending
CASP Methods Approved as of March 16, 2022
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Training and Education Accomplishments
Setting Up a Cannabis Lab (330 registrants)
Microbial Contaminants in Cannabis (397 registrants)
Heavy Metals in Cannabis (271 registrants)
Chemical Contaminants in Cannabis (240 registrants)
USDA Update on Final Hemp Rules (193 Registrants)
Vape Science Panel (156 Registrants)
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Working Groups: Proficiency Testing
• Chair of PT Working Group (and Subgroups)
Other Subgroups
•
Dr. Brent (Walter) Wilson
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o AOAC is determining a schedule for the remaining subgroups o Certain subgroups take priority based on WG feedback Other Subgroups Moisture/Aw-this group has met once and will be scheduled to meet soon o
• Technical requirements for the following potential PT programs have been determined:
Cannabinoids
o
Pesticide Residues The technical recommendations will be provided to the Advisory Task Force for implementation
o
• Moisture/Aw (reporting would be a component of other PT program areas)
Advisory Task Force has been formed
•
Terpenes Heavy Metals Mycotoxins Residual Solvents
• The Microbial Contaminants Subgroup met on 4-30-21 o The meeting was well attended, and members provided excellent feedback on technical recommendations
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Questions about the PT Working Group? Contact Shane Flynn, Director of PT at CASP_PT_WG@aoac.org
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Ballot for Cannabinoids in Beverages
Ballot for Heavy Metals in Beverages
Coming Soon…
Comment Periods: Residual Solvents in Beverages , Micro Validation Guidelines
Mid-year meeting
• Live Vote on Cannabis Microbial Validation Guidelines • Live Vote on Cannabis Drying Guidance Document
New Calls for Method
• •
Cannabinoids in Cannabis Beverages Heavy Metals in Cannabis Beverages
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CASP Advisory Panel
CASP
Microbial Working Group
Chemistry Working Group
Proficiency Testing
Training Development
Community
Conformity Assessment
{ AOAC Staff & CASP Science Advisor }
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CASP Community • This is you!
• All are invited to semi-annual in person CASP meetings.
• Consists of all members of the working groups, advisory panel, expert review panels and anyone who has signed up for the CASP mailing list.
• How we communicate our offerings to the community AND where we source our experts for the various working groups, ERPs, training sessions, etc.
If you want to join ONLY the CASP Community, visit http://tinyurl.com/CASPAOAC and select “mailing list only” OR the working group(s) you would like to join.
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Advisory Panel
• Determines the priorities and direction of the program
• Meet quarterly to review program progress and when needed discuss priorities
• Different levels of membership (Pioneer, partner, affiliate, and now government)
• Members join at an organizational level
• Staff contact is Alicia Meiklejohn, Director of Business Development, ameiklejohn@aoac.org.
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Affiliate • Horiba • CEM Corporation • Hygiena • Canopy Growth • Q Laboratories • Medicinal Genomics • Antylia • PSI Labs • Meter Group
Pioneer • AFDO • SōRSE Technology • Millipore Sigma • Deibel Bioscience
Partner • Eurofins
CASP Advisory Panel Members
Government • MD Department of Agriculture • University of CA, San Diego
Want to join the Advisory Panel and set next year’s priorities? Contact Alicia Meiklejohn, Director, Governance and Business Development, ameiklejohn@aoac.org
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2022 Survey Results
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• Complete 2021 Projects (on or around MYM 2022)
•
Micro Validation Guidance
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Drying Guidance Document
•
Beverages
Confirmed 2022 Workplan
• Standards Dev Groups Commence 2022 Workplan
•
Microbial Contamination of Edibles
•
Cannabis Containing
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(a) Dietary Supplements
•
(b) Hempseed Oil
• Training Dev Group will develop training sessions around the following
themes:
•
Testing Cannabis Beverages
•
Validation of Cannabis Testing Methods
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Cannabis Microbiology Working Group
• Chair is Julia Bramante of the Colorado Department of Public Health and Environment
• Most recent project was guidelines for cannabis microbiology, a new appendix for the AOAC Official Methods of Analysis.
• Next, as per the Advisory Panel’s survey, they will start looking at microbial contamination of edibles, taking a product centric approach.
• Most of this group’s work will lead to SMPRs, standards that methods need to meet to become OMAs via AOAC ERP review.
If you want to join any of our CASP working groups, visit http://tinyurl.com/CASPAOAC and select your desired groups.
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Cannabis Chemistry Working Group
• Merger of the Chemical Contaminants Working Group and the Cannabinoids Working Group
• Co-Chairs are Holly Johnson, AHPA and Julie Kowalski, Kowalski Science Solutions
• Will focus on cannabinoid content and chemical contamination of finished products. NOT Micro.
• Most of their work will lead to SMPRs, standards that methods need to meet to become OMAs via AOAC ERP review.
• Could also be developing guidelines, other standard documents, whatever the community needs.
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Working Groups: Training Development
• Chaired by Toby Astill, PerkinElmer.
• Organized several educational sessions with input from working group members.
• Will continue to develop training sessions as per the Advisory Panel’s priorities.
• Survey feedback showed a high level of satisfaction with sessions so far.
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CASP Conformity Assessment • Three Expert Review Panels (ERPs) for CASP:
• Variety of Potential Method Submissions • Cannabinoids
• Cannabinoids ERP, Chair: Melissa Phillips, NIST
• Pesticides
• Chemical Contaminants ERP, Chair: Andrew Pham, Epic Labs • Microbial Contaminants ERP, Chair: Julia Bramante, Colorado Dept. of Public Health and Environment
• Residual Solvents
• Salmonella
• Aspergillus
• See them all at www.aoac.org
Recent Meetings:
Upcoming Meetings: March 30, 2022: Total Yeast and Mold Matrix Extension TBD June, 2022: Quantitative Mycotoxins (new method)
April 28, 2021: Cannabinoids ERP, two methods approved August 3, 2021: Chemical Contaminants ERP, one method approved August 5, 2021: Microbial Contaminants ERP, two matrix extensions approved December 14, 2021: Microbial Contaminants ERP, one method approved December 15, 2021: Cannabinoids ERP, reviewed but not approved
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Open Calls for Methods
• Details at www.aoac.org
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New Call for Methods!
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Thank you, CASP Community!
Scott Coates Program Lead Effective March 16
Allison Baker Coordinator, Science Programs
• Susan Audino, CASP Science Advisor (Audino & Associates)
AOAC CASP Staff
• Deborah McKenzie • Alicia Meiklejohn
• Katie Bergmann • Shane Flynn • Dawn Frazier • Jonathan Goodwin
• Palmer Orlandi • David Schmidt
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So long!
www.linkedin.com/in/christopher-james-dent
www.facebook.com/christopher.j.dent
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The Changing Regulatory Landscape
Susan Audino, PhD Science Advisor, AOAC CASP Susan.Audino@gmail.com
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A Jump Back in Time
TEAM CANNABIS: Cynthia Ludwig
– AOCS
Holly Johnson Seth Wong John MacKay
– Alkemist Labs – TEQ Analytics – Waters Corp.
Roger Brauninger – A2LA
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• Medical Patients ~ 1.5 to 2M • Adults • Muscle spasms caused by multiple sclerosis • Glaucoma • Anemia caused by chronic illness such as HIV • Crohn’s Disease • Psychiatric Disorders including PTSD
• Children
• Seizure Disorders • Attention Deficit Disorder • Autism
• Recreational Users
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MAP OF MARIJUANA LEGALITY BY STATE | DISA Updated February 2022
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• 2015
• Each state self ‐ regulated • A flurry of activities with non ‐ profit and other advocacy groups began to emerge • Accreditation Bodies began increased awareness and realized cannabis testing would become a staple • Major conferences for cannabis related businesses • CANNRA formed in November 2020 • Advocacy groups continue; some have merged • Accreditation Bodies have specialized “cannabis” assessors • Major conferences for cannabis related businesses, the scientific community , and international publications.
Progress
• 2022
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Another Jump Back in Time
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2017 • 5 states do not require independent testing • 4 states “may” include testing, but nothing strict • About 10 states ambitious require testing • 5 states require testing and require labs be ISO/IEC 17025 accredited • 1 state requires TNI accreditation • 1 state requires testing by DEA authorized/certified laboratory • At least 5 states currently require testing as outlined in the AHP Monograph … or better 2022 • 10 states do not require independent testing • 29 states have rigorous requirements for testing • Some states “recommend” but do not require testing
Requirements for Testing: Then and Now
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• MYM: Stakeholder Panel for Strategic Food Analytical Methods • Starting Advisory Panel: • SPEX • SCIEX • SC Labs • GW Pharmaceuticals (now Jazz Pharmaceuticals) • Sigma Aldrich • CEM
2017: AOAC takes action
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Develop 2 SMPRs
• Determine potency of defined cannabinoids in select food matrices • Determine residual pesticide residues in dry plant materials
GOAL in 2017
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Launched in 2019 * Advisory Panel Growth
• Expand response to laboratory needs for sound scientific methods • Provide bridge between science & scientists and regulations & regulatory bodies
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SMPRs Developed: 2017 ‐ 2021
SMPR 2018.011: Identification and
SMPR 2017.001: Quantitation of Cannabinoids in Cannabis Concentrates
SMPR 2017.002: Quantitation of Cannabinoids in Dried Plant Materials
SMPR 2017.019: Quantitation of Cannabinoids in Edible Chocolate
SMPR 2019.001: Detection of Aspergillus in Cannabis and Cannabis Products
Quantitation of Selected Pesticide Residues in Dried Cannabis Materials
SMPR 2019.002: Identification and Quantitation of Selected Residual Solvents in Cannabis Derived Materials
SMPR 2019.003: Quantitation of Cannabinoids in Plant Materials of Hemp (low THC varieties of Cannabis)
SMPR 2020.001: Determination of Heavy Metals in a Variety of Cannabis and Cannabis Derived Products
SMPR 2020.012: Detection of Shiga Toxin Producing Escherichia coli in Cannabis and Cannabis Products
SMPR 2020.013: Mycotoxin Screening Technique in Cannabis Plant Material and Derivatives
SMPR 2021.009: Total Yeast and Mold
SMPR 2021.010: Quantitative Mycotoxins
Find them all at: https://tinyurl.com/caspsmprs
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• AOAC OMA 2018.11 Quantitation of Cannabinoids in Cannabis Dried Plant Materials, Concentrates, and Oils
• AOAC OMA 2018.10 Cannabinoids in Dried Flowers and Oil
• AOAC OMA: Method for the Quantification of Cannabinoids in Edible Chocolate by High-Pressure Liquid Chromatography: Single Laboratory Validation*
• AOAC OMA: Quantitating Cannabinoids in Edible Chocolates Liquid Chromatographic Separation with Photodiode Array Detection*
• AOAC OMA 2021.03: Determination of Heavy Metals in a Variety of Cannabis and Cannabis-Derived Products
• Matrix Extensions of OMA 997.02, OMA 2002.11, and 2018.02* for Total Yeast and Mold in Cannabis
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AOAC Responds to Critical Needs
• CASP
• USDA Hemp Requirements • Guidance for Drying • Guidance for Micro validation
• Research Institute
• Emergency Response Validations – molecular testing
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Improper specification limits such as “LOD, LOQ” prompt labs to reduce instrument sensitivity. Trace amounts of pesticide residues that are ubiquitous prompt labs to find ways to ‘skirt around’ requirements.
Regulatory Landscape Impedes Ethical Science
Testing into compliance is real.
Dry ‐ labbing continues to occur.
Laboratory shopping is at an all ‐ time high.
Collaborative efforts between/among labs may result in creation of unfair playing field. Misunderstanding and mis ‐ application of Measurement Uncertainty and Measurement Bias are used to bolster desired appearance of test results.
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Back to the Future
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• Designer cannabinoids, for example Δ 10, Δ 8 • Do these represent exploitation of regulations? • Are they synthetic or natural? Or both? • How can regulations and the scientific community improve the technical landscape before similar situations become “crises”?
Additional Challenges/Problem Areas
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• Regulatory Bodies that perform their own random/unannounced audits may create adversarial relationship with lab.
• Labs that are required to perform field sampling are not following statistically significant methods.
Additional Challenges/Problem Areas
• “Whistleblowers” may be one lab fabricating or exacerbating issues with a competitor lab.
• Poor technology and poor expertise are rewarded.
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We are making progress.
The regulatory landscape can continue along the path of improvement by utilizing resources.
Summary
Laboratories can continue along the path of improvement by utilizing resources.
CASP will continue to answer the call of regulations by facilitating the development of sound standard test methods that are approved by several teams of experts vetted to the highest standards by AOAC International.
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THANK YOU CASP Progress made possible by Christopher Dent and the entire AOAC Staff
CASP Advisory Panel
CASP Working Group Chairs Holly Johnson Julie Kowalski Julia Bramante Brent Wilson Toby Astill
CASP Working Group Members: MANY from around the world!
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Julie Kowalski Co-chair Cannabis Chemistry Working Group
March 16, 2022 AOAC INTERNATIONAL Annual Meeting
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Cannabis Containing Beverages
• Teleconferences ~2/month • One SMPR completed and approved Determination of Heavy Metals in Cannabis Containing Beverages • Draft published Dec 2, 2021 • Approved in early 2022 • Currently working on one SMPR Determination of Pesticides in Cannabis Containing Beverages
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Determination of Heavy Metals in Cannabis Containing Beverages
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Determination of Heavy Metals in Cannabis Containing Beverages
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Determination of Heavy Metals in Cannabis Containing Beverages
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Determination of Heavy Metals in Cannabis Containing Beverages
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Determination of Heavy Metals in Cannabis Containing Beverages
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Determination of Heavy Metals in Cannabis Containing Beverages
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Determination of Heavy Metals in Cannabis Containing Beverages
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Determination of Heavy Metals in Cannabis Containing Beverages
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Determination of Heavy Metals in Cannabis Containing Beverages
Approved Will be published soon
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DRAFT: Pesticides in Cannabis Containing Beverages
• Teleconferences ~2/month • Matrix Categories • Analyte list and target levels • Rest of SMPR
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DRAFT: Pesticides in Cannabis Containing Beverages • Matrix Categories
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DRAFT: Pesticides in Cannabis Containing Beverages • Matrix Categories
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DRAFT: Pesticides in Cannabis Containing Beverages • Matrix Categories • in process
• guidance on categories (“high fat”) • How to use in validation guidance?
matrix claim specific
require all
require some
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DRAFT: Pesticides in Cannabis Containing Beverages • Matrix Categories • in process
• guidance on categories (“high fat”) • How to use in validation guidance?
matrix claim specific
require all
require some
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DRAFT: Pesticides in Cannabis Containing Beverages • Up Next…pesticides and target levels
Spreadsheet with states/countries Required pesticides and action levels Confirmed for beverage specific regulations
Thank You! Diana McKenzie Richard Middlebrook
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Thank you Any questions?
Julie Kowalski julie@kowalskiscience.com
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Holly E. Johnson, Ph.D.
Chief Science Officer
American Herbal Products Association
16 March 2022
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Product Centric Working Group: Beverages
Quantitation of cannabinoids in beverages SMPR
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Product Centric Working Group: Beverages
Quantitation of cannabinoids in beverages SMPR
0.0002
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Product Centric Working Group: Beverages
Quantitation of cannabinoids in beverages SMPR
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Product Centric Working Group: Beverages
Quantitation of cannabinoids in beverages SMPR
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Product Centric Working Group: Beverages
Quantitation of cannabinoids in beverages SMPR
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Product Centric Working Group: Beverages
Quantitation of cannabinoids in beverages SMPR
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Product Centric Working Group: Beverages
Quantitation of cannabinoids in beverages SMPR
Comment 1: · Include Delta 10 THC as it is gaining attention.
Somewhere include the need to use glass consumables for experimentation as cannabinoids are purported to adhere to plasticware
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Product Centric Working Group: Beverages
Quantitation of cannabinoids in beverages SMPR
Comment 2:
1. I would recommend to consider a LOQ at a lower concentration than 0.002 for the following reason: Consider the example of a 12 oz beverage serving containing 5 mg THC or CBD per serving as may be common in the industry. This beverage contains 0.00147% of the cannabinoid, which is lower than the current LOQ. At a LOQ of 0.002%, a 12 oz beverage would need to contain more than 6.8 mg of THC to avoid reporting as non-detectable. This is not sufficiently low, in my opinion. 2. Likewise the max concentration range of 15% seems too high , because at this concentration a beverage serving size would be 60 mg for a liquid containing 10 mg of a cannabinoid. Also the solubility or dispersibility limits the practical concentration. 3. I don't see that ethanol or hydroethanol tinctures are included in the list of matrices, nor are carbonated water, botanicals or essential oils/terpenes and flavors listed as part of the matrices. Why were these omitted? Considering these may be some the most common interference factors inherent to cannabis drinks, they should be listed in the set of matrices.
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Product Centric Working Group: Beverages
Quantitation of cannabinoids in beverages SMPR
Comment 3:
118 Table 1B. May consider CBL and CBLA cannabinoids.
Nano-emulsion or encapsulated formulations commonly found in infused beverages - likely identified in the sample preparation?
Working closely with the manufacturer for "blank" matrix would be helpful or obtain a commercially available SRM could also assist in determining the success of the method
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NEW - Product Centric Working Group Product category: Beverages
Evaluation of stakeholder needs Testing requirements by State
Priorities: pesticides, residual solvents, microbiology
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Product Centric Working Group: Residual Solvents in Beverages SMPR
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Product Centric Working Group: Residual Solvents in Beverages SMPR
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Product Centric Working Group: Residual Solvents in Beverages SMPR
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Product Centric Working Group: Residual Solvents in Beverages SMPR
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Product Centric Working Group: Residual Solvents in Beverages SMPR
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Product Centric Working Group: Residual Solvents in Beverages SMPR
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Product Centric Working Group: Residual Solvents in Beverages SMPR
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Product Centric Working Group: Residual Solvents in Beverages SMPR
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Product Centric Working Group: Residual Solvents in Beverages SMPR
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Questions?
Holly E. Johnson, Ph.D.
Chief Science Officer
American Herbal Products Association
16 March 2022
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Cannabis & Hemp Proficiency Testing Program
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CASP Proficiency Testing Working Group
(Chair) Dr. Brent Wilson of NIST
(AOAC) Shane Flynn, Senior Director of PT (AOAC) Chad Stephan, Program Coordinator of PT
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Proficiency Testing Working Group (Chair) Dr. Brent Wilson of NIST Working Group Subgroups- each met several times Cannabinoids
Terpenes Moisture Heavy Metals
Mycotoxins Pesticides Residual Solvents Microbials
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Proficiency Testing Working Group Objective Different from other WGs To determine technical requirements needed
Time for analyses Report needs Statistical needs Method Information Equipment information
to develop a proficiency testing program in cannabis/hemp flower based on SMPRs Sample size Reporting units Frequency Specific analytes to report for
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Developed by the stakeholders, for the stakeholders
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Proficiency Testing Program Development What Next? Advisory Task Force Differs from WG Objective of Advisory Task Force
Advisory Task Force has been set up with 11 members Advisory Task Force will start to meet to address any questions that come up during development
The Advisory Task Force will consist of 8-12 volunteers selected by AOAC. The task force will help implement the technical recommendations that have been determined by the subgroups
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Proficiency Testing Program Development Proficiency Testing Website Technical requirements from subgroups used Section for each group of analytes was created Secure and confidential Report Condition of samples upon receipt Safe handling of samples Method information Results SAS statistical software created Z-scores and other statistics Receive final technical report and results Assign reviewer function
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Proficiency Testing Program Development Samples Test Material Provider Finalizing Agreement DEA License Hemp and > 0.3% THC Cannabis Unique Program
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Proficiency Testing Program Development Comprehensive samples Based on feedback Sample 1 Cannabinoids Sample 2 Pesticide residues 6-8 spiked residues
Future analytes Mycotoxins (to be added) Residual solvents (to be added)
Terpenes Moisture Heavy Metals
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Proficiency Testing Development Comprehensive program Potency (cannabinoids, terpenes), moisture, heavy metals and pesticides Potency, moisture, heavy metals Pesticides
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Proficiency Testing Program Development Program process Lab enrolls 30 days prior to a shipment
Labs are notified and reminded of shipment 5-10 days prior to shipment Samples shipped overnight to lab 3 weeks to analyze and report Final technical report and results issued to labs within 30 days of program due date Usually, 2 weeks after due date
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Proficiency Testing Program Development Pilot Round Dried Hemp Flower Matrix 20 labs selected based on criteria Analytes tested for Geographic locations Others Scheduled for May 2, 2022 First Live Round Scheduled for November 2022 Add Mycotoxins and Residual Solvents
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Proficiency Testing Program Future Programs Microbials 1. Salmonella 2. Aspergillus 3. Yeast & Mold 4. E. coli (Shiga Toxin)
Specific Products/Matrices Gummies Chocolate Beverages
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AOAC Has the Tools for Cannabis Laboratories Working Groups SMPR OMA ALACC-new Cannabis Appendix Proficiency Testing
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For More Information Contact AOAC PT Staff Cannabis_PT@AOAC.org
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Update on ALACC Revisions
Susan Audino, PhD
Science Advisor, AOAC CASP
Susan.Audino@gmail.com
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ISO/IEC 17025:2017 has limitations
• Gold Standard for ALL Labs!
• “Beautifully Ambiguous”
• The standard does not require employment of the ‘best science’
• The standard does not guarantee the best or most trustworthy test results
• The standard does not offer strict guidance to mitigate known risks
• AOAC embraced the opportunity to provide some direction/guidance in light of the ambiguity… in the food/feed sector • The challenges are bountiful in this nascent cannabis-testing industry that is operated by young/inexperienced scientists and new/inexperienced business owners
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Analytical Laboratory Accreditation Criteria Committee (ALACC)
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American Council of Independent Labs (ACIL)
www.acil.org/page/About_ACIL
• Trade Association representing independent, commercial scientific and testing laboratories.
• Founded in 1937
• Vision: “Realizing a healthy safe environment for society through the application of unbiased, scientific testing.” • Mission: “Providing the independent testing community with advocacy, education, and alliances to enable members to better address environmental and product risks to the public.”
• Values: “Ethical, Objective and Quality Business Practices”
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Independent Laboratories Institute (ILI)
2018: Guide to a Harmonized National Cannabis Laboratory Accreditation Program (CannaLAP)
Developed by:
o Industry-expert stakeholders
o Laboratory personnel
o Accreditation Bodies
o Regulatory Bodies
“Developed to provide inputs into a consistent approach to each state’s accreditation process by developing the basic quality requirements for the accreditation of laboratory testing of cannabis plant material, cannabis-based products, or hemp across the nation.”
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December 2021 TASK Accepted!
Great Fit with AOAC Mission
and CASP Objectives
Create an ALACC Appendix for Cannabis Labs using the work established by ACIL/ILI
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Experienced Sub-Committee Team
17025:2017 Section 6
Glossary & Nomenclature
17025:2017 Sections 4 & 5
17025:2017 Section 7
17025:2017 Section 8
Special Considerations
Lead: Joe Konshnik
Lead: Shawn Kassner
Lead: Brad Stawick
Lead: Jane Weitzel
Lead: Jane Weitzel
Lead: Matt Sica
Chair: Susan Audino
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Additional Team Members
Chad Stephan , AOAC
Tracy Szerszen , PJLA
Shane Flynn , AOAC
Keith Klemm , ANAB
Sarah Dorris , A2LA
Danny Noe , FDA
Aniko Solyom , Gass Analytical
Leeza Akimenko, PJLA
Heather Krug , CDPHE
Erik Paulson , Infinite Cal
Josh Swider , Infinite Cal
Danielle Houston , PJLA
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Amazing Work Products in Short Time
Glossary & Nomenclature: LOD and LOQ, Cannabis, Marijuana, Hemp, etc. Not always straightforward yet critical to SMPR and Standards. 17025, sections 4 & 5: Specific risks do exist for cannabis laboratories, for example confidentiality is risked every time a lab uses state-required METRC to report test results, or when testing a sample into compliance. Special Considerations: Unique challenges exist for cannabis labs. This section is intended to identify some of the most significant risks. For example: Legal risks to labs and clients on basis of country, state, federal regulations; moisture correction requirements for hemp analysis; and ensuring proper scientific practices. Note: this is not a comprehensive list!
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Next Steps
• ALACC is currently in scheduled 5-year review.
• The Cannabis Subcommittee has compiled information/data that will comprise the Cannabis Appendix in the next ALACC revision. • The draft (Cannabis-centric) document will be available for review by stakeholders within the next 1-2 months. • The required AOAC channels and processes will be followed to integrate that cannabis appendix into the revised ALACC document; document business as usual!
• Our hope is to have a revised ALACC document published within 6-9 months.
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THANK YOU
THANK YOU to all members of the Subcommittee.
Special Appreciation for the Collaboration with ACIL
Susan Audino
Susan.Audino@gmail.com
410.459.9208
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Holly E. Johnson, Ph.D.
Chief Science Officer
American Herbal Products Association
16 March 2022
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A brief history.. Pre-CASP Stakeholder Panel for Strategic Foods Analytical Methods (SPSFAM) Cannabis Working Group SMPRs:
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SMPR 2017.001 Cannabinoids in Cannabis Concentrates
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SMPR 2018.011 Pesticides in Cannabis
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SMPR 2017.002 Cannabinoids in Dried Plant Materials
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SMPR 2017.019 Cannabinoids in Chocolate
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A brief history.. Pre-CASP Stakeholder Panel for Strategic Foods Analytical Methods (SPSFAM) OMAs:
AOAC Official Method 2018.10 Cannabinoid in Dried Flowers and Oil Liquid Chromatographic Method
AOAC Official Method 2018.11 Quantitation of Cannabinoids in Cannabis Dried Plant Materials, Concentrates, and Oils using Liquid Chromatography–Diode Array Detection Technique with Optional Mass Spectrometric Detection
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A brief history.. Pre-CASP Stakeholder Panel for Strategic Foods Analytical Methods (SPSFAM) OMAs:
AOAC Official Method 2018.11 Quantitation of Cannabinoids in Cannabis Dried Plant Materials, Concentrates, and Oils using Liquid Chromatography–Diode Array Detection Technique with Optional Mass Spectrometric Detection
Reported Results on an as-is basis
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Agricultural Improvement Act 2018 (aka the 2018 Farm Bill)
“…any cannabis plant, or derivative thereof, …, that contains not more than 0.3 percent delta-9 tetrahydrocannabinol ("THC”) on a dry - weight basis .
CASP Cannabinoids Working Group:
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Agricultural Improvement Act 2018 (aka the 2018 Farm Bill)
“…any cannabis plant, or derivative thereof, …, that contains not more than 0.3 percent delta-9 tetrahydrocannabinol ("THC”) on a dry - weight basis .
CASP Cannabinoids Working Group:
Definition for “Dry weight basis”:
Dry weight basis: Reported results are mathematically corrected for the amount of moisture present in the sample at the time of weighing.
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Agricultural Improvement Act 2018 (aka the 2018 Farm Bill)
“…any cannabis plant, or derivative thereof, …, that contains not more than 0.3 percent delta-9 tetrahydrocannabinol ("THC”) on a dry - weight basis .
AOAC Official Method 2018.11 Quantitation of Cannabinoids in Cannabis Dried Plant Materials, Concentrates, and Oils using Liquid Chromatography–Diode Array Detection Technique with Optional Mass Spectrometric Detection Reported Results on an as-is basis; Modified 2018.11 to include an LOD procedure so results reported on a dry weight basis
Compliance testing – hemp or not hemp?
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USDA AMS guidance on hemp testing: (https://www.ams.usda.gov/sites/default/files/media/TestingGuidelinesforHemp.pdf)
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USDA AMS guidance on hemp testing: (https://www.ams.usda.gov/sites/default/files/media/TestingGuidelinesforHemp.pdf)
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USDA AMS guidance on hemp testing : (https://www.ams.usda.gov/sites/default/files/media/TestingGuidelinesforHemp.pdf)
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Objective To provide guidance for laboratories in developing standard operating procedures for processing hemp plant materials received fresh from the field (approximate moisture 70-80%) to obtain a moisture content appropriate for grinding (generally <15%) when preparing samples for determining total THC on a dry weight basis, for example when using AOAC 2018.11 or other appropriate methods. Cannabinoids Working Group: Laboratory guidance for drying field-fresh hemp plant samples in preparation for determination of total THC on a dry weight basis
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Cannabinoids Working Group: Laboratory guidance for drying field-fresh hemp plant samples in preparation for determination of total THC on a dry weight basis
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Cannabinoids Working Group: Laboratory guidance for drying field-fresh hemp plant samples in preparation for determination of total THC on a dry weight basis
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Cannabinoids Working Group: Laboratory guidance for drying field-fresh hemp plant samples in preparation for determination of total THC on a dry weight basis
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Cannabinoids Working Group: Laboratory guidance for drying field-fresh hemp plant samples in preparation for determination of total THC on a dry weight basis
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Cannabinoids Working Group: Laboratory guidance for drying field-fresh hemp plant samples in preparation for determination of total THC on a dry weight basis
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Cannabinoids Working Group: Laboratory guidance for drying field-fresh hemp plant samples in preparation for determination of total THC on a dry weight basis
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Cannabinoids Working Group: Laboratory guidance for drying field-fresh hemp plant samples in preparation for determination of total THC on a dry weight basis
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Cannabinoids Working Group: Laboratory guidance for drying field-fresh hemp plant samples in preparation for determination of total THC on a dry weight basis
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Cannabinoids Working Group: Laboratory guidance for drying field-fresh hemp plant samples in preparation for determination of total THC on a dry weight basis
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Many thanks to : Chris Dent, AOAC Susan Audino, AOAC Advisor Dustin Sawyer, Rock River Laboratory, Inc. Frank Sikora, Division of Regulatory Services, University of Kentucky Don Gilliand, G-SQUARED Consulting
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Questions?
Holly E. Johnson, Ph.D.
Chief Science Officer
American Herbal Products Association
28 August 2021
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Laboratory Guidance - Drying Field-Fresh Hemp Plant Samples in 1 Preparation for Determination of Total THC on a Dry-Weight Basis 2 AOAC Cannabinoid Analytical Science Program (CASP) Working Group 3 4
5 6 1.0 Objective 7
The objective of this Appendix is to provide general guidance for laboratories to aid in 8 the development of Standard Operating Procedures (SOPs) appropriate for processing hemp 9 plant materials received fresh from the field. Field-fresh materials typically have a higher 10 moisture content of 70-80% (1) requiring a preliminary drying step to reduce moisture content to 11 a value that is sufficiently low (approx. 15%). Dried, milled samples are needed for requisite 12 sample preparation by appropriate methods including AOAC 2018.11 for the determination of 13 total tetrahydrocannabinol (THC) on a dry-weight basis. 1 1 4 5 2.0 Purpose and Scope 16 This document offers guidance to be used by laboratories to aid in the development of 17 procedures to sufficiently dry field-fresh hemp material. The purpose of the procedure is to dry 18 the material enough to facilitate adequate grinding and homogenization prior to analysis. The 19 scope of this guidance is limited to the initial drying step only and is not intended to be used as 20 the primary procedure used for sample preparation for determination and reporting total THC. 21 Complete sample preparation details are described within published methods such as AOAC 22 OMA 2018.11 (2). 23 In this context, the drying procedure needed and discussed herein is a preliminary step 24 that, while representing an important step to ensuring that sample integrity is maintained, is not 25 intended for use to directly generate final, reportable results for total THC (dry-weight basis). 26 It is critical for laboratories to develop a procedure in such a way that it can be applied in 27 a consistent manner to minimize the introduction of measurement error as well as maintain 28 sample integrity. During procedure development and validation, the laboratory should identify, 29 evaluate and document critical steps and parameters of the final procedure, assess overall 30 performance and address details that produce inconsistencies or errors in the final reported 31 results for total THC (dry-wight basis). This document provides guidance with that 32 documentation. 3 3 3 4
Draft Version 20.6
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3 3 5 6 37 3.0 Introduction and Background – Drying Hemp Plant Materials 38 39 Agricultural Marketing Service (AMS) for determination of total THC (dry-weight basis) in 40 hemp explicitly state that hemp plant samples must be delivered to the testing laboratory as 41 harvested from the field, i.e. in field-fresh condition (3). In this state and immediately post- 42 harvest, the material will have a moisture content of between 70 – 80% and, while the USDA 43 AMS rule does not mandate a specific drying process or procedure it does outline that testing 44 laboratories “remove the majority of water” from hemp material prior to milling and 45 homogenizing. 46 This initial drying step is crucial to the removal enough moisture from the plant material 47 received by the laboratory to facilitate effective grinding and homogenization while not changing 48 the material and possibly introducing analytical error. However, this step is not intended to take 49 the material completely to dryness as it will undergo additional sample preparation prior to 50 analysis for the determination of total-THC (dry weight basis). Rather, the target moisture 51 content after this initial drying step is 10-15%. Moisture content significantly higher than this 52 and the material will not mill properly. Moisture content less than 10% can result from overly 53 aggressive drying and lead to change in cannabinoid profile and should also be avoided. 54 Consequently, the sample drying procedure is intended only to be used in preparing field- 55 fresh hemp plant materials for subsequent regulatory analysis that reports total THC through full 56 decarboxylation of tetrahydrocannabinolic acid (THC-A) or using the approved mathematical 57 calculation for total THC shown below in Eq. (1): 5 5 8 9 Total THC = 0.877 * THC-A + delta-9 THC Eq. (1) 6 6 0 1 62 minimize compromising the sample and introducing analytical error to the reported total-THC 63 Requirements specified by the United States Department of Agriculture (USDA) The drying procedure developed by the laboratory must be carefully crafted in order to
Draft Version 20.6
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