AOAC CASP Meeting Minutes, March 2020

Dent provided a presentation on behalf of Deborah McKenzie who was unable to attend. He reviewed AOAC’s products and services, including Standards and Methods Development, Proficiency Testing Services, Publications, and Official Methods o Analysis and Performance Tested Methods. He explained that the basic principles of AOAC’s programs are transparency, openness, balanced interests, due process, consensus, and appeals. Examples include performance requirements, guidelines, sampling standards, methods of analysis, best practices, operational documents. AOAC achieves this through targeted communication, invitations to subject matter experts, email blasts, participation in meetings, association news, public comment periods and public hearings. He then reviewed the past year’s timeline of the CASP program’s standard development activity, which included development of three (3) new SMPRs by the three (3) working groups, which would be put forward to the group later during this meeting. Dent also advised that there were not enough CASP participants present at this meeting to constitute a quorum so the votes today will be simply to recommend SMPRs be moved forward to an e-ballot, which will be sent to the entire CASP community. Update on the USDA Domestic Hemp Program – Kerry Smith, USDA AMS Smith provided a presentation on the USDA Domestic Hemp Production Program. She described the mission of the USDA Agricultural Marketing Service – to facilitate the marketing of U.S. agriculture products while ensuring fair trading practices and promoting a competitive and efficient marketplace to the benefit of producers, traders and consumers of U.S. food. The U.S. Domestic Hemp Production Program is part of their Specialty Crops Program. She advised that the 2018 Farm Bill removed industrial hemp from the controlled substances act and directed USDA to develop a domestic production program and establish a federal plan for producers. She explained that the interim final rule (IFR) was published in 2019 and the comment period was extended to January 2020 to allow the USDA to get input on the rule. Key provisions of the IFR are procedures for tracking where hemp is grown, procedures for testing total THC, procedures for disposal of plants, and compliance provisions. The IFR also includes sampling provisions and testing provisions. Next steps will be for USDA to approve state and tribal plans, review applications from producers, develop a system to share information with law enforcement, and to process comments submitted to IFR. Further, the comment period will be reopened after the 1 st growing season to ask what has been learned and how things can be improved. Smith then reviewed the analytical challenges involved, such as calculation on a dry weight basis, standardization of sample processing, what other methods besides LC and GC may be useful, what constitutes a ‘representative’ sample and how to clearly define total THC. In conclusion she emphasized that the USDA AMS is eager to receive input from the community by way of expertise and general feedback. Attendees were advised to visit ams.usda.gov/rules-regulations/hemp or to email farmbill.hemp@usda.gov with questions. During a follow up discussion the following issues were addressed: the need for reference materials and/or proficiency testing materials, the need for resolution over the ‘conversion factor’ issue, guidance required regarding the use of proficiency testing programs, and a request on clarity of language regarding the definition of THC then talking about concentrations of THCA and Δ - 9 -THC versus total THC.

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Predecisional Draft, Do Not Distribute

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