AOAC CASP Meeting
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AOACTHANKS OUR CASP MEMBERS CASP Pioneers :
• ABCTesting, Inc. • Association of Food and Drug Officials • Bia Diagnostics • BioRad
• PathogenDx • PerkinElmer • R‐BiopharmAG • SCIEX • Supra Research & Development • TEQAnalytical
• BIOTECON Diagnostics • GW Pharmaceuticals • Industrial Laboratories • Materia Medica Labs • MilliporeSigma • SōRSETechnology
• TITANAnalytical • Trilogy Analytical
CASP Affiliates: • Charm Sciences • Crystal Diagnostics • Hygiena • Institute of FoodTechnologists • BIOTECON • Lazarus Naturals • Medicinal Genomics • SC Labs • Emerald Scientific
CASP Partners • CEMCorporation • CV Sciences • Eurofins Scientific • Trace Analytics
AOAC INTERNATIONAL Cannabis Analytical Science Program (CASP) Saturday, September 7, 2019 | 9:00AM – 5:00PM EDT Sheraton Denver Downtown, Grand Ballroom 1
MEETING AGENDA
I. WELCOME, INTRODUCTIONS AND ANNOUNCEMENTS (9:00AM – 9:15AM) David Schmidt, AOAC INTERNATIONAL II. PROGRAM OVERVIEW (9:15AM – 9:45AM) Scott Coates, AOAC INTERNATIONAL III. CONSENSUS BUILDING AT AOAC INTERNATIONAL (9:45AM – 10:15AM) Deborah McKenzie, AOAC INTERNATIONAL
IV. REPORT FROM THE MICROBIAL CONTAMINANTS WORKING GROUP (10:30AM – 11:30AM) Pat Bird, PMB Biotek and Julia Bramante, Colorado Department of Public Health & Environment V. REPORT FROM THE CHEMICAL CONTAMINANTS WORKING GROUP (11:30PM – 12:30PM) Susan Audino, Audino and Associates VI. REPORT FROM THE CANNABOIDS IN CONSUMABLES WORKING GROUP (1:30PM – 2:30PM) Holly Johnson, American Herbal Products Association VII. CHALLENGES IN CHEMICAL CONTAMINANT TESTING AND APHL’S CANNABIS COMMUNITY OF PRACTICE (2:30PM – 2:50PM) Heather Krug, Colorado Department of Public Health & Environment VIII. TESTING CBD PRODUCTS FOR SAFETY AND QUALITY (3:05PM – 3:25PM) Toby Astill, PerkinElmer IX. RESPONSIBLE MICROBIAL TESTING POLICY IN CANNABIS: CHALLENGES AND FUTURE OUTLOOK (3:25PM – 3:45PM) Ben Katchman, PathogenDx X. CBD/THC IN HEMP PERSPECTIVE (3:45PM – 4:05PM) Roy Bingham, BDS Analytics XI. UPDATE FROM INSTITUTE OF FOOD TECHNOLOGIES LEGALIZED HEMP AND EDIBLES (4:05PM – 4:25PM) Rosetta Newsome, Institute of Food Technologists XII. 2020 WORK PLAN PROPOSAL (4:25PM – 4:45PM) Scott Coates, AOAC INTERNATIONAL XIII. SUMMARY/WRAP UP (4:45PM – 5:00PM) Scott Coates & Palmer Orlandi, AOAC INTERNATIONAL
Breaks at 10:15am and 2:50pm, Lunch at 12:30pm 08-26-2019 Version 7 – Subject to Change Without Notice
September 7, 2019 AOAC CASP Meeting – Presenter Bios
AOAC INTERNATIONAL CASP MEETING – SPEAKER BIOS
Toby Astill, Ph.D.
PerkinElmer
Global Marketing Manager for Cannabis & Hemp
Dr. Toby Astill is PerkinElmer’s Global Market Manager for Cannabis & Hemp. Dr. Astill has a Ph.D. in Chemistry and has spent the last 15 years working in Science, Technology and Business Roles for leading technology companies. For the last 8 years he has worked for PerkinElmer, based in locations across the West Coast of Canada & the US. Dr. Astill is now focused on driving PerkinElmer's global cannabis and hemp business; including but not limited to new product development, market & industry research, collaborations with customers, application development and marketing initiatives.
September 7, 2019 AOAC CASP Meeting – Presenter Bios
Susan Audino, Ph.D
Audino & Associates
Owner
Dr. Susan Audino is a chemist/chemometrician and independent consultant to chemical and biological laboratories. On behalf of Accreditation Bodies, she assesses laboratories to and is an instructor for multiple ISO/IEC standards such as ISO 17025. She is recognized as a leader in the cannabis industry, focusing on consumer safety and sound science in the development of official and consensus analytical test methods. Susan serves as a scientific advisor to several scientific organizations, regulatory bodies, and sits on expert review panels. Dr. Audino has chaired the AOAC cannabis advisory panel and currently chairs the chemical contaminants working group, and is a board member for the Center for Research on Environmental Medicine. She has provided seminars, workshops, webinars, and facilitated symposia domestically and internationally.
September 7, 2019 AOAC CASP Meeting – Presenter Bios
Patrick M. Bird, M.S. PMB BioTek Consulting LLC Owner
Pat has been an active member of the food safety community for the last 15 years serving in numerous roles including manufacturing and laboratory management before starting his own consulting business in 2018. Pat spent extensive time as the supervisor of a R&D laboratory where he oversaw the development and validation of rapid diagnostic methods for microbiology, allergens and mycotoxins. As a consultant, Pat continues to work with method developers, laboratories and industry to optimize method performance and testing workflow. In December 2018, Pat joined AOAC INTERNATIONAL as a technical consultant, where he works on the development of validation outlines for the Performance Tested Methods SM (PTM) and Official Method of Analysis SM (OMA) processes. Pat has been an active member within AOAC INTERNATIONAL for over 12 years, serving on the AOAC Research Institute Board of Directors and as the microbiology community lead for AOAC’s Technical Programing Council. Pat has authored and co-authored over 40 peer reviewed publications and has presented over 15 OMA validations to the Microbiology Expert Review Panel as part of the OMA First Action submission process. Pat is a member of A2LA’s Laboratory Accreditation Council, and actively participates in many working groups including ASTM D37 on Cannabis , ASTM E35 on Pesticides, Antimicrobials and Alternative Control Agents , IAFP’s Applied Laboratory Methods working group on method validation and verification and two working groups in US ISO/TC34/SC9 Food Microbiology: WG3 for Method Validation and WG19 Guidelines for conducting challenge studies. Pat holds a BS in Microbiology from the Ohio State University in Columbus, Ohio and a MS in Food Safety from Michigan State University in East Lansing, MI.
September 7, 2019 AOAC CASP Meeting – Presenter Bios
Julia Bramante, Ph.D.
Colorado Department of Public Health and Environment Lead Scientist
Julia began her career in the cannabis industry in 2014 at Gobi Labs, one of the first cannabis testing facilities to open in Colorado. She then transitioned to the Colorado Department of Public Health and Environment’s Marijuana Reference Laboratory where she currently serves as Lead Scientist. Julia is also the Chair of the Cannabis Chemistry Subdivision of the American Chemical Society and the Co-Chair of the AOAC CASP Microbial Contaminants Working Group.
September 7, 2019 AOAC CASP Meeting – Presenter Bios
Scott Coates, M.S.
AOAC INTERNATIONAL Senior Director of the AOAC Research Institute
Scott was appointed as the Senior Director of the AOAC Research Institute on July 1, 2018. He is responsible for daily management of and business development for the AOAC Research Institute. Scott also serves as the Program Lead for the Cannabis Analytical Science Program. Scott served as the Chief Science Office from 2009 until June 2018. In this capacity, he served as the technical lead for many AOAC projects. Scott led the writing and development of Appendix F in the Official Methods of Analysis of AOAC INTERNATIONAL that describes validation requirements and the development of Standard Method Performance Requirements . Before joining AOAC, he worked for 10 years as the Operations Manager for an in-vitro diagnostic manufacturer making medical test kits such as Strep tests and specialized bacterial culture media. Scott holds a B.S. in Microbiology (1978) and a M.S. in Biotechnology Management (1994) from the University of Maryland. Contact Scott at: scoates@aoac.org , (301) 924-7077 x137
September 7, 2019 AOAC CASP Meeting – Presenter Bios
Benjamin Katchman, Ph.D.
PathogenDx Principal Scientist
Dr. Katchman leads the research and development of sample preparation and assay development at PathogenDx, a Scottsdale, AZ based company which provides disruptive DNA-based pathogen testing technology and solutions for the cannabis, botanical, food and agricultural industries. Previously, Dr. Katchman spent worked with various universities and small companies developing novel nucleic acid and proteomic approaches for biomarker discovery and molecular diagnostics. This includes the development of plate-based and microarray-based diagnostic systems for use in clinical laboratories and point-of-care diagnostics for Arizona State University, FlexBioTech, Inc., and Eccrine Systems, Inc. Prior to joining PathogenDx, Dr. Katchman was a Principle Investigator at Eccrine Systems, Inc. where he led all clinical research, regulatory pathway implementation, assay development, and biomarker studies. He was the co-founder of FlexBioTech, Inc., where he led the development of novel OLED-based molecular diagnostic assay platforms. Dr. Katchman received a B.S. in Microbiology, from Indiana University in 2005, then carried out graduate research with Prof. Douglas F Lake at Arizona State University where he was the first to identify QSOX1 as a proto-oncogene and novel tumor biomarker resulting in over $2M in funding and multiple patents. He performed his postdoctoral research with Prof. Karen S Anderson and Prof. Joshua LaBaer where he designed novel high-density protein microarrays and novel clinical and point of care diagnostics utilizing flexible OLED based electronics resulting in over $15M in funding, multiple patents and high-impact publications.
September 7, 2019 AOAC CASP Meeting – Presenter Bios
Holly Johnson, Ph.D.
American Herbal Products Association
Chief Science Officer
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 Pharmacopeia’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 Pharmacopeia. 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.
September 7, 2019 AOAC CASP Meeting – Presenter Bios
Heather Krug, M.S.
Colorado Department of Public Health and Environment State Marijuana Laboratory Sciences Program Manager
Heather Krug is the State Marijuana Laboratory Sciences Program Manager for the Colorado Department of Public Health and Environment. She oversees inspections of Colorado retail/medical marijuana laboratories for compliance and suitability for certification, and is responsible for the state Marijuana Reference Laboratory. Heather holds a Bachelor of Science degree in Biomedical Sciences and a Master of Science degree in Forensic Toxicology.
September 7, 2019 AOAC CASP Meeting – Presenter Bios
Rosetta Newsome, Ph.D.
Institute of Food Technologists Director of Science, Policy & Scientific and Regulatory Affairs
Rosetta Newsome, Ph.D., is Director of Science, Policy & Scientific and Regulatory Affairs at the Institute of Food Technologists (IFT). Dr. Newsome is involved in developing content generated by the Science & Policy Initiatives team and guiding and participating in IFT’s scientific and regulatory affairs. She also leads IFT’s engagement in Codex, serves as a scientific and technical resource, and provides guidance in government relations and public policy activities. She has substantial experience in grant and contract activities, and extensive experience working with a variety of entities. She is a member of the American Association for the Advancement of Science, American Chemical Society, International Association for Food Protection, and Sigma Xi, as well as IFT. Rosie received her bachelor’s degree from Kentucky State University and master’s and doctoral degrees, focused on food science, from the University of Kentucky. The Institute of Food Technologists (IFT) is a global organization of nearly 17,000 individual members from more than 100 countries committed to advancing the science of food. Since 1939, IFT has brought together the brightest minds in food science, technology and related professions from academia, government, and industry to solve the world’s greatest food challenges. IFT works to ensure that members have the resources they need to learn, grow, and advance the science of food as the population and the world evolve. IFT believes that science is essential to ensuring a global food supply that is sustainable, safe, nutritious, and accessible to all.
Scott Coates Senior Director
AOAC Research Institute AOAC INTERNATIONAL
September 7, 2019
Cannabis-Related AOAC Standard Method Performance Requirements (SMPR) • SMPR 2017.001 Cannabinoids in Cannabis Concentrates • SMPR 2017.002 Cannabinoids in Dried Plant Materials • SMPR 2017.019
Cannabinoids in Chocolate • SMPR 2018.011 Pesticides in Cannabis
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Cannabis-Related AOAC Official Methods of Analysis
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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Cannabis Analytical Science Program (CASP) • AOAC decided to create a full-time, dedicated program to cannabis analytical science in 2018. • CASP to include all of AOAC’s programs:
• SMPR • OMA • Performance Tested Methods
• Laboratory Proficiency Testing • Publications (Journal) • Meetings
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CASP Objectives • Facilitate a forum where the science of cannabis analysis is discussed with international experts. • Facilitate the development and publication of cannabis and hemp- specific methods and standards. • Develop cannabis and hemp reference materials.
• Establish a cannabis and hemp proficiency testing program in accord with International Standards. • Provide analytical and laboratory management training, in particular ISO accreditation training. • Provide resources and education to regulators responsible for establishing rules and laws around cannabis and hemp.
Current CASP Projects Microbiology in Cannabis • Initial focus on Aspergillus . Cannabinoids in Consumables
• Initial focus on cannabinoids in hemp plant materials. • Recommendation on reporting total THC (THC + THCA ) • Recommendation on dry weight. Chemical Contaminants in Cannabis • Review Target Limit of Quantitation for pesticides. • Residual Solvents in Cannabis 5
2019 CASP Work Plan (as of Sept. 7, 2019)
Click Here For Work Plan
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Advisory Panel
• composed of CASP supporting organizations • annual membership (Pioneer, Partner, Affiliate)
CASP Pioneers: ABC Testing, Inc.
PathogenDx PerkinElmer
Association of Food and Drug Officials (AFDO)
• meets by web-conference quarterly • agenda-setting & priority-ranking
Bia Diagnostics
R-Biopharm AG
Bio-Rad
SCIEX
GW Pharmaceuticals Industrial Laboratories Materia Medica Labs MilliporeSigma SōRSE Technology
Supra Research & Development TEQ Analytical Laboratories
Titan Analytical Trilogy Analytical
2019 CASP Advisory Panel – 30 Member Organizations Web-conferences: • February 14, 2019 (Midyear Meeting planning) • April 9, 2019 (workplan finalization, confirmation of working groups) • August 5, 2019 (Annual Meeting planning)
CASP Partners: CEM Corporation
Eurofins Scientific Trace Analytics
CV Sciences
CASP Affiliates: Charm Sciences Crystal Diagnostics
Lazarus Naturals Medicinal Genomics
Hygiena
SC Labs
Institute of Food Technologists (IFT)
Emerald Scientific
BIOTECON Diagnostics
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Advisory Panel – Looking Forward
Sept 2019 CASP Meeting Receive community feedback on 2019 deliverables, and future work
Oct 2019 CASP Advisory Panel Call Endorsement of DRAFT 2020 workplan
Oct – Dec 2019 Renewal & Recruitment of 2020 Advisory Panel Members Confirm membership and identify potential new stakeholders
Dec/Jan 2020 CASP Advisory Panel Call Workplan finalized based on funding commitments (potential to add deliverables/working groups)
Mar 2020 AOAC Midyear Meeting Receive community feedback, evaluate workplan progress
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Targeting cannabis- and hemp specific standards and/or methods of analysis such as: • potency • pesticide residues • biological contaminants • chemical contaminants including select mycotoxins
• untargeted testing profiles • method validation guidelines
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Contacts Scott Coates, MSBTM CASP Program Lead Senior Director AOAC Research Institute scoates@aoac.org 301-924-7077 x137 Jonathan Goodwin, , SHRM-SCP, SPHR Deputy Executive Director & Chief HR Officer AOAC INTERNATIONAL jgoodwin@aoac.org 301-924-7077 x104 Palmer A. Orlandi, Jr., Ph.D. Deputy Executive Director and Chief Science Officer AOAC INTERNATIONAL
Christopher Dent Manager, Standards Development & Official Methods of Analysis® AOAC INTERNATIONAL cdent@aoac.org 301-924-7077 x119. Alicia Meiklejohn Governance and Business Development
AOAC INTERNATIONAL ameiklejohn@aoac.org 301-924-7077 x101
porlandi@aoac.org 301-924-7077 x163.
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2019 CASP Work Plan (as of September 7, 2019)
Individual meetings with Advisory Panel members, experts. Advisory Panel meeting to identify priorities. Organize CASP Meeting in Gaithersburg, MD. First CASP Meeting March 12 th . (A/V, catering)
Jan to March
Finalize 2019 program (timetable and budget) and review with Advisory Panel. Recruit Microbiology Working Group Chair. Populate working groups
April 1 to April 15
Convene working groups to: 1) select specific topics; 2) initial development of SMPR; and 3) identify meetings for AOAC participation. Three separate conference calls. Six conference calls per working group to develop SMPR. Total of 18 conference calls. Possible attendance at cannabis meetings. FDA public hearing, IFT and AFDO.
April 15 to April 30
May 1 to July 15
Public review of draft SMPRs. Attendance at cannabis meetings.
July 15 to Aug 15
Reconcile comments and prepare final daft SMPRs. Advisory Panel Conference Call
Aug 15 to Sept 1
CASP Meeting in Denver. Adopt 3 SMPRs. Select 2 nd set of topics for working group.
Sept 7
Advisory Panel Conference Call.
Three conference calls per working group to develop SMPR.
Oct to December
Total of 9 conference calls.
3 calls for methods.
Develop initial 2020 program and confirm participation.
Legend
= completed; = in‐process ; and = future tasks.
AOAC Standards Development
Approval of AOAC Standards & Consensus Documents
Deborah McKenzie Sr. Director, Standards & Official Methods SM AOAC INTERNATIONAL
ANALYTICAL AOAC Products, Services, and Analytical Excellence
Standards & Methods Development
A Complete & Harmonized Quality System Through
Official Methods of Analysis SM (OMA) & Performance Tested Methods SM (PTM)
Laboratory Proficiency Testing & Quality Systems
Analytical Excellence
Publications, Training, Educational Outreach & Horizon‐scanning
Standards Drafting Overview
Working Group Meets
• Draft
standard
• Public
Post draft standard
Comment Period (≥ 30 days)
Reconcile Comments
• Recommend final draft to CASP
AOAC Standard Development Process
Consensus
US National Technology Transfer and
Advancement Act (PL 104‐ 113) and OMB Circular A‐ 119
Defensibility
Acceptability
Examples: AOAC Consensus Products
Basic Principles
• Transparency • Openness • Balance of Interests • Due Process • Consensus • Appeals
• Performance Requirements • Guidelines
• Sampling Standards • Methods of Analysis • Best Practices • Operational Documents
AOAC Consensus & Products
CASP Standards Development Activity
Initial CASP meeting and launch of 3 working groups with a proposed an outline for each working group March 2019 – AOAC Midyear Meeting
July ‐ August 2019
Comments on draft standard method performance requirements Comment period for all 3 documents began on July 2019 through August 16 2019. Online Open Comment Session held on August 12, 2019
Deliberate and reach consensus on a final versions of the documents WG chairs will present summaries of draft document for deliberation and consensus. September 7, 2019
Working groups developed draft documents: Working groups met to begin their work and continued drafting documents via web conference April– July 2019
To Date – Opportunities to Participate Balance of Perspectives & Due Process
TARGETED COMMUNICATION
INVITATIONS TO SMES
EMAIL BLASTS & WEBSITE NOTIFICATIONS
PARTICIPATION IN MEETINGS – AOAC AND EXTERNAL MEETING
ASSOCIATION NEWS ARTICLES
ONLINE & WRITTEN ‐ PUBLIC COMMENT FORMATS
BRIEFINGS & PUBLIC HEARINGS
Global Perspectives Included
Contract Research Laboratories Independent Contractors US Rule Makers Academia Commodity Producers Product Manufacturers Instrument & Technology Providers State Regulators and Laboratories Reference Material Organizations Proficiency Testing Programs Trade Organizations Scientific Associations Rapid Method Developers Accreditation Organizations
Approving the Draft Standards
Program Lead and Standards Manager will oversee the approval process
STEP 2 : Program Lead will conclude deliberation and Standards Manager will record and verify with WG chair(s) any revisions, if needed
STEP 1: WG chair(s) introduced to present the draft standard along with how comments were reconciled followed by discussion on the draft standard
STEP 3 : After final revisions are complete, the WG chair will make a motion for approval of the standard and a second to the motion may be entertained, but is not necessary
STEP 4: Program lead will acknowledge the motion (and second, if offered) and offer time for discussion/questions on the motion.
STEP 5: After any due discussion, Program Lead will all for a vote on the motion.
STEP 6: Standards Manager will walk attendees through the electronic balloting process. All attendees will be able to participate in the vote
NOTE: 2/3 vote in favor of a motion will pass a motion. 2/3 of those voting will demonstrate consensus in passing a motion
Documentation and Communication
AOAC carefully documents the actions of CASP and the Working groups
AOAC will prepare summaries of the meetings Communicate summaries to the stakeholders Publish status and summaries in the Referee section of AOAC’s Inside Laboratory Management Publish documents in Journal of AOAC INTERNATIONAL, Official Methods of Analysis of AOAC INTERNATIONAL
Roles and Responsibilities
Establish working groups to develop standards & consensus documents Comment, deliberate, and establish voluntary consensus standards
Stakeholder Panel
Develop draft standards & consensus documents Reconcile comments Present draft standard to stakeholders
Stakeholder Panel Working Groups
Official Method Board
Provide process oversight and review
Coordinate stakeholder panel, working groups, and facilitate their meetings Document actions/decisions of working groups and program meetings Post draft standards, collect comments, and publish approved standards
AOAC Staff
Questions?
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Patrick Bird & Julia Bramante Co-Chairs, CASP Microbial Contaminants Working Group Working Group Presentation
September 7, 2019 Sheraton Denver Downtown 1550 Court Place, Denver, CO, 80202
CASP Microbial Contaminants: Working Group Members AldwinAnterola, Southern Illinois University Carbondale NathanHordyk, Industrial Laboratories
MikePfaller,University of Iowa
TobyAstill,PerkinElmer
ChrisHudalla, ProVerdeLaboratories
Melissa Phillips, NIST
SusanAudino, S.A.Audino&Associates
KristenHypes,Mile HighLabs Ron Johnson,BioMerieux
AlenaRodriguez,Rm3Labs Yvonne Salfinger,AFDO Nandakumara Sarma,USP
BrianBeck,Microbiologics
Cornelius Berka,BIOTECONDiagnostics
JuanRodriguez,GreenHillsAnalytics Lab
PatBird,PMBBioTek
BenKatchman,PathogenDx
EdwardSawicki,Think20Labs Rachel Shegog,SoRSETechnology
Rafael Bombonato,Curaleaf KyleBoyar,Medicinal Genomics
JasonKircos,Neogen
JulieKowalski,TraceAnalytics Jasen Lavoie, U.S.CannabisPharma Quynh‐Nhi Le,NeogenCorporation
CaseySimmons,Hygiena
JuliaBramante,CDPHE
Sidney Sudberg,Alkemist Labs
Roger Brauninger,A2LA (accreditation body)
SungOuiSuh,ATCC
RobertBrodnick, TitanAnalytical MikeClark,BioRad Laboratories
Raymundo Lerma,Phytatech
ChristySwoboda,Romer Labs, Inc.
Cynthia LeVesque,Caligreen Laboratory Kyle Lorenzen,Young Living EssentialOils
KatherineThomas,NJDepartmentofHealth AnandThota,Vivariant Laboratories Michael (Bhodi) Tims,Radix Medicina, LLC
BobClifford, Shimadzu
Danielle Deschene, SC Laboratories
EvaLynch,RockRiver Laboratory
LoriDodson,Maryland Medical CannabisCommission KevinMcKernan,Medicinal Genomics
TriciaVail, SartoriusCorporation
Wilfredo Dominguez,3M
MeganMurn,Microbiologics
GordonVrdoljak,StateofCADeptofPublicHealth
JanieDubois,ContractAnalytical Services
MariaNelson,AOAC
ChristopherWaggener,VirginiaDCLS
TedGatesy,MDARD
DustinNewman, Instituteof FoodSafety&Defense
MatthewWard,CDPHE
StephenGoldman,PhytaTech
GaryNiehaus,CrystalDiagnostics Melissa Nutter,TitanAnalytical
JaneWeitzel, Independent Consultant
BridgettGraham,OrganaKannalytics
DanielWene,New JerseyDepartmentofHealthPHEL
Bradford Haskell,DesignGroupCollaborative
ShawnO'Leary,NJDOH ShaunOpie,E4Bioscience BenOrsburn,Think20Labs
AnnaWilliamsWilliams,A2LA
DarinHayakawa,HawaiiDOH
SethWong,TEQAnalytical Laboratories
YvonneHelbert,Medicinal Genomics
VictoriaWu,ABCTesting&MateriaMedica Labs
ShannonHoffman, SteepHill
JessPaoletti,TEQAnalytical Labs
JoshuaWurzer,SCLaboratories
ShermanHom,NJDOH
SalvatoreParisi,AlBalqaApplied University
ChristineYeo,NaturalProductsAssociation WendiYoung,MileHigh Labs JessaYoungblood,HardyDiagnostics
Microbial Contaminants Working Group: Work To Date
• Eight teleconferences (April 2019 – August 2019) • One SMPR drafted • Public comment period (June – July, 2019) • SMPR made ready for review and approval
SMPR Development
Standard Method Performance Requirements ® (SMPRs) for Detection of Aspergillus in Cannabis and Cannabis Products Applicability: Candidate methods used to detect Aspergillus ( Aspergillus niger, Aspergillus fumigatus, Aspergillus flavus, and Aspergillus terreus ) in cannabis (plants/flowers) and/or cannabis products (concentrates, infused edibles and infused non‐edibles). Candidate methods may be validated for specific matrices, categories or broader claims.
Aspergillus species • A common mold that produces spores that become airborne. • The spores are easily spread through air currents and are found in most environments, both indoors and outdoors. • Most people breathe in the spores everyday without getting sick. • People with weakened immune systems are at a higher risk of developing aspergillosis. • Infections start in the lungs and can quickly lead to infection. Infections can be serious and sometimes fatal.
• Aspergillus contaminates cannabis flowers and plants. • Individuals who consume cannabis through smoking are at higher risk for infection
Definitions • POD, Probability of Detection.— The portion of positive analytical outcomes for a qualitative method for a given matrix at a given analyte level or concentration • dPOD CP – This difference in POD values between presumptive and confirmed results • LPOD – The POD value obtained from combining all valid collaborator data sets for a given matrix at a given analyte level or concentration • LCL, Lower confidence limit.— Calculated to determine 95% confidence interval of various POD values • UCL, Upper confidence limit.— Calculated to determine 95% confidence interval of various POD values • CFU, Colony forming unit.— Number of viable microorganisms, presented per a specific quantity. (ex. CFU/mL) • MPN, Most probable number.— Method used to estimate contamination levels
Method Performance Requirements
Table 1. Validation Acceptance Criteria (Plants/Flowers, Concentrates, Infused Edibles, Infused Non‐Edibles)
Parameter Requirements
Target Test Concentration a
Parameter
Minimum Acceptable Results
Single Laboratory Validation with artificial contamination
Low level to produce fractional positive results Ex. 0.2‐2 CFU/Test Portion High level to produce consistently positive results Ex. 2‐10 CFU/Test Portion 0 CFU/Test Portion
Fractional positive results, 25‐75% (5‐15 positive test replicates) dPOD CP 95% CI: LCL < 0 < UCL b
Replicates per matrix: 20 Inoculation procedure: AOAC Appendix J
Fractional Concentration (low level)
Replicates: 5 Inoculation procedure: AOAC Appendix J
High Concentration
POD of 1.00 c
Non‐Inoculated (Zero) concentration
Replicates: 5
POD of 0.00 c
Single Laboratory Validation with natural contamination
Fractional positive results, 25‐75% (5‐15 positive test replicates) for minimum 1 lot dPOD CP 95% CI: LCL < 0 < UCL b
Acceptable minimum detection level (low level)
2 separate lots of 20 replicates
N/A
Method Performance Requirements
Table 1. Validation Acceptance Criteria (Plants/Flowers, Concentrates, Infused Edibles, Infused Non‐Edibles)
Parameter Requirements
Target Test Concentration a
Parameter
Minimum Acceptable Results
Multi Laboratory Validation
0.15 ≥ LPOD ≥ 0.85
12 replicates
1‐10 CFU/Test Portion
95% CI: LCL < 0 < UCL b
dPOD CP
LPOD
12 replicates
10‐50 CFU/ Test Portion
LPOD ≥ 0.95
12 replicates
0 CFU/Test Portion
LPOD ≤ 0.05
LPOD (0)
a Determined through MPN Procedures (see Table 4) b The range between the lower and upper confidence interval should encompass 0, if not, the results must be investigated, and an explanation provided. c If acceptance criteria is not observed, results must be investigated, and an explanation provided.
Method Performance Requirements
Table 6. Inclusivity/Exclusivity Performance Requirements
Final Test Concentration (CFU/mL)
Minimum Acceptable Results
Parameter
Parameter Requirements
Inclusivity Single‐laboratory validation (SLV) study: At least 10 strains per required Aspergillus spp. (reference Annex I) cultured by the candidate method enrichment procedure. A minimum of 50 strains is required. Exclusivity SLV study: At least 30 non‐target organisms, (including those required in Table 8), cultured under optimal conditions for growth b
10‐100 x limit of detection of the candidate method
100%positive results a
Overnight growth undiluted
100%negative results a
a. 100% correct analyses are expected. All unexpected results are to be retested following internationally recognized guidelines (ISO 16140, AOAC OMA Appendix J, The Compendium of Analytical Methods of Health Canada). Some unexpected results may be acceptable if the unexpected results are investigated, and acceptable explanations can be determined and communicated to method users b. In instances where an exclusivity culture produces a positive result by the candidate method, the culture may be reanalyzed after culture following the candidate method enrichment procedure. Both results (optimal growth conditions and candidate methodenrichment) must be reported.
Method Performance Requirements
• Bulk inoculation of test material is required. • One matrix must contain microflora at 10x the level of the target microorganism. • MPN analysis to determine concentration of target microorganism. Use of matrix study replicates is encouraged.
• Use of live (viable) cultures and/or fungal spores (liquid stressed/non- stressed, lyophilized) is required. • To screen samples for the presence or absence of the target analyte, two methods that employ different technologies (agar plate, PCR, ELISA) must be used. • Extended primary enrichment (up to at least 48 total hours) followed by plating of the sample to a minimum of two different types of agar plates.
Method Performance Requirements
Table 2. Category Test Portion Requirements
Table 3. Acceptable Matrix Claims
Minimum Test Portion Size a
Criteria
Category
Matrix Claim
Plants & Flowers
10 g
Number of Matrices Minimum Number of Categories
15 (minimum 3 matrices/category) ≥ 10 (minimum 2 matrices/category)
Concentrates
5 g
Broad Range
4 categories
Infused Edibles
25 g
Variety
4 categories 2 categories 1 category 1 category
Infused Non‐Edibles 10 g a Minimum test portion size required for validation. Alternatively, larger test portions may be validated.
Select
≥ 5 ≥ 5 ≥ 1
Specific Category Specific Matrix (s)
Comments Submitted
The definition for acceptable minimum detection level does not align with the final version presented in ISO 16140‐1. No minimum detection level has been set as a requirement; therefore this definition has been removed from the document. Table 1 has been modified to emphasize the low contamination level should produce fractional positive results. This aligns the SMPR with Appendix J. After spores, more descriptive language regarding the state of the inoculum (liquid stressed/non‐stressed, lyophilized) has been added parenthetically. The SMPR has been updated to the following: At the time of the publication, no national reference standard method exists for the confirmation of Aspergillus from cannabis products. The SMPR has been updated to: Until a suitable reference method is established the following is recommended for method developers. The SMPR has been updated to change probably to probable.
Line 34: The entire 90% confidence interval on the POD falls above 0.95.
Line 154: Add additional details regarding condition of culture for inoculation Line 165: Suggestion to replace word "standard" with "method" Line 166: Replace "until one" with "until a suitable reference standard method ... Line 190: "probable" not "probably"
Comments Submitted Line 190: Add "Which if possible, should include the replicates run in the validation study"
See Next Comment for change made regarding Line 190
Line 191: Right before "See appendix" please add a new statement, if possible, regarding the use of matrix study test portions in the MPN study.
The following sentence has been added to the SMPR: If possible, the use of test portions included in the matrix study should be included as a level in the MPN study. Contamination levels have been modified to be broader and not as prescriptive. AMDL has been changed to Fractional Concentration (Low Level) in column one. The minimum acceptance criteria has been reworded to be more straightforward: Fractional positive results 25‐75% (5 to 15 positive test replicates). No change to the dPODCP criteria as it matches Appendix J Table 1 has been updated to indicate 12 replicates are required for each contamination level for an MLV
Method performance table: Review the number of CFUs and dPOD in AMDL
Method Performance table: Include the number of test replicates per contamination level for the MLV
Comments Submitted
Table 5 ‐ Conditions of inoculating culture needs more details
Additional details have been added to describe the inoculating cells state prior to inoculation (ex. Liquid non‐stressed) Table 6 has been updated to indicate ‐ Minimum # of strains (50) needed to test for inclusivity; Final test concentration of inclusivity organisms has been changed to 10‐ 100x the LOD of the candidate method. Requirement for exclusivity cultures to be grown in non‐selective media (and not following candidate method enrichment process) has been added. A footnote has been included to reference that positive exclusivity strains may be recultured following the candidate method enrichment procedure and analyzed a second time. Both sets of data will be reported. All changes align the SMPR with Appendix J Use of confidence intervals for inclusivity and exclusivity testing is not established in international validation guidelines. ATCC strains have been kept in the table, but a footnote indicating that the strains are recommended due to previous misidentification as one of the four target strains. Alternative strains for the same genus/species may be substituted
Table 6 Inclusivity does not align with Appendix J.
Table 6 Inclusivity: Use of POD and 95% CI to determine acceptance criteria
Table 8: Remove ATCC designations
Motion: Move to accept the Standard Method Performance Requirements ® (SMPR ® ) for Detection of Aspergillus in Cannabis and Cannabis Products as presented.
Discussion?
DRAFT AOAC SMPR 2019.XXX; Version 5; August 22, 2019 1 2 Method Name: 3
Standard Method Performance Requirements for Detection of Aspergillus in
4 5 6
Cannabis and Cannabis Products
Intended Use : 7 8 1. Purpose: AOAC Standard Method Performance Requirements SM (SMPRs) describe the minimum 9 recommended performance characteristics to be used during the evaluation of a method. The 10 evaluation may be an on‐site verification, a single‐laboratory validation, or a multi‐site collaborative 11 study. SMPRs are written and adopted by AOAC stakeholder panels composed of representatives from 12 industry, regulatory organizations, contract laboratories, test kit manufacturers, and academic 13 institutions. AOAC SMPRs are used by AOAC expert review panels in their evaluation of validation 14 study data for method being considered for Performance Tested Methods SM or AOAC Official Methods 15 of Analysis SM and can be used as acceptance criteria for verification at user laboratories. [Refer to 16 Appendix F: Guidelines for Standard Method Performance Requirements , Official Methods of Analysis 17 of AOAC INTERNATIONAL (2019) 21 st Ed., AOAC INTERNATIONAL, Rockville, MD, USA.] Consensus‐based Reference method. Candidate methods used to detect Aspergillus ( Aspergillus niger, Aspergillus fumigatus, Aspergillus flavus, and Aspergillus terreus) in cannabis (plants/flowers) and/or cannabis products (concentrates, infused edibles and infused non‐edibles). Candidate methods may be validated for specific matrices, categories or broader claims. See Table 3 for matrix/category claim acceptance criteria. 2. Applicability :
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3. Analytical Technique :
Any analytical technique that meets the method performance requirements is acceptable.
4. Definitions :
Candidate Method . — The method submitted for validation [Appendix J: AOAC INTERNATIONAL Methods Committee Guidelines for Validation of Microbiological Methods for Food and Environmental Surfaces , Official Methods of Analysis of AOAC INTERNATIONAL , (2019) 21 st Ed., AOAC
INTERNATIONAL, Rockville, MD, USA]
Candidate Method Presumptive Result . —Preliminary result for a test portion produced by following
a candidate method’s instructions for use.
Candidate Method Confirmed Result . —Final result obtained for a test portion after cultural
confirmation of a candidate method.
Cannabis .—genus of flowering plants within the Cannabinaceae family that commonly contain 9‐ tetrahydrocannabinol (THC), cannabidiol (CBD), and other cannabinoids and terpenes. Cannabis
includes, but is not limited to, high‐THC and high‐CBD cultivars.
Cannabis Concentrates . —Extracts (primarily composed of cannabinoids and/or terpenes) manufactured through the extraction and concentration of compounds derived from the cannabis plant or flower. Final products can be many forms including oils, wax, or hash (Category II).
49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95
Cannabis Infused Edibles .—Food and drinks containing extracts of cannabis and/or cannabis
materials (Category III).
Cannabis Infused Non‐Edibles .—Products containing extracts of cannabis and/or cannabis materials intended to be applied to the human body or any part thereof. Final products can be many forms
including creams, ointments, cosmetics and therapeutic pads (Category IV).
Cannabis Plant and Flower . —General terms for the structural and flowering unadulterated parts of
the cannabis plant (Category I).
Cannabis Products .—Products (Edible, and non‐edible) extracted or infused with compounds derived
from the cannabis plant including but not limited to CBD and THC.
Probability of detection (POD) .—The portion of positive analytical outcomes for a qualitative method for a given matrix at a given analyte level or concentration. This difference in POD values between
presumptive and confirmed results is termed dPOD CP .
Exclusivity .—Study involving pure nontarget strains, which are potentially cross‐reactive, that shall be not detected or enumerated by the candidate method. See Table 8 for a list of recommended nontarget strains. [Appendix J: AOAC INTERNATIONAL Methods Committee Guidelines for Validation of Microbiological Methods for Food and Environmental Surfaces , Official Methods of Analysis of AOAC INTERNATIONAL , (2019) 21 st Ed., AOAC INTERNATIONAL, Rockville, MD, USA] Fractional positive .—Validation criterion that is satisfied when an unknown sample yields both positive and negative responses within a set of replicate analyses. The proportion of positive responses should fall within 25 and 75% and should ideally approximate 50% of the total number of replicates in the set. A set of replicate analyses are those replicates analyzed by one method. Only Inclusivity .—Study involving pure target strains that shall be detected or enumerated by the candidate method. See Table 7 for a list of recommended target strains. [Appendix J: AOAC INTERNATIONAL Methods Committee Guidelines for Validation of Microbiological Methods for Food and Environmental Surfaces , Official Methods of Analysis of AOAC INTERNATIONAL , (2019) 21 st Ed., Laboratory probability of detection (LPOD) .—The POD value obtained from combining all valid collaborator data sets for a method for a given matrix at a given analyte level or concentration. [Appendix H: Probability of Detection (POD) as a Statistical Model for the Validation of Qualitative Methods , Official Methods of Analysis of AOAC INTERNATIONAL , (2019) 21 st Ed., AOAC one set of replicates per matrix is required to satisfy this criterion. AOAC INTERNATIONAL, Rockville, MD, USA]
INTERNATIONAL, Rockville, MD, USA]
LCL .—Lower confidence limit.
Aspergillus .—Filamentous, cosmopolitan and ubiquitous fungus found in nature producing colonies typically of 1‐9 cm in size (select species produce 0.5‐1 cm colonies). Colonies are powdery in texture and color varies based on species. Reverse color is typically uncolored to pale yellow. Growth is typical
96 97 98 99
at 20‐30 o C. Aspergillus fumigatus is thermotolerant and can grow at a temperature range of 20 to 50 °C. For all species, hyphae are septate and hyaline. The conidiophores originate from the basal foot cell located on the supporting hyphae and terminate in a vesicle at the apex. Vesicle is the typical formation for the genus Aspergillus . The morphology and color of the conidiophore vary from one species to another. Covering the surface of the vesicle entirely (“radiate” head) or partially only at the upper surface (“columnar” head) are the flask‐shaped phialides which are either uniseriate and attached to the vesicle directly or are biseriate and attached to the vesicle via a supporting cell, metula. Over the phialides are the round conidia (2‐5 µm in diameter) forming radial chains. Other microscopic structures include sclerotia, cleistothecia, aleuriconidia, and Hulle cells are of key importance in identification of some Aspergillus species. Cleistothecium is a round, closed structure enclosing the asci which carry the ascospores. The asci are spread to the surrounding when the cleistothecium bursts. Cleistothecium is produced during the sexual reproduction stage of some Aspergillus species. Aleuriconidium is a type of conidium produced by lysis of the cell that supports it. The base is usually truncate and carries remnants of the lysed supporting cell. These remnants form annular frills at its base. Hulle cell is a large sterile cell bearing a small lumen. Similar to cleistothecium, it is associated with the sexual stage of some Aspergillus species. See Table 9 & 10 for more
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macroscopic and microscopic information on Aspergillus species.
Chen, S.C.A., Meyer, W., Sorrell, T.C. , Halliday, C. L. (2019) in Manual of Clinical Microbiology , 12th Ed, Landry, M.L., McAdam, A.J., Patel, R., & Richter, S.S. (Eds)ASM Press, Washington, D. C., ,
pp. 2103‐2131.
Anaissie, E.J., McGinnis, M.R., Pfaller, M.A. (2009) in Clinical Mycology , Ed 2, Churchill
Livingstone, New York, NY, pp 1‐687.
Walsh, T.J., Hayden, R.T., Larone, D.H. (2018) in Larones Medically Important Fungi: A Guide to
Identification , 6 th Ed, ASM Press, Washington, D.C., pp. 1‐500
Test portion . —The test portion is the sample size used in most validation studies. For cannabis flower/plant and cannabis infused non‐edible products a 10 g test portion is used. For cannabis concentrates, a 5 g test portion is used. For cannabis infused edibles, a 25 g test portion is used. A larger test portion can be used in validation studies when appropriate. See Table 2 for minimum test
portion requirements.
United States Pharmacopeia. Microbiological Examination of Nonsterile Products: Microbial
Enumeration Tests (61), USP 40. United States Pharmacopeia.
United States Pharmacopeia. Microbiological Examination of Nonsterile Products: Tests for
Specified Microorganisms (62), USP 40. United States Pharmacopeia.
Feng, P., Weagant, S.D., Grant, M.A., Burkhardt, W. (2017) Bacteriological Analytical Manual:
Chapter 4 Enumeration of Escherichia coli and the Coliform
Bacteria https://www.fda.gov/Food/FoodScienceResearch/LaboratoryMethods/ucm064948.htm Andrews, W. H., Wang, H., Jacobson, A., Hammack, T. (2018) Bacteriological Analytical Manual
Chapter 5: Salmonella
https://www.fda.gov/Food/FoodScienceResearch/LaboratoryMethods/ucm070149.htm
UCL . —Upper confidence limit.
5. System suitability tests and/or analytical quality control:
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