Me Medica cal Ma Marijuana Te Testing Advisor Advisory Council - - PowerPoint PPT Presentation
Me Medica cal Ma Marijuana Te Testing Advisor Advisory Council - - PowerPoint PPT Presentation
Me Medica cal Ma Marijuana Te Testing Advisor Advisory Council Council October 24, 2019 Councils Charge A.R.S. 36 2821(B) The MMJ Testing Advisory Council shall make recommendationsregarding: Establishing a required testing
Council’s Charge
A.R.S. §36‐2821(B)
The MMJ Testing Advisory Council shall make recommendations…regarding:
- Establishing a required testing program
- Testing and potency standards
- Procedural requirements for collection, storing,
and testing
- Reporting results to patients and the department
- Remediation and disposal requirements
Review of timeline and steps for lab certification
Lab Certification Process
- Administrative Review (30 days)
○ NOD or Notification of Admin Complete ■ Lab has 90 days to respond to an NOD
- Substantive Review (60 days)
○ RFI ■ Lab has 10 days to respond to an RFI ○ Inspection ■ SOD and POC
Review of current lab testing practices – Tabitha Hauer
Discussion/recommendations of testing and potency standards
NOTE: The following slides are intended as a starting point for Council discussion based on information presented at the initial Council meeting on 9/26/19.
Key Discussion Points
- What parameters should be tested for within
each category?
- What is the safety level before a product must
be remediated or disposed?
- What test method options should be used?
Considerations for Discussion
- Statutory intent is to detect “unsafe levels” and
confirm potency
- What framework should guide setting action
levels? Variable? Protective for children? For immunocompromised?
- Consider requiring existing methods OR in-
house developed methods meeting method criteria of previously validated methods
Microbial Contamination
- E. coli Considerations
Microbial Contamination
Aspergillus Considerations
- Option: Test for Aspergillus flavuus, fumigatus,
niger, terreus
○ If positive, product cannot be sold
OR
○ If positive, product cannot be sold in an inhalable form
- Option: Do not test; label inhalables with a
warning that they may contain Aspergillus
Microbial Contamination
Methods
- Use Bacteriological Analytical Manual (FDA
2013a) and validated by AOAC Appendix J
Microbial Contamination
Additional Discussion Microbial Contamination
- Any other parameters for testing?
- Any other method options for testing?
Heavy Metals
Considerations
- Varying limits based on method of consumption
○ Inhalable ○ Other
- Any FDA/USP or in-house developed method
that is validated by AOAC Appendix K and can meet the method criteria from the EPA methods
Heavy Metals
Metal Limit (ppm) Method Inhalable Other Arsenic 0.2 1.5
Any FDA/USP
- r in-house
developed method that is validated by AOAC Appendix K and can meet the method criteria from the EPA methods
Cadmium 0.5 0.5 Lead 0.5 0.5 Mercury 0.1 3.0 Chromium 0.6 2.0
Heavy Metals
Additional Discussion
- Any other parameters for testing?
- Any other method options for testing?
Heavy Metals
Pesticides, Fungicides, Herbicides, Growth Regulators
Considerations
- Utilize Oregon’s list of parameters plus at least
- ne herbicide.
- Utilize Oregon’s safety limits and the USP
limits for herbicides.
- Utilize any AOAC or in-house developed
method that is validated by AOAC Appendix K and can meet the method criteria from the EPA methods.
Pesticides, Fungicides, Herbicides, Growth Regulators
Oregon List and Limits
Pesticides, Fungicides, Herbicides, Growth Regulators
Additional Discussion
- Any other parameters for testing?
- Any other method options for testing?
Pesticides, Fungicides, Herbicides, Growth Regulators
Residual Solvents
Considerations
- Utilize Oregon’s list of parameters
- Utilize Oregon’s safety limits
- Any EPA, AOAC, or in-house developed
method that is validated by AOAC Appendix K and can meet the method criteria from the EPA methods
Residual Solvents
Oregon List and Limits Residual Solvents
Additional Discussion
- Any other parameters for testing?
- Any other method options for testing?
Residual Solvents
Potency Potency
Considerations
- Create an Arizona cannabinoid list that
includes the acid forms: THCa, CBDa, CBCa
- Test the cannabinoid list by AHP or in-house
methods that are validated by AOAC Appendix K and can meet the method criteria from the EPA methods
Potency
Additional Discussion
- Set limits for THC, CBD, and/or CBC levels?
- Any other method options for testing?