Cannabis Testing Self-Sampling Guidance

STATE OF NEW MEXICO

MICHELLE LUJAN GRISHAM, GOVERNOR

Linda M. Trujillo, Superintendent

Kristen Thomson, Director

The Cannabis Control Division of the New Mexico Regulation and Licensing Department is providing this guidance

for any cannabis establishment collecting its own samples for mandatory testing (“self-sampling”). The guidance is

based on the Maine Office of Marijuana Policy’s Best Practice Guide for Sample Collection, Version 3 (September

2020). The self-sampling establishment shall follow this guidance and any additional instructions provided by the

cannabis testing laboratory to perform required actions. Each time an employee designated to collect samples (“self-

sampler”) performs this task, another employee is required to witness the collection of samples and sealing of sample

containers.

Planning

Each sampling event must be preceded by a discussion between the establishment and the cannabis testing

laboratory(ies) performing analyses to ensure that the documentation is appropriately completed and necessary

guidance from the cannabis testing laboratory is followed.

Sample Collection Records

An establishment shall use chain of custody forms complying with NMAC § 16.8.2.12 and is responsible for contacting

the cannabis testing laboratory and ensuring that all information required by NMAC § 16.8.2.48(B) is recorded in

required sample collection records.

The self-sampler shall sign a statement attesting that the individual:

•

Collected all samples in accordance with this guidance and any instructions provided by the cannabis

testing laboratory conducting the mandatory analyses;

•

Collected all sample increments randomly and did not intentionally enrich, alter, tamper with, degrade

or otherwise

alter the sample increments collected;

•

Was not asked by, nor allowed, another person to

enrich, alter, tamper with, degrade or otherwise

alter the sample increments

collected;

•

Sealed the sample collection containers with tamper evident seals in the presence

of the witness

countersigning the attestation; and

•

Acknowledges that any intentional misrepresentation in the sample collection

records or any attempt

at tampering with the samples collected is grounds for

revocation,

suspension, or limitation of the

establishment’s license.

The employee acting as a witness shall sign a statement that the individual:

•

Was present for the sealing of the sample containers;

•

Did not witness the sample collector enrich, alter, tamper with, degrade or

otherwise alter the sample

increments when affixing the tamper evident seals to

the sample containers;

•

Did not enrich, alter, tamper with, degrade or otherwise alter the sample

increments;

and

•

Acknowledges that any intentional misrepresentation by the witness is grounds

for revocation,

suspension or limitation of the establishment’s license.

Equipment and Supplies

Appendix B of this guide provides pictures and descriptions of the equipment and tools listed below. The

minimum equipment and supplies for sample collection for mandatory testing are listed in this guide; however, the

cannabis testing laboratory must advise an establishment of the appropriate sample collection equipment necessary

to take a

consistent representative sample of the matrices for which mandatory testing is requested.

A self-sampler may use single use, disposable, or reusable tools and equipment, as appropriate, but must use

sterile equipment and tools for the collection of samples for microbiological testing and must have

procedures

for decontaminating any tools and equipment that are not disposable. The decontamination

procedures must

effectively eliminate carryover by removing any analyte of interest, regardless of the

concentration of the

analyte. The decontamination procedure must ensure no cross contamination

between cannabis, cannabis

concentrate, or cannabis products occurs. This decontamination procedure must be validated any

time there is

evidence of contamination in samples, as indicated by

the cannabis testing laboratory conducting mandatory

analyses. A cannabis testing laboratory will notify the

self-sampler to discuss the process for validating

decontamination procedures if the

cannabis testing laboratory finds evidence that a sample is contaminated by

the use of reusable sample

collection tools.

Equipment (items used repeatedly; must be clean and sterile where applicable)

•

Reusable scoops or spatulas, as directed by the cannabis testing laboratory;

•

Forceps and/or scissors/shears;

•

Field balance (capable of 0.01g measurements, capable of measuring sample weight in

collection container, tare weight; semi-annual calibration verified by certificate of

calibration);

•

Calibrated verification weights appropriate to verify accuracy of field balance;

•

NIST-traceable thermometer or infrared thermometer gun calibrated every 6 months;

•

Cooler or other appropriate refrigeration to maintain collected samples for analysis as

applicable to ensure sample integrity; and

•

Equipment logbook.

Supplies (items used only once; must be clean and sterile, where applicable)

•

Mylar bags, amber jars, borosilicate volatile organic analysis (VOA) vials, Whirl-Pak bags

or equivalent sample collection containers, as directed by the cannabis testing laboratory;

•

Disposable or reusable syringes or pipettes (for liquid transfer);

•

Disposable scoops, dippers, sampling spoons, spatulas, other appropriate tools for

collecting a

sample from a batch;

•

Nitrile, latex, or rubber gloves;

•

Teri-Wipes, or equivalent;

•

Decontamination supplies, as determined by decontamination procedures – bleach, 70%+

isopropyl alcohol, 70%+ ethanol, etc.;

•

Deionized water;

•

Chain of custody labels;

•

Security tamper evident tape or custody seals, as applicable; and

•

Sample labels.

Sample Collection

Equipment Preparation

Prior to sample collection, equipment must be decontaminated (and sterile, as applicable) and inspected

for

damage, then collected and organized into the designated area where the sample collection will occur. All work

areas, contact surfaces, utensils, and equipment shall be washed with isopropyl alcohol (70%+), denatured

alcohol (70%+), bleach (10%+), or equivalent as directed by the cannabis testing laboratory; rinsed with

filtered water; and dried completely prior to sampling

The self-sampler must ensure that all equipment to be used is appropriately calibrated and otherwise

verify that

all equipment used is appropriately prepared to eliminate cross contamination and ensure that

samples are

reliable for analytic purposes. The preparation area must include:

•

Gloves to be worn, to avoid sample contamination;

•

Decontaminated tool(s), including stainless steel spatulas, knives and/or disposable or reusable

pipettes and syringes;

•

Decontaminated surfaces for sample processing;

•

Labels and pens with indelible ink;

•

Necessary supplies for thoroughly decontaminating and drying sample preparation tools and

equipment between samples.

Sample containers shall be decontaminated (and sterile, when applicable) and dry prior to the sample

collection

event. The number of containers, depending on the batch size, and the proper sample size, shall

be collected

and packaged appropriately.

All paperwork shall be populated with pertinent information prior to the end of the sample collection

event.

General Guidelines for Sample Collection

The individual collecting samples for

mandatory testing must:

•

Survey the entire batch from which the samples are to be collected and ensure that the cannabis or

cannabis product is appropriately

labeled and tracked in the track and trace system. Self-samplers may

not collect samples from any batch of cannabis or cannabis product that is not labeled with an

appropriate label containing information generated by the track and trace system and accompanied by a

transport manifest generated by the track and trace system.

•

Use appropriate sample collection equipment and consistently follow this guidance.

•

Take equal quantities of the cannabis, cannabis concentrate or cannabis product for each

sample

increment.

•

Obtain the required number of sample increments, based on batch size, as required by NMAC §

16.8.2.48(B).

•

Record all observations and procedures used while collecting the sample increments in sample

collection records.

Representative Sample

The person

collecting samples for mandatory testing shall check for any signs of non-uniformity, including:

• Different types or sizes of containers;

• Variations in marks and labels;

• Mixed

batch numbers; or

• Differences in in color,

shape, size, or other characteristics.

Variations in the product may indicate nonuniformity in the batch, meaning that any sample collected may not

be representative for testing. Samples from batches appearing nonuniform may be collected and used for

mandatory testing, provided that anomalies are recorded in the sample collection records and indicated in

the

certificate of analysis.

If a

batch appears to be contaminated with a potentially transmissible agent that could affect the

environmental integrity of the cannabis testing laboratory, the establishment shall contact the cannabis testing

laboratory, which may advise the establishment on how to proceed, including providing additional

instructions

for transportation or delivery of such samples. If the cannabis testing laboratory determines that the risk of

contamination is too great for

sample collection to proceed, the cannabis testing laboratory must immediately

contact the division to

apprise it of the circumstances.

Random Sampling

Sample increments must be randomly selected from different locations within a container or set of

containers

which hold the batch to be tested to ensure the representativeness of the samples for mandatory

testing based

upon matrix-type, using the following method:

Assign consecutive numbers to each possible location from which a sample increment can be

collected;

Using a random number generator or other similar means to determine from which numbered

locations random sample increments shall be collected:

▪ Assign divisions based on the type of container in the site-specific sample collection plan.

▪ Use a random number generator with the higher number equal to the number of divisions

for

the container (for multiple containers, use existing or arbitrary order of containers to

assign

numbers to the total of “divisions multiplied by total number of containers” to

determine the

total number of random increments within a container and record in the

chain of custody

form).

Document in the sample collection field log where each sample increment was collected and the

volume collected from each sample collection location.

Examples of random sampling by matrix type are included in Appendix A of this Guide.

Post Sample Collection Procedure

Sample Collection Review

All samples collected shall be verified to the manifest generated by the track and trace system and the

sample

collection form prior to sealing and labeling all sample collection containers.

Equipment and Sample Collection Area Decontamination

The area where the sample collection occurs shall be decontaminated and/or sterilized and dried between

each

batch sampled. Forceps and any additional sample collection equipment shall be decontaminated,

sterilized, and

dried between each batch sampled.

Sample Storage and Retention

Following sample collection and during transport to the cannabis testing laboratory performing the

mandatory

analyses, appropriate storage and retention methods must be employed to ensure the sample

continues to be

representative of the sampled batch.

•

Upon collection, samples must be stored at the same temperature and under the same

environmental conditions from which the samples were collected.

•

Samples shall be stored in a manner to prevent unauthorized access to samples and must be sealed

with

a tamper evident seal that is intact upon receipt by the cannabis testing laboratory.

•

The cannabis testing laboratory must provide guidance to the self-sampler or sample collector to ensure

sample

integrity during transport to the cannabis testing laboratory.

•

Containers for sample transport shall be designed to prevent damage, contamination, spillage, or

commingling of the samples during transport. The required container for sample collection must

appropriate for the sample matrix and the tests required.

Appendix A. Sampling Techniques, by Matrix and Container

The methods demonstrated below were developed by the Maine Center for Disease Control and Prevention. They are provided for

reference purposes and should not be

construed to be the only acceptable method for collecting samples from each matrix

type.

Appendix B. Sample Collection Equipment and Containers.

Sampling Equipment

Sampling Tools

Sample Collection Containers