Effective July 1, 2023, adult-use licensees and RO’s must begin utilizing approved cannabis sampling firms for the sampling and transportation of their final cannabis product samples for laboratory testing.
A random, representative number of final products from each lot of cannabis products produced must be tested and will be collected by the sampling firm’s technician. The licensee must not prepare the samples. “How much” or the representative number of samples that the technician collects, depends on the lot size. The Office’s Sampling Quality System Standard (page 4) includes tables with the number of random sample increments for different batch or lot size ranges.
Additionally, the Office issued guidance on 03/17/2023 to address packaging the final product for sale and subsequent to receiving passing results. This is a reminder that the entire lot must be in its ready-to-consume form but does not have to be packaged in final packaging prior to sample collection. The samples collected from a lot must be placed in the final packaging before they can be sent to the laboratory for testing. This can be done at the time of sample collection.
Once the licensee receives passing compliance testing results from the permitted laboratory, the licensee must package the entire lot prior to releasing for retail sale.
A cannabis product batch, or lot, is defined in Part 130 laboratory regulations as a uniquely defined quantity of cannabis product; including pre-rolls, that is uniform in processing, manufacture, and packaging within a concurrent time frame.
Once the entire lot is packaged and there is no remaining final product in bulk storage, the product then can be made available for distribution for retail sale.
The final product, in bulk storage, that has passed all compliance testing must be packaged within 30 days to ensure the quality of the product in accordance with individual standard operating procedures using good manufacturing practices for each product type.
It is the licensee’s responsibility to space out testing of the product to ensure they have the time and resources to package the final product that passes compliance testing within the 30-day allotment.
This guidance can be found in Section 5 of the OCM Laboratory Testing Guidance for AUCC and AUCP Licensees
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The implementation of this requirement offers a range of benefits that are integral to the cannabis sector, including:
With the new requirement, the testing of all cannabis products slated for New York’s cannabis dispensaries will be accurately representative of the overall batch.
By utilizing third-party sampling firms, the results from the sampling and testing processes will be unbiased, further improving their validity.
All samples are securely stored in a fully enclosed box during transport, accompanied by a comprehensive shipping manifest and chain-of-custody documents. These measures minimize the risk of sample contamination.
The new policy cuts back on delivery and sampling costs, freeing up valuable time for your team to focus on more essential tasks.
You will need to schedule your sample pick-up requests three days in advance. This ensures that we can best accommodate your preferred pick-up day and time.
The CannaPort website will facilitate clients in establishing their warehousing setup, making it simple to select where samples will be taken from.
Upon scheduling, CannaPort will arrive at your facility and sample from the requested batches under the supervision of one of your employees.
The samples will be labeled at the time of collection and submitted in the final packaging or equivalent.
The sampling and transport fee will be added to your testing invoice, eliminating the need for additional payment steps.