By Lori Kanter
•
October 9, 2022
There is a need for USP standards for cannabis to be accepted by the medical community it must conform to the same standards and regulations as any other medicine. Cannabis must be tested so patients know what they are using, providers know what to recommend, and product labels need to be accurate. Currently, there is no federal oversight or regulatory control, instead, the laws governing the testing of cannabis have been left up to the states. Some states have very stringent controls in place while others do not, which has put the consumer at risk. Consumers and patients expect quality to be inherent in the products they use, and poor-quality control procedures can lead to adverse events and increased health risks. These standards could also provide access to quality materials for use in clinical trials. These trials are needed to demonstrate the safety and efficacy of cannabis.1 The United States Pharmacopeia (USP) is a scientific nonprofit organization that plays a role in developing and formulating standards for medicines, dietary supplements, and foods based on expert advice from the medical and scientific community. 1 Once the USP determines there is a need for guidance, methodology, or standards for a new industry, product, or process they produce a draft standard and guidance document. Once the draft is approved the monographs, chapters, and other standards are published in the Unites States Pharmacopeia-National Formulary (USP-NF). 2 Monographs are documents that explain the expectations for a food, drug, or material to ensure its identity, purity, strength, and performance. Monographs contain the chemical information for the ingredient or material and outline the tests and procedures that must occur to meet quality criteria and limit impurities. General chapters provide information on accepted processes, tests, and methods to support industry in product development and manufacturing quality controls. General chapters must be referenced in a specific monograph to be enforceable on a legal basis. 2 The 1938 Food Drug and Cosmetic Act decreed that all medicines sold in the United States must meet USP quality standards. USP standards are enforced by the FDA. Since cannabis is a Schedule 1 drug and is illegal at the federal level, USP has not created a formal official compendium. 2,3 Cannabis first appeared in the 1850 edition of the United States Pharmacopoeia and the Extractum Cannabis monograph was published. In 1916, USP published the Cannabis americana monograph. In 1936 USP published an additional monograph, USP XI. Cannabis was removed from the pharmacopeia in 1940.3 With the reemergence of cannabis as a medicinal product, the goal of the USP is to ensure the quality of cannabis intended for medical purposes. It is imperative for public safety that the USP develop standards to address laboratory verification of cannabis identity, quantitative analysis of cannabinoids and terpenes, and measures to limit exposure to contaminants such as mycotoxins, pesticides, and heavy metals.2 One of the first challenges the USP had to address was how to classify the various varieties and subtypes of the plant product. USP has divided the plant material into three main chemotypes based on the amount of THC and CBD present. These three classifications are, THC dominant, CBD dominant, or intermediate containing both THC and CBD. 1,2This classification system is needed since brand names associated with strain names such as Sativa or Indica can be misleading. 1There can be considerable variation in cannabinoid content among specimens of the same strain and the total THC and CBD levels of a given chemotype can be profoundly affected by cultivation methods, processing, and storage conditions. These factors can be altered to produce strains with higher THC levels.3 USP recommends the use of science-based analytical procedures to identify cannabis varieties. These techniques include high-performance liquid chromatography (HPLC) and gas chromatography (GC) to separate and quantify THC, CBD, and 11 other cannabinoids that may have therapeutic potential.1,3 Reference materials or physical standards currently produced by USP can be used to confirm the identity of various cannabinoids by chromatographic techniques. 1,2 Different cannabis varieties can also vary in the composition of terpenes. USP identified five different terpenes that are abundant in cannabis and recommends profiling these terpenes via separate GC procedures. These detailed profiles of cannabinoid and terpene content can help guide prescribers and ensure patients that they are receiving a consistent product.1 USP standards establish guidelines to ensure safety and create analytical limits for possible contamination from pesticides, heavy metals, mycotoxins such as aflatoxin, and adulteration. One of the most cited reasons for the recall of cannabis products was the contamination of products with pesticides due to exceeding state limits or the presence of restricted pesticides.2 Since cannabis is classified as a schedule one drug, there are no federally approved crop protection agents, this is regulated at the state level. With the absence of legal guidance, growers have used pesticides not intended for use with food or medicinal crops. The US Environmental Protection Agency regulates pesticides for food crops but there is no specific tolerance or exemption for cannabis. 1 The USP maximum acceptable exposure limits for each pesticide are 1000-fold lower than the acceptable daily intake established by the Food and Agriculture Organization of the United Nations and the World Health Organization. Also, the nature and extent of risk could differ for a smoked or vaporized product compared to dietary exposure. USP general chapter articles of botanical origin establish pesticide limits based on acceptable daily exposure, body weight consumed, and a safety margin for oral exposure that can be used for the development of pesticide residue standards for inhaled cannabis materials. Cannabis is a concentrator of heavy metals which then accumulate in the plant and pose a health risk. There have been several product recalls that have occurred due to elevated levels of heavy metals 2Potential sources of elemental impurities include environmental pollutants, manufacturing, processing, and delivery sources. There are no federal testing requirements for heavy metals but rather is regulated at the state level. Most states test for four metals, cadmium, arsenic, lead, and mercury but this is not sufficient. There is a need for a federally regulated list of possible elemental containments that should be tested, instead of the patchwork of testing that currently exists at the state level. USP has several chapters on heavy metal limits and testing, which could be applied to cannabis. 2,4 Cannabis plants are susceptible to microbial contamination including molds especially Aspergillus fumigatus and mycotoxins such as aflatoxins during cultivation, harvesting, drying, storage, and/or distribution. Aspergillus spores can survive when cannabis is smoked or vaporized and can subsequently infiltrate the lungs causing infections resulting in respiratory injury which may be fatal for patients with a weakened immune system. Currently, there is no validated test for Aspergillus. There are USP chapters that address standards for monitoring microorganisms and aflatoxins which can be applied to create limits and methodologies for cannabis.1,3 There is also a need for quality standards for medical cannabis that ensures the identity purity and strength of cannabis to reduce the possibility of adulteration. Cannabis has been mixed with synthetic analogs to increase its psychotropic effect. USP has recently addressed this issue with the development of a new general chapter, Adulteration of Dietary Supplements with Drug and Drug Analogs. This approach could be used to develop cannabis standards to detect this type of adulteration. 3 There is also a need to establish guidelines addressing the potential exposure to toxic solvents used to prepare cannabis extracts. Exposure to these solvents poses a significant health risk. USP has developed procedures and general approaches described in the general chapter Residual Solvents that could be applied to address this risk in cannabis products.1,3 Without the availability of references standards produced by the USP it would be difficult to ensure that products available to a consumer are of the appropriate identity, strength, quality, purity or consistency. These standards are used in pharmaceutical development and manufacturing. To ensure that references materials produced by USP meet the highest standards they are evaluated by multiple independent laboratories. 5 Reference standards help to confirm accuracy and reproducibility in testing, they are required so analytical procedures accurately identify and measure the content of constituents in a material. Reference standards may also be used for qualitative applications such as identification tests, system suitability tests, or chromatographic peak markers. 6 The USP produces cannabis reference standards for medicinal cannabis which provide for the consistent characterization of cannabis for medical use. These references standards are used in analytical procedures to verify the identity and determine the constituents of product samples. The USP has developed multiple compounds including USP Delta-Tetrahydrocannabinol 1 mL (l mg/mL), USP Exo-Tetrahydrocannabinol 1 mL, USP cannabinoid Acid Mixture 1 mL (in acetonitrile and triethylamine with stabilizer, USP Cannabinoids Mixture 1 mL (in methanol), USP Cannabidiol Solution 1mL (lmg.ml) and USP Cannabidiol 25 mg. These reference standards can be used for the quantitative measurement of cannabinoids which is vital in the determination of potency. 7 References 1. Eisenstein M, Muldoon Jacobs KL. Cannabis for Medical Use: Consistent Quality to Help Protect Patients. USP. https://cdn2.hubspot.net/hubfs/3402974/USP%20%7C%20Cannabis%20for%20medical%20use%20consistent%20quality%20to%20help%20protect%20patients.pdf Accessed November 12, 2020. 2. Atkins PL. Everything Old is New Again: Cannabis Returns to USP. Cannabis Science and Technology. June 2020;3(5):17-22 https://www.cannabissciencetech.com/view/everything-old-new-again-cannabis-returns-usp 3. Giancaspro GI, Kim NC, Venerna J, et al. The Advisability and Feasibility of Developing USP Standards for Medical Cannabis. In Pharmacopeial Forum 2016;42(1). https://www.uspnf.com/sites/default/files/usp_pdf/EN/USPNF/usp-nf-notices/usp_stim_article_medical_cannabis.pdf Accessed November 12, 2020. 4. Thomas BF, ElSohly MA. Chapter 4: Analytical Methods in Formulation Development and Manufacturing. Thomas BF, ElSohly MA, eds. The Analytical Chemistry of Cannabis: Quality Assessment, Assurance, and Regulation of Medicinal Marijuana and Cannabinoid Preparations. Elsevier; 2015:63-82. 5. USP Reference Standards. https://www.usp.org/reference-standards Accessed November 14, 2020 6. Sarma, ND, et al, Cannabis Inflorescence for Medical Purposes: USP Considerations for Quality Attributes. Journal of Natural Products. 2020; 83(4):1334-1351 https://dx.doi.org/10.1021/acs.jnatprod.9b01200 7. Cannabis References Standards https://www.usp.org/dietary-supplements-herbal-medicines/cannabis Accessed November 14, 2020.