Cannabis Coaching & Compliance

Avoiding Recalls: Preparing for the What-Ifs

By Maureen McNamara
8 Comments

The best way to avoid recalls from occurring is using preventative strategies like HACCP and GMP’s.

Recalls are a necessary part of our lives, and they occur quite often. There are hundreds of food recalls performed each year. Now we are experiencing recalls in the cannabis industry. It is important to keep in mind that the primary objective of performing a recall is to protect consumer safety.

Welcome to a whole new game!

The Scoop:

A recall occurs to remove defective or potentially harmful products from the marketplace.

Recalls can be expensive and stigmatizing. Companies involved are usually highly motivated to remedy the issue and recover as quickly as possible. It is in the producer’s best interest to do everything in their power to maintain and regain patient & customer confidence and brand trust as soon as possible.

In the United States, food recalls are typically generated by the U.S. Food and Drug Administration (FDA), or by the U.S. Department of Agriculture (USDA) through the Food Safety and Inspection Service (FSIS). Food manufacturers regularly perform mock recalls and, when needed, perform voluntary recalls of possibly contaminated product. Recently, listeria has become a major concern for contamination in the food industry and as a result, many companies are preparing themselves for prevention strategies.

As cannabis is still federally illegal, the FDA does not perform cannabis recalls. As a result, we are seeing local health departments and the state departments of agriculture getting involved in cannabis recalls. Recent recalls are voluntary and are related to potentially dangerous pesticide residue on flower, concentrates and infused products. Colorado has come into the spotlight recently for businesses performing a number of voluntary recalls, in the interest of protecting consumer safety. This January, a recall included “individual units of marijuana concentrates that are used for vaporizing” testing positive for Imidacloprid, Myclobutanil, Etoxazole and/or Avermectin, which are all pesticides determined by the Colorado Department of Agriculture as not usable on cannabis.

How do we know there is a problem?

  • A manufacturer discovers a problem
  • Inspectors reveal a potential issue
  • A product fails a test carried out by a licensed laboratory
  • A state health department may be alerted to an issue

Preparing for the “What- Ifs”

  • What is your crisis management strategy?
  • How will your team communicate the issue with regulators?
  • What is the protocol to recover or destroy recalled product?
  • What is the communication plan with purveyors & consumers?
  • What new structures will be in place to prevent future issues?

How do we avoid a Recall?

Manufacturers and cultivators endeavor to prevent issues in the first place. Good Manufacturing Practices (GMP), Good Agricultural Practices (GAP) and Hazard Analysis and Critical Control Points (HACCP) plans are used to ensure quality and safety during the production process. Mistakes can occur. It is ultimately the manufacturer’s responsibility to remove any possibly contaminated product from the market quickly and before potential damage is incurred.

As we pioneer the cannabis industry, it is important to be as proactive as possible at every step of the supply chain, from seed to the sale of cannabis: Cultivating, trimming, curing, extracting, infusing, producing, packaging, shipping, receiving, storing and selling are all points where safety measures should be in place.

Prevention Rules!

How is your team doing with the following?

  • GAP, GMP & HACCP plans to ensure quality product
  • Testing, TESTING, Testing- to confirm safety of your goods
  • Requiring strict & tested operating procedures from your suppliers
  • Internal quality reviews
  • Training and Accountability

Our desire is that you do not ever need to recover from a crisis, but mistakes happen. They create a learning opportunity for us to make a higher quality product, to strengthen our procedures and to show our consumers that we are committed to excellence.

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Comments

  1. Diane Dulmage

    Good to see that food safety is being incorporated into this industry. Testing is often not utilized by food companies until there is a problem. PS – I hope we can start doing Organic certification for cannabis!

    1. Maureen McNamara

      Hello Diane,
      Yes- we are so happy to see many compliant, professional, responsible businesses choosing food safety training and detailed standards for their operations.
      Thank you for your feedback!

  2. Cody Stiffler

    Maureen,

    Fantastic segment! Hope we can connect at the Cannabis Labs Conference. I will be discussing similar information and how systems like BioTrackTHC’s Government Traceability System integrates these laboratory testing values into the custody chain to assist in ensuring only safe tested products reach shelves. Have a great day and hopefully I will see you at the conference!

    -Cody

    1. Maureen

      Thank you Cody!
      Yes- systems to track cannabis and cannabis products throughout it’s journey are tremendously important. Thank you for the work you do to ensure only lab tasted safe products are getting into consumer’s hands.
      Here’s to wellness!

  3. Erik Janus

    What would be fabulous is ACTUAL risk-based tolerances for pesticide residues on cannabis crops, as determined by EPA through its implementation of FIFRA. That way, when sampled cannabis products turn up “hot” (i.e. positive detection), than an actual risk-based process can be applied. This may result in less recalls due to the fact that minimal residue found that pose minimal to no risk. The current system of “detection = risk” is unsustainable and will continue to keep the market there from the highest degree of quality and certainty. It looks to me that California will develop these well ahead of EPA, per MMRSA legislation. (unless there is removal of cannabis from CSA, in which case EPA could theoretically start working on tolerances the following day…)

    The exciting think about “track and track” prorgams is the (eventual) ability to incorporate both fintech data streams and “big data” analytics to allow the eventual establishment of point-of-sale systems that allow your budtender to suggest strains BASED ON ACTUAL DATA. And not suggestions from Leafly, which leaves a lot to be desired in terms of informed decisonmaking.

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