Tag Archives: best practices

Cannabusiness Sustainability

Dear Cannabusiness Community

By Olivia L. Dubreuil, Esq., Brett Giddings
2 Comments

Dear Cannabusiness Community,

You may have read our two recent articles. We received so much positive feedback that Aaron Biros (editor-in-chief of Cannabis Industry Journal) has invited us to continue with our own column at CannabisIndustryJournal.com. We are very happy to launch this column, and we thought we would take this opportunity to introduce our project, our vision and ourselves so you can understand where we are coming from when you read this series of articles.

Brett and I both have a background in business sustainability and corporate responsibility. We both have backgrounds in management consulting, with a specific expertise in sustainability issues along the supply chain. We have been working together for almost nine months now on sustainability issues in the Bay Area. In May, we started to get interested in sustainability in the cannabis industry and before we knew it we were diving deep into research relating to the environmental, social and ethical impacts of the legal cannabis industry. It was actually difficult to find a lot of information, as the reign of prohibition still very much influences what is available.cannabusiness

In June, we attended the National Cannabis Industry Association’s conference in Oakland to open up the conversation with cannabis industry players and to find out about people’s attitudes and approach to sustainability. The results were overwhelmingly positive. Not only were we encouraged to launch a project, but also excited to discover that many of the speakers presenting at the conference referenced sustainability in one way or another when they talked about environmental impact awareness, social justice, ethics or about staying competitive when “big business” enters the market.

What started out as a side project quickly became the center of focus this summer when we decided to incorporate Project Polaris, a California non-profit, to deliver sustainability knowledge and expertise to the cannabis industry.

Our thinking is as follows:

Thinking about sustainability, means thinking strategically about business. As we forge a new and upcoming industry, let’s seize the opportunity to make it a sustainability-focused one! Let’s create generally accepted industry principles that fosters a positive image of the industry and teaches newcomers about best environmental and social practices. Let’s create a voluntary and industry-led socially responsible code of conduct for cannabis business owners and suppliers, helping the regulators, as they will be drafting all of the future regulations of the legalized cannabis market. Let’s do more research on the market and the consumer. Let’s develop clean and green alternatives to dirty processes or practices. Let’s elevate the discussion and create a model industry, one where short-term, large-scale, quality-lowering corporate interests are kept at bay.

With this vision in mind, we created Project Polaris because we believe that this is a real opportunity for the industry to be a role model for other industries (and educate legislators as well as drive public opinion in those states that are still under prohibition laws). We believe there is a real economic opportunity for those businesses that understand how to embed sustainability properly within their business model. Because we know that sustainability influences legislators in a positive way because it sheds a positive light on businesses.

In the upcoming months, we will continue to research and report on sustainability-related issues facing the cannabis industry, such as packaging, edibles, “organic” in cannabis, butane extraction versus CO2 extraction and so on. We also welcome questions from our readers. If you have a question, please post it in the comments section below.

We will also take this opportunity to call out to cannabis industry organizations, cannabis businesses, or cannabis related services and product suppliers to get in touch with us if they wish to find out how to integrate sustainability more concretely into their action plan. We are not planning on doing this alone, we are seeking partners to join us on this journey, and we want to partner with you on your journey to Cannabusiness Sustainability.

PS: We still have one seat open for the board of directors and would love to hear from you if you are interested!

OGanalytical instruments.

New Cannabis Lab Rules In Oregon Aim to Curb Fraud

By Aaron G. Biros
No Comments
OGanalytical instruments.

The Oregon Health Authority (OHA) recently implemented a set of temporary rules effective through June 28th of this year with the goal to establish a set of regulations for cannabis testing by October 1st. An investigation by The Oregonian highlighted some of the previous problems with cannabis testing in the state.

The most impactful rule changes include The NELAC Institute (TNI) mandatory standards for laboratories that the Oregon Environmental Laboratory Accreditation Program (ORELAP) will use to accredit labs. Initial rules in the Oregon medical cannabis program, HB 3460 from 2013, did not specify accreditation rules for cannabis testing.

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The OG Analytical laboratory in Eugene, Oregon is working to comply with new regulations, including new sample collection rules

ORELAP currently performs accreditation for lab testing under the Clean Air Act, Clean Water Act, Resource Conservation and Recovery Act and the Safe Drinking Water Act. The new cannabis testing rules will give ORELAP the authority to accredit and regulate cannabis labs in the state of Oregon.

Rodger Voelker, Ph.D., laboratory director of OG Analytical in Eugene, OR, believes these rules are monumental in establishing legitimacy in cannabis testing. “These new rules have major repercussions mainly because they require not only getting accreditation, but maintaining it with very strict requirements,” says Voelker. “That also includes procedural guidelines that very carefully outline the quality of laboratory practices and establishes a set of criteria for method validation.”

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Rodger Voelker, lab director at OG Analytical laboratory

Voelker notes that two of the biggest changes are in quality control and data management. “The documentation they require is very thorough and strict with the idea that any aspect of an analysis can be replicated,” adds Voelker. “This is a real win for us in my opinion because now we have an agency that can issue the appropriate credentials as well as have the authority to make punitive measures.”

The timeline for implementation with temporary rules allows state regulators to work with laboratories to perform accreditation and bring laboratories up to speed. According to Shannon Swantek, ORELAP compliance specialist, products that dispensaries sell in medical and recreational markets are required to be tested under the new rules and in the analyte lists by an ORELAP accredited laboratory, starting on October 1st.

Swantek’s job is to accredit cannabis labs to the TNI standards, which is essentially very similar to ISO 17025, just with more prescriptive measures and the ability to pair with state agencies to enforce rules after accreditation. “The timeline for accreditation is dependent on how ready the lab is and how compliant they are to the TNI standard already,” says Swantek. “The culture had gotten so fraudulent that the legislature felt Oregon needed some serious, more strict rules in place.”

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Labs need very expensive instruments to perform all of the testing required by OHA

One of the biggest changes coming to Oregon cannabis testing is the new sampling requirement. “An accredited laboratory employee must take the sample because sampling is where a lack of training or outright fraud is skewing results, which occurs when a grower brings in a sample not representative of the batch,” adds Swantek. Sample preparation methods will also be required to be more robust to meet the action limits of pesticide testing in particular, helping to identify lower levels like parts-per-billion, according to Swantek.

Reports were also lacking key information in the past. The new rules will require more information such as the procedure used, the analyst carrying it out, dilution factors and any other information you need to theoretically reproduce the result. This will result in more accurate labels on products.

Many are concerned that the new lab testing requirements will raise the price of testing too much. In reality, those current prices are not realistic for accurate data, which points to the rampant fraud that ORELAP is trying to eradicate. “The old rules were written in such an ambiguous way that the prices were set by laboratories without a proper quality program or even without proper instrumentation,” says Swantek.

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OG Analytical had to close its doors briefly to meet accreditation

The accreditation process will require particularly robust quality control systems in labs. “Accreditation to the TNI Standard means that lab quality systems will require a documentation system, training procedures, record keeping, personnel requirements, organization details, proof of no conflicts of interest and corrective actions if noncompliant,” adds Swantek. “We single out each method or procedure, look at their raw data and proficiency testing and determine if they are meeting the technical requirements.”

According to Voelker, other industries have learned to adjust their costs with stringent lab testing rules. “I get that no one wants to pay more for lab testing, but the reality is that joining the world of commodities comes with additional costs to ensure consumer safety,” says Voelker. These rule changes will undoubtedly bring more consistency to Oregon’s cannabis industry with accurate lab testing and help the OHA shed more light on issues surrounding consumer safety.

Ask the Expert: Straight Talk on Safety, Defense and Security, Part II

By Aaron G. Biros, Bruce E. Lesniak, Lezli Engelking
1 Comment

In this week’s Straight Talk on Safety, Defense and Security, we answer a reader’s question about traceability in quality processes and offer some practical advice for building a safety and security strategy. Travis Lodolinsky from Gleason Technology submitted this week’s question. For a response, we sit down with Lezli Engelking, founder of the Foundation of Cannabis Unified Standards (FOCUS), to help answer your questions. If you have questions about safety, defense and security in cannabis, please ask them in the comments section below and we will address them in the next edition of Straight Talk on Safety, Defense and Security.

T. Lodolinsky: How are safety processes being tracked in the industry to ensure regulations and quality assurance are being uniformly enforced throughout?

Lezli Engelking: In related industries, such as herbal products or pharmaceuticals, the FDA has created guidelines, or current good manufacturing processes (CGMP) that control for the quality, consistency and safety of the products being produced. Businesses must be certified by independent third parties to demonstrate they are following CGMP to protect public health and consumer safety. CGMP is a proactive approach to quality assurance. A basic tenant of CGMP is that quality cannot be tested into a product after it is made; quality must be built into the product during all stages of the manufacturing process. One common misconception is that CGMP only covers the process of manufacturing itself. CGMP actually covers all aspects of the production process including materials, premises, equipment, storage, staff training and hygiene, how complaints are handled and record keeping.

Because cannabis is federally illegal in the US, the FDA has not developed cannabis-specific CGMP guidelines, so lawmakers do not have the benefit of having those guidelines available to base regulations on. So to answer your question, state cannabis regulations do not track processes and procedures used by cannabis businesses to control for safety or quality because they do not have the federal guidelines. Instead, most state cannabis regulations currently take a reactive approach to safety, mandating only for testing of the final product. While testing is an extremely important and valuable part of any quality management program, just analytics is not enough.

This is precisely why FOCUS was created and how they assist business owners and regulators, while fulfilling the mission of protecting public health, consumer safety and safeguarding the environment. The FOCUS standards are a cannabis-specific system of guidelines (cannabis-specific current good manufacturing practices) to ensure products are consistently produced according to quality standards. FOCUS provides detailed guidance and independent, third party auditing services for all key aspects of the cannabis industry including cultivation, extraction, infusion, retail, laboratory, security, packaging, labeling and sustainability.

CannabisIndustryJournal: What advice can you offer to cannabis businesses for product safety, defense and security prior to standardization?

Bruce E. Lesniak: Businesses that make products infused with cannabis (I call these businesses “plus one” companies because they produce products that include one more ingredient than traditional food products), require a carefully written master plan that specifically addresses the unique qualities, sensitivities and critical areas of the business. When building a comprehensive plan I address three questions:

  • Why (identify the why, this is your preventative, overarching strategy)?
  • How (addresses the “why question” with products, services and training)?
  • What (what is your reactive strategy that addresses actions and activities to be performed in the event of a breech)?

First and foremost, consumer-facing businesses must safeguard their products to the public. One product recall or illness related incident could spell disaster. Build your plan correctly the first time. Contact an industry expert to review your facility and help build and implement your plan. This will save you money by quickly exposing vulnerabilities and providing corrective measures specific to your business needs and requirements. Even though product safety and defense are closely related to security and should share a complementary strategy, product safety and defense are unique (due to standards and regulations), and should be treated as such.

Banks not accepting industry money complicates normal business operations and security planning, causing retail operations to handle and store large sums of cash. I asked industry expert and security professional, Tony Gallo of Sapphire Protection LLC, what is the single most important piece of security equipment you are currently providing for the retail and dispensary owner? “Design an air tight policy of handling money,” says Gallo. “Remove money often from cash registers and place it into the best safe for your application!”

Spend time familiarizing yourself with all things product safety and defense (there are volumes written on food safety and food defense, thus the “plus one” reference). This a great starting point and protecting the consumer protects your business. When it comes to designing your security application, consult an expert! Take into account that the cannabis industry is unique due to its “plus one” ingredient. Therefore you need to build your security systems, applications and policies to systematically protect your employees, facility, suppliers, transportation, manufacturing, distribution, warehousing, supply chain and brand.

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Dispensary Best Practices: A Q&A with Stephen Spinosa

By Aaron G. Biros
1 Comment
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Stephen Spinosa, vice president of retail operations at Good Chemistry, has over seven years of experience working in the cannabis industry in the operation and management of licensed dispensaries.

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Stephen Spinosa, VP of retail operations at Good Chemistry, delivering the keynote at Dispensary Next

He was previously an inventory manager in a 7,000-square-foot medical marijuana cultivation in Colorado. Spinosa is currently part of the team at Good Chemistry dispensaries, which has locations in Aurora and Denver, Colorado. He oversees staff training, state and local regulatory compliance and seed-to-sale inventory tracking.

Spinosa recently delivered a keynote presentation at the Dispensary Next Conference in Portland, Oregon titled “From Waiting Room to High-End Retail Experience: How Dispensary Culture Has Changed from 2009 to Now.” He discussed the rise of high-end experience and gave tools for dispensaries to improve retail operations.

In the presentation, he covered supplier quality, security, tiered pricing, inventory tracking and safety issues. Much of what he discussed revolved around the consumer experience and how important the culture at a dispensary is for the buying experience. After his keynote presentation, I sat down with Spinosa to discuss the customer experience, consumer education and safety and sales trends.

Cannabis Industry Journal: What are some of the key areas where dispensaries can improve the quality of customer experience?

Stephen Spinosa: Ultimately, the dispensary experience is like any retail experience. Good Chemistry’s staff is always friendly, smiling, welcoming and helpful to all customers that walk through our doors. Having employees who are experts at providing advice to any user level, and who are extremely knowledgeable on each strain and edible effect is extremely important to us. It is all about making the customer feel comfortable in their experience, especially for novice users who may feel timid when entering a dispensary for the first time.

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Smiling employees greet customers in a clean environment

Good Chemistry’s high-end retail experience includes our up-to-date LED menu screens that present our daily flower menu. That may seem like common sense, however, you would be surprised how many dispensaries do not have a flower menu for their customers to peruse.  It helps the customer navigate through all the strains that we offer, and adds to the overall retail experience. We offer twenty or more strains every day.

Additionally we do not have an armed guard hovering at the entrance, making our guests feel uncomfortable. We have highly sophisticated security, like every dispensary, but we’ve left out this intimidating and unnecessary aspect.

CIJ: Can you discuss what you and your employees do for consumer education and safety?

Spinosa: When introducing cannabis to consumers, it is our mission to educate our customers on the correct dosage based on experience level. Our bud tenders are trained to ask a lot of questions before recommending anything. If a customer is a first timer, the bud tenders will have certain recommendations based on their experience level, such as high-CBD [cannabidiol] flower, a low THC percentage vaporizer pen, or a 1-5mg edible serving.

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The exterior of a Good Chemistry dispensary

That said, strains of cannabis often cannot be neatly compartmentalized into sativa vs. indica, so our bud tenders also educate customers about the entourage effect, the interaction of the various compounds in marijuana to produce each strain’s unique feeling.

We have developed a pioneering category system to help our customers, whether novice or connoisseur. The system is broken down into four main categories to help consumers decide what sensation they would like to experience: stimulation, relaxation, sleep or relief. We use the four categories to guide our customers through our daily flower menu by labeling each strain with a category.

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This wall display shows customers the Good Chemistry categories of strains

If a customer is purchasing edibles, we provide an Edibles Education brochure from the Cannabis Business Alliance that stresses the Start Low, Go Slow motto. We also educate consumers on the difference between edibles made with butter vs. oil. Additionally, all of our third party vendor edible products for adult-use are packaged safely in 100% child resistant packaging.

It is important that our customers have a great experience, which is always possible with good guidance. A happy customer is a repeat customer. We are also well aware of the importance of educated employees. Our employees go through a formal training program, and we have monthly meetings where vendors come in and educate the employees on how to sell and dose various products.

CIJ: Can you tell me about your inventory and some consumer trends you are noticing?

Spinosa: Flower is the biggest seller, and for good reason: we have award-winning strains that are $30 an eighth, every strain, every day. Not many dispensaries offer such incredible pricing. Right now, the purchasing trend tends to lean toward the strains that have the highest THC percentage.

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The interior of the dispensary has digital displays and ample lighting.

This may not accurately depict the best strains, because there have been findings that the entourage effect means different strains can have unique lifts, but it is definitely what the industry is seeing as far as sales trends. As far as edibles, gummies are the biggest sellers followed by hard candies, chocolate and baked goods. Lastly, concentrates such as live resin, shatter and wax have increased in popularity. Good Chemistry produces a new product called solvent-less rosin, concentrated THC oil that is produced using just heat and pressure. Rosin is currently picking up a good amount of traction, although not many dispensaries currently offer it.