Tag Archives: food safety

Ask the Expert Series: Straight Talk on Safety, Defense and Security with Bruce Lesniak

By Aaron G. Biros, Bruce E. Lesniak
3 Comments

This is the first part of a series dedicated to understanding more about defense, security and safety as they relate to the cannabis industry, the importance of having standards and some tips for cannabis business plans. Over the next few weeks, we will hear from multiple industry pioneers discussing those topics and offering practical solutions for problems that many cannabis businesses face daily.

Inconsistent laws across multiple states created a fragmented network of regulations for cannabis. Some third parties are filling the gaps between the industry standards and state regulations. The Colorado Marijuana Enforcement Division (MED) and the Washington Liquor and Cannabis Board’s i-502 rule provide guidance on regulations surrounding packaging and labeling, advertising, pesticide use, retail and other areas.

Still there are many opportunities to fill the gaps. The Foundation of Cannabis Unified Standards (FOCUS), is an independent non-profit founded to develop some consistency in standards governing public health, consumer safety and the environment. In cultivation, the third party certification, Clean Green Certified, works to provide some guidance for growing cannabis organically based on USDA organic standards. For laboratories, Washington’s regulations provide some guidance, but organizations like FOCUS, the American Association for Laboratory Accreditation (A2LA) and the Cannabis Safety Institute seek to fill the gaps in laboratory standards along with the ISO 17025 requirements.

Security and defense is one particular area of the cannabis industry that still needs a benchmark for businesses to follow. In this series, we sit down to discuss security, defense and safety with Bruce Lesniak, president of the Food Safety and Defense Institute and member of the oversight committee for the establishment of standards in the cannabis industry in conjunction with FOCUS.

Cannabis Industry Journal: What changes do you see coming to the cannabis industry related to product safety, defense and security? 

Bruce Lesniak: As in every industry that provides a public consumable product, the primary objective is to protect the consumer by providing products that are consistently safe. The largest change coming to the cannabis industry will be the implementation of enforceable, nationally uniform standards across all states and all product lines. I believe that the standards and regulations developed for the cannabis industry will mirror those of the food industry. Companies are already busy working to develop this uniform standard, one such group is FOCUS. Founded by Lezli Engelking, FOCUS works with diverse professionals from regulatory, quality assurance, medical, law enforcement, business, research, and the government officials, medical and research professionals along with subject matter experts from numerous business disciplines across the industry to develop impartial, comprehensive, cannabis specific standards that will be presented for adoption by state and federal governing bodies. Lezli summarizes the FOCUS Mission as “ To protect public health, consumer safety, and safeguard the environment by promoting integrity within the cannabis industry.” Look for more on this in our next Ask the Expert update, on CannabisIndustryJournal.com or you can contact Lezli Engelking at FOCUS here: 866-359-3557 x101.


This series will highlight important issues involving security, defense and safety in the cannabis industry. Next week, Bruce, along with cannabis security professional, Tony Gallo of Sapphire Protection, will provide some advice on what companies can do to improve their master business plan. Stay tuned for next week’s Part II of Ask the Expert: Straight Talk on Safety, Defense and Security with Bruce Lesniak.

Cannabis Coaching & Compliance

What You Need to Know About Food Allergies

By Maureen McNamara
No Comments

I rolled up my sleeve and turned my hand palm up. The doctor placed a medieval looking torture device, 18 needles loaded with potential allergic venom right onto my little kid arm. Then, BAM – shot it right into me. Then we waited to see what, if anything, would happen. Would one of those spots react? Would we see some swelling? Where the hell was my lollipop? Hopefully we wouldn’t discover that I was allergic to sugar.

Okay, so maybe that description is a bit dramatic. I do hope that allergy testing protocol has improved over the decades.

Do you have allergies? Is there a certain time of year that makes you sneeze up a storm, your eyes water and you wonder when the pollen is going to ease up?

It is uncomfortable. And if you have or crossed paths with people that have a food allergy… it is way more than uncomfortable. It can be deadly.

In America alone, there are 15 million+ people with food allergies.

Here are the most common culprits in the world of food allergies:

  • Tree nuts
  • Peanuts
  • Soy
  • Wheat
  • Dairy
  • Milk
  • Eggs
  • Fish & shellfish

Be aware, even if these items are not an ingredient in what you are producing- cross contact (the transferring of allergens from one food to another food) can create reactions as well.

Here are a few of the mild symptoms:

  • Hives
  • Redness of the skin or around the eyes
  • Nausea or vomiting
  • Diarrhea
  • Stomach pain
  • Nasal congestion
  • Sneezing

Here are some of the severe allergic reactions:

  • Obstructive swelling of the lips, tongue, and/or throat
  • Trouble swallowing
  • Shortness of breath or wheezing
  • Drop in blood pressure (feeling faint, confused, weak, passing out)
  • Loss of consciousness
  • Death

Management and kitchen staff must be thoroughly trained regarding the dangers of food allergens and cross contact. Food safety training can help prevent your customers or patients from having a food-allergic reaction, which can lead to a medical emergency.

Here is a document, developed by the Food Allergy Research and Resource Program (FARRP) and the University of Nebraska, that shares details about how to create a manufacturing plan to ensure safe production with a focus on reducing potential allergic reactions.

In the cannabis industry, I know we are committed to contributing to people’s wellness. And when we produce infused products, ensuring that your patients receive a wholesome product is essential.

Here’s to your team increasing their knowledge, creating the best products and your thriving success with raving (hiveless) fans!

Cannabis Coaching & Compliance

Keep It Professional~Food Safety Musts!

By Maureen McNamara
No Comments

There are many aspects to the cannabis industry that demand an owner’s attention: Compliance, great products, great people, great location, finances…. So is a focus on food safety a priority?

Yes, yes it is. And not just for infused products.

For starters, in some states like Colorado, it is required. In other states it will be required in the foreseeable future, and generally speaking, it is a vital component for a professional industry that continues to show the community that you are committed to creating safe products.

Have you ever had a foodborne illness? I’m going to assume you just nodded your head or thought yes. Check out this statistic: according to the Center for Disease Control there are about 48 million cases of foodborne illnesses (and 3000 people die) every year in the United States.

A quick reminder about the typical symptoms of foodborne illness: vomiting, diarrhea, headaches and nausea. Experiences we would all like to avoid.

What I know for sure… you do not want your product or your company to ever be associated with making people sick.

Take into account that for medical marijuana patients, they may already have compromised immune systems. This puts them at an even greater risk for foodborne illness. We need to ask questions like “Are my employees doing everything possible to ensure a safe, wholesome product?”

A properly trained staff is a critical necessity in the cannabis industry. Whether it is currently required or not, your commitment to safety for your patients and consumers show that you care and are committed to high standards. Additionally, you may avoid fines, closures and recalls. These all create a drain on your finances… as well as your reputation.

The FDA has identified five key factors that often contribute to outbreaks:

  • Purchasing Food from Unsafe Sources
  • Improper Holding Time and Temperature
  • Inadequate Cooking
  • Improper Cleaning and Sanitizing
  • Poor Personal Hygiene

Safe Purchasing:

Be aware of starting with high quality ingredients. Ask your suppliers questions about their inspections and quality controls. If possible conduct a tour of the supplier facilities to verify they meet necessary standards. Are you impressed with their food safety standards and protocols?

Avoiding Time & Temperature Abuse:

Bacteria needs an ideal temperature (between 41°-135°) and a bit of time (4+hours) to grow to harmful levels. Keep your cold food cold and cool your heated foods quickly.

Inadequate Cooking:

If you are infusing oil, I strongly encourage you to work with your local health department for a procedure that will ensure the oil is cooked to a safe temperature (while not interfering with your chemistry) to eliminate potential pathogens or microbials.

Cleaning and Sanitizing:

Microorganisms grow well at room temperature. Cleaning and sanitizing is important to ensure microorganisms are reduced or eliminated. Certainly all of your food contact surfaces must be cleaned and sanitized whenever you change tasks and at least every four hours. This is not just for making infused products, please keep this in mind at the retail level as well. Think of how many hands (both employees and customers) may be touching the product containers. Avoid cross-contamination by cleaning and santizing thoroughly and often.

Personal Hygiene:

In each food safety class I have facilitated in the last 18 years, everyone admits they or their team could improve personal hygiene. Shout out to any bearded folks… did you know that the FDA food code requires facial hair that is 1-inch or longer to be restrained? Got a beard net?

Because most of the foods manufactured in the cannabis industry are “ready to eat” foods, great personal hygiene and frequent, thorough handwashing is essential. The FDA reccommends a 20 second handwashing procudure with hot water (≥100°), a soapy lather, vigoursly rubbing hands for at least 10-15 seconds, rinsing well and using a single-use towel to dry your hands.

I know… it sounds very basic. However, when I observe people washing their hands it is often for less than 8-seconds. Not only is handwashing a great way to stay healthy ourselves, it is a key way to ensure your products are safe and not putting public health in jeopardy.

I’ll throw down a challenge for you! This month: focus with your team on personal hygiene and hand washing. Whether you are growing, infusing or selling this is a vital component for a professional, responsible industry. When it comes down to it, you make things that go right into your customer’s and patient’s bodies. Create those products on a foundation of food safety and you will more easily create a thriving business.

Cannabis Trainers provides ServSafe® food safety training for edible makers and Sell-SMaRT™ the responsible cannabis vendor program for sellers. (www.CannabisTrainers.com)

We would love to hear from you! Comment below and let us know what your team does to ensure you are making and selling safe products.

MRAs

The Role of 3rd Party Accreditation in Cannabis Safety

By Roger Brauninger
1 Comment
MRAs

Living in a world of ever-increasing interdependence and an era of limited state government, financial and human resources, it is imperative that those charged with protecting the health and safety of patients and users of medical and recreational cannabis products leverage what private sector institutions and existing frameworks already offer in setting up quality standards for laboratory testing operations. That this moment arrives now – at a point where state governments are being tasked with undertaking the most significant change in the regulation of this substance whilst the federal government appears unwilling to play a substantial role – makes this partnership both inevitable and absolutely necessary.

Accreditation is an internationally accepted conformity assessment tool for ensuring laboratory competence and confidence in the accuracy and reliability test data. The accreditation infrastructure is well-established through accreditation bodies (ABs) and the Mutual Recognition Arrangement (MRA) of the International Laboratory Accreditation Cooperation (ILAC), supported by regional cooperative arrangements, including those of the Asia Pacific Laboratory Accreditation Cooperation (APLAC) and the Inter-American Accreditation Cooperation (IAAC). ILAC functions as a forum for harmonization of laboratory accreditation procedures and policies, thus reducing technical barriers to trade and promoting laboratory accreditation as a mechanism for establishing confidence in testing facilities. ILAC MRA signatory ABs are recognized, through a rigorous peer evaluation process, as competent to accredit testing organizations. All signatory ABs must meet the requirements of ISO/IEC 17011 and use ISO/IEC 17025 as the basis for accreditation of laboratories. In turn, under the ILAC MRA and the regional co-operations, competent laboratories are recognized globally, thus facilitating acceptance of the test results that accompany goods across international borders.

MRAs
A map showing the mutual recognition agreements across the globe

In other areas, such as the food supply and energy, both state and federal government have been an active participant in accreditation activities. According to The Administrative Conference of the United States in its Agency Use of Third-Party Programs to Assess Regulatory Compliance*, “…agencies in diverse areas of regulation have developed third-party programs to assess whether regulated entities are in compliance with regulatory standards and other requirements. Through these programs, third parties are charged with assessing the safety of imported food… Third parties also ensure that products labeled as organic and energy-efficient meet applicable federal standards. In these regulatory third-party programs, regulated entities generally contract with third parties to carry out product testing and other regulatory compliance assessment activities in the place of regulatory agencies. Regulatory agencies take on new roles in coordinating and overseeing these third-party actors.” While this reference largely deals with areas outside of cannabis regulation, it remains useful and relevant because of the manner in which cannabis products are used.

Traditionally, ABs have worked with regulators to establish specific technical requirements to supplement the ISO/IEC 17025 accreditation framework. In this partnership, the AB is responsible for executing the assessment and accreditation process but the regulator retains responsibility for the ultimate decisions on the acceptance of that organization’s accreditation. In the example of our food supply and its various sources, governmental recognition of accreditation bodies operating in accordance with international standards is much more practical than government agencies themselves accrediting the individual testing organizations or ABs. Thus the public/private partnership paradigm: To assess regulatory compliance a Regulatory Agency approves ABs that accredit organizations that assess whether Regulated Entities or Regulated Products are in conformity with a Regulatory Standard.*

In this example, all of the organizations are treated equally by the regulatory agency since they use the same recognition criteria for ABs and the same accreditation requirements in the assessment of conformity assessment bodies. This approach would also provide consistency at a point in time where many states are grappling with trying to find the best quality standard to use and which, to date, has resulted in many different standards being chosen or considered for implementation. This is especially true when one looks at the requirements put into place by the “early adopter” states. However, in those states that have entered this area more recently, it seems clear that the consensus is use of ISO/IEC 17025 as the most appropriate quality management standard for testing laboratories.

Cannabis Coaching & Compliance

Food Safety Training: A Story of Poo

By Maureen McNamara
No Comments

Cannabis Trainers: A Story of Poo

Are you an excellent hand washer?
Almost everyone answers this question with a big “YES!”

The reality? Researchers let us know that most people don’t wash their hands thoroughly or frequently. Especially men… sorry fellas!

I know, I understand that this sounds super basic. However, it is an integral part of ensuring that your business doesn’t contribute to any of the millions of food borne illnesses each year in the United States. According to the Center for Disease Control and Prevention, there are approximately 48 million cases of food borne illness, 128,000 hospitalizations and 3000 deaths resulting from food borne illness. 

For us in the cannabis industry, many of our products are known as “ready to eat foods” or, foods that do not require heating prior to eating. This allows us to keep things a bit simpler for our customers and patients. The most prevalent foodborne illness is the norovirus, which is linked to ready to eat foods and poor personal hygiene factors.

Keep in mind that even though we [typically] are not working with high risk foods (think: poultry, fish, beef etc.), we may very likely be creating food for a high risk population (patients with compromised immune systems), and great personal hygiene is imperative.

  1. Is your team using gloves or utensils to handle all ready to eat foods?

  2. Do you wash hands prior to gloving?

  3. Are hands being washed with at least 100*F water for 20 seconds?

One tool that I like to use in our food safety classes to illustrate the point that hand washing is typically done quickly and poorly is GloGerm. This highlights where the areas for improvement are for each person with hand washing.

I am often asked about hand sanitizer. For all you busy people out there… listen up! Hand sanitizer does NOT replace hand washing ever.
Seriously- never. Here is my analogy for you:
Hand sanitizer on dirty hands is like whipped cream on poop. You’re welcome for that mental image.

Frequent, thorough hand washing is essential to ensure that your team creates food safely and with integrity. The truth is, fecal contamination is a big deal. And although we may all claim that we are great hand washers, there is often room for improvement.

Ready to learn more? Join us for one of our ServSafe Food Handler courses that we customize to the specific needs of the cannabis industry.

www.CannabisTrainers.com

incredibles chocolate

Manufacturing Edibles With Integrity

By Aaron G. Biros
No Comments
incredibles chocolate

Without federal guidance on food products containing marijuana (a result of the plant remaining a Schedule I narcotic), state regulators and manufacturers are fighting to keep the market safe for consumers. Manufacturers of marijuana edibles are not only trying to ensure consumer safety, but are also attempting to advance industry and legalization efforts nationwide.

Recent investigations in Colorado revealed that certain marijuana edibles, along with some extracts, tested positive for illegal pesticides. Many cannabis businesses are looking to the industry leaders in edibles manufacturing for advice. Marijuana edibles are a food product, so they must first enlist standard food sanitation procedures and then comply with state regulations for cannabis to ensure safety. Some of the product consumers are patients with weakened immune systems, thus highlighting the need for consistent and accurate dosing in products.incredibles logo

Maureen McNamara, founder of Cannabis Trainers, recently sat on a panel with Bob Eschino, co-founder of incredibles and Krystal Kiathara, CEO of Yummi Karma at the Cannabis World Congress and Business Expo, hosted by the International Cannabis Association in Los Angeles. The panelists discussed the need for integrity in manufacturing edibles.

The regulations are not quite there yet and states are adjusting legislation to help promote safety. “It is our job to educate legislators and make sure that our products are accurate and consistent,” said Bob Eschino, co-founder of incredibles.

incredibles chocolate
An infused chocolate bar, manufactured by incredibles, separated into 10mg of THC doses

Maureen McNamara says there are four criteria for producing edibles with integrity: Compliance, training, research and product testing.

“Starting with the foundation of compliance, utilizing strategies involving HACCP plans and FDA guidance, the first pillar is training,” says McNamara. “Food safety training is essential to ensure your team is aware and making a wholesome product.” She also stressed the importance of shelf-life testing and R&D before the product goes onto shelves.

Because food laboratories often will not test products that contain cannabis, many companies work with food scientists and in-house testing. “Moving forward, we need to ensure that we achieve consistent results from the various testing labs,” said McNamara. “But to make edibles with integrity, laboratory testing is paramount.”

RFID tags on drying marijuana flowers

Marijuana Edibles: Update on a Rapidly Developing Market

By Aaron G. Biros
No Comments
RFID tags on drying marijuana flowers

A lot has changed since last year’s article, “Marijuana Edibles: A Regulatory Nightmare.” Marijuana has since catapulted into mainstream thinking via activism, state decriminalization, and medical reforms while investors and banks are beginning to trust the market more, further legitimizing the nascent industry. According to an article from the Washington Post, Colorado’s legal marijuana industry reached $700 million in 2014 and is expected to grow to $1 billion by 2016. 

Innovators are beginning to analyze trends on a national level, looking toward federal rescheduling of the drug as a catalyst for more state reforms and wider legalization measures. Federal legalization is in the back of many minds, as the introduction of pivotal state and federal legislative reforms promises more access to banking services, medical research, and more state independence. 

While a black market mentality remains prevalent, widespread state reforms, increased venture capital investment, and further legitimization of an industry with less barriers of entry have fostered a perceived reduction in risk. States like Oregon, Washington, and Colorado that have already legalized marijuana for recreational and medical sales are beginning to implement strict packaging rules, requirements for traceability, QA programs, testing and laboratory monitoring requirements, and other regulations that would suggest FDA oversight down the road. 

marijuana buds drying in racks biotrackthc
Dried marijuana buds curing with RFID tags as part of the traceability system of BiotrackTHC

State regulatory bodies such as the Colorado Marijuana Enforcement Division (MED) have matured and expanded their oversight to include certifications and requirements for lab testing and analysis. Marijuana testing facilities can now be certified by the MED to test for residual solvents, poisons or toxins, harmful chemicals, dangerous molds, mildew or filth, harmful microbials such as E. coli or Salmonella, pesticides, and THC levels and Cannabinoid potency. 

According to an article from theCannabist.com, edible marijuana took 45% of the market share in 2014 and continues to grow, proving that food manufacturers and processors will gain a bigger share of the market. 

BioTrackTHC develops a seed-to-sale traceability system that is the state-mandated reporting system used by any business that touches the plant in compliance with Washington’s i502 regulations (The company also won the contract bid for New Mexico’s and New York’s state-run traceability systems). “From day one, all retail products under i502, including infused edibles, must have laboratory-submitted passing test results and data in the traceability system before it can be unlocked for shipment to retailers,” says Patrick Vo, CEO of BioTrackTHC.  

RFID tags on drying marijuana flowers
RFID tags on drying marijuana flowers, from BioTrackTHC

Regulations, especially those addressing traceability, are crucial for advancing the industry and fighting the black market, performing recalls, and improving product quality and safety. Vo adds, “As more states adopt a centralized traceability system, food safety will improve as we see the industry grow.”

“Most of the marijuana edibles producers we advise are working comfortably within their state health department regulations versus a year ago when they were struggling to implement routine compliance,” says Stephen Goldner, CEO of Regulatory Affairs Associates.  “But there is a long way to go to make this new marketplace meet the standards routinely met by US food producers in other markets such as nutritional supplements and medical foods.”

Many edible producers are sadly mistaken to ignore FDA labeling and production regulations just because the producer only ships within their own state, according to Goldner. “Whenever FDA has found label or food safety violations of products, whether they are food, drugs or any other product, it has always acted quickly to seize the product, inspect the producer and insist that violative labeling or production practices be remedied,” he says, adding that it won’t be surprising to see FDA start to “seize marijuana-infused food products that make drug claims, especially from the leading current producers” as a way for the agency to insert itself into the inspection and compliance process. “These companies need to have FDA food GMP’s solidly in place and properly documented,” says Goldner.

 “Those who have experienced the most consistent and long term success in this industry are those who play above board, those who take the extra effort and make the investment in effort, time, and money to treat their business as if it was already federally legal and had to adhere to standards that other industries must follow,” says Vo. He agrees with the view held by many that long term planning is vital in this industry. “Those who have implemented best practices, QA programs, and traceability software will succeed in the long run, and the bad actors will eventually, by their own poor practices, be filtered out by regulatory and market forces.”

In the near future, the industry will look to other states in regulatory experiments on opposite sides of the spectrum. “New York, which legalized medical marijuana in 2014, is handing out 5 licenses to operate 4 dispensaries each, and allowing licensees to have a grow facility to supply their respective dispensaries. The Commissioner of the New York State Department of Health will have authority on licensing, testing, and medical requirements for patients seeking treatment with medical marijuana,” says R. David Marquez, who operates a Long Island law firm focusing on the cannabis industry.

New York is implementing very strict rules regarding cultivating and processing the plant. California, on the other side of the spectrum, already operates a somewhat loosely regulated medical marijuana market and has been doing so since 1996. The bill to legalize marijuana recreationally in the state is widely expected to pass vote and be implemented in 2016. This would open up an enormous market potential and contribute to the growth of the industry on a national level. 

Because marijuana edibles are theoretically both a food and a drug, it is only appropriate that the FDA should look to regulate the industry in the future. In the meantime “Those who have invested the time and money in staying compliant now will be far ahead of the game tomorrow,” says Patrick Vo, who is looking toward federal legalization.

It seems that manufacturers and processors at the forefront of quality and safety testing will succeed in the long run. 

Footnote: This is a regulatory update on the cannabis industry with an emphasis on edible marijuana. CannabisIndustryJournal.com, the newest publication, will be launched in September of this year. CannabisIndustryJournal.com will educate the marketplace covering news, technology, business trends, safety, quality, and the regulatory environment, aiding in the advancement of an informed and safe market for the global cannabis industry. Stay tuned for more!