Tag Archives: standard operating procedures

California Manufacturing Regulations: What You Need To Know

By Aaron G. Biros
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In late November, California released their proposed emergency regulations for the cannabis industry, ahead of the full 2018 medical and adult use legalization for the state. We highlighted some of the key takeaways from the California Bureau of Cannabis Control’s regulations for the entire industry earlier. Now, we are going to take a look at the California Department of Public Health (CDPH) cannabis manufacturing regulations.

According to the summary published by the CDPH, business can have an A-type license (for products sold on the adult use market) and an M-type license (products sold on the medical market). The four license types in extraction are as follows:

  • Type 7: Extraction using volatile solvents (butane, hexane, pentane)
  • Type 6: Extraction using a non-volatile solvent or mechanical method
    (food-grade butter, oil, water, ethanol, or carbon dioxide)
  • Type N: Infusions (using pre-extracted oils to create edibles, beverages,
  • capsules, vape cartridges, tinctures or topicals)
  • Type P: Packaging and labeling only

As we discussed in out initial breakdown of the overall rules, California’s dual licensing system means applicants must get local approval before getting a state license to operate.

The rules dictate a close-loop system certified by a California-licensed engineer when using carbon dioxide or a volatile solvent in extraction. They require 99% purity for hydrocarbon solvents. Local fire code officials must certify all extraction facilities.

In the realm of edibles, much like the rule that Colorado recently implemented, infused products cannot be shaped like a human, animal, insect, or fruit. No more than 10mg of THC per serving and 100mg of THC per package is allowed in infused products, with the exception of tinctures, capsules or topicals that are limited to 1,000 mg of THC for the adult use market and 2,000 mg in the medical market. This is a rule very similar to what we have seen Washington, Oregon and Colorado implement.

On a somewhat interesting note, no cannabis infused products can contain nicotine, caffeine or alcohol. California already has brewers and winemakers using cannabis in beer and wine, so it will be interesting to see how this rule might change, if at all.

CA Universal Symbol (JPG)

The rules for packaging and labeling are indicative of a major push for product safety, disclosure and differentiating cannabis products from other foods. Packaging must be opaque, cannot resemble other foods packaged, not attractive to children, tamper-evident, re-sealable if it has multiple servings and child-resistant. The label has to include nutrition facts, a full ingredient list and the universal symbol, demonstrating that it contains cannabis in it. “Statute requires that labels not be attractive to individuals under age 21 and include mandated warning statements and the amount of THC content,” reads the summary. Also, manufacturers cannot call their product a candy.

Foods that require refrigeration and any potentially hazardous food, like meat and seafood, cannot be used in cannabis product manufacturing. They do allow juice and dried meat and perishable ingredients like milk and eggs as long as the final product is up to standards. This will seemingly allow for baked goods to be sold, as long as they are packaged prior to distribution.

Perhaps the most interesting of the proposed rules are requiring written standard operating procedures (SOPs) and following good manufacturing practices (GMPs). Per the new rules, the state will require manufacturers to have written SOPs for waste disposal, inventory and quality control, transportation and security.

Donavan Bennett, co-founder and CEO of the Cannabis Quality Group

According to Donavan Bennett, co-founder and chief executive officer of the Cannabis Quality Group, California is taking a page from the manufacturing and life science industry by requiring SOPs. “The purpose of an SOP is straightforward: to ensure that essential job tasks are performed correctly, consistently, and in conformance with internally approved procedures,” says Bennett. “Without having robust SOPs, how can department managers ensure their employees are trained effectively? Or, how will these department managers know their harvest is consistently being grown? No matter the employee or location.” California requiring written SOPs can potentially help a large number of cannabis businesses improve their operations. “SOPs set the tempo and standard for your organization,” says Bennett. “Without effective training and continuous improvement of SOPs, operators are losing efficiency and their likelihood of having a recall is greater.”

Bennett also says GMPs, now required by the state, can help companies keep track of their sanitation and cleanliness overall. “GMPs address a wide range of production activities, including raw material, sanitation and cleanliness of the premises, and facility design,” says Bennett. “Auditing internal and supplier GMPs should be conducted to ensure any deficiencies are identified and addressed. The company is responsible for the whole process and products, even for the used and unused products which are produced by others.” Bennett recommends auditing your suppliers at least twice annually, checking their GMPs and quality of raw materials, such as cannabis flower or trim prior to extraction.

“These regulations are only the beginning,” says Bennett. “As the consumer becomes more educated on quality cannabis and as more states come online who derives a significant amount of their revenue from the manufacturing and/or life science industries (e.g. New Jersey), regulations like these will become the norm.” Bennett’s Cannabis Quality Group is a provider of cloud quality management software for the cannabis industry.

“Think about it this way: Anything you eat today or any medicine you should take today, is following set and stringent SOPs and GMPs to ensure you are safe and consuming the highest quality product. Why should the cannabis industry be any different?”

Wellness Watch

Employee Training: Compassionate Customer Service

By Dr. Emily Earlenbaugh, PhD.
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Compassion is a frequent buzzword used in the cannabis space and many businesses start up with a mission surrounding compassion and strive to be compassionate towards their patients or consumers.

Research shows that profit-driven retail management and compassionate service can be accomplished in the same way. By turning to the industry mantra of compassion, companies can contribute to the well-being of patients or consumers served and employees, while also increasing sales, positive reviews and return visits.

One large aspect of dispensary management is setting up a corporate culture around employee-customer interactions. Some dispensaries have mastered this through employee training and thoughtful SOP’s, which help maintain a compassionate, positive environment for every person that walks through the door.

Research shows that when consumers have positive interactions in retail environments, they are more likely to make a purchase and to positively rate the products they select. When feeling these positive mental states, our perceptions of products become more positive as well, and our trust in those around us increases. Conversely, when we feel negative emotions like loneliness or exclusion, our perceptions of products also become more negative.

People experiencing positive mental states, like gratitude, joy or compassion also have better health and increased emotional well-being. For both compassionate and profit-driven reasons, getting people into a positive emotional state is extremely beneficial. Of course, creating a compassionate, mood-boosting environment is easier said than done. Thankfully, there is a lot of research on how to do this as well.

So how can we set up a corporate culture that fosters more positive states in others? It takes energy and intention, but it can be done. As a dispensary manager, one of the most important things you can do is ensure that your employees have what they need to function well. Research shows that when employees are working under stressful conditions their interactions with customers suffer. This could mean being underpaid, overworked, unsure of job security, rushed, or crowded; but whatever the reason, a stressed employee is less able to maintain positive interactions with customers. Once you have a happy and well-treated staff, you can start training them to cultivate positive states in your consumers.

Here are a few time-tested methods to teach to your dispensary staff and practice with your patients or recreational customers:

Positive Feedback Exercise

One of the simplest methods is giving positive feedback. It has been demonstrated over and over again that when you give someone positive feedback, his or her mood is instantly boosted. They become more grateful, creative and engaged.

Positive feedback can come in different forms. It might be a simple compliment like “Wow, I love your earrings.” or it might be a positive response to a question, such as “That’s a great question, not everyone thinks to ask about what these test results mean.”

To cultivate positive feedback, make a point of looking for things you can genuinely compliment about your customers or coworkers. Be careful not to fake your positivity. Most people can tell when positivity is faked; and it can actually have negative health risks for the person doing the faking.

Active Listening Practice

You can foster positive emotions in your customer base through active listening and compassion for the challenges they are going through. Research finds that active listening can improve communication dynamics and reduce stress.

For this practice, notice when your patients are complaining and pay careful attention to what they are saying. Try to really feel what it might be like to be in their situation and sympathize with them. You can show this sympathy by acknowledging what they are going through.

These practices may seem simple but they can yield big changes in a customer’s impression of your dispensary environment. By cultivating compassionate practices with your staff and customers, you can take care of your community while helping your business to thrive.