Food manufacturers are intensely aware that they are responsible for ensuring their products are safe for consumers. After all, manufacturers have numerous food safety regulations to follow, from the federal Food Safety Modernization Act (FSMA) to state food codes. Though the expanding cannabis industry is not yet federally regulated, makers of infused edibles that supply states that have legalized medical and/or recreational-use cannabis must follow state laws that regulate the testing of cannabis.
Whether in-house or through third-party labs, testing can detect several issues in cannabis. Labs test for Aspergillus mold or Salmonella contamination, potency (i.e., THC, CBD levels), and the presence of heavy metals and banned pesticides and fertilizers.
This blog from ImEPIK will explore the need for edibles makers to have microbial programs as part of their food safety plans, plus protocols to prevent contamination in facilities making cannabis-infused products.
Labs Under the Microscope as States Establish Cannabis Laws
An essential food safety practice is ensuring that ingredients arriving at your production facility are free of pathogens and other contaminants. In addition, companies must have confidence that the labs testing the cannabis they use are trustworthy and follow strict protocols.
Unfortunately, that’s not always the case. In November, Michigan’s Marijuana Regulatory Agency reported “inaccurate and/or unreliable results” in tests from Viridis North LLC and Viridis Laboratories LLC. It warned that consumers with weakened immune systems or lung disease could be at risk because of possible Aspergillus and other contaminants. In 2019, the State of Oregon released an audit citing numerous failures of regulatory mandates, including lab testing of contaminants.
Some patients in medical marijuana programs are immunocompromised and are especially susceptible to health problems caused by Aspergillus, other molds, and pathogens such as Salmonella.
Although companies can’t be 100 percent sure that a company they source from is trustworthy, preventive controls, such as buying only from an internally-approved list of suppliers, will help limit exposure to bad actors in the industry.
Identify and Address Problem Areas
Companies with FDA-regulated facilities must assess all areas of their operations to identify safety and adulteration hazards associated with their foods and processes, according to the FSMA’s Preventive Controls Rule. Cannabis edibles manufacturers who adopt similar safeguards can reduce risks significantly.
Microbial programs include ensuring that storage and handling environments and processes don’t invite pathogens and other contaminants to ingredients or final products.
Hazard Analysis and Critical Control Point (HACCP) plans can expose some microbial pain points throughout your operation. Questions raised when creating the HACCP plan can shine a light on areas of concern, such as:
- When a hazard is identified, are there steps to control it?
- Could contamination with an identified hazard occur at unacceptable levels?
- Will a subsequent step eliminate the hazard?
Be Vigilant, and Prove it with Documentation
The HACCP planning process should show makers of cannabis edibles why they, and their suppliers, are responsible for ensuring that ingredients and products are safe to eat. In addition, a comprehensive Edibles Safety Plan will lay out how the production environment and process to make the edibles could affect food safety.
Sanitation plans should highlight areas of concern, from food contact surfaces and equipment to drainage systems.
Following sanitation procedures includes a record-keeping system that documents a schedule and identifies who completed the assigned tasks. Documenting all microbial testing results is also critical. All documentation is designed to back up food safety claims when working with regulators and customers and when assessing food safety plans internally.
ImEPIK’s Cannabis Food Safety Courses Help Establish Micro Programs
ImEPIK’s training courses for makers of cannabis-infused edibles help companies address issues that can affect food safety, from receiving ingredients from trusted suppliers to shipping a safe product to retailers.
Contact ImEPIK to learn more about the courses, including a team pricing plan tailored to your needs.