The Cannabis Quality series will feature presentations by subject matter experts in the areas of regulations, edibles manufacturing, cannabis safety & quality as well as laboratory testing. The Food Safety Consortium itself is hosted by our sister publication, Food Safety Tech, but the Cannabis Quality series will be co-hosted by Cannabis Industry Journal as well.
Citing the need to address safety in a burgeoning market, Rick Biros, conference director, believes education is key to helping the cannabis industry mature. “As the cannabis industry evolves, so does the need to protect the consumer,” says Biros. “Just as we protect the safety of our food supply chain, it is important to educate the cannabis industry about protecting their supply chain from seed to sale. Through these educational talks, we want to help bridge that gap, hosting a forum for those in the cannabis industry to interact with food safety professionals.”
The 2018 Food Safety Consortium Conference & Expo will be held November 14–16 in Schaumburg, Illinois. The event is a top food safety conference that features Food Safety and Quality Assurance (FSQA) industry experts and government officials.
The conference focuses on food safety education and networking, providing attendees information on best practices and new technology solutions to today’s food safety challenges. Previous keynote speakers have included food safety leaders such as Stephen Ostroff, M.D., deputy commissioner for Foods and Veterinary Medicine, U.S. Food and Drug Administration and Frank Yiannis, vice president of Food Safety at Walmart and author of Food Safety Culture: Creating a Behavior-Based Food Safety Management System.
Before submitting an abstract, following are a few points to keep in mind:
The abstract should be about 300 words
Presentations will be judged on educational value
Don’t submit a sales pitch!
Presentation time is about 45 minutes—this includes a 10-15 Q&A session
Editor’s note: This article should serve as a foundation of knowledge for yeast and mold in cannabis. Beginning in January 2018, we will publish a series of articles focused entirely on yeast and mold, discussing topics such as TYMC testing, preventing yeast and mold in cultivation and treatment methods to reduce yeast and mold.
Cannabis stakeholders, including cultivators, extractors, brokers, distributors and consumers, have been active in the shadows for decades. With the legalization of recreational adult use in several states, and more on the way, safety of the distributed product is one of the main concerns for regulators and the public. Currently, Colorado1, Nevada and Canada2 require total yeast and mold count (TYMC) compliance testing to evaluate whether or not cannabis is safe for human consumption. As the cannabis industry matures, it is likely that TYMC or other stringent testing for yeast and mold will be adopted in the increasingly regulated medical and recreational markets.
The goal of this article is to provide general information on yeast and mold, and to explain why TYMC is an important indicator in determining cannabis safety.
Yeast & Mold
Yeast and mold are members of the fungi family. Fungus, widespread in nature, can be found in the air, water, soil, vegetation and in decaying matter. The types of fungus found in different geographic regions vary based upon humidity, soil and other environmental conditions. In general, fungi can grow in a wide range of pH environments and temperatures, and can survive in harsh conditions that bacteria cannot. They are not able to produce their own food like plants, and survive by breaking down material from their surroundings into nutrients. Mold cannot thrive in an environment with limited oxygen, while yeast is able to grow with or without oxygen. Most molds, if grown for a long enough period, can be detected visually, while yeast growth is usually detected by off-flavor and fermentation.
Due to their versatility, it is rare to find a place or surface that is naturally free of fungi or their spores. Damp conditions, poor air quality and darker areas are inviting environments for yeast and mold growth.
Cannabis plants are grown in both indoor and outdoor conditions. Plants grown outdoors are exposed to wider ranges and larger populations of fungal species compared to indoor plants. However, factors such as improper watering, the type of soil and fertilizer and poor air circulation can all increase the chance of mold growth in indoor environments. Moreover, secondary contamination is a prevalent risk from human handling during harvest and trimming for both indoor and outdoor-grown cannabis. If humidity and temperature levels of drying and curing rooms are not carefully controlled, the final product could also easily develop fungi or their growth by-product.
What is TYMC?
TYMC, or total yeast and mold count, is the number of colony forming units present per gram of product (CFU/g). A colony forming unit is the scientific means of counting and reporting the population of live bacteria or yeast and mold in a product. To determine the count, the cannabis sample is plated on a petri dish which is then incubated at a specific temperature for three to five days. During this time, the yeast and mold present will grow and reproduce. Each colony, which represents an individual or a group of yeast and mold, produces one spot on the petri dish. Each spot is considered one colony forming unit.
Why is TYMC Measured?
TYMC is an indicator of the overall cleanliness of the product’s life cycle: growing environment, processing conditions, material handling and storage facilities. Mold by itself is not considered “bad,” but having a high mold count, as measured by TYMC, is alarming and could be detrimental to both consumers and cultivators.
The vast majority of mold and yeast present in the environment are indeed harmless, and even useful to humans. Some fungi are used commercially in production of fermented food, industrial alcohol, biodegradation of waste material and the production of antibiotics and enzymes, such as penicillin and proteases. However, certain fungi cause food spoilage and the production of mycotoxin, a fungal growth by-product that is toxic to humans and animals. Humans absorb mycotoxins through inhalation, skin contact and ingestion. Unfortunately, mycotoxins are very stable and withstand both freezing and cooking temperatures. One way to reduce mycotoxin levels in a product is to have a low TYMC.
Yeast and mold have been found to be prevalent in cannabis in both current and previous case studies. In a 2017 UC Davis study, 20 marijuana samples obtained from Northern California dispensaries were found to contain several yeast and mold species, including Cryptococcus, Mucor, Aspergillus fumigatus, Aspergillus niger, and Aspergillus flavus.3 The same results were reported in 1983, when marijuana samples collected from 14 cannabis smokers were analyzed. All of the above mold species in the 2017 study were present in 13 out of 14 marijuana samples.4
Aspergillus species niger, flavus, and fumigatus are known for aflatoxin production, a type of dangerous mycotoxin that can be lethal.5 Once a patient smokes and/or ingests cannabis with mold, the toxins and/or spores can thrive inside the lungs and body.6, 7 There are documented fatalities and complications in immunocompromised patients smoking cannabis with mold, including patients with HIV and other autoimmune diseases, as well as the elderly.8, 9, 10, 11
For this reason, regulations exist to limit the allowable TYMC counts for purposes of protecting consumer safety. At the time of writing this article, the acceptable limit for TYMC in cannabis plant material in Colorado, Nevada and Canada is ≤10,000 CFU/g. Washington state requires a mycotoxin test.12 California is looking into testing for specific Aspergillus species as a part of their requirement. As the cannabis industry continues to grow and advance, it is likely that additional states will adopt some form of TYMC testing into their regulatory testing requirements.
Centre for Disease control and prevention. 2004 Outbreak of Aflatoxin Poisoning – Eastern and central provinces, Kenya, Jan – July 2004. Morbidity and mortality weekly report.. Sep 3, 2004: 53(34): 790-793
Cescon DW, Page AV, Richardson S, Moore MJ, Boerner S, Gold WL. 2008. Invasive pulmonary Aspergillosis associated with marijuana use in a man with colorectal cancer. Diagnosis in Oncology. 26(13): 2214-2215.
Szyper-Kravits M, Lang R, Manor Y, Lahav M. 2001 Early invasive pulmonary aspergillosis in a leukemia patient linked to aspergillus contaminated marijuana smoking. Leukemia Lymphoma 42(6): 1433 – 1437.
Verweii PE, Kerremans JJ, Voss A, F.G. Meis M. 2000. Fungal contamination of Tobacco and Marijuana. JAMA 2000 284(22): 2875.
Ruchlemer R, Amit-Kohn M, Raveh D, Hanus L. 2015. Inhaled medicinal cannabis and the immunocompromised patient. Support Care Cancer. 23(3):819-822.
McPartland JM, Pruitt PL. 1997. Medical Marijuana and its use by the immunocompromised. Alternative Therapies in Health and Medicine. 3 (3): 39-45.
Hamadeh R, Ardehali A, Locksley RM, York MK. 1983. Fatal aspergillosis associated with smoking contaminated marijuana, in a marrow transplant recipient. Chest. 94(2): 432-433.
The CannaGrow Conference & Expo, held in San Diego on May 7th and 8th, educated attendees on the science of cannabis cultivation. The conference brought subject matter experts from around the country to discuss cannabis breeding and genetics, soil science and cultivation facility design.
Discussions at the conference delved deep into the science behind growing while providing some expert advice. Drew Plebani, chief executive officer of Commercial Cultivator, Inc., gave a comprehensive review of soil ecology and how understanding soil fertility is crucial to successfully growing consistent cannabis. “Soil fertility is measured by laboratories in terms of soil minerals, plant-available nutrients, percent of organic materials, pH levels and most importantly the balance of the soil’s chemical makeup,” says Plebani. “There is no silver bullet in soil ecology; increasing your soil fertility comes down to understanding the composition of soil with analytical testing.” Plebani went on to add that soil systems for cannabis need to be slightly fungal-dominant in developing an endomycorrhizal system, which is optimal for cannabis plant growth.
Tom Lauerman, colloquially known as Farmer Tom and founder of Farmer Tom Organics, kicked off the conference with an introduction to cultivation techniques. Lauerman also delved into his experience working with federal agencies in conducting the first ever health hazard evaluation (HHE) for cannabis with the National Institute for Occupational Safety and Health (NIOSH). Through the HHE program, NIOSH responds to requests for evaluations of workplace health hazards, which are then enforced by the Occupational Safety & Health Administration (OSHA). Lauerman worked with those federal agencies, allowing them to tour his cultivation facilities to perform an HHE for cannabis processing worker safety. “I was honored to introduce those federal agencies to cannabis and I think this is a great step toward normalizing cannabis by getting the federal government involved on the ground level,” says Lauerman. Through the presentation, Lauerman emphasized the importance of working with NIOSH and OSHA to show federal agencies how the cannabis production industry emerged from the black market, branding itself with a sense of legitimacy.
Adam Jacques, award-winning cultivator and owner of Grower’s Guild Gardens, discussed his success in breeding CBD-dominant strains and producing customized whole-plant extractions for specific patients’ needs. “I find higher percentages of CBD in plants harvested slightly earlier than you would for a high-THC strain,” says Jacques. “Using closed-loop carbon dioxide extraction equipment, we can use multiple strains to homogenize an oil dialed in for each patient’s specific needs.” As a huge proponent of the Entourage Effect, Jacques stressed the importance of full plant extraction using fractionation with carbon dioxide. He also stressed the importance of analytical testing at every step during processing.
Zacariah Hildenbrand, Ph.D., chief scientific officer at C4 Laboratories, provided the 30,000-foot view of the science behind compounds in cannabis, their interactions and his research. With the help of their DEA license, he started the C4 Cannabinomics Collaborative, where they are working with Dr. Kevin Schug at the University of Texas-Arlington to screen various cannabis strains to discover new molecules and characterize their structure. “Secondarily, we are using gene expression profiles and analysis to understand the human physiological response and the mechanism through which they elicit that response,” says Hildenbrand. “As this research evolves, we should look to epigenetics and understanding how genes are expressed.” His collaborative effort uses Shimadzu’s Vacuum Ultraviolet Spectroscopy (VUV), and they use the only VUV instrument in an academic laboratory in the United States. “Pharmaceuticals are supposed to be a targeted therapy and that is where we need to go with cannabis,” says Hildenbrand. Him and his team at C4 Laboratories want to work on the discovery of new terpenes and analyze their potential benefits, which could be significant research for cannabis medicine.
Other important topics at the conference included facility design and optimization regarding efficient technologies such as LED lighting and integrated pest management.
Regulators in Colorado last week announced another massive recall of cannabis found to contain banned pesticides. 92 batches of cannabis plants, with roughly a dozen plants in each batch, were recalled for using the product, Guardian, on the plants. The culprit was an ingredient in the product called avermectin, a pesticide listed as a ‘bad actor’ by the Pesticide Action Network.
The recall follows dozens of others in Colorado this year, all because tests found pesticides present in cannabis samples. When news spreads of cannabis recalls due to concerns of pesticide contamination, it paints a picture of worrisome problems rampant in the cannabis industry. Alarmists say continued recalls could have disastrous consequences like stalling legalization initiatives or slowing growth in new markets.
In the food industry, recalls are a part of routine business. The FDA created the Reportable Food Registry (RFR) as a way to prevent the shipment of contaminated food products into the supply. In 2015, Chipotle Mexican Grill made news when it sickened dozens with an E.coli outbreak and issued extensive recalls as a result. After that happened, the company reevaluated its practices and improved their food safety program to prevent future outbreaks.
When a recall occurs, it should prompt a surge in inquiries, responses and audits that need to be addressed and reviewed carefully. Ample proactive planning including HACCP, comprehensive risk analysis and validation studies or documents help prevent recalls from occurring in the first place. When recalls do happen, reactive measures should occur immediately with a strategy in place to deal with all of the regulatory compliance, quality, safety and branding ramifications.
When a recall occurs in the food industry, it generally means that there was a foodborne illness outbreak, followed by a reactive measure. That reactive measure, the recall itself, is what prevents foodborne illness outbreaks from growing or becoming an epidemic. Recalls in the food industry show that regulators are concerned about contamination and taking action to safeguard public health. In other words, when a recall occurs, it means that someone is watching.
I think recalls in the cannabis industry are a sign of the marketplace growing up. Recalls can be seen as a good thing, a sign of proper safety measures in place to prevent further contamination. Reporting recalls or failures means that professionals are beginning to pay attention to the safety and quality of processes in place at cannabis production facilities. Looking at the long-term sustainability of the cannabis industry, keeping quality and safety at top of mind will help businesses self-legitimize. Those not striving for the safest practices and the best quality will lose their ability to compete as the market continues to grow. Recalls can tarnish a company’s brand, but they also indicate that the industry has reached a point of legitimacy. Cannabis is now out of the closet and under a microscope.
As of now, it is difficult to find information available on pesticide use and flowering, its effect on the body through combustion and inhalation, and its effect on medical patients with already weakened immune systems. Research suggests up to 69.5% of pesticide residues can stay in marijuana smoke. Of course, there is a need for more research, but it is safe to accept that pesticides already banned for use on foods by the USDA or state departments should not be allowed in cannabis production.
The Oregonian and OregonLive investigation found pesticides in most of the 10 marijuana concentrates that were screened. “Many of the pesticides detected aren’t regulated by Oregon’s medical marijuana rules, which means products that contain these chemicals still can be sold.”
Just last week, two of the largest recalls in the cannabis industry occurred in Colorado due to potential pesticide contamination. According to The Denver Post, as many as 30,000 packages of edibles produced by two companies were recalled by the Denver Department of Health.
Alex Garton, a cultivator in Michigan, agrees with many proponents of organic methods, citing the need for close management of the plants without pesticides. “The best way to avoid pests is to keep the grow room clean,” he says. “Mites will come and go, as will temperature and humidity issues, but without using pesticides, there are some safe, natural products that are very effective.”
“I treat my plants with natural compounds that are permitted under the federal government’s guidance for use in vegetable applications for human consumption,” Garton adds. “Never use anything remotely resembling a pesticide on flowers particularly when maturing and in the flowering process.”
Adam Jacques, master cultivator and owner of The Growers Guild in Eugene, Oregon, agrees with the sentiment of caution shared by many in the industry. “I would say, nationwide, there needs to be a more in depth look at pesticides, even organic strawberries can have [the pesticide] Eagle 20 on them,” he says. “With cannabis, we can’t scrub and wash pesticides off like fruit that you take off the vine, and there is a real lack of research on residues and combustion.”
Jacques tests all of his cannabis products for pesticides, molds, microbials and pathogens along with potency profiles, most of which is not required by the state. Growers should take lessons from Garton and Jacques by forgoing any application of pesticides until there is more confident state-level guidance on the dangers associated with pesticides on cannabis.
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.
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
Improper Cleaning and Sanitizing
Poor Personal Hygiene
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.
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.
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.
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.
Is your team using gloves or utensils to handle all ready to eat foods?
Do you wash hands prior to gloving?
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.
With cannabis-infused edibles gaining a bigger market share in 2014 (See the marijuana edibles regulatory update here), it comes as no surprise that cannabis-infused beverages are growing in popularity. Some of these beverage manufacturers operate in a very interesting legal environment because of the differentiation between compounds found in hemp and marijuana, two different varieties of cannabis.
“Under federal legislation, there is an exemption for hemp and as long as we process our CBD (Cannabidiol) molecules from the hemp plant, we are allowed to sell our products federally,” says Chris Bunka, CEO of Lexaria, a company that makes a hemp-infused tea.
A number of scientific research studies have suggested that the compound CBD has medical properties that can help mitigate symptoms like inflammation, anxiety, chronic pain, and much more.
Because of the federal exemption for hemp, Lexaria can enjoy interstate commerce and other freedoms that manufacturers using marijuana flowers do not, such as access to banking services. Dried marijuana flowers contain the psychoactive compound, Tetrahydrocannabinol (THC). This compound is responsible for the regulatory and legal schism between the states that have legalized marijuana and the federal government, which still considers it to be a Schedule I narcotic.
Much unlike a number of marijuana edibles manufacturers operating in states where marijuana is currently legal, hemp-infused beverage manufacturers operate in full FDA compliance.
Michael Christopher, founder of Loft Tea, is working with a laboratory and bottler that are both 100% FDA compliant. “We definitely operate up to and abide by all FDA best practices with our laboratory and as far as producing and handling material we use best manufacturing practices and processes,” says Christopher.
“We have to partner with a bottler and laboratory who have the reputation to build trust with our brand as an industry leader in safety and quality,” says Christopher. “Until the FDA gives us complete guidelines on cannabis-infused products, we will continue to operate above and beyond best manufacturing practices with our infusions.”
Because these manufacturers view their hemp tea as a health and wellness product, it is only a matter of time before we see these types of products lining the shelves of health-food stores nationally. However, before this happens, an FDA regulatory framework specific to hemp-infused products is needed to address this growing industry.
“The hemp infusion industry has a lot of opportunity when presented in the right framework,” Christopher says. “There is still education needed in the marketplace to get it to the point where it will be on the shelves in stores like Whole Foods.”
Until that time comes, expect to see a steady growth of interest and inquiry from consumers, manufacturers, and regulators alike in the cannabis industry, whether federally legal or not.
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