Tag Archives: growing

By Brett Giddings, Olivia L. Dubreuil, Esq.

As with any product, packaging has a vast range of sustainability considerations that should be accounted for in its design, development and use. Often the most visible component of any product, and certainly so for most forms of cannabis products, packaging is a key sustainability issue for the entire cannabis supply chain.

What is sustainable cannabis packaging and what does it look like? This can be a loaded question, but one we can revisit after considering the basic functions of packaging.

Cannabis packaging, and packaging generally, is designed to perform three basic functions: protection, preservation and promotion. If it does not adequately address these three areas then the chance of product failure, loss of consumer trust and increased waste is likely.

Let’s take a high level look at each of these:

Protection: Whilst cannabis is not currently travelling huge distances, like some of the food we consume, protection is key at each point of the supply chain. Inputs into the growing process often come packaged, flowers and such are packaged for shipping and storage, bulk-packaged cannabis is sent to dispensaries, extractors, etc, and ultimately re-packed into what will become the consumer-facing packaging. Importantly for cannabis, it may require an additional level of protection to ensure children are not able to access the contents.

Preservation: Like any consumable item, cannabis has a shelf life, and packaging plays a key role in preserving the usability of the product. Whether it is a chocolate, a cannabis-infused drink, or flowers, it is critical that each product maintains a certain level of quality and consistency.

Promotion: Packaging allows one part of the supply chain to communicate specific elements of a product to those further along the supply chain. The most obvious, and for cannabis probably the most important, is the communication of contents within a packaged item (labeling), such as the percentage of CBD in a gummy or origin of a particular bud. Packaging is also the reflection of a brand, an image.

Taking these basic elements into account, we can apply a framework for designing and choosing more sustainable packaging. This framework for cannabis packaging accounts for and balances four principles: Fit for purpose, efficient, low impact and re-usable.

Fit-for-purpose. Essentially, this involves making sure that the packaging adequately performs the ‘3-Ps’ above. Packaging commonly accounts for less than 10% of the energy inputs that have gone into a complete product (for example, a candy packaged in a foil-lined plastic wrap). If the packaging fails to protect and preserve the candy, then the energy (or the water, the material, the investment) embedded in the product it contains is wasted.

The second principle relates to material efficiency. Once the packaging works, it is then important to minimize material and resource inputs. Effectively designed packaging uses lighter-weight materials and reduced numbers of materials and components. It also reduces air space and maximizes transport yields.

The third principle involves using low-impact materials. Material inputs should come from non-controversial sources, such as verified/certified supply chains and suppliers that have been assessed to ensure appropriate sustainability-related issues are addressed. Wherever possible, consider renewable and recycled-content inputs, and those made using renewable energy.

Finally, cannabis packaging should be re-usable, recoverable and/or recyclable at end of life. Consider materials and design formats that can be reused multiple times, and packaging that can be recycled and composted by consumers in the systems readily available. Linking back to the third ‘P’, Promotion can be used to make sure that your packaging clearly communicates what someone should do with your packaging. If it is recyclable, returnable, reusable or plantable, tell them it is and how to proceed.

Bear in mind that the most sustainable packaging options are often the result of thinking outside the box. The design process of your packaging should include brainstorming and researching outside of your own industry. What are new and innovative solutions, new materials, new ways to think about product conception that could negate the need for unnecessary packaging elements. New and innovative packaging solutions can raise your business’ profile, catch consumers’ attention and attract investors. It showcases your business as a forward-thinking one.

Packaging sustainability can look different for each and every cannabusiness. It is important to make sure that the four principles are part of your packaging selection/design process. As with any other sustainability issue, it is best to start thinking about packaging early on, and considering packaging as a part of the actual product system.

If you are not thinking about packaging sustainability, be assured that regulators, consumers and your industry peers are. Make sure you are driving the discussion about packaging, rather than being driven by those who may not fully understand your packaging needs.

September 6, 2016

Adam Jacques and Team Launch Sproutly, Dispensary in Eugene, Oregon

By Aaron G. Biros

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Adam Jacques and his team officially launched the newest arm of their business last week, Sproutly, a dispensary located in Eugene, Oregon. “This is an extension of what the Grower’s Guild Gardens does and what the Microgrower’s Guild was,” says Jacques. The Grower’s Guild Gardens, Jacques’ award-winning cultivation business, is known for their high-CBD genetics and patient-focused work, most notably with Leni Young, which helped lead to the passing of legislation in Alabama called Leni’s Law, decriminalizing the possession of cannabis oil for patients in the state.

Sproutly’s shelves boast over 75 strains of cannabis from Jacques’ farm.

Sproutly is a medical and recreational dispensary that boasts a wide variety of high-CBD strains, a reflection of the team’s focus in the past. “We are extremely medically focused with a variety of unique CBD strains in stock,” says Jacques. “First and foremost are the patients, but entering the recreational market means we will be carrying a wider variety.” The opening of the dispensary is well timed as the team received their Tier II cultivation license, allowing them to grow cannabis up to 20,000 square feet in an outdoor space and 5,000 square feet indoor. So in addition to the handful of brands they carry, including Lunchbox Alchemy edibles, Northwest Kind and Marley Naturals, they also carry over 75 strains from their own Grower’s Guild Gardens.

Adam Jacques in front of a display shelf at Sproutly.

Adam and Debra Jacques pride themselves in rigid standards for quality in sourcing, so it should be no surprise that they plan on supplying their dispensary with over 150 strains coming from more than 1,200 plants on their farm. “We really only take products from people we know and trust,” says Jacques. “That is why most of the flower in the dispensary is coming from our farm, so we know exactly what is going into it.” Jacques points to third-party certifications such as Clean Green, for other vendors to find reputable growers. “I need to know where it is coming from and that requires a personal relationship to trust the quality of their products.” The value of trust and personal relationships is also why they go through extensive training of their staff, using their own expertise for in-house training.

The team includes Chris West, Elton Prince and John De Kluyver, all of whom have a decade or more of experience cultivating cannabis and working with patients. “We take our bud tenders through training classes, they get tested on their knowledge of products and the science of cannabinoids and terpenes and how the combinations affect people differently,” says Jacques. By leveraging that high level of in-house expertise, the team prides themselves on customer service, helping patients and customers find the right strain or product that suits them best.

In the front of the dispensary, a receptionist greets patients or customers, checking identification and showing you to a bud tender. As you walk into the retail space, you immediately notice the professionalism of the staff, taking time to personalize each customer’s experience without making him or her feel rushed. The clean aesthetics, product selection and knowledgeable staff provide for a friendly retail culture without the common ‘stoner culture’ that usually follows.

Jacques and his team will not be trading in their overalls and work boots just yet as they are inching toward harvesting their 1,200 outdoor cannabis plants soon. Grinning ear-to-ear, Jacques showed off his Tier II cultivation license on the farm, and with it came a glimpse into their exciting growth.

September 6, 2016

Quality From Canada

The Devil is in the Detail – Changes to Canada’s Cannabis Regs to Encourage Patient Independence and Business Competition

By Tegan Adams, Elfi Daniel-Ivad MSc

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Canada’s new ACMPR was launched late last month on August 24^th. The key change that most notice is that Canadians may now again grow their own cannabis at home for medical purposes. In addition, more strict guidelines for product testing and labeling requirements for Licensed Producers (LPs) were released.

Short term pain for long term gain. While the combination of allowing patients to grow at home and more strict regulations for LPs may at first seem like a business disadvantage; overtime LPs will be thankful for the combination switch. Health Canada’s new requirements encourage a leveling of the playing field globally between LPs and large scale product manufacturers of pharmaceuticals, therapeutics and natural health products. The steps Health Canada is taking to regulate our producers, is exactly what they need to get ready for mass production that will be necessary for recreational markets, scheduled for release in Spring 2017.

Picture rows of Tylenol bottles on the shelf at your favorite pharmacy. Now picture rows of cannabis bottles on the shelf beside them. This is what medical cannabis will look like in Canada perhaps as early as 2018, if not sooner. With just under forty LPs on the map and a projected sales volume of modest billions, Canada’s LPs’ eyes are widening with dollar signs as they lube up their oil production and more to see what shelves in Canada will hold.

Curious to know more? Our regulatory department manager Elfi Daniel-Ivad is an expert in regulatory change. She has worked on close to 150 submissions for cannabis licensees in Canada and beyond. Here are a few key changes from her department’s overview to better understand.

MMPR	ACMPR (Updated)
No personal production or designated production available to patients (aside from that grandfathered in by MMAR).	Personal production and designated production available. Patients may grow 5 indoor plants OR 2 outdoor plants at any given time per gram prescribed to them.
Licensed Producers were not required to label THC or CBD amounts in dried cannabis, though most producers did for sales and educational purposes. Oils had to be labeled with THC and CBD amounts.	Licensed Producers must label their percent THC and CBD for dried and fresh cannabis products.
For the labelling of oils, the total quantity of THC, CBD and oil in a container had to be shown. Restrictions on THC allowed no more than 10mg/mL THC per capsule and no more than 30mg/mL THC per mL oil to be distributed.	In addition, oil labels must now include information on “carrier” oil and allergen information. Containers must be labelled with number of capsules, the net weight and volume of each capsule. .
No reference to validation of analytical testing methods.	Analytical testing must be completed using validated testing methods; confirming reliability and consistency in results for contaminants, disintegration, residues and THC, THC-A, CBD and CBD-A
Accredited labs can only test products as received from Licensed Producers.	In addition to Licensed Producers, patients growing their own or having a designated grower growing for them may also test their products at an accredited lab.

In addition to these changes, it is important to note that if an individual or company has an MMPR proposal already submitted they can now revise it to include oil production (previously, it was first dried bud only). If a company submits a new ACMPR proposal, they can include oil production on their application right away. Interested in submitting your own application? Or need help with one in the USA? Our regulatory department would be happy to answer any questions you might have about the process.

July 14, 2016

Soapbox

Learning from the Horticultural Industry at Cultivate’16

By Nic Easley

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This past week, over 10,000 individuals traveled to Columbus, Ohio to attend Cultivate’16, a conference hosted by AmericanHort, an organization dedicated to leading and unifying the horticultural industry. Cultivate’16 had hundreds of vendors displaying the latest technology and equipment for greenhouse production, design and controls along with the latest innovations in software, manufacturing, automation and more.

For all of the energy surrounding the nascent cannabis industry, there was very little representation from it at Cultivate’16. Our associates encountered an estimated thirty cannabis industry professionals, compared to an estimated total of 10,000 attendees. This further compounds the reality that the cannabis industry is still a very young industry when compared with the more mature and well established industries such as conventional agriculture, finance, information technology and others.

At Cultivate’16, there was enormous potential for businesses in the cannabis industry to learn from the traditional horticultural industry. The horticultural industry has had to become extremely efficient with its capital, resources and time in a manner which the cannabis industry has not had to accommodate yet. There were automated container filling machines, cost effective nutrient solutions and greenhouses that are controlled wirelessly. Those were just a fraction of the products and systems that could save cannabis cultivators hundreds of thousands of dollars.

Horticulturalists have been forced through shrinking margins to increase their output and savings. The horticultural market is expanding at an average rate of 5% per year as opposed to the cannabis market which is currently growing at a rate of 68% year over year. Cannabis operators can still get anywhere from $1,200 to $1,400 a pound in most legal markets on the lower end. This is in comparison to basil at $4 a pound. This difference is stark. It means that cannabis cultivators are not under the same pressure to be efficient as other traditional crop cultivators. It is clear though that with increasing legalization of cannabis in both the medical and adult use markets that the price of cannabis will fall. Therefore, it would be wise for the cannabis professionals to attend events such as Cultivate’16 in greater numbers to prepare for the eventual decrease in price.

3C Consulting was present at Cultivate’16 because we understand the importance of looking to other successful industries for guidance. We were able to converse with a diverse array of vendors and business owners to further our own knowledge on the best practices to bring to the cannabis industry. To be able to learn from those that have come before you is a strength, not a weakness. Far too often the cannabis industry seeks to reinvent the wheel. It does not have to be this way.

By learning from other industries, utilizing the latest horticultural technology and becoming more cost-effective the cannabis cultivators will be able survive and thrive. It is those that prepare for turbulence that are best able to capitalize on change. In the Chinese language, the word for crisis is the same as the word for opportunity. It is wise to prepare for a crisis so that when it does occur you are able to transform it into an opportunity.

June 1, 2016

Soapbox

Cannabis, Soil Science and Sustainability

By Drew Plebani

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The average commercial cannabis cultivator seems to be following the modern agricultural paradigm. That model is based on questionable and, one might say, ineffective soil systems management.

In the high-yield cannabis world, amidst decades of prohibition, following the lead of the modern agricultural model has resulted in the adoption of cultural practices that go something like this: Use and destroy the soil, then dispose of it once it is rendered lifeless and useless due to repeated heavy applications of chemical fertilizers, pesticides, and other poisons.

commercialcultivator — (Left) unimproved site soil next to (right) improved site soil. Notice the root mass developing on the right

Certainly conventional agricultural food production and the soil management systems underpinning them are faltering, evidenced by soil systems deteriorating many times faster than they are being improved. This qualifies as a failure in my book.

What will be the fate of profit margins, sustainability and medicine in the cannabis industry if we continue to follow blindly in the footsteps of chemical agriculture? Perhaps it is time to turn over a new leaf.

A little context for the discussion: scientists say the Earth has lost a third of arable land in the past 40 years, and some say soil erosion is the number one challenge facing the world today. Why? How?

Well…world agricultural production accounts for about three-quarters of the soil erosion worldwide. This steep decline in arable soil is occurring during a time when the world’s demand for food is rapidly increasing. It is estimated that the world will need to grow 50% more food by 2050, and it is important to note that, the total volume of food necessary, remains relative to the nutrient density of the food.

Time for a radical solution, and cannabis can lead the way.

Currently, cannabis is the most profitable crop per land area and very likely the most resource-consumptive crop grown (due to the current legal and regulatory climate and thus limited supply vs. demand).

As the cannabis industry continues to grow, now more than ever we have the opportunity, and I believe the responsibility, to cultivate in ecologically mindful ways, improve the end product and it’s positive impacts, increase both short-term and long-term profits, decrease or eliminate waste and lower the carbon footprint of cannabis cultivation operations.

Most importantly, we have the opportunity to fund, implement and lead the way in research and development of sustainable, medical, phytonutrient-dense crop production methodologies.

Only by implementing more rigorous scientific methods to cannabis cultivation can we hope to provide truly meaningful improvements in and contributions to the fields of agriculture, science, medicine and human health.

While dumpsters of potting soil continue to roll off to the landfill, complex health and human science and the cultivators truly engaged in science will continue to provide meaningful data regarding plant compounds and what factors influence the best outcome for the desired end product.

I am willing to bet that what is best will not be coming from the business models employing antiquated, wasteful and destructive cultivation strategies, and that in due time these models will fade into distant memories.

This is the first in a series of articles, in which we will explore topics related to the pursuit of high yield, phytonutrient-dense “high brix” cannabis production.

The next article will provide a historical and geologic context to the cannabis plant, as viewed from the scope of soil biology and the progression of ecosystems and soil types, and how maximized genetic expression, through maximized soil and plant health influence the production of high quality cannabis.

May 23, 2016

Building or Converting to a Greenhouse? Four Considerations for Commercial Growers

By Taylor Engert

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Successful cannabis cultivation practices leverage commercial agricultural industry practices for the most efficient and cost-effective production of the crop. Since the 1990s, the cannabis industry has cultivated primarily in indoor warehouses and outdoor farms, however the industry is experiencing a significant shift toward greenhouses.

Shelly Peterson, vice president of light product solutions at urban-gro, joined a recent panel of industry experts including Shivawn Brady, chief executive officer and founder of Seva Crop Consulting, and Karl Keich, executive director at Canna Consulting Group, at the Marijuana Business Conference in Orlando, Florida, to discuss how to transition from an indoor or outdoor grow to a greenhouse facility.

What are the considerations when deciding between a warehouse and greenhouse? The panel shares four factors around the costs and operational challenges, and the benefits of a greenhouse.

Maximize Efficiency in Every Process

Why are cannabis cultivators looking toward greenhouses? Peterson says it is all about efficiency. “In a warehouse, electricity costs can run up to 50 percent of the total cost of goods sold, which is a tremendous amount that can be decreased by switching to a greenhouse,” says Peterson. “In a greenhouse, you can add supplemental lighting to augment what the plant is receiving from the sun.”

For cultivators, Peterson noted that it is critical to ensure growers have experienced vendors and advisors on the team to help maximize the efficiency of the greenhouse. “As the cost of this product comes down, the efficient growers will be the ones in it for the long haul,” added Peterson.

Construction vs. Operating Costs

A greenhouse facility that urban-gro helped bring to operation.

The panel identified upfront cost as one of the biggest challenges faced when building out a greenhouse. “The cost of retrofitting a warehouse and building a greenhouse are similar, but where you will save is in the operational costs,” says Peterson. “Lighting can be up to one third of your total cost in indoor facilities, when you switch to a greenhouse that cost can be reduced by 50 to 70 percent.”

Brady acknowledged that some traditional greenhouses have challenges in controlling the environment, but automated greenhouses offer retractable roofs and siding. “If you have the resources to invest in your greenhouse system upfront, that is generally a better way to save money in the long run,” says Brady. “Managing pests in greenhouses can also become very challenging if you don’t have the proper climate regulations.”

Lighting for Your Greenhouse

One of the greatest benefits of growing in a greenhouse is the ability to source natural light. But what about the required light levels? Peterson pointed out that light levels change throughout the year and the plants have different light needs in different stage. Supplement with a lighting system that can read the natural light levels received over any given period of time and be adjusted accordingly. “Greenhouse facilities also need to be outfitted to meet the needs of the cannabis plant, which differ in some ways from other agricultural crops,” says Peterson.

Peterson explained that every light is designed with a different purpose in mind. “There are different lights for indoor warehouse facilities where the lighting system provides 100 percent of the available light for cannabis growth versus supplemental lighting for greenhouses,” Peterson adds. “The key is to measure how much light is actually delivered by the sun on a daily basis, which changes throughout the year; at urban-gro, we supplement the facility with light fixtures that will not create shadowing during hours of sunlight and adjust to reach the optimal collective light levels.”

With LED lighting a hot button topic, Peterson explained that the most important consideration for any light fixture, whether LED or HPS, is it’s efficiency capacity. “It all depends on the budget and payback period and a lot of numbers need to be crunched,” says Peterson. “Yield is directly correlated to light; planning properly, sealing your environment, making sure you have the right target DLI, and buying good light meters, are all key.”

Make a Positive Impact and Quality Product

Brady noted that industry leaders are conscious of positive impact towards human health and environmental stewardship when moving to a greenhouse. Cultivators may find the process challenging initially, however the facilities are quite easy to operate and manage, and allow stress-free cultivation of commercial-scale crops.

Keich added that the cannabis industry is becoming more like commercial agriculture. By utilizing the correct technologies and regulators, greenhouse cultivation makes the crop smell, taste and look that much better. “Let’s use natural sunlight to minimize costs and be environmentally friendly to produce a superior product,” says Keich.

Peterson wrapped up by stressing that cultivators should evaluate the greenhouse environment and lighting to improve their bottom line. “Look at the most efficient way to lower your cost of goods sold. Lighting is a very big component to that,” she continued. “Make sure you evaluate the efficiency of the fixture and ask the questions: Why are we targeting this light level? Is the color spectrum correct? Are you measuring in micromoles per watt? These are all different questions, however figure out how much light is coming out of the fixture and verify it for yourself, and you will be successful,” says Peterson.

May 18, 2016

Solutions for Cannabis Cultivation: Integrated Pest Management

By Aaron G. Biros

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Pest problems in cultivating cannabis such as spider mites and powdery mildew are major concerns facing growers on a daily basis. Colorado’s ongoing recalls for cannabis products containing pesticides serve as a reminder that pest problems continue to plague growers. Utilizing integrated pest management (IPM) can help reduce the need to use any pesticides, as well as mitigate the risk of unwanted pests wreaking havoc on a cannabis harvest. urban-gro, a solutions provider for commercial cannabis cultivation, builds IPM plans for large-scale cannabis growers tailored to meet specific needs in regulatory compliance for different states.

Biological controls are essential to any proper IPM solution for growers. Beneficial living organisms such as insects, mites, nematodes or entomopathogenic fungi can all be applied as a method for controlling pests. Biological controls like those can reduce the need to use pesticides on cannabis. John Chandler, vice president of cultivation technologies at urban-gro, believes IPM requires a broad, systematic approach to eliminate the need for pesticides. “IPM is a combination of cultural, chemical and biological control,” says Chandler. “We start by evaluating the air flow of the facility, how plants are transported, any exclusion barriers and air filtration.” A robust IPM plan begins in the design phase of a new facility. “We can make key adjustments in floor plans, layouts and mechanical systems to optimize that first line of defense that is critical to mitigating the risk of pest issues.” Incorporating good agricultural practices can also help mitigate those risks.

durangopot — A close-up of a plant entering flowering at the Durango facility

“We help develop standard operating procedures with good agricultural practices in mind, including preventing cross contamination, which is the biggest pest issue facing cannabis growers,” says Chandler. “I encourage clients to set up harvest and vegetative rooms so that the plants are moving in one specific direction between rooms rather than back and forth.” Using positive air pressure with proper ventilation can further prevent cross contamination. Chandler also recommends scrubbing air coming into the building with gaseous hydrogen peroxide to keep filtering air in ventilation.

According to Mark Doherty, director of sales at urban-gro, their IPM plans are customized to meet different states’ rules and regulations, including each list of approved pesticides. “We work to design a system that meets each individual grower’s needs, while helping them navigate regulations in any given state,” says Doherty. “It is important to make cannabis safe for patients and IPM is critical in building a healthy ecosystem for plants to be grown in a safe, yet cost-effective manner.” Proper use of IPM can reduce the need to use pesticides, which could impact a cultivator’s bottom line, but ultimately protect patients’ wellbeing by providing safe and pesticide-free cannabis.

prosodic — Procidic works on contact and with residual action.

When all else fails and pests still find their way onto cannabis, there is a solution to address major losses. urban-gro distributes a product called Procidic2®, a broad-spectrum bactericide and fungicide compound, manufactured by Greenspire Global. The advanced commercial formula is designed to eliminate pathogenic bacteria and fungi. Procidic2® can be applied as a preventive and a curative. WSDA Organic Program has approved Procidic2® for use in organic agriculture production and handling. According to Steve Knauss, president of Greenspire Global, “Procidic2® works in sync with the plant through two modes of action: First it controls powdery mildew and gray mold on contact, and secondly it is absorbed systemically into the plant to control disease infection such as root rot,” says Knauss.

Implementing a comprehensive IPM system requires making key changes in cultural, biological and chemical controls. In doing so, growers can successfully mitigate the risk of pest problems, thus reducing the need for potentially harmful pesticides.

April 29, 2016

BudGloves Makes Handling Cannabis Safer

By Aaron G. Biros

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Kush Bottles, a packaging provider specific to the cannabis industry, recently launched the product BudGloves aimed at reducing the amount of human contact to cannabis products. The company is known for their child-resistant, regulatory compliant packaging.

The product BudGloves is the first glove of its kind engineered specifically for cannabis. The nitrile gloves do not contain any powder and are designed to prevent any transfer of resin, latex or powder to the cannabis. They are also slightly thicker than most other gloves to avoid getting caught or tearing, extending their life to withstand the typical shift of a trimmer or processor.

Nick Kovacevich, chief executive officer of Kush Bottles, wants to see a standard for preventing human contact with cannabis products to reduce the risk of contamination or loss in quality. Whether it is during cultivation, trimming, inspection, processing, transferring cannabis to instrumentation or even at the point of sale, it is important to minimize human contact to the cannabis.

“In California, we see bud tenders in dispensaries actually reach in a jar and grab cannabis to show the patient without gloves, which is a terrible standard operating procedure,” adds Kovacevich. “I would want all bud tenders to handle cannabis with gloves on.”

Particularly when handling food-grade products, most health code regulations require the use of gloves like these. According to Kovacevich, oils and extracts can be at a greater risk of contamination. “It is imperative that concentrates and extracts, especially those with activated THC, are handled with gloves to prevent any outside materials or contaminants from sticking to them,” says Kovacevich. The gloves are manufactured to meet stringent quality standards. To promote safety and quality of cannabis, reducing human contact with the product should be an important part of any company’s employee manual.

April 28, 2016

Biros' Blog

Ongoing Pesticide Recalls a Sign of Industry Maturity

By Aaron G. Biros

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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.

April 20, 2016

The Importance of Traceability

By Aaron G. Biros

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With the news of Pennsylvania’s medical cannabis legalization measure passing, lawmakers are clamoring for strict regulatory oversight in the form of traceability to prevent diversion and misuse. State Senator Daylin Leach (D- Montgomery/Delaware) introduced the bill and believes it will have the most intensive protections for safety in the country. “Our goal was to create a system that helps as many patients as possible, as soon as possible and as safely as possible,” says Steve Hoenstine, spokesperson for State Senator Leach. “The seed-to-sale tracking system and the bill’s other protections do just that.”

At the recent Cannabis Labs Conference, Cody Stiffler, vice president of government affairs at BioTrackTHC, discussed why traceability is so important. Stiffler previously served as the chief executive officer of the American Medical Management Association, where he fought the Florida prescription drug abuse epidemic. “We originally started tracking prescription medications and methamphetamine precursors to combat the prescription drug abuse and meth epidemic in Florida,” says Stiffler. He focused on providing accountability and traceability, making sure every prescription was legitimate and keeping drugs off the black market. Implementing tracking protocols allowed for the accountability of pharmacists, physicians and patients.

The primary goals of a traceability system, according to Stiffler, are to prevent diversion and promote public safety. “We want to advance the cannabis industry with respect to traceability and regulatory compliance by integrating laboratory testing with traceability,” says Stiffler. “Our software helps get safe products to patients and consumers in a responsible manner.”

Stiffler’s role at BioTrackTHC is to provide industry insights to states looking to legalize cannabis and support them with identifying the best practices that meet requirements in their state. Traceability is commonly defined as the ability to verify history, location and application of a product from source to distribution. BioTrackTHC’s tracking software covers everything from seed to sale, involving regulatory bodies in oversight. In the beginning of cultivation, each plant is assigned a bar code or sixteen-digit identifier. According to Stiffler, Colorado’s system uses radio-frequency identification (RFID) tags while Washington’s system gives the business a choice because the software can work with any type of identifier, whether it is a barcode, QR code or RFID tag. “Our system generates those numbers and prevents diversion with a closed loop system,” says Stiffler.

Washington, Illinois, New York, New Mexico and Hawaii are the five states that use BioTrackTHC’s software. “If the state wants to see the chain-of-custody, they can go back in the system and see every touch point and the full life cycle of the product in real time,” says Stiffler. “Our system also incorporates lab testing to ensure no product reaches shelves unless test values are associated with it.”

flowcharttracking — A flowchart showing tracking from seed to sale.

For many states, problems lie not in diversion, but inversion, where black market growers bring their products into the legal market. “A lot of people growing black market product are inverting it into the regulated market,” notes Stiffler. This kind of black market activity can flood the legal market with un-tested cannabis.

Product recalls are examples of when traceability software can be very useful. Pesticides, microbiological contaminants, heavy metals and other contaminants are at issue. Stiffler invokes an example from a company in Washington making THC-infused drinks. “Because of an issue in the manufacturing process, the bottles were exploding in refrigerators and on shelves,” says Stiffler. “Because the product’s lineage was completely tracked, we could isolate all of the products in that specific batch from that specific manufacturer and then forward trace to every retailer that had it in inventory,” he adds. “Whenever someone who did not get the recall notice would attempt to scan that barcode at point of sale, a message appeared noting its recall status and that it is not for sale.” The software’s financial data analytics can provide real time visibility for profit margins or losses resulting from recalls.

According to Stiffler, these kinds of protections in place give law enforcement and government agencies piece of mind that they are helping to prevent diversion and promote public safety. Traceability software is one of the very important safeguards protecting food safety and product safety.