Tag Archives: SOPs

Radojka Barycki picture

Food Safety Planning for Cannabis Companies

By Radojka Barycki
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Radojka Barycki picture

Food safety incidents can be prevented. However, prevention requires planning, which requires the effort of everyone in a company to create a culture of quality and food safety. How exactly do you plan for food safety? Food safety planning implies the building of a food safety management system. Food safety management systems allow for an efficient management of hazards that may be present in the food by the development and implementation of pre-requisite programs (PRPs) and a food safety plan, while supported by management commitment. So, let’s take a closer look at each of these building blocks:Radojka Barycki will lead a plenary session titled, “Cannabis: A Compliance Revolution” at the 2018 Food Safety Consortium | Learn More

Management Commitment

The development and implementation of a food safety management system requires financial, equipment, and technically sound personnel in order to be successful and sustainable. The management team of any cannabis product manufacturer must be committed to food safety, so the needed resources to develop and implement a food safety management system are provided. Management commitment creates a culture within the operation that supports, sustains and continuously improves food safety. 

Pre-Requisite Programs (PRPs) 

Pre-requisite programs are procedures that establish the minimal operations conditions to produce safe and quality products. Pre-requisite programs are the foundation of food safety and must be developed and implemented prior to creating a food safety plan. They keep potential hazards from becoming serious enough to adversely impact the safety of products produced. Pre-requisite programs include but are not limited to:

  • Document Control
  • Supplier Verification Programs
  • Raw Material Receiving (ingredients, processing aids and packaging)
  • Good Manufacturing Practices (GMPs)
  • Preventative Maintenance (PM) Program
  • Calibration Program
  • Integrated Pest Management (IPM)
  • Environmental Monitoring Programs (EMPs)
  • Water Management Programs (WMPs)
  • Allergen Management Program
  • Standard Sanitation Operating Procedures (SSOPs)
  • Standard Operating Procedures (SOPs)
  • Storage and Transportation Procedures
  • Crisis Management
  • Traceability
  • Recall
  • Record keeping
  • Waste Management
  • Training

Food Safety Plan (FSP)As you can see, food safety planning requires the development and implementation of a lot of programs.

A food safety plan is a documented systematic approach that follows the Codex Alimentarius HACCP Principles to identify, prevent and minimize to an acceptable level or control hazards that may be present in food and that can cause an illness or injure the consumer. The first step in this systematic approach is the formation of a food safety team, which main responsibility is to identify the scope of the food safety plan and to oversee all of the activities associated with the plan (e.g. monitoring, verification, validation, etc.) After the food safety team is formed, the steps outlined below are followed in order (systematically):

  1. Product Description
  2. Product Intended Use
  3. Development of the flow diagram
  4. Verification of the flow diagram
  5. Conduct a Hazard Analysis
  6. Identify Critical Control Points (CCPs) or Preventive Controls
  7. Establish Critical Limits
  8. Monitor Critical Limits
  9. Establish Corrective Actions
  10. Establish Verification Procedures
  11. Establish Record Keeping Procedures

As you can see, food safety planning requires the development and implementation of a lot of programs. Therefore, I highly recommend that you hire a food safety consultant that can guide you through this process.

budgloves

BudGloves Makes Handling Cannabis Safer

By Aaron G. Biros
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budgloves

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.budgloves

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.”rsz_budgloves2

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.

Marijuana Matters

A Guide to Documentation and SOPs for Start Ups

By David C. Kotler, Esq.
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As your company grows, or whether you want to have certain documentation to make an application for licensure and/or for outside entities looking to invest, it is necessary to handle issues from a documentation standpoint. Learning how to handle situations with staff through proper employee manuals and how to establish and practice standard operating procedures can help businesses avoid common pitfalls with a little forethought.

Beginning with standard operating procedures (SOPs), there are many resources available to get assistance in crafting them. You can consult with individuals such as safety content producers, business consultants, lawyers, technical writers, and even borrowing SOP writers from other industries. I am aware of a Connecticut producer who tapped pharmaceutical SOP writers as consultants with the focus of establishing their standard operating procedures. I am not convinced that there is any proper person or method by which an entity may want to consider an SOP. As a threshold, however, it is important that a proper format is created, i.e., simple steps, hierarchical steps format or perhaps even a flow chart format.

One would want to consider the audience who will be reading the SOP and the information to impart to that audience. It is also important to consider SOPs that you want to update as practices evolve or change.

It is possible to create SOPs internally, and frankly, this may be the most recommended route. If the SOPs are being used for guidance and not just to support the license application process, this is particularly important. It is a time-consuming task and if created from the inside out, it can be most effective.

It is possible to get lost in the minutia by documenting every step taken within a particular process. I have seen SOPs number in the hundreds just for cultivation and processing operations. One particular entity in Colorado created over 63 SOPs within the past year. If you are writing your own SOPs, it is important to understand the scope and applicability, i.e. why a particular process is performed and how it is used, then the procedures and/or steps that are necessary to accomplish that particular process, clarify any terms that are necessary so that the reader is able to follow the steps throughout a particular outline, cover health and safety issues, address equipment and supplies and provide emergency procedures.

The process that I can attest to as being fruitful is interplay between an employee who is actually responsible for a given task and a third party looking from a 1000-foot view. For instance, have the employee who completes a number of tasks within the organization provide a list of what they do on a general day-to-day basis. From that list, have the third party extrapolate what topics might be covered, often times borrowing from other well known standard operating procedures that are seen across industries and come up with a master list of the SOPs which are desired. It is important for the employee and third party to collaborate to finalize SOPs.

Employee guides or manuals provide information on benefits, when time sheets are due, paydays, holidays, vacation days, sick days and more. For employees, it helps mitigate risk by providing guidelines for conduct, discipline, and local practices in the states in which you operate. Employee guides are most effective when they are created to match your company’s needs. When it is tailored to your company, you are certain that the policies meet the laws of the places where your offices and employees are located. It allows you to provide input so you can ensure that you have developed policies that your company will follow. Unwritten policies are unwise as they may cause issues and can potentially lead to lawsuits. There are three types of multi-state employee guides: a guide with favored nations status, meaning that the most liberal laws in one location apply to the entire organization; an employment guide for each location in which you operate; or you can create one guide with a local practice section.

Creation of employee guides is a time consuming and arduous practice, but once completed, they help guide the relationship between employee and employer. Employees should review the employee manual and sign off upon receipt and review. This will serve to protect the employer in the future should an issue covered by the manual arise.

An effective employee guide might include (but certainly not be limited to) the following:

  • An “employment at will” disclaimer
  • An anti-harassment policy
  • An internal grievance procedure
  • Equal Employment Opportunity (EEO)
  • Employee benefits
  • Paid time off (vacation, personal days, sick leave)
  • Unpaid leaves of absence
  • Americans with Disabilities Act (ADA) (for employers with more than 15 employees)
  • Jury duty, military leave
  • Hours of work
  • Introductory/probationary period
  • Legally mandated language concerning pay deductions
  • Proper E-mail/Internet usage
  • Professionalism/dress code
  • Drugs in the workplace
  • Social media policy

There are many other policies that would be included in order to comply with requirements that might be mandated by a particular regulatory scheme i.e. security compliance. The guide should be a living, breathing document that evolves over time based on new knowledge, changes in laws and business fluidity.

Both standard operating procedures and employee manuals or guides are integral to the viability of a cannabis related business whether a hands on the plant license holder or an ancillary company. I encourage my clients to craft self-created content that they have invested their time and knowledge into, with some help where necessary. Purchasing forms online does not provide a workable format and will only lead to problems in the future. You get what you put in and creating these documents internally and from the ground up gives more control to the business.

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.

Nic Easley: How Far Have We Come?

By Cannabis Industry Journal Staff
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Nic Easley, chief executive officer at Comprehensive Cannabis Consulting (3C), delivered the keynote address at the first annual Cannabis Labs Conference, co-located with Pittcon. Easley begins with a discussion of the 2014 milestone where Colorado and Washington legalized recreational cannabis, opening the floodgates for a diverse range of products and business opportunities in quality and safety testing. With members of his team sitting on the Colorado Department of Agriculture’s Pesticide working group, they are working with industry leaders and regulators to comprehensively write the standards. “The industry gets regulated in 2014 in Colorado with a total of $2.7 billion in sales in the first year of the industry’s history,” says Easley. “We have this giant influx of business, but without process validation, good agricultural practices and proper SOPs, each state is left to fend for themselves to write regulations.”