If you missed the Cannabis Industry Journal’s 3rd Annual Infused Products Virtual Conference last week, one of the speakers, Ellice Ogle, founder and CEO of Tandem Food presented on Food Safety Culture in the Cannabis Industry. An overview of the information in the presentation can be found here, Concentrate On a Food Safety Culture In Your Workplace. Below are answers to some of the post-presentation questions we received, but were unable to answer during the Q&A session. To get your additional questions answered or for a complimentary consultation for your company, specially provided to readers of Cannabis Industry Journal, contact Ellice Ogle at Ellice@tndmfood.com.
Question: What are some recommended digital programs for internal auditing?
Ellice Ogle: Before looking at the tools for conducting an internal audit, understand the goal of the internal audit. One key aspect of internal auditing is knowing which standard(s) to audit against. For example, regulatory audits for cGMP certification are different than optional third-party certifications such as any GFSI scheme (SQF, BRC, PrimusGFS, etc). While the standards ultimately have the same goal of food safety with varying focuses, it is important to have an experienced food safety specialist conduct the audit as realistically as possible. The experienced specialist will then be able to recommend an appropriate tool for internal auditing moving forward, whether it is software such as FoodLogiQ, SafetyChain, Safefood 360°, among many others, or simply providing a template of the audit checklist. Overall, the risk of foodborne illnesses can be minimal, but it takes persistence and commitment to achieve a successful food safety culture. Metrics can assist in assessing the commitment to food safety and, as a result of these efforts, you will minimize the risk of compromising the health and safety of your guests, employees, foods and business. If you want a specific example, I’d like to direct you to a case study in partnership with Heylo LLC in Washington state, posted on the Tandem Food website.
Q: What are examples of ways to share environmental monitoring results to enhance a good edible safety culture?
Ellice: In the Control of Listeria monocytogenes in Ready-To-Eat Foods: Guidance for Industry Draft Guidance (2017), the FDA states that “a well-designed environmental monitoring program promotes knowledge and awareness of the environmental conditions that could result in product contamination and is a more effective program than product testing alone.” In other words, environmental monitoring programs and results can identify environmental conditions within a facility that could cause potential contamination. Publishing these findings, for example in the form of a case study or sharing the details of the practice, can enhance the food safety culture in the specific niche industry. For example, to borrow from the meat industry, Tyson Foods, Inc developed and shared environmental monitoring programs that are used by their peers, promoting a unified food safety culture, rather than competitive, guarded secrecy.
Q: Are the food safety requirements the same for retail and manufacturing?
Ellice: The food safety requirements are not exactly the same for retailers and manufacturers. The difference is inherent that retailers are working with finished product while manufacturers are working with raw ingredients and the manufacturing process to develop the finished product. Let’s take a closer look at cannabis regulation in Washington state. Chapter 314-55-104(12) states “Processors creating marijuana extracts must develop standard operating procedures (SOPs), good manufacturing practices (GMPs), and a training plan prior to producing extracts for the marketplace.” Compare this to the requirements for retailers, 314-55-105(11) which states “A marijuana producer, processor or retailer licensed by the WSLCB must conduct the production, processing, storage, and sale of marijuana-infused products using sanitary practices.” While SOPs and GMPs are not explicitly mentioned for retailers as they are for manufacturers, sanitary practices could be documented as Sanitation Standard Operating Procedures (SSOPs). Proper storage practices can also be an overlapping food safety concern with respect to temperature control or pest management systems. Overall, food safety should remain a top priority in maintaining the integrity of the products throughout the supply chain.
Q: To your knowledge, has there been a food safety outbreak associated with a cannabis-based product?
Ellice: One possible cannabis-related death investigated in 2017 uncovered deadly pathogens in medical cannabis. However, to my knowledge, I have not seen a food safety outbreak associated with a cannabis-based product. There might be any number of reasons that this is so, for example, possibly because a food safety outbreak associated with a cannabis-based product might not have had a large impact to make headlines. Although, with the cannabis industry already misunderstood and a stigma so prevalent to even promote fake news, it is better to prevent an outbreak from ever occurring. One thing to note is that ultimately cannabis is just another ingredient in existing products, of course with special properties. So, the common food safety offenders are present: listeria, Salmonella, E. Coli, among others. On the plant, cannabis food product manufacturers must minimize the risk of mycotoxins produced by molds, pest contamination, and pesticide contamination. For products that contain cannabis infusions or extractions as an ingredient, there is the possibility of the growth of Botulism toxin. Many of these pathogens can be minimized by appropriate heat treatment or maintenance of refrigeration, testing, and by practicing preventive measures. Arguably, the largest potential for pathogenic contamination is due to improper employee handling. To refer to what we discussed earlier, employee training is key, as well as proper enforcement. Having a strong food safety culture ensures that people have the knowledge of food safety risks and the knowledge of preventing outbreaks.
Q: Do any of the panelists know of any efforts to develop a food safety-oriented standard for the cannabis industry?
Ellice: One example of a specific effort to develop a food safety-oriented standard for the cannabis industry includes TraceTrust A True Dose™ & hGMP™ certification. However, there are efforts for other standards that have food safety included. Take organic certification, there are several companies creating and auditing against their own standard such as Clean Green Certified, Oregon Sungrown Farm Certification, or Washington Sungrowers Industry Association. The California Department of Food and Agriculture (CDFA) is also preparing a cannabis program comparable to the USA National Organic Program.
Q: Can you assist with cGMP certification?
Ellice: Yes, Tandem Food LLC is positioned to consult on cGMP certification for manufacturing facilities in the cannabis industry. First, a gap assessment can be conducted to obtain useful actionable data for you, rather than be an intimidating experience. Working from the identified baseline, Tandem Food will work with you to create and implement all related documentation and programs, providing training as necessary. Overall, with the right commitment, cGMP certification can take 6-12 months.
Events across the globe have been postponed or canceled due to the coronavirus. COVID-19 is taking down many industries and leaving hundreds of thousands of people without jobs. At Innovative Publishing Company, our top priority is safety. In light of the recent travel restrictions and our concern over attendees’ safety, we have made the decision to convert our Cannabis Labs/Food Labs Conference to a virtual event. The event will no longer take place June 3–4. Instead, we are in the process of reorganizing the agenda to give our attendees the full benefit of sessions over a period of June 1–5. Recognizing the strain on the industry, this event will be free to attendees and underwritten by our sponsors. Check back soon here as we update the website and announce the new agenda for the virtual program. We look forward to seeing everyone virtually there.
Additionally, the Cannabis Quality Conference & Expo remains scheduled for October 21–23, 2020, however the Food Safety Consortium will now be postponed to December 2–4, 2020. More information on that can be found on Food Safety Tech. Innovative Publishing has developed a contingency plan in the event that COVID-19 continues to be a serious health concern throughout the fall season. This is very possible and we take these health concerns very seriously. That plan includes converting the conference to a virtual event, similar to our Cannabis Labs/Food Labs Conference.
A Message To Our Readers
If you have any questions or concerns, feel free to get in touch with us via the Contact Us page. Our editorial content in the newsletters and on the website will continue as usual, so check back regularly for news articles, features and columns as we continue to work remotely and provide you with educational content. We look forward to the upcoming virtual event and hope you’ll join us. We feel this is the smartest decision to make in the midst of the global pandemic. We hope our readers and their families remain safe and healthy. We’ll all get through this together.
On January 15th, 2020, Cannabis Industry Journal is hosting the 3rd Annual Cannabis Labs Virtual Conference. From 11–4 pm ET, you’ll get access to five veterans of the cannabis industry discussing a wide range of cannabis testing issues. Hear from subject matter experts who will share their perspectives on regulations for cannabis and hemp testing, THC and CBD testing, laboratory management, moisture content and water activity and microbiological testing.
- Charles Deibel, President & CEO of Deibel Labs, Inc.
- Dr. Brady Carter, Sr. Applications Scientist with Neutec
- Aaron Hilyard, Microbiologist at DigiPath Labs
- Heather Wade, President of Heather Wade Group, LLC
- Heather Ebling, Senior Applications & Support Manager at Medicinal Genomics
Attendees will have the opportunity to ask speakers questions during the live Q&A session that follows each presentation. Five experts, five presentations, all on the same day and free to attend. Register now for this complimentary series of webinars.
The 2ndAnnual Cannabis Labs Virtual Conference is set to take place on Tuesday, April 2, 2019, starting at 12:00 Noon and concluding at 4:00 PM EDT. This complimentary series of webinars will take a deep dive into a variety of subjects related to cannabis testing and the laboratory industry.
The virtual event will help attendees better understand some of the more technical aspects of starting and operating a laboratory. Topics discussed will include pesticide testing, cannabinoid and terpene testing, the new ISO 17025:2017 accreditation and a lesson in starting a laboratory in a new market.
Attendees registering for this complimentary series of webinars will get access to four veterans of the cannabis lab testing industry, who are available for Q&A after each presentation. In addition to getting the opportunity to chat with these subject matter experts on April 2, a recording of the presentations will be made available to all who register.
Here is a snapshot of the agenda:
Pesticide Testing: Methods, Strategies & Sampling
Charles Deibel, President & CEO – Deibel Labs, Inc.
Pesticides represent the number one area for batch failures in the US cannabis market. These are concerns not only for consumers, but are a very big concern for cultivators and manufacturers of cannabis products. remediation of the pesticides, once they are in the product are not always feasible From the lab level, they are also the hardest test to run in the laboratory, even one equipped with state-of-the-art equipment. The best instruments on the market are very expensive and there are no standardized methods, meaning lab to lab variability has happened.
- What are the pesticides in cannabis and are there any that are the “main concerns” or ones that stand out as particularly damaging?
- What is a basic breakdown of the testing and methods used for pesticide testing?
- What are the best strategies for the sampling of cannabis products?
Building a Lab in an Emerging Market
Chris Martinez, Co-Founder & President, EVIO Labs FL
- Will present a discussion of the genesis of EVIO Labs Florida, how to start a lab in a new market
- Challenges in how we navigated changing regulations in a state with newly legalized cannabis
- Expanding a lab to a second location – logistics, hiring, training, consistency.
Cannabinoid & Terpene Testing: Methods, Strategies & Standardization
Dr. Cindy Orser, Chief Science Officer, Digipath Labs
- Appreciation of “measurement uncertainty” in cannabis testing
- Standardization of testing methods is a high priority
- Terpenes are the distinguishing chemicals in cannabis sensory perception and chemotaxonomy
Benefits of Accreditation to the ISO 17025:2017 Standard
Jane Weitzel, Independent Consultant
- The ISO/IEC 17025:2017 standard is now being used to accredit cannabis testing laboratories. From this presentation you will learn the key new aspects of the standard. This includes risk-based thinking. Many aspects of this risk approach require the use of measurement uncertainty. This means the measurement uncertainty must be adequately evaluated. You will be introduced to evaluating and using measurement uncertainty.
- The 2017 standard emphasizes conflict of interest and impartiality. Procedures and practices to achieve impartiality will be shown. This reduces the risk of potentially damaging leaks of information or the risk of people not working to the best interests of the laboratory and its clients.
- The 2017 standard is a valuable and useful business tool that can save the laboratory resources, effort and money. Are you doing too much testing? Are you doing too little testing? When you evaluate the measurement uncertainty you can use it to learn the steps in your test method that need enhancement to reduce the risk of making mistakes. You can also use the measurement uncertainty to focus on the significant steps and stop wasting time on steps and activities that are insignificant.
- These benefits of laboratory accreditation will be demonstrated with examples from the cannabis industry.