HACCP for Cannabis Edibles
By Shirley Toms, Senior Quality & Regulatory Consultant
Cannabis Compliance Inc.
Hazard Analysis Critical Control Point (HACCP) Application in Cannabis Edibles
Legalization of recreational cannabis in 2018 is now a reality. We’ve been experiencing the industry’s rush to become licenced for cannabis production and expect that pressure to continue into 2019. With the expected approval of edibles in 2019, the next cannabis rush will be for development of edible and drinkable cannabis products where preparing for quality controls will be imperative to the security of the cannabis edibles industry.
From the medical perspective, the most vulnerable parts of our populations are already using cannabis as medicine, many of them with health conditions that have weakened their immune systems. Pathogens like viruses, bacteria and molds become particularly dangerous to people with reduced immunity, so it’s especially important that the GPP standards set by Health Canada are met for cannabis production.
The potential hazards in Cannabis production
During growth, cannabis plants can become contaminated with microorganisms such as mold, mildew, bacteria and yeast. Salmonella as well as fungal toxins can cause severe illness, particularly in children or immunocompromised patients who are taking medical cannabis. Human pathogens are not especially common in plants and in most cases, are introduced by poor employee handling practices or contamination from processing surfaces, water or other materials.
Pathogenic bacteria like Salmonella could potentially survive on cannabis and be transferred to humans or other items during handling. Although it would not survive the heat of smoking or decarboxylation, it could nevertheless be carried into homes and come into contact with people who handle the cannabis, setting up the opportunity for cross-contamination. With products like infused oils (oil extractions and butter), Clostridium botulinum could be a hazard as it produces heat-resistant endospores that can survive adverse conditions.
Cannabis as a food product
Cultivation of cannabis and production of cannabis edibles can also result in chemical residues from cultivation (fertilizers, pesticides) and processing (sanitizers, solvents) inputs. Food grade chemicals that have been approved for cannabis must be used throughout the process to address these types of concerns.
All this to say, practices associated with employee hygiene, cultivation, sanitation, harvesting packaging and handling can contribute hazards to dried cannabis or cannabis oil. Using cannabis and its derivatives as ingredients in food processing could carry these potential hazards into the edibles world.
If we are talking about safety of edibles, what are the concerns and hazards? What do growers and food processing companies need to consider?
Whether you are cultivating cannabis or using cannabis as a food ingredient, it is prudent to work on proactive approaches to hazard management. This is where HACCP comes into the picture.
Application of HACCP
Hazard Analysis Critical Control Point (HACCP) is a systematic and preventive approach that is broadly used around the world, in food production as well as other industries such as cosmetics and pharmaceuticals. It is based on seven universally-accepted HACCP principles:
- Identify the potential hazards associated with food production at all stages.
- Determine the critical control points, procedures and operational steps that can be controlled to eliminate the hazards or minimize their likelihood of occurrence.
- Establish critical limits
- Establish a system to monitor control of CCPs
- Establish the corrective action to be taken
- Establish procedures for verification
- Establish documentation
Whether you are getting into the cultivation of cannabis or are developing edible cannabis foods and beverages, the implementation of a HACCP program is strongly recommended.
When you apply HACCP correctly as a control process, it aids in preventing, eliminating and reducing biological, chemical and physical hazards and allow your products to meet safety regulations. Avoiding product recalls also helps you to protect your financial investment, your reputation and your brand.
CCI specialists offer a vast knowledge in plant science, pharmaceutical science and food science, and can help you with developing your HACCP plan and your audit program for cannabis cultivation or for cannabis edibles and beverage manufacture.
Cannabis Compliance Inc. is the world’s largest consulting firm devoted exclusively to the cannabis sector. Our track record is unparalleled, with projects around the globe supported by over 50 fulltime staff. Contact us for more information.