Different Protocols
There are several differences in food safety protocols between traditional food processing and cannabis-infused food production. “The biggest difference with cannabis vs. traditional food manufacturing is that weight would not affect food safety in traditional manufacturing,” Wilson said. “In cannabis, since weight determines the dosage of the product, we have to be meticulous about weighing every single piece of edible we manufacture to ensure that it is the stated dosage, making it ‘safe’ for consumption.”
The law provides for a 10% variance on dosing, which requires adherence to very rigid manufacturing practices involving weighing every piece of product before it gets packaged for distribution. Meanwhile, with traditional food manufacturing, only package weight needs to be adhered to.
Another main difference is that within the food industry, testing is performed from farm-to-fork. “Raw materials, environmental monitoring, and finished products are all evaluated in a risk-based approach to minimize the chance that hazards may be present,” Bird said. “For cannabis-infused products, only the minimal required compliance testing on finished product is performed, which can increase public health risks associated with contamination from the environment or in the raw materials of the product.”
Lab testing required by law in cannabis also screens for pesticides, heavy metals, and other harmful substances that traditional food testing is not subjected to. If products fail lab testing, the entire batch becomes unusable.
While regulations differ among states, manufacturers need to understand the basics to ensure they are compliant. “It is very challenging to navigate the regulatory landscape in the cannabis business,” Wilson said. “The regulations are different in every state, making it like setting up an entirely new business in every state. I can’t think of a single other industry where this is the case.”
Navigating the patchwork regulatory landscape can be very difficult for food manufacturers. “Multi-state operators—producers active in more than one state—often implement separate QA programs at each facility, which adds complexity to managing from a corporate standpoint,” Bird said. “These groups often rely on a senior regulatory advisor to help with navigation, but these individuals traditionally have a cannabis background, not a food safety background. This process helps ensure compliance with regulations but can result in less focus on implementing traditional food safety procedures.”
Thankfully, in many states, cannabis commissions will directly engage with manufacturers to proactively work toward better production and quality procedures.
Working with Suppliers
It isn’t uncommon for manufacturers to find issues working with suppliers because cannabis is still federally illegal. “We have had issues with being able to buy directly from large suppliers through wholesale accounts, as they don’t want to sell to cannabis companies,” Wilson said. “As such, we are forced to buy most products at retail. This is a huge issue with COGS, as they could be much lower if purchased through wholesale agreements.”
Knutson notes that while a few big players deal with everything in the supply chain the same way as normal food companies, the majority of cannabis manufacturers are still very small, operating more on the level of a restaurant kitchen or a pilot plant with small production. “So it’s a different scenario, and these companies are more likely to go to big box stores to get their ingredients,” she says. “That’s more common. Every cannabis company is still doing their product development and fine-tuning recipes, and flavors are evolving. They don’t have the consistency of purchasing, but that will change as the companies grow.”
What’s Ahead
Cannabis-infused producers that fail to invest in a strong quality assurance (QA) plan often have the most difficulty producing consistent and safe products.
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