Microbial Contamination of Cannabis-Infused Foods

When it comes to infused food products, FDA treats them more like medicine than like food, says Glauser. “The FDA requires that manufacturers have ‘reasonable assurance that food is not adulterated,’ and will perform sampling of certain commodities.” But the safety of THC-infused foods is overseen at the state level alone, and the differences in requirements from state to state vary widely.

“In California, each batch of cannabis is tested for E. coli, Salmonella, Aspergillus, and mycotoxins, says Glauser. “In Oregon, there is no requirement for microbial testing yet, but that is expected to change in 2021. In other states, product is tested for yeast and mold. In Massachusetts, product is tested for all of the above, plus coliforms and certain bacteria.”

But even between states that test for the same pathogens, differences may arise, says McKernan, who stresses that the sample size requirements, targets, and thresholds for failure differ from state to state.

All that testing is less demanding than that required of food products under FDA, adds Deibel, who says that food producers subject to FDA oversight must test many more batches of higher weights than are ever demanded of edible cannabis products.

Risk On the Rise

While the chances of getting Salmonella from a cannabis-infused gummy are fairly low, says Deibel, that relative safety is only for the time being. Producers may begin shifting norms and ingredients that have made previous gummies shelf stable. Meanwhile, with so many hoping to strike gold selling cannabis-infused foods and beverages, the variety of food types is expanding dramatically beyond gummies, cookies, and brownies.

The problem with savvy consumers looking for high-end quality and flavors is that they want nothing to do with the mass-produced ingredients that have proven themselves safe for consumers in large numbers. They want new and inventive flavors, and they often want them in chocolate products.

“Chocolate, and especially some of the toppings—fresh fruit, nuts—those can absolutely have Salmonella in them,” Deibel says. “If I were to name my five biggest concerns for Salmonella, they’d be chocolate, nuts, raw meat, raw ag [agricultural produce], and spices. Well, you’ve got raw ag in the form of fruit, and nuts, and spices, and those are all going on top of chocolate. Really fancy chocolates with curry spices or whatever, they are getting out onto the market, but they are not going through the same rigor of testing that the food industry would have subjected them to.”

He concludes that many food safety insiders are waiting for the first big Salmonella or Listeria or recall in the cannabis market. “It’s going to happen,” he adds. “It’s just a matter of time.”

GMPs

To avoid becoming the company that suffers that recall, Deibel advises producers of infused foods to adhere to good manufacturing practices (GMPs) supplemented with aggressive sanitation programs, extensive training, and routinely validated equipment.

McKernan goes back even farther: He suggests food producers source ingredients from cannabis cultivators offering “good genetics,” such as the cannabis cultivars that exhibit pathogen resistance. “In [the] absence of fungi-resistant cannabis,” McKernan says, “testing for pathogen load throughout the cultivation process as opposed to just at the end is consistent with GMP. Gambling an entire crop on a single test at the end of the long growth and harvest process is not advised.”

Beyond that, McKernan joins Glauser in stressing that testing infused food and beverages for microbial contamination is done in the same manner as it is for non-infused foods, and that it should be done, whether or not FDA insists upon it.

Companies producing food products must expect to encounter pathogens eventually, says Deibel, whether FDA is testing the products or not. “Even the best company with all the right programs working in concert, they’ll still find a pathogen, Salmonella or Listeria, in their finished product, maybe once every five years—10 years if they’re lucky. But they find it. The pathogen is always waiting at your door.”