By Kathy Knutson
This month’s Ask the Expert is answered by Independent Consultant, Kathy Knutson, Ph.D. Kathy is a lead instructor for Preventive Controls for Human Food (PCHF); Preventive Controls Qualified Individual (PCQI) and trained in the prevention of Intentional Adulteration (IA). Each month EAS experts tackle one question sent in by readers. To ask your question, click here.
Question: How can implementing a GMP system for regulatory compliance also streamline business at a cannabis facility?
Knutson: I am a food microbiologist with expertise in food safety. I work with the food industry in writing Hazard Analysis and Critical Control Point (HACCP) and food safety plans. I find myself using the same food safety knowledge from the food industry, in the cannabis-infused edibles industry. It makes sense because it is all just food that must be manufactured and be safe for human consumption. Unlike the food industry, currently, there is no federal legislation for the cannabis industry. At the federal level, cannabis is illegal.
Manufacturers of cannabis-infused edibles are legally found in states where legislation has been passed at the state level for either medical or recreational cannabis. It could be argued that edibles sold by way of prescription for medical use need to have a higher level of rigor in food safety than an edible for recreational use. In some states, the manufacturers are inspected like a restaurant. There is the talk of HACCP, but many states are just not there yet. The cannabis industry would do well to learn lessons from the food industry on HACCP from the late 1950s and preventive controls from 2011. Good Manufacturing Practices (GMPs) must be instituted, before making the leap to HACCP or preventive controls. GMPs are the foundation of HACCP and preventive controls. Without GMPs, there is no food safety.
Manufacturers of cannabis-infused edibles can find GMPs in 21 CFR 117 Part B. This is the Preventive Controls for Human Food rule where much of the food industry lives. A quick search for information on GMPs leaves one overwhelmed. There are university extension specialists, HACCP organizations and private businesses which offer GMP training. As a valued partner of EAS Consulting Group, the many experts are here to show you the path to food safety. Like a start-up company in the food industry, manufacturers of cannabis-infused edibles would be wise to start with GMPs. Once the foundation is solid, the manufacturer can build food safety.