Cannabis Recalls: Lessons Learned from Contamination
In the first part of this series, we looked at labelling errors, the number one cause of cannabis recall events in Canada since legalization in 2018. In this article, we will explore another critical aspect for cannabis processors: contamination with pathogens and extraneous materials.
Pathogens are the #2 Cause of Cannabis Recalls in Canada
In our last article, we talked about the number one cause of cannabis recalls in Canada: labelling and packaging errors. Pathogens are the second most common cause of recalls in Canada, claiming 18% of total cannabis recall incidents. And while that doesn’t sound like much, it affects the highest volume of product recalled with over 360,000 units affected. Biological hazards such as yeast, mould, and bacteria compromise consumer health and safety, which is why enforcing food safety standards with HACCP plans and ensuring regulatory compliance with proper traceability systems are priorities for both cannabis processors and industry regulators.
An effective Preventive Control Plan (PCP) with regular quality control checks and standardized testing has a big role to play in avoiding safety hazards and winning consumer trust, as evident in some of the recent recalls due to pathogens and extraneous materials. Here are some instructive examples of cannabis recalls – and how to prevent them.
Start at the Farm: Extend Critical Controls to the Growing Process
The primary causes of allergens and microbiological contamination of cannabis products is yeast, mould, and bacteria found on cannabis flower. Companies like Atlas Growers, Natural MedCo, and Agro-Greens Natural Products have all learned this lesson through costly recalls.
These contaminants pose obvious health risks, from allergic reactions like sneezing and itchy eyes to gastrointestinal diseases and more. Especially for people using cannabis for medical conditions and who may be more susceptible to illness, pathogens can cause even more serious health complications. Moreover, this type of cannabis recall not only drives significant cost since microbiological contamination of flower could easily affect several product batches processed in the same facility and/or trigger downstream recalls, but also affect consumer confidence for established cannabis brands.
Preventive control plan requirements for cannabis manufacturers note that holders of a licence for processing that produce edible cannabis or cannabis extracts in Canada must identify and analyze the biological, chemical, and physical hazards that present a risk of contamination to the cannabis or anything that would be used as an ingredient in the production of the edible cannabis or cannabis extract. Biological hazards can come from a number of sources, including:
- Incoming ingredients, including raw materials
- Cross-contamination in the processing or storage environment
- Cannabis extract, edible cannabis and ingredient contact surfaces
- Insects and rodents
To mitigate risks, addressing root causes with preventative measures and controls is essential. For instance, high humidity levels and honeydew secreted by insects are common causes of mould on cannabis flowers. Measures such as leaving a reasonable distance between plants, using climate-controlled areas to dry flowers, applying antifungal agents, and conducting regular tests are necessary to combat such incidents.
Of course, placing all the necessary controls into action is not as simple as it may sound. Multiple facilities and a wide range of products in production mean more complexity for cannabis producers and processors. Any gaps in processing flower, extracts or edibles can result in an uncontrolled safety hazard that may lead to a costly cannabis recall.
These challenges are not just limited to cannabis growers. The food industry has been effectively mitigating the risk of biological hazards for decades with the help of food ERP solutions. Icicle’s ERP software, for instance, can help standardize processes and set in place a comprehensive preventative control plan with safety controls, data tracking, and documentation to prevent biological hazards, starting right from the farm.
Its agriculture-related tools are designed to help streamline growing activities like keeping records on applied pesticides and tracking of humidity levels to keep biological hazards in check. It can even integrate these with manufacturing processes to ensure safety throughout the entire supply chain. This is critical for cannabis processors, as much as it is for food manufacturers, to ensure complete traceability.
In addition, Icicle offers powerful tools to implement specific agricultural safety hazard prevention programs for the cannabis industry. It can, for instance, help cannabis companies adopt the BC Ministry of Environment and Climate Change Strategy’s (MECCS) Integrated Pest Management program by setting up preventive control plans, automating procedures, and tracking data to ensure product specifications are within defined tolerance thresholds, triggering corrective actions when necessary.
Standardize Testing for Biological Hazards and Achieve Safety Excellence
Like most food products, cannabis edibles such as brownies can develop mould and bacteria, even during production. Regular, standardized testing should be an important element of a preventive control plan alongside other measures in order to avoid a potential cannabis recall. In fact, some recalls have been conducted due to missing test data.
One advantage of a food ERP like Icicle is that it already caters to food industry testing needs, and these extend to cannabis processing as well. An example is the Food and Drugs Act’s testing specifications for microbiological factors, which cannabis processors must refer to for guidance. Even microbial tests like Total Yeast and Mould Count are crucial for both the food and cannabis industries.
With Icicle’s laboratory management features, cannabis manufacturers can meet all these mandatory testing needs with minimum customization. They allow users to add relevant testing criteria under product specifications and validate them at multiple stages using in-house inspections and third-party testing, which many cannabis brands rely on today. Icicle provides a centralized audit-ready system that gathers all the data on a production lot. Brands that are looking to build consumer confidence offer up state-compliant certificates of analysis to their customers when desired..
But Icicle goes beyond regulatory compliance. It can even help companies stay ahead of cannabis regulations by implementing additional control points with voluntary testing and audits.
Take, for example, Health Canada’s testing requirements for microbial contaminants. In most instances, it’s limited to the final form of the cannabis product. Naturally, this doesn’t leave much room for manufacturers to take corrective action in the event of a failed test result. Usually, the only option is to discard the products. But by using Icicle to integrate regular monitoring and voluntary testing at each stage of the manufacturing process, cannabis companies can tackle a safety hazard as and when it arises.
Watch Out for Hazardous Extraneous Material: Take Cues From the Food Industry to Prevent Cannabis Recalls
If overlooked, extraneous material can also lead to a serious safety hazard with potentially long-term ramifications. This was evident with WPCP’s recall of KUSHKRAFT Hybrid Blue Iguana dried cannabis pre-rolls. The recalled batch containing pieces of metal wire may have been under 2,000 units, but the brand damage and loss of credibility could leave a significant dent in WPCP’s revenue for some time.
Of course, the potential for these risks is much higher for large-scale food manufacturers, but they use food ERP software like Icicle to avoid such contamination hazards by integrating all their processes, from harvesting to processing, into a single intelligent platform. It allows them to seamlessly implement data-driven HACCP-based safety programs with regular quality control checks to reinforce food safety compliance. And this enables greater accuracy, transparency, control, and accessibility — vital components for food safety excellence.
Icicle even has advanced capabilities like smart hazard suggestions that automatically suggest potential hazards of not just physical and chemical nature but even biological and radiological ones. It also uses automation technology to update HACCP plans with a single click. This can save hours of manual work flipping through hundreds of pages. All these tools are of significant value to cannabis processors, as they are to food manufacturers.
Build a Safe and Healthy Cannabis Industry, Together
Undoubtedly, contamination by pathogens and extraneous materials stands to pose serious health risks for cannabis users. It can also expose manufacturers to various risks, from lost consumer confidence and reputational damage to possible legal action.
An effective preventative control plan with regular quality checks, internal audits, and standardized testing is important to minimize these threats. At the same time, robust, real-time traceability systems play a pivotal role in the event of a cannabis recall by enabling manufacturers to trace back incidents to the exact point of contamination and identify affected products with surgical precision. As seen with craft cannabis manufacturers, maintaining smaller lot sizes also helps achieve higher quality levels and minimize contamination risks.
Now, a food ERP solution like Icicle is essential to integrate and manage these critical steps with data-backed safety programs. Features like automated HACCP plans, laboratory management functions, QA Dashboards, and cannabis reporting tools can help set in place more effective controls and make safety and compliance effortless.
As demonstrated by food manufacturers, integrated platforms like Icicle are crucial to building a safe and healthy cannabis industry. The power of data and paperless, automation technologies these solutions possess could certainly be the key to the industry’s future profitability and growth.