Tag Archives: pesticides

Michele Pfannenstiel, Dirigo Food Safety
FST Soapbox

Quality Assurance and Food Safety in Cannabis-Infused Products

By Michele Pfannenstiel, DVM
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Michele Pfannenstiel, Dirigo Food Safety

The legal cannabis-infused products industry is growing with impressive and predictable rapidity. But because the rollout of new regulations occurs in an awkward and piecemeal fashion, with stark differences from one state to another, and sometimes even one county to another, uncertainty reigns.1 Many entrepreneurs are diving headlong into the nascent industry, hoping to take advantage of an uncertain regulatory environment where government audits and inspections are rare. These business owners will see quality assurance and product safety as burdens—costs to be avoided to the greatest extent possible.

I have seen this time and time again, even in the comparatively well-regulated food industry, and it is always a mistake.

If you find yourself thinking about quality assurance or food safety as a prohibitive cost, annoyance or distraction, I encourage you to change your thinking on this issue. The most successful businesses realize that product safety and quality assurance are inextricably linked with profitability. They are best thought of not as distractions, but as critical elements of an efficient and optimized process. Proper QA and safety are not costs, they are value.

Food safety and quality assurance should be seen as important elements of the process that you undertake to enforce the high standards and consistency that will win you repeat customers. The fact that they guard against costly recalls or satisfy meddlesome auditors is only a bonus. Realizing this will make your business smarter, faster and more profitable.

Learn more about the science, technology, regulatory compliance and quality management issues surrounding cannabis at the Food Labs / Cannabis Labs Conference | June 2–4, 2020If today you cannot clearly communicate your product standards to your employees and to your customers, then you have some work to do. That’s because quality assurance always begins with precise product specifications. (A good definition of “quality” is “conformance to specifications.”) How can you assess quality if you don’t have a definitive standard with which to evaluate it? My consulting firm works with food businesses both small and large, and this is where we begin every relationship. You might be surprised how often even a well-established business has a difficult time naming and describing every one of its products, let alone articulating objective standards for them.

This may be doubly difficult for fledgling businesses in the cannabis world. Because the market is so new, there are fewer agreed-upon standards to fall back on.

When we help businesses create specifications, we always look at the relevant regulations while keeping in mind customer expectations. In cannabis, the regulations just aren’t as comprehensive as they are for conventional food and agriculture. Laws and guidelines are still in flux, and different third-party standards are still competing for market dominance. Different states have entirely different standards, and don’t even agree, for example, whether cannabis edibles should be considered pharmaceuticals or food. To some extent, it’s the wild west of regulation, and as long as the federal government remains reluctant to impose national guidelines, it’s likely to remain so.

The wild west may be a good place for the unscrupulous, but it’s not good for business owners that care about the health of their customers and the long-term health of their brand. Don’t take advantage of confusing quality and safety standards by doing the least possible to get by. At some point there will be a scandal in this country when a novel cannabis product makes dozens of customers sick, or worse. You don’t want it to be yours.

With cannabis-infused products, there is a unique additional factor at play: The strength of THC and other psychoactive compounds. Again, there are few agreed-upon standards for potency testing, and relatively little oversight of the laboratories themselves. This allows labs to get sloppy, and even creates an incentive for them to return inflated THC counts; at the very least, results may hugely differ from one lab to another even for identical products.2 Some labs are ISO 17025 accredited, and some are not. Using an unaccredited laboratory may prevent your efforts to create consistent and homogeneous products.

Even in comparatively well-regulated states, such as Colorado, it is ultimately your responsibility to create products that are safe and consistent. And in the states where the politicians haven’t even figured out which department is regulating cannabis products, your standards should be tougher than whatever is officially required.

And so we look to the more established world of conventional food and agriculture as a guide for the best practices in the cannabis industry.

Hazards

The most constructive way to look at food safety, and the way your (eventual) auditors and regulators will view it, is to look at your product and process from the perspective of the potential hazards.

Some day, when regulation finally gets sorted out, you are likely to be asked to implement a Hazard Analysis and Critical Control Points (HACCP) safety system. HACCP framework recognizes three broad categories of hazards:

  • Physical hazards: Foreign material that is large enough to cause harm, such as glass or metal fragments.
  • Chemical hazards: Pesticides and herbicides, heavy metals, solvents and cleaning solutions.
  • Biological hazards: The pathogens that cause foodborne illness in your customers, such as E. coli, and other biological hazards, such as mycotoxins from molds.

All of these hazards are highly relevant to cannabis-infused product businesses.

The HACCP framework asks us to consider what steps in our process offer us the chance to definitively and objectively eliminate the risk of relevant hazards. In a cannabis cookie, for example, this might be a cooking step, a baking process that kills the Salmonella that could be lurking in your flour, eggs, chocolate or (just as likely!) the cannabis extracts themselves.

A good HACCP system is merely the capstone resting atop a larger foundational system of safety programs, including standard operating procedures, good manufacturing practices, and good agricultural practices. It’s important to use these agreed-upon practices and procedures in your own facility and to ensure that your suppliers and shippers are doing the same. Does your cultivator have a culture of safety and professionalism? Do they understand their own risks of hazards?

HACCP offers a rigorous perspective with which to look at a process, and to examine all of the places where it can go wrong. The safety system ultimately holds everything together because of its emphasis on scrupulous documentation. Every important step is written down, every time, and is always double-checked by a supervisor. It sounds like a lot of paperwork, but it is better viewed as an opportunity to enforce consistency and precision.

When you thoroughly document your process you’ll create a safer product, run a more efficient business, and make more money.

References

  1. Rough, L. (2016, March 4). Leafly’s State-by-State Guide to Cannabis Regulations. Retrieved from https://www.leafly.com/news/industry/leaflys-state-by-state-guide-to-cannabis-testing-regulations
  2. Jikomes, N. & Zoorob, M. (2018, March 14). The Cannabinoid Content of Legal Cannabis in Washington State Varies Systematically Across Testing Facilities and Popular Consumer Products. Retrieved from https://www.nature.com/articles/s41598-018-22755-2
Alert

Q3 Hazard Beat: Fruits & Vegetables

By Food Safety Tech Staff
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Alert

The following infographic is a snapshot of the hazard trends in fruits and vegetables from Q3 2019. The information has been pulled from the HorizonScan quarterly report, which summarizes recent global adulteration trends using data gathered from more than 120 reliable sources worldwide. Over the past and next few weeks, Food Safety Tech will provide readers with hazard trends from various food categories included in this report.

Hazards, fruits, vegetables, HorizonScan
2019 Data from HorizonScan by FeraScience, Ltd.

View last week’s hazards in seafood.

Spices, Paprika, Curry

Q3 Hazard Beat: Herbs and Spices

By Food Safety Tech Staff
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Spices, Paprika, Curry

The following infographic is a snapshot of the hazard trends in herbs and spices from Q3 2019. The information has been pulled from the HorizonScan quarterly report, which summarizes recent global adulteration trends using data gathered from more than 120 reliable sources worldwide. Over the next several weeks, Food Safety Tech will provide readers with hazard trends from various food categories included in this report.

Hazards, Herbs, Spices
2019 Data from HorizonScan by FeraScience, Ltd.

View last week’s hazards in meat and meat products.

USDA Logo

USDA PDP Report: Farmers Doing a Good Job Complying with Regulations

By Food Safety Tech Staff
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USDA Logo

Fruit and vegetable farmers are doing an “impressive” job of complying with the laws and regulations related to pesticide use in production, according to the USDA’s annual Pesticide Data Program (PDP) report. Based on data from 2016, the report found that more than 99% of samples had pesticide residues that were “well below” the EPA’s established tolerances, and more than 23% had no detectable residues. Less than half-a-percent of samples (0.46%) had residues that exceeded the EPA established tolerance.

To compile the PDP report, surveys were conducted in 2016 on several foods, including eggs, milk, and fresh and processed fruit and vegetables. The report contains data from more than 10,000 samples collected throughout the United States.

A release from the Alliance for Food and Farming states that the U.S. food supply is one of the safest in the world, yet: “Activists groups often manipulate the findings from the USDA PDP report taking the very positive results and somehow turning them into something negative. This tactic has been used routinely for 20-plus years to create a so-called ‘dirty dozen’ list, which has been repeatedly discredited by scientists.”

Egg

Egg Contamination Spreads Across Europe

By Food Safety Tech Staff
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Egg

At least 17 countries have been hit with the European egg scandal involving insecticide contamination. Ground zero of the problem has not been definitively identified, as Belgium, the Netherlands and Germany are reportedly pointing fingers over which country is to blame and how long they knew about the problem. Dutch authorities may have known about the problem as far back as November 2016.

The eggs have been tainted with the pesticide Fipronil, doses of which are not harmful to humans engaging in short-term consumption. When consumed in large doses, it can cause damage to the kidneys, liver and thyroid glands.

Farmers in the Netherlands used a company, Chickfriend, to delouse their chickens, but this company reportedly mixed fipronil into the cleaning solution and could have contaminated nearly 180 farms in the country as a result, according to The New York Times. As many as 20% of Dutch egg-laying chickens could be affected. Chickfriend was recently raided by authorities and two of its directors were arrested. Antwerp-based Poultry-Vision stated that it provided Chickfriend with fipronil via a source in Romania, according to The Guardian.

Contaminated eggs, which have been distributed to at least 17 countries (mainly in Europe) have also been found at producers in Belgium, France and Germany, and as a result, millions of eggs have either been destroyed or removed from store shelves.

USP Food Fraud Database

Why Include Food Fraud Records in Your Hazard Analysis?

By Karen Everstine, Ph.D.
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USP Food Fraud Database

Food fraud is a recognized threat to the quality of food ingredients and finished food products. There are also instances where food fraud presents a safety risk to consumers, such as when perpetrators add hazardous substances to foods (e.g., melamine in milk, industrial dyes in spices, known allergens, etc.).

FSMA’s Preventive Controls Rules require food manufacturers to identify and evaluate all “known or reasonably foreseeable hazards” related to foods produced at their facilities to determine if any hazards require a preventive control. The rules apply both to adulterants that are unintentionally occurring and those that may be intentionally added for economically motivated or fraudulent purposes. The FDA HARPC Draft Guidance for Industry includes, in Appendix 1, tables of “Potential Hazards for Foods and Processes.” As noted during the recent GMA Science Forum, FDA investigators conducting Preventive Controls inspections are using Appendix 1 “extensively.”

The tables in Appendix 1 include 17 food categories and are presented in three series:

  • Information that you should consider for potential food-related biological hazards
  • Information that you should consider for potential food-related chemical hazards
  • Information that you should consider for potential process-related hazards

According to the FDA draft guidance, chemical hazards can include undeclared allergens, drug residues, heavy metals, industrial chemicals, mycotoxins/natural toxins, pesticides, unapproved colors and additives, and radiological hazards.

USP develops tools and resources that help ensure the quality and authenticity of food ingredients and, by extension, manufactured food products. More importantly, however, these same resources can help ensure the safety of food products by reducing the risk of fraudulent adulteration with hazardous substances.

Incidents for dairy ingredients, food fraud
Geographic Distribution of Incidents for Dairy Ingredients. Graphic courtesy of USP.

Data from food fraud records from sources such as USP’s Food Fraud Database (USP FFD) contain important information related to potential chemical hazards and should be incorporated into manufacturers’ hazard analyses. USP FFD currently has data directly related to the identification of six of the chemical hazards identified by FDA: Undeclared allergens, drug residues, heavy metals, industrial chemicals, pesticides, and unapproved colors and additives. The following are some examples of information found in food fraud records for these chemical hazards.

Undeclared allergens: In addition to the widely publicized incident of peanuts in cumin, peanut products can be fraudulently added to a variety of food ingredients, including ground hazelnuts, olive oils, ground almonds, and milk powder. There have also been reports of the presence of cow’s milk protein in coconut-based beverages.

Drug residues: Seafood and honey have repeatedly been fraudulently adulterated with antibiotics that are not permitted for use in foods. Recently, beef pet food adulterated with pentobarbital was recalled in the United States.

Heavy metals: Lead, often in the form of lead chromate or lead oxide which add color to spices, is a persistent problem in the industry, particularly with turmeric.

Industrial Chemicals: Industrial dyes have been associated with a variety of food products, including palm oil, chili powder, curry sauce, and soft drinks. Melamine was added to both milk and wheat gluten to fraudulently increase the apparent protein content and industrial grade soybean oil sold as food-grade oil caused the deaths of thousands of turkeys.

Pesticides: Fraud in organic labeling has been in the news recently. Also concerning is the detection of illegal pesticides in foods such as oregano due to fraudulent substitution with myrtle or olive leaves.

Unapproved colors/additives: Examples include undeclared sulfites in unrefined cane sugar and ginger, food dyes in wine, and tartrazine (Yellow No. 5) in tea powder.

Adulteration, chili powder, skim milk powder, olive oil
Time Series Plot of Records for Chili Powder (blue), Skim Milk Powder (green), and Olive Oil (orange)

Continue to page 2 below.

New Report Gives Failing Grade to Many Food Retailers on Pesticide Use

By Food Safety Tech Staff
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A recent report released by Friends of the Earth revealed that very few of the nation’s biggest food retailers have what it considers satisfactory policies and practices in pollinator protection, pesticide reduction and organic offerings. The organization graded 20 of largest retailers in the report, “Swarming the Aisles: Rating Top Retailers on Bee Friendly and Organic Food”.

In the category of publicly available policies on reducing or eliminating pesticides in order to protect pollinators, only Aldi, Costco and Whole Foods received passing grades.

“U.S. food retailers must take responsibility for how the products they sell are contributing to the bee crisis,” said Tiffany Finck-Haynes, food futures campaigner with Friends of the Earth, in a press release. “The majority of the food sold at top U.S. food retailers is produced with pollinator-toxic pesticides. According to Friends of the Earth, neonicotinoids (insecticides) are a leading cause of pollinator declines, while glyphosate (the most widely used herbicide) has been tied to monarch butterfly declines.

“To protect pollinators, we must eliminate pollinator-toxic pesticides from our farming systems and expand pollinator-friendly organic agriculture,” said Dr. Kendra Klein, staff scientist at FOE. “Organic farms support 50% more pollinator species than conventional farms. This is a huge opportunity for American farmers. Less than one percent of total U.S. farmland is in organic production — farmers need the support of food retailers to help them transition dramatically more acreage to organic.”

In conducting the report, FOE mainly used publicly available information sources such as company websites and annual reports, SEC filings, corporate social responsibility and sustainability reports, press coverage, and other forms of industry analysis.

Censorship, USDA

Amidst Censorship Concerns, Call for Reform at USDA

By Food Safety Tech Staff
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Censorship, USDA

A group of industry stakeholders in sustainable agriculture, environmental, beekeeper and public interest groups are call for reform at the USDA. In a letter sent to Doug Banner, scientific integrity officer at USDA yesterday, the coalition of more than 50 organizations ask for reforms to the agency’s scientific integrity policy. “The agency must prohibit suppression and alteration of scientific findings, employ clear and enforceable procedures for conducting loss of scientific integrity investigations, assure transparency and consistency in the administration of policies, adopt strong protections for scientists who file misconduct complaints, and participate in misconduct investigations when scientists and their work face interference. These actions are needed to ensure that USDA scientists can properly do their jobs.”

A recent article in The Washington Post details the story of USDA Entomologist and whistleblower Jonathan Lundgren, who has attributed the rapid decline in honeybees to the overuse of pesticides and the lack of crop diversity. Lundgren filed a whistleblower suit last fall, claiming he was suspended to prevent his research on the harmful effects of pesticides on pollinators.

According to a news release from Friends of the Earth: “An internal scientific integrity review panel at the USDA recently rejected the complaint of scientific suppression by Lundgren, claiming that agency had not violated its scientific integrity policies. In February 2016, USDA Inspector General Phyllis Fong said the USDA will open a broad investigation into the issue of scientific censorship, but did not specify whether the investigation would be made publicly available.”

The USDA, which outlines its scientific integrity policy on its website, has not released a public statement addressing the coalition’s letter.