Tag Archives: safety

Jill Ellsworth, Willow Industries
FST Soapbox

Modeling Cannabis Safety from Food and Beverage Quality Regulations

By Jill Ellsworth
1 Comment
Jill Ellsworth, Willow Industries

There’s a reason you can eat or drink pretty much anything you want from American grocery stores and not get sick. Food manufacturing is highly regulated and subject to rigorous quality control.

Before food and beverages hit store shelves, the manufacturer must have a Hazard Analysis Critical Control Point (HACCP) system in place. The HACCP system requires that potential hazards—biological, chemical and physical— be identified and controlled at specific points in the manufacturing process. In addition, fresh foods undergo a kill-step. This is the point in the manufacturing or packaging process where food is treated to minimize and remove deadly pathogens like bacteria, mold, fungus and E. coli.

Generally speaking, when cannabis hits dispensary shelves, a less stringent set of rules apply, despite the fact that cannabis is ingested, inhaled and used as medicine. Cultivators are required to test every batch, but each state differs in what is required for mandated testing. Compared to the way food is regulated, the cannabis industry still has a long way to go when it comes to consumer safety—and that poses a considerable public health risk. In the early stages of legalization, the handful of legal states did not have rigid cannabis testing measures in place, which led to inconsistent safety standards across the country. State governments have had a reactionary approach to updating testing guidelines, by and large implementing stricter standards in response to product recalls and customer safety complaints. While local regulators have had the best intentions in prioritizing consumer safety, it is still difficult to align uniform cannabis testing standards with existing food safety standards while cannabis is a Schedule I substance.

The stark differences in safety measures and quality controls were first obvious to me when I moved from the food and beverage industry into the cannabis industry. For five years, I operated an organic, cold-pressed juice company and a natural beverage distribution company and had to adhere to very strict HACCP guidelines. When a friend asked me for advice on how to get rid of mold on cannabis flower, a light bulb went off: Why was there no kill step in cannabis? And what other food safety procedures were not being followed?

What to know more about all things quality, regulatory and compliance in the cannabis industry? Check out Cannabis Industry Journal and sign up for the weekly newsletterThe current patchwork of regulations and lack of food safety standards could have dire effects. It not only puts consumer health in jeopardy, but without healthy crops, growers, dispensaries and the entire cannabis supply chain can suffer. When a batch of cannabis fails microbial testing, it cannot be sold as raw flower unless it goes through an approved process to eliminate the contamination. This has severe impacts on everyone, starting with the cultivator. There are delays in harvesting and delivery, and sometimes producers are forced to extract their flower into concentrates, which really cuts into profits. And in the worst cases, entire crop harvests may have to be destroyed.

So, what do cannabis cultivators and manufacturers have to fear the most? Mold. Out of all the pathogens, mold is the most problematic for cannabis crops, perhaps because it is so resilient. Mold can withstand extreme heat, leaving many decontamination treatments ineffective. And most importantly, mold can proliferate and continue to grow. This is commonplace when the cannabis is stored for any length of time. Inhaling mold spores can have serious adverse health effects, including respiratory illness, and can even be deadly for immunocompromised consumers using it for medical reasons.

What the industry needs is a true kill step. It’s the only way to kill mold spores and other pathogens to ensure that they will not continue to grow while being stored. States that mandate microbial testing will benefit from the kill step because more cultivators will be in compliance earlier in the process. In states that don’t require comprehensive microbial testing, like Washington and Oregon, the kill step is a critical way to provide consumers with a preemptive layer of protection. Microbial testing and preventative decontamination measures encourage customer brand loyalty and prevents negative press coverage.

Adopting a HACCP system would also build additional safeguards into the system. These procedures provide businesses with a step-by-step system that controls food safety, from ingredients right through to production, storage and distribution, to sale of the product and service for the final consumer. The process of creating HACCP-based procedures provides a roadmap for food safety management that ultimately aligns your staff around the goal of keeping consumers safe.

It’s high time for the cannabis industry to adopt FDA-like standards and proactively promote safety measures. Cannabis growers must implement these quality controls to ensure that their products are as safe to consume as any other food or drink on the market. Let’s be proactive and show our consumers that we are serious about their safety.

Don Groover, DEKRA OSR
FST Soapbox

Why Changing Workplace Safety Culture Must Start From the Top

By Don Groover
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Don Groover, DEKRA OSR

Workplace safety in the food industry can be challenging. The precision required of workers in slaughter, meat packing or wholesale processing facilities can lead to serious harm or worse. The Bureau of Labor Statistics reports that the potential hazards in this industry are many: Knife cuts to the hands and the torso, falls, back injuries, exposure to toxic substances, carpal tunnel syndrome, and even infectious diseases.

This industry may have more challenges in safety than any other industry. Yet, there are companies that excel in safety performance, even given these challenges.

Organizations that are serious about protecting their workers must do far more than react after an injury or rely on awareness-based safety efforts. Typically this approach only delays the next injury. Safety is not just about responding to injuries, but is about the ongoing identification of exposure, the implementation of control systems, and assuring these controls are used to neutralize the exposure.

The challenge is that the root of why an exposure exists or can even thrive in an organization maybe due to culture, organizational urgency, operational instability or a lack of understanding about the concept of exposure, to mention a few. Because the issue is bigger than safety programs, safety excellence requires all levels of an organization, from the C-Suite to the frontline worker, committing to a process that focuses on exposure. This needs to be done in a way that creates trust that safety is a value and if there is a values conflict, that safety has top priority.

Ultimately, it’s about shifting culture by making a safety excellence a priority.

Oftentimes leaders articulate that they want a safe culture, but they may not fully understand their role in creating the culture they desire and how they sustain the change. Senior leaders must go beyond a catch phrase approach to safety and actually articulate what are the cultural attributes they want to see firmly embedded in their organization.

These may be:

  • Workers watching out for each other and a willingness to step in if somebody is at risk.
  • Excellent housekeeping.
  • Workers stepping up to address physical hazards without being asked.
  • A willingness to report safety concerns and incidents.

Once the attributes are defined, then the organization is ready to understand what it takes to support that culture.
However, senior leadership needs to drive that change. Once upper management understands that accountability starts with them and not with the worker, they can move forward and create a culture that reinforces practices that identify potential exposure before incidents take place and not after. Doing so not only has the potential to lower incident rates, but it also:

  • Boosts morale. Workers believe the company has their backs and will commit to safety principles.
  • Strengthens trust between workers and management. Workers believe that safety excellence is a shared responsibility.
  • Increases commitment to all organizational objectives. Social theory research has shown that if you do something for someone else, they experience a pull to reciprocate. The more we do, the stronger the pull. When management shows that they can be trusted with employee safety, employees are free to reciprocate in other areas.

Our strongest and deepest relationships are built on a foundation of safety—not just physical safety but also psychological safety. If we come to believe that another person is interested in our physical or mental wellbeing, the foundation strengthens.

When leadership uses the power of safety they will see employee engagement increase. And the safety implications of worker engagement are profound: Disengaged workers are focused on their own safety. Involved workers are concerned with their own safety but are likely also concerned with the safety of their workmates and perhaps certain other people they interact with. Fully engaged workers are concerned with the safety of everyone around them and without prompting take proactive actions to help others.

Engaged workers are more likely to follow rules and procedures, be more receptive to change, and give discretionary effort. It seems like all companies are doing some type of engagement survey, yet the actions they develop to try and raise their scores are often lacking. Organizations that are serious about having an engaged workforce must fully understand how safety is foundational to engagement. More importantly, safety involvement activities need to be designed and implemented in a way that moves employees beyond mere involvement to full on engagement.

When a company demonstrates it values safety, workers will volunteer to get involved. Leadership must carefully consider what safety involvement activity is right for the culture. When employees participate in a successful and rewarding involvement activity, their personal level of engagement will move upward. Leadership must then figure out how to expand safety involvement. This isn’t done by demanding involvement. It requires purposeful planning and patience.

Megan Nichols
FST Soapbox

How Automation Benefits the Food and Beverage Industry

By Megan Ray Nichols
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Megan Nichols

During seasonal volume and demand peaks in the food and beverage industry, common practice is to increase labor and mobile equipment supplies temporarily. While this works great for small- to medium-sized businesses even in the current landscape, it’s not ideal for larger teams. This is primarily due to the evolution of technology, especially in the automation sector.

Adding more labor and machines can help increase volume, but it comes with a sizeable cost, one that could be shaved with the right process and system updates. As one might expect, adopting advanced automation systems, robotics and processes that can be controlled via machinery or software is the answer. Believe it or not, these systems can be made to work alongside and improve performance of existing laborers and teams.

In fact, automation is taking many industries by storm, and it’s about time food and beverage companies climbed aboard. Automotive, construction and healthcare are just three examples of industries already being disrupted by automation and AI.

But how is the technology being adopted or implemented in the food industry, and how will companies benefit from incorporating such systems?

Better Quality Control

Along the food and beverage supply chain, there are so many involved processes, workers and touchpoints that it can be difficult to not only keep track of food, but also to monitor its quality. As you know, quality is of incredible importance in the industry. You don’t want faulty or contaminated foods entering the market because it can be detrimental. Food must always remain traceable and safe, and it’s difficult to guarantee a system that has so many working cogs.

Automation, however, can change that completely. With the appropriate systems, defects and issues can be noticed much earlier in the supply chain. By detecting problems during packaging or processing, you can cut down on the total number of problematic goods that enter the market. Better yet, you can accurately identify when and where those problems are coming from and remedy the issue for improved performance in the future. If something along your supply chain is the culprit, automation will help you hone in.

Eliminating contamination can be controlled — and achieved — by deploying the appropriate cooling and air compressor systems. However, that also means understanding where this hardware must be utilized for maximum reliability. Automation and analytics systems can be helpful in discerning this information, better protecting foods and goods along the chain.

It’s not a pipe dream, either — systems are already being adopted and implemented to achieve such a thing.

End-To-End Traceability

While we touched on the idea of traceability a little in the point above, it’s the lion’s share that’s really going to make a difference. Automation and modern analytics tools can be deployed to track products and goods from inception to fulfillment. Because the systems in question are designed to track and monitor on their own with little to no input, you can tap in anywhere along the chain to seek the information you need.

Have a contaminated shipment that was discovered too late? You can use the modern analytics and automation tools at your disposal to find exactly where they are shipped or headed. This way you can head off a massive health problem before it even starts.

This, in turn, can help alleviate compliance costs and stressors, as well as improve the overall performance of the supply chain and various key processes. You could, for example, see how long a particular stop or touchpoint along the supply chain is taking and use the information provided to speed up performance.

End-to-end traceability and all the data that comes with it is about more than just watching where food comes from, where it is handled and where it goes. You can use the data provided to build an accurate profile and predictive system for future gains.

Improved Worker Safety

Automation systems, AI and modern robotics are often used to control rote, repetitive and sometimes even dangerous tasks. In this way, you can save human laborers from the dangers of a particular activity or even the monotony of busy work. It frees them up to handle more important demands, which is another benefit.

Of course, increased safety and protection for your loyal workforce can also work to alleviate operation or maintenance costs in the long run. It can lead to faster and more widespread adoption of new standards and regulations for your workforce at large as well. Traditionally, such a change might require additional training, new equipment or even better protection for your workers.

In the case of automation, you can simply update the existing hardware and software to be compliant and save the trouble of maintaining everything else, such as updating safety gear for your workers, which would no longer be necessary.

Efficiency Boost

It’s no secret that when deployed and developed properly, a machine or automation system can perform work faster and better than human laborers, at least in some cases. A machine never tires, never gets bored and can never slack off—unless it has a malfunction. That’s not to say modern technologies will be used to replace workers outright, but instead, they might be deployed alongside them to help them work faster, better and safer.

Take Amazon, for instance, which has deployed an army of AI and automation robots inside their warehouses to improve the efficiency of their order fulfillment process. It has the added benefit of speeding up the entire system, so customers get their items faster. It also improves safety and performance for the workers, effectively eliminating unsafe tasks or rote work.

Automation can provide benefits across the board for the food and beverage industry. It will be interesting to see how technological developments unfold.

RFID tags on drying marijuana flowers

Marijuana Edibles: Update on a Rapidly Developing Market

By Aaron G. Biros
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RFID tags on drying marijuana flowers

A lot has changed since last year’s article, “Marijuana Edibles: A Regulatory Nightmare.” Marijuana has since catapulted into mainstream thinking via activism, state decriminalization, and medical reforms while investors and banks are beginning to trust the market more, further legitimizing the nascent industry. According to an article from the Washington Post, Colorado’s legal marijuana industry reached $700 million in 2014 and is expected to grow to $1 billion by 2016.

Innovators are beginning to analyze trends on a national level, looking toward federal rescheduling of the drug as a catalyst for more state reforms and wider legalization measures. Federal legalization is in the back of many minds, as the introduction of pivotal state and federal legislative reforms promises more access to banking services, medical research, and more state independence.

While a black market mentality remains prevalent, widespread state reforms, increased venture capital investment, and further legitimization of an industry with less barriers of entry have fostered a perceived reduction in risk. States like Oregon, Washington, and Colorado that have already legalized marijuana for recreational and medical sales are beginning to implement strict packaging rules, requirements for traceability, QA programs, testing and laboratory monitoring requirements, and other regulations that would suggest FDA oversight down the road.

marijuana buds drying in racks biotrackthc
Dried marijuana buds curing with RFID tags as part of the traceability system of BiotrackTHC

State regulatory bodies such as the Colorado Marijuana Enforcement Division (MED) have matured and expanded their oversight to include certifications and requirements for lab testing and analysis. Marijuana testing facilities can now be certified by the MED to test for residual solvents, poisons or toxins, harmful chemicals, dangerous molds, mildew or filth, harmful microbials such as E. coli or Salmonella, pesticides, and THC levels and Cannabinoid potency.

According to an article from theCannabist.com, edible marijuana took 45% of the market share in 2014 and continues to grow, proving that food manufacturers and processors will gain a bigger share of the market.

BioTrackTHC develops a seed-to-sale traceability system that is the state-mandated reporting system used by any business that touches the plant in compliance with Washington’s i502 regulations (The company also won the contract bid for New Mexico’s and New York’s state-run traceability systems). “From day one, all retail products under i502, including infused edibles, must have laboratory-submitted passing test results and data in the traceability system before it can be unlocked for shipment to retailers,” says Patrick Vo, CEO of BioTrackTHC.

RFID tags on drying marijuana flowers
RFID tags on drying marijuana flowers, from BioTrackTHC

Regulations, especially those addressing traceability, are crucial for advancing the industry and fighting the black market, performing recalls, and improving product quality and safety. Vo adds, “As more states adopt a centralized traceability system, food safety will improve as we see the industry grow.”

“Most of the marijuana edibles producers we advise are working comfortably within their state health department regulations versus a year ago when they were struggling to implement routine compliance,” says Stephen Goldner, CEO of Regulatory Affairs Associates.  “But there is a long way to go to make this new marketplace meet the standards routinely met by US food producers in other markets such as nutritional supplements and medical foods.”

Many edible producers are sadly mistaken to ignore FDA labeling and production regulations just because the producer only ships within their own state, according to Goldner. “Whenever FDA has found label or food safety violations of products, whether they are food, drugs or any other product, it has always acted quickly to seize the product, inspect the producer and insist that violative labeling or production practices be remedied,” he says, adding that it won’t be surprising to see FDA start to “seize marijuana-infused food products that make drug claims, especially from the leading current producers” as a way for the agency to insert itself into the inspection and compliance process. “These companies need to have FDA food GMP’s solidly in place and properly documented,” says Goldner.

“Those who have experienced the most consistent and long term success in this industry are those who play above board, those who take the extra effort and make the investment in effort, time, and money to treat their business as if it was already federally legal and had to adhere to standards that other industries must follow,” says Vo. He agrees with the view held by many that long term planning is vital in this industry. “Those who have implemented best practices, QA programs, and traceability software will succeed in the long run, and the bad actors will eventually, by their own poor practices, be filtered out by regulatory and market forces.”

In the near future, the industry will look to other states in regulatory experiments on opposite sides of the spectrum. “New York, which legalized medical marijuana in 2014, is handing out 5 licenses to operate 4 dispensaries each, and allowing licensees to have a grow facility to supply their respective dispensaries. The Commissioner of the New York State Department of Health will have authority on licensing, testing, and medical requirements for patients seeking treatment with medical marijuana,” says R. David Marquez, who operates a Long Island law firm focusing on the cannabis industry.

New York is implementing very strict rules regarding cultivating and processing the plant. California, on the other side of the spectrum, already operates a somewhat loosely regulated medical marijuana market and has been doing so since 1996. The bill to legalize marijuana recreationally in the state is widely expected to pass vote and be implemented in 2016. This would open up an enormous market potential and contribute to the growth of the industry on a national level.

Because marijuana edibles are theoretically both a food and a drug, it is only appropriate that the FDA should look to regulate the industry in the future. In the meantime “Those who have invested the time and money in staying compliant now will be far ahead of the game tomorrow,” says Patrick Vo, who is looking toward federal legalization.

It seems that manufacturers and processors at the forefront of quality and safety testing will succeed in the long run.

Footnote: This is a regulatory update on the cannabis industry with an emphasis on edible marijuana. CannabisIndustryJournal.com, the newest publication, will be launched in September of this year. CannabisIndustryJournal.com will educate the marketplace covering news, technology, business trends, safety, quality, and the regulatory environment, aiding in the advancement of an informed and safe market for the global cannabis industry. Stay tuned for more!

GM Apples and Potatoes are ‘Safe’: FDA

Arctic Apples have ‘silenced’ genes that prevent them from turning brown when bruised, while genetic modification of Innate potatoes reduces the activity of genes that cause tubers to turn brown.

The U.S. Food and Drug Administration has completed its evaluation for two varieties of apples genetically engineered by Okanagan Specialty Fruits, Inc., and for six varieties of potatoes genetically engineered by J. R. Simplot Company and concluded that these foods are “as safe and nutritious as their conventional counterparts.”

Okanagan’s Granny Smith and Golden Delicious varieties of apples, known collectively by the trade name “Arctic Apples,” are genetically engineered to resist browning associated with cuts and bruises by reducing levels of enzymes that can cause browning.

Simplot’s varieties of Ranger Russet, Russet Burbank and Atlantic potatoes are collectively known by the trade name “Innate” and are genetically engineered to reduce the formation of black spot bruises by lowering the levels of certain enzymes in the potatoes. In addition, they are engineered to produce less acrylamide by lowering the levels of an amino acid called asparagine and by lowering the levels of reducing-sugars. Acrylamide is a chemical that can form in some foods during high-temperature cooking, such as frying, and has been found to be carcinogenic in rodents.

Foods derived from genetically engineered plants must meet the same legal standards, including safety standards, as foods derived from traditional plant breeding methods. Though producers of genetically engineered foods are not compelled to submit their products for FDA approval, both Okanagan, of British Columbia, Canada, and Simplot, of Boise, Idaho, submitted to FDA a summary of their safety and nutritional assessments.

“The consultation process includes a review of information provided by a company about the nature of the molecular changes and the nutritional composition of the food compared to traditionally bred varieties,” said Dennis Keefe, Ph.D., director of the FDA’s Office of Food Additive Safety. “This case-by-case safety evaluation ensures that food safety issues are resolved prior to commercial distribution.”

The changes are expected to make the produce healthier, more palatable and easier to transport and sell without spoilage, and hence result in less food waste. But the approval is expected to spark controversy among critics who argue that genetically modified foods will introduce potentially dangerous unknowns into the American food supply. Okanagan and Simplot may label their products as GMO, something that many consumer groups have advocated for.

Source: FDA.gov

Is Beneful Dog Food Poisoning Pets?

A lawsuit filed in Northern CA claims that the dog food was responsible for sickening three dogs – and killing one of them; concerns have been raised about some of the ingredients such as propylene glycol and mycotoxins.

A class-action lawsuit filed in a District Court in Northern District of California claims that Nestle’s Purina PetCare Company’s Beneful dry kibble dog food has sickened – and even killed – thousands of dogs.

According to the lawsuit filed by Frank Lucido of Discovery Bay, CA, since the family began feeding their three dogs Beneful in late December 2014 or early January 2015, all of them became ill, and one died. Internal bleeding in the stomach and liver lesions were was revealed during the post-mortem examination of the dog that died, while similar symptoms were found in the other two dogs, a German Shepherd and a Labrador Retriever.

Nestlé Purina has retaliated describing the lawsuit as “baseless,” adding that two similar class-action lawsuits earlier had been dismissed by the courts. Bill Salzman, the company’s director of corporation communications said that: “Beneful is occasionally the subject of social media-driven misinformation. Online postings often contain false, unsupported and misleading allegations that cause undue concern and confusion for our Beneful customers. Bottom line: Consumers can continue to feed Beneful with total confidence.”

There are concerns raised in the lawsuit about ingredients in the dog food such as propylene glycol and mycotoxins, stating that the first one is a known animal toxin and a component of antifreeze, and mycotoxins, produced by mold found in grains, are a health risk to dogs. However, the company states that the type propylene glycol it uses is FDA-approved, and the type that’s used in human foods such as salad dressing and cake mix.

Following Lucido’s story, Jeff Cereghino, of Ram, Olson, Cereghino & Kopczynski in San Francisco, checked further and saw a much widespread pattern among several pet owners. “Several folks were trying to draw exactly the same causal link. Thousands,” said Cereghino, in San Francisco.

The lawsuit has raised concerns among pet owners. Veterinarians have advised those who are concerned to be aware of common poisoning symptoms and bring any concerns to their family vet.

Lucido’s lawsuit is alleging negligence, misrepresentation, product liability and unfair business practices on the part of Nestlé Purina and is reportedly seeking more than $5 million in damages, plus costs and fees.