Food Safety Lessons for Cannabis-Infused Edibles

Kathy Knutson

• Publisher: Academic Press
• Year: 2020
• Print ISBN: 9780128195123
• eBook ISBN: 9780128195376
• Topic: Biological Sciences
• Subtopic: Biology
• Index: Biological Sciences

Food Safety Lessons for Cannabis-Infused Edibles details the world of cannabis-infused edibles and the way its manufacturing is evolving as the industry moves from isolation to regulatory compliance. The cannabis industry has unique challenges as cannabis-infused edibles are not regulated as food, drugs or dietary supplements at the federal level. Despite these current conditions, the industry is aware of the need to examine the safety of these edibles and prepare for a future of federal compliance. The book looks at the cannabis industry through a scientific lens to increase awareness and expertise in food safety within the field of cannabis-infused edibles.- Includes lessons learned by the food industry- Presents unique challenges in the manufacture of cannabis-infused edibles- Provides information of US Federal food safety compliance- Explores the current state of research regarding edibles

Chapter 1

Introduction

Abstract

Cannabidiol products are widely available in the United States, and patients in 33 states have access to medical marijuana. In the United States, cannabis companies are licensed and regulated at the local and state levels. Canada legalized cannabis for smoking at the federal level in October of 2018 and followed with the legalization of cannabis-infused edibles in October of 2019. Legalization of cannabis in the United States requires the descheduling of marijuana off the federal Drug Enforcement Administration's list of scheduled drugs. After descheduling, cannabis regulation can align with existing regulations for pharmaceuticals, food and dietary supplements under the enforcement of the Food and Drug Administration.

Keywords

Cannabinoid; CBD; Deschedule; Dietary supplement; Dispensary; FDA; Hemp; Legalize; Licensing; Marijuana; Regulation; THC

Introduction to the author: it’s personal

I work in the cannabis industry, and I don't get high

As a food scientist, I am used to writing in the third person about science, not about me. In scientific and technical writing, we are trained to not use the word “it” and to write about the methods, observations, and analysis of data. Well, this book will have plenty of observations, but they will be my observations and, in some cases, a single data point. I will ask the questions I had about the cannabis industry, the questions that you probably have too. I will describe my lessons learned in getting the answers to those questions. I speak only of which I know. I am a bucolic girl from Wisconsin, a foodie, a locavore, and a cook. Training of adult learners is my career passion.

Note

Definitions of vocabulary start in a later section of this chapter. Turn ahead for definitions if you need them sooner.

My first exposure to weed was at a dry cleaner

Nearly everyone has a personal story of their first exposure to cannabis. Until 2017, I had almost no exposure to marijuana in my 50-plus years of life. I grew up in a small town outside Madison, Wisconsin. My first job was working six hours per week at the one dry cleaner in town and closing up after the full-time ladies finished. I was 16 and alone when one day a high school teacher of mine came in to pick up his dry cleaning. I knew him well from after-school activities he supervised. It was custom to staple anything found in the pockets of the clothes to the paper ticket stapled to the plastic bag. When I retrieved his dry-cleaned sport coat from the turning rack, there on the ticket was stapled a baggie of weed. As I did with all the customers, I simply asked if the stapled item belonged to him. He was not able to get a yes or a no out among the stammering, but he paid the dry-cleaning bill and left with the sport coat and baggie of weed. At that time, I literally had no idea it was weed. Given his reaction, it is only my logical conclusion that it was weed. It could have been oregano.

In the last week of high school, I was at a friend's house and smelled something funny. I followed the smell and found her older brother with a few friends in the living room smoking weed. He asked me if I wanted to try it, and I said no. Beside the one time, I was never exposed to weed or asked to smoke weed through my entire K–12 education and 10 years of university education. I just did not have friends who smoked. I grew up in a time when cigarettes were advertised on billboards and in magazines. Kids smoked. Adults smoked. Restaurants and bars were smoke-filled. I tried a cigarette once. That hurt my lungs. Most of my extended family did not smoke cigarettes. Again, I just did not have friends who smoked cigarettes, yet alone weed.

Fast-forward through jobs, marriages, and raising my two sons, and “someone” in my house tried to flush weed down the toilet and it floated. “Someone” left a mostly empty bag of weed on the passenger side of my husband's car, after “someone” used the car to drive with a friend to an amusement park. I was not amused. Thus began my journey of learning about cannabis use. They say education begins at home.

In 2017 I was talking with my colleague, Rick Biros of Innovative Publishing, at the Food Safety Summit. Innovative Publishing Company LLC owns Food Safety Tech and manages the Food Safety Consortium annual meeting and exhibits. I have known Rick since 2000 and my days as Outreach Manager for the National Center for Food Safety and Technology (NCFST), renamed as the Institute of Food Safety and Health. Rick was telling me that his son, Aaron Biros, had graduated from college and joined his company to write a cannabis publication. The thought was so foreign to me that I burst out loud laughing. Oops. Rick kindly explained the role of the Cannabis Industry Journal and how the cannabis industry was growing. That was my first lesson.

In the fall of 2017, I received a call from another NCFST colleague, Sanford Wolgel. Sanford was looking at writing a state application for a cannabis-infused edible manufacturer and wanted to know if I was available to help with the Good Manufacturing Practices and maybe other documentation such as Standard Operating Procedures. That was my second lesson. While the project with Sanford did not go to fruition, I listened to and learned everything I could from Sanford about the cannabis industry. He had worked in laboratory operations and product development, knew the chemistry of cannabis, and still is an expert in regulations.

Note

The words product and products are obviously the singular and plural forms. However, use of product can be plural as well. In other words, products is plural. Product can be either singular or plural in use. English is fun.

My role as a consultant

While most of my career has been in academia and laboratory operations, I dipped my toe into the consulting pool in the beginning of 2016, when I became employed by Jeff Kornacki of Kornacki Microbiology Solutions, Inc. In addition to my work with Jeff, I was a Lead Instructor for the Food and Drug Administration (FDA) Preventive Controls for Human Food (PCHF) rule in the training of Preventive Controls Qualified Individuals (PCQIs) and a member of the Expert Services Team at ConnectFood where I assisted in writing food safety and Hazard Analysis and Critical Control Point (HACCP) plans. In this gig economy, I was looking for more work as an independent consultant. I thought I could take my food safety expertise and transfer my skill set to cannabis-infused edibles. I will talk more about transferring your skill set to the cannabis industry in a later chapter. The next step was to call Rick Biros. Rick got me connected to Aaron Biros, and my inauguration into the cannabis industry started with the publication of a series of my articles in Aaron's online journal, the Cannabis Industry Journal. That was my third lesson.

Box 1.1 Preventive controls

Preventive and preventative are synonyms, and the FDA chose to use preventive. Preventive controls are procedures to control identified hazards in a food or cannabis-infused edible facility. Chapter 6, The Hazard Analysis, and Chapter 7, Preventive Controls, will detail the steps for writing a food safety plan to include a hazard analysis and preventive controls.

I was ready to learn more about the cannabis industry. I continued to talk with Sanford and Aaron about the industry and research online. The perfect opportunity came for me in 2018 to attend a major cannabis conference and exhibit. I was scheduled to deliver the PCQI course close to San Jose just ahead of the annual conference managed by the National Cannabis Industry Association (NCIA), called the Cannabis Business Summit & Expo. As an exhibitor, Aaron had an extra badge for me to get in without paying, and my flight was covered by the training I delivered, so I attended. At the time, I was talking up the application of the FDA requirement for a written food safety plan and implementation of preventive controls because that is what I know. Most of the cannabis industry was not there yet,...

Table of contents

• Cover image
• Title page
• Table of Contents
• Copyright
• Chapter 1. Introduction
• Chapter 2. Overview of the cannabis industry
• Chapter 3. Begin with the end in mind®: the dispensary
• Chapter 4. Good manufacturing practice compliance is not optional
• Chapter 5. Chemistry of cannabidiol and Δ9-tetrahydrocannabinol
• Chapter 6. The hazard analysis
• Chapter 7. Preventive controls
• Chapter 8. Nobody is talking about environmental monitoring
• Chapter 9. Operation: manufacturing of edibles
• Chapter 10. Operation: packaging and labeling of edibles
• Chapter 11. Training needed in the cannabis industry
• Chapter 12. Jobs in the cannabis industry
• Chapter 13. Final thoughts
• Appendix 1
• Appendix 2
• Index