As Canada approaches the legalization of cannabis for recreational use, the question of regulatory oversight has been a hot topic. In the US, the FDA governs both food and drugs, but in Canada, drugs are regulated by Health Canada while food products are regulated under the CFIA. The public is largely focused on issues like age restrictions and impaired driving, but there is another pressing question on the table: should cannabis be treated as a drug or a food product when it comes to safety? In addition to that, when it comes to food safety, what hazards should we be concerned with?
In terms of food safety, cannabis and cannabis edibles are no different than any other food product. Although the food safety hazards associated with cannabis will be unique to the specific product/process, they can be adequately controlled through the introduction of a HACCP or HARPC program to mitigate risk. There are many food safety hazards associated with cannabis products that are not currently being adequately controlled in the industry which have resulted in foodborne illness outbreaks and recalls. Some of the product recall causes have included pesticide contamination, temperature abuse and high coliform counts.
Although we do not have a large number of studies or set criteria for the microbiological standards to refer to on the subject of cannabis and food safety, we do have some knowledge surrounding the hazards associated with cannabis growing, manufacturing and distribution. We can also refer to foods that are similar such as greenhouse grown tomatoes, sprouted seeds, hops and medical supplements as a basic guideline for hazard determination.
Currently, when developing HACCP Plans for cannabis products, the following hazards need to be fully considered and controlled.
Due to the fact that cannabis is an agricultural product, improper growing conditions, handling and storage can result in unfavourable mold growth (Aspergillus, Fusarium, Penicillium, Mucor, Actinomycetes) which can produce mycotoxins including aflatoxins, which are poisonous carcinogens. Deuteromycota in general are also of concern, due to the fact that they are super-spore producers, allowing easy distribution and propagation. Poorly controlled humidity throughout the process can contribute to the growth of mold and will require control at every level of cannabis production.
Opportunistic pathogens have been encountered in the limited number of studies performed and include Cronobacter, Enterobacter, Raoultella, and Escherichia hermannii. Enteric pathogens (Salmonella, Hepatitis A) have been found in cannabis when contacted with fecal material such as contaminated irrigation water. Due to the fact that edible cannabis is heated in its process to undergo decarboxylation the inactivation of these microbes will occur, although post-cook contamination is still possible. For infused oils (including oil extractions and butter) Clostridium botulinum is a concern, as it produces heat-resistant endospores that are able to survive in adverse conditions.
Chemical residues from growing (fertilizers, pesticides) and processing (it is important to use food grade chemicals throughout the process) are a major concern. Pesticide use has been responsible for recalls in the cannabis industry, as the use of pesticides is restricted. A total of 16 recalls were recorded in August-December of 2015 due to pesticide contamination. It is important to note that the cost associated with recalls such as these can threaten a business financially and destroy a brand. Growers are often faced with needing to exert some sort of control over their crop due to the susceptibility of cannabis to pests, for example powdery mildew. There are currently four pesticides approved for use, although the general consensus is that these pesticides have limited efficacy leading growers to choose more potent varieties with the hope that these will not be screened for during regulatory testing. As the industry matures, the issue of pesticide use will require careful consideration in order to ensure public health is protected.
Some studies have shown that there is antimicrobial activity associated with THC, CBD and especially terpenes. The minimum inhibitory concentration (MIC) is in the order of micrograms and is well below the average serving of 40mg. This could mean that very robust antimicrobials exist in the mosaic of marijuana that could actually benefit a broad range of foods. Once there is scientifically validated evidence available regarding the antimicrobial properties of cannabis it will be possible to include these considerations in the development of a HACCP or HARPC Plan.
Although more research is required before we can fully understand the food safety concerns associated with cannabis growth, manufacturing and distribution, one thing is clear: food safety risks will require mitigation and a key piece to the puzzle with be the development of a robust HACCP or HARPC Plan.
dicentra Cannabis Consulting is committed to keeping you well informed and educated on the proposed Cannabis Act and the proposed cannabis regulatory framework. We are committed to providing you with news, updates and information as Bill C-45 (the proposed Cannabis Act) progresses through the legislature. For any cannabis related questions, please contact us by phone at 416-361-3400 or toll free at 1-866-647-3279 or via email at info@dicentra.com.