“Ohio officials on Friday recalled several medical marijuana products from cultivator Pure Ohio Wellness after it was found the products hadn’t been properly tested for contaminants.”  https://420intel.com/articles/2020/03/16/ohio-medical-marijuana-recalled-after-it-wasnt-fully-tested#.Xm-zNprkNCY.email

Essentially a clerical error allowed this cultivator to sell its product without proper contaminant testing. But the blame doesn’t fall on one person here and this should be used as an opportunity to learn what each party’s responsibility is.

It is common for states in the early stages of regulating cannabis to have difficulties with testing programs. In this case, seemingly innocent errors were made by the lab and cultivator that led to a relatively costly consequence: a product recall. 

Ohio state officials and the seed-to-sale tracking system should review how a simple input error allowed product to be sold without proper testing, but the real responsibility falls on the lab and even more so on the cultivator. The lab should review its protocol for marking products as passing or failing testing. This may require a two-person review before submission. 

The impact here largely falls on the cultivator, in the form of performing a recall. Product recall typically requires the originating facility to:

  1. Track all products that have been delivered to different facilities. 
  2. Transfer all products left under recall back to originating facility 
  3. Isolate/quarantine all product and packages attached to the harvest or production batch on hold
  4. Follow storage and retesting requirements to remove hold
  5. If required, destroy product 

 

Product recalls are costly, and every cultivation and production facility should mitigate this risk with a strong product testing and sanitation procedures.

Every cultivation and production facility should establish procedures to submit, track and report mandatory contaminant testing (typically E. coli, salmonella, microbial, pesticide residue), based on the state’s rules and regulations. There should be clear ownership of the testing program and procedures. No products should be available for sale until these testing program/process owners validate the mandatory testing has been passed. Without a clearly defined and executed testing program these facilities are at heightened risk for recall.

In cultivation operations, contamination by E. coli and salmonella are a minor risk, as they are not commonly found on cannabis. Pesticide residue recalls happen but are largely avoidable if the facility only uses allowable pesticides and follows the label’s instructions. The biggest risk for failing a contaminant test and recall comes from microbial tests. These microbial tests include bacteria, yeast, and molds. A recent ‘random mold test’ done in Colorado shows how widespread this risk really is. 

https://www.westword.com/marijuana/in-random-mold-tests-80-percent-of-denver-marijuana-dispensaries-fail-11467203

The way to mitigate these risks is by setting minimum standards for sanitation and hygiene and strictly adhering to them. Ohio and other emerging states should take a lesson from more mature states like Colorado and establish sanitation protocol. Procedures should include

  • Personnel hygiene
  • Proper product handling 
  • Room cleaning procedures, and
  • Equipment cleaning procedures

 

While these procedures may seem like common sense, without a clearly defined sanitation or hygiene program ‘microbial’ issues will likely be costly to a facility. 

Find more information about these risks see the NCRMA’s training in risk management and cannabis hygiene.