9 Ways to Avoid Product Recalls
in the Cannabis Industry
Before we get into the meat of the matter, we
need to define recalls and why they are
Recalls in the Cannabis Industry
Now we can specifically talk about the recalls in the cannabis industry.
Recalls in the Cannabis Industry According to the data we have, the cannabis industry is still battling compliance issues. Looking at recall data over the last three years, we can see that 73 percent of recalls since October 2018 have been caused by labeling and packaging concerns. Pathogens are the second most common reason for cannabis product recalls, accounting for 18% of all recalls. Pathogens, although being the second recalled class, account for the biggest number of infected units. Recalls can be costly and result in a loss of customer confidence, yet they are frequently preventable. The challenge now is to figure out ways to avoid recalls in the first place.
Canadian Cannabis Recalls – Total number of affected units and noted causes (Image Ref:https://cannabisindustryjournal.com/feature_article/cannabis- recalls-lessons-learned-after-three-years-of-Canadian-legalization/)
The following are the Nine Ways to Avoid Recalls:
Stay Abreast of the Rules and Regulations
It is critical to be up to date and informed about any changes in the regulations. Having up-to-date information on all regulatory changes will allow you to amend your documentation appropriately and in a timely manner, avoiding any potential recall. Furthermore, in some cases, it is necessary to be aware of all applicable legislation. The Food and Drug Act and the Pest Control Products Regulations are two examples.
Interpretation of Regulations–Carefully read and
interpret the regulations accurately
Food safety is critical– Be aware, understand and
The first step in prevention is always to understand what you are attempting to prevent. For edibles and extracts, Health Canada requires the development of a preventative control plan (PCP). Identifying and mitigating all potential dangers, such as physical, biological, and chemical risks, is critical to the successful implementation of an effective PCP. It is also critical that all batch documents are produced in such a way that all recognized hazards in the process are avoided throughout processing and that there is a verification step. This will undoubtedly reduce the number of pathogen-related recalls in edibles and extracts. Good Production Practices (GPP) and Good Agricultural Practices (GAP) can be implemented to avoid pathogen-related recalls in cannabis flowers and pre-rolls.
Formulate Correctly – make sure your formulation
is not prone to pathogen growth
Another critical component in avoiding recalls in edibles is proper formulation. Health Canada’s recommendations for edibles should be taken into account. If you’re following the rules of the cannabis legislation, you’ll need to keep your cannabis goods out of the fridge or freezer. At room temperature, cannabis-infused products should be free of bacterial or fungal growth. Shelf-life and/or stability studies are strongly suggested as part of product approval.
Perform Random testing –Do not rely on COAs
/COC from the suppliers only
In terms of supplier management, many cannabis businesses rely solely on certificates of analysis given by suppliers. This is insufficient because many food safety hazards arise during storage and transportation. These will not be detected by your supplier’s finished product testing. To circumvent this, you should implement a random testing technique. Furthermore, suppliers frequently employ a certificate of conformity (COC), which is just an administrative declaration that the product, according to the provider, meets the standard specification. Random testing of raw materials in-house can improve product quality and avert recalls.
Finished Product Testing – Have a good sampling plan
To guarantee that the product produced is safe for human consumption, Health Canada gives instructions on which Pharmacopeias to employ and when to do finished product testing. A sample that is not representative of the batch, on the other hand, may not provide an accurate picture of the batch. It is critical to develop an SOP with a sampling plan that is a true depiction of the Batch. Furthermore, execution of the written plan is critical. If a plan is properly drafted but not executed, there is a risk.
Batch documents and Checklists
Create a checklist for your batch documents that ensures compliance with all regulations. Include several steps of label review and verification in your batch document to reduce the possibility of mislabeling, missing labeling information, and other concerns.
Internal Audits or Self Inspection
Internal audits or self-inspections are required by GMP regulations. The cannabis sector in Canada, on the other hand, adheres to Good Production Practices (GPP) in accordance with the Cannabis Act and regulations, which do not necessitate this. Licensed producers can include this into their quality system, lowering the chance of recalls. To avoid bias, hire a third-party expert to conduct self-inspections.
Learn from others
It is highly recommended that you visit the Health Canada recall page and look at the recalls that other people have experienced. Preventing recalls in this manner will benefit you in the long term.
Reference: 1. https://cannabisindustryjournal.com/feature_article/cannabis- recalls-lessons-learned-after-three-years-of-canadian-legalization/
Working diligently and investing a few extra dollars to get expert advice can save thousands of dollars in recall costs and increase customer trust in your product.
President at MF License & Regulatory