Cannabis Safety Program – ANAB

History of Cannabis Legalization in the United States

North America was first introduced to hemp in 1606. American farmers have grown hemp that was used for a variety of products including ropes and paper and the oil was used as lamp oil. A draft of the United States constitution was written on hemp paper.

Marijuana was widely used for medicinal and occasionally recreational uses during the early 20th century and was legal on a national level until it was outlawed nationally when in 1937 Congress passed the Marijuana Tax Act, effectively criminalizing marijuana.

During the 1980s the United States pursued a war on drugs which included mandatory sentences for possession of marijuana, including the “3 strikes you’re out” policy which required life sentences for repeat offenders.

In 1996 the legalization of marijuana in California occurred when Proposition 215 was passed allowing for the sale and medical use of marijuana for patients with AIDS, cancer, and other serious painful diseases. Several states thereafter approved medical use of marijuana.

The first state to legalize the recreational use of cannabis was Colorado which legalized cannabis in 2012 under amendment 64. At this writing, 11 states have approved recreational use of cannabis and 33 states have approved medical use of cannabis.

Each state that has legalized medicinal or medicinal and recreational use of cannabis controls the application of safe growing and production practices under individual mandates and regulatory requirements.

In general, most states use federal guidelines for this control, including USDA requirements, GAP (good agricultural practices) for growers and GMP (Good Manufacturing Practices) for producers of edibles, tinctures and cannabis infused products.

Food and agricultural certification that currently apply to cannabis growing and production of edibles are:

• SQF – Certification can be achieved on production under the SQF code in Canada only, as cannabis is legal throughout Canada.
• BRCGS – Certification can be achieved on production under BRCGS for production of cannabis edibles only.
• GLOBALG.A.P. – GLOBALG.A.P. certification can be achieved for low THC hemp products.
• GMP/GAP and GMP/HACCP – Certifications are awarded by several registrars for both growers and producers of edibles, tinctures and cannabis infused.

Benefits of Certification

Benefits include:

• Improvements in control of products ensuring that contaminants such as pesticides and concentration levels are consistently monitored and controlled.
• Minimizing the potential of recalls.
• Promotes product recognition by adding consumer confidence.
• Gains in public trust.

PJFSC – Implementation Program Steps (may include)

• Step 1: Gap Assessment – Perry Johnson consultants will assess the current state of compliance of your facility. This assessment will include review of your facility’s current practices including assessment of documentation required by the chosen appliable code or standard, and the executional practices, such as cleaning methods. Additionally, the consultant will evaluate the HACCP plan, if in place. At the conclusion of the initial consult, a written report will be provided. This report will identify the areas where the organization meets the requirements and where the organization does not meet the requirements to attain certification.
• Step 2: Documentation Development – Development of the Product Safety Manual, Product Safety Procedures including procedures addressing pre-requisite programs and the HACCP plan, including identifying records to be retained as proof of ongoing food safety compliance. The documentation preparation will be conducted off site. Perry Johnson will help ensure that the system established is robust, effective, transparent and consistent.
• Step 3: Consult – Assist in implementing the developed program, including training management and staff on executing documented processes. Perry Johnson will also assist in training members of the Product Safety Team on maintenance of the Product Safety System.
• Step 4: Internal Audit – Once the Product Safety system has been established, documented and implemented, Perry Johnson will perform a full system internal audit.
• Step 5: Close-out Nonconformances – Thus preparing the organization for the certification audit by an accredited certification body.