Building the Right Quality Assurance / Safety Team for Success – things to consider
Although generally thought of as a segment of the cannabis industry, cannabis-infused edibles are, in fact, also squarely under the auspices of the food industry’s regulating powers. Not yet federally, as we all know, since neither the FDA nor the USDA can legally regulate something that is federally illegal. But facilities are being inspected by state-authorized regulatory agencies, and attention is being paid to food safety.
What makes the cannabis segment of the food industry unique is that most of its workers came up through the cannabis production rather than food, so many have no background or experience in food science, food safety or quality assurance or control (QA/QC). Thus, it can be difficult for cannabis providers to find qualified food safety or QA/QC managers. This is compounded by the fact that there is currently a shortage of qualified people in this field – due not only to increased demand but also attrition of Baby Boomers finally deciding to retire, FDA and USDA snagging workers to fulfill increased inspection needs, residency requirements to work in the cannabis industry in some states, and few students majoring in the food sciences. So even many in the federally legal food industry are having difficulties finding quality workers.
But no inspector – state or federal – will accept that as an excuse. So how do you build a qualified team to ensure the food safety and quality of your team and guard against recalls? What do you need to look for in hiring … or training for current employees?
Depending on the size of your operation, your team may be made up of just the team leader, i.e., your food safety, QA/QC manager, or you may be able to have a full team with supervisors, floor workers, and possibly even an administrator. In any case, each member of the team should have knowledge of quality and safety issues of both cannabis and food production.
Regardless of the size of the team, there should be at least one person who has a background in or at least a strong understanding of food production, preferably with experience in quality assurance, control, and/or food safety. If you are able to nab a person with a food science degree, all the better. If your team is already in place without such background, and you aren’t looking to hire further, you will want to ensure your lead person receives training and/or is able to call on and work with knowledgeable consultants.
Key areas of knowledge should include, at minimum:
Food safety. An understanding and ability to apply HACCP principles and Preventive Controls to your edibles production. The team also should have a strong understanding and ability to apply key food safety aspects such as sanitation, worker hygiene, sampling and testing, etc.
State and federal food regulations. Although cannabis is not (yet) federally legal, the FDA and USDA regulations will provide you with a strong foundation of food safety – and ensure you are prepared when federal legality arrives.
Quality assurance vs. control. Quality assurance is the pre-production development of a process that will ensure a quality. Quality controls are the in-production actions focused on the product, such as sampling and testing. Both are important to achieving quality.
Allergen Control. Knowing the “Big 8” food allergens of the U.S. and how to ensure you are producing an allergen-free product or labeling any that are present is critical to the safety of food-allergic customers.
Desire to learn. Though a much more subjective area, both cannabis and food are subject to ever-changing standards and regulations as well as technological advancements. The more willing your team is to learn and grow the better your product will ultimately be.