Food Standards and Regulations: What you Need to know
Whether or not a producer is subject to federal standards and regulations today, following them will help to ensure that the facility meets state food safety regulations and enables the company to be prepared when cannabis and its edibles eventually, finally, become federally legal. Thus, in addition to knowing and following all state standards and laws, your food safety/QA/QC team should know, understand, and implement (as applicable):
Hazard Analysis and Critical Control Points (HACCP). Originally developed for NASA, HACCP was first adopted by the food industry in 1972. Since then it has grown to become the standard in food standard, upon which many federal regulations (such as FSMA) have been based. HACCP is a systematic approach to the identification, evaluation, and control of food safety hazards based on seven principles: Conduct a hazard analysis; determine the critical control points (CCPs); establish critical limits; establish monitoring procedures; establish corrective actions; establish verification procedures; establish record-keeping and documentation procedures.
Good Manufacturing Practices (GMPs). GMPs describe the methods, equipment, facilities, and controls for producing processed food. As the minimum sanitary and processing requirements for producing safe and wholesome food, GMPs have long provided guidance for the food industry, but with the development of FSMA’s Preventive Controls rule, GMPs are now a regulatory requirement.
Food Safety Modernization Act (FSMA). Enacted in January 2011, FSMA is today’s primary food safety regulation which incorporates seven major rules: Preventive Controls Rules for Human Food; Preventive Controls Rules for Animal Food; Produce Safety Rule; Sanitary Transportation Rule; Intentional Adulteration Rule; Foreign Supplier Verification Program (FSVP) Rule and Accredited Third-Party Certification. While all seven rules will not be applicable to the edibles producer, particular attention should be paid to the Preventive Controls rule and its GMPs, along with any applicable portions of the Produce Safety Rule.
Safe Food for Canadians Regulations (SFCR). For Canadian producers – where cannabis is now legal, though edibles still a grey area – the SFCR is the country’s new food safety rule which takes effect January 2019. Like FSMA, it focuses on prevention and allowing for faster removal of unsafe food from the marketplace.
Global Food Safety Initiative (GFSI). In April, 2018, the first GFSI certification for a medical marijuana provider was awarded to a producer in Florida. While GFSI compliance and certification could be an eventual goal for edibles manufacturers, at this point, it could be primarily an area to further develop the understanding of food safety issues and solutions, and what is being expected of food on the global level.
Labeling and packaging. While rules for labeling and packaging of marijuana products vary from state to state, they are critical components of food safety. If mislabeled, a consumer may not have a good understanding of portion control – or even realize it is a cannabis-infused product. If not well-packaged, a child could access and consume the product. Knowledge of general food labeling and packaging standards and regulations also is critical so that ingredients – including allergens – are properly labeled, food-contact approved packaging is used, etc.