Marijuana Business Leaders Please Read This
Your Entire Industry Is At Risk If You Do Not Start Taking Food Safety Seriously
One outbreak, one death, maybe even just a few serious illnesses definitively linked to a marijuana edible could be all it takes to trigger the total and complete dismantling of the legal recreational marijuana industry in the United States. You think perhaps I am exaggerating, that it could never happen to you? Do you really want to take that chance? Businesses shutter all the time because of links (sometimes real, sometimes only perceived) to foodborne disease outbreaks. The Trump administration is itching for any excuse at all to crack down and crack down hard on you as it is. Do not give them an excuse because I have to believe they will take full advantage of any presented.
Unfortunately the nature of your product and its producers puts you at even higher risk for contamination with food pathogens than most more traditional food commodities. The idea of organic, if not the actual practice, is a major focus/selling point of many of the biggest players. One way to be “organic” is to eschew the use of chemical fertilizers. When chemical fertilizers are not available the next best option is manure and from what I can gather its use is rampant in your industry. Animal manure will contain human pathogens that will transfer onto the marijauna plant and will (probably) become internalized. There will be an outbreak linked to a marijuana edible traced back to the use of manure on the “farm”. It is only a matter of time.
Fortunately your consumer base skews young which tends to diminish the risk, unfortunately another major part of that user base are the chronically ill. Along with the elderly and newborns the chronically ill are at greatly elevated risk for serious illness from exposure to foodborne pathogens. More than likely when the first major, conclusively marijuana edible linked, foodborne disease outbreak happens, it will hit these chronically ill users first and hardest.
What should you be doing to protect yourself? There is so much that needs to be done but a place to start is with product testing. Full disclosure, I have been involved in food pathogen diagnostics for most of my career and currently work for a large third party testing lab that would stand to benefit greatly from an increase in business because of marijuana industry involvement. So yes I have a stake in this from a business perspective but I am also a public health advocate and truly believe in the power of testing as one leg of the stool in preventing foodborne disease. I am also a food microbiologist and as such can speak specifically to the approach I would consider if I were in your shoes.
First and foremost you should start testing now for indicator organisms and pathogens of the highest risk potential in the highest risk edibles (i.e. those manufactured at the highest volume at the largest producers and that have no actual or potential kill step as part of the manufacturing process or in typical consumer end use)— For indicator organisms I would suggest coliforms and generic E. coli to start with possible inclusion of Enterobacteriaceae at some point in the future. Coagulase positive staphylococci i.e. S. aureus may also be good to include as I imagine a lot of persons touching these products with ungloved hands during the production/packing/shipping process.
In terms of pathogens I would suggest E. coli O157:H7 and the big six STEC. Since none of the rest of the food industry is testing for the big six at the moment despite the FSIS directive to do so it would not be a requirement that you do. At the very least E. coli O157:H7 testing should start as soon as possible. That said if you want to look like a leader in food safety rather than someone being dragged kicking and screaming into it, testing for the big six in addition to E. coli O157:H7 may be a good way to differentiate yourself from other food industries. In addition to O157:H7 Salmonella testing needs to start asap. I also think their is a risk from Listeria monocytogenes and would suggest starting a testing program for that pathogen. In that regard I may be a bit of an outlier and a less intensive testing program may be acceptable.
Look to other food industries for examples of what works and what doesn’t. In one sense you are lucky in that so far you do not have FDA or USDA with a mandate to regulate you. In another sense however it makes things more difficult especially when it comes to designing and implementing microbiological sampling plans and testing programs. The two agencies have different approaches in a number of key areas along with some broad areas of agreement. I would suggest modeling your sampling programs on those used by the produce or beef industries. N=20 , 25g or 375g samples, compositing, etc. More than likely FDA will be the agency charged with your industries regulation if the day ever comes when the feds finally recognize it as legitimate.
Testing is not a panacea and will not prevent every outbreak. Testing alone would more than likely never prevent any outbreaks. However, it is relatively straightforward to implement, easy to explain, and something to hang your hat on and point to if/when the feds come calling. You can bet when they do they will ask you what exactly you are doing to address the concerns about the risks of foodborne pathogens in marijuana edibles. So much more I could say on this topic but I am going to stop there for now. If any marijuana people read this and are interested in more information contact me in the comments. I am happy to discuss any and all food micro related topics at any time.