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Can you have a vape and food line side by side?

vape food fda allergen nicotine crosscontamination

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#1 Quality elf

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Posted 22 January 2021 - 07:36 PM

If I produce Vape juice and I decide I want to put a food line, is that something I can do? So far I havent seen anything saying I cant.

The goal is to eventually product regular food and CBD infused food on the food line. My plan is to treat the nicotine (and eventually CBD) as an allergen, write up a plan for making sure there is no cross contact ect. But how do I validate for cleaning? is there such thing as a nicotine swab test or a cbd swab test? or would I need to send out the food for analysis and then how often? could I do each time and taper it down with data to support the validation? The room where the vape juice is produced would also be where we mix the food ingredients, and the lines would run parallel. We are US based. Any helpful guidance would be much appreciated! Thank you all!



#2 Scampi

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Posted 22 January 2021 - 07:46 PM

Just don't do that

 

Nicotine/cbd etc MAY be allergen inducing for some and I don't believe there are swab kits out there to test like the other big allergens

 

Plus you're opening your self up to selling product without cbd accidently when someone screws up (and they will)

 

The sates where there is a fairly robust regime for cbd (and thc) have made it abundantly clear that processing food and infused edibles in the same place (never mine on the same line) is a really bad idea

 

Nicotine and CBD ARE NOT FOOD  and are not regulated as such........ergo, since they aren't food you cannot produce them on a regular food line


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#3 Quality elf

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Posted 22 January 2021 - 08:09 PM

Do you have sources for the CBD vs food ? because that would be very helpful. 



#4 Scampi

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Posted 22 January 2021 - 08:14 PM

what state are you in?


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#5 SQFconsultant

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Posted 22 January 2021 - 08:36 PM

To me is it actually quite wild as to how CBD is viewed.  Non-THC producing industrial hemp can be grown all over the US and a bunch of other places. It can be harvested, exacted and then capsules and oils can be directly consumer as OTC.

 

When it comes to infusing CBD into food it gets real sticky with regulations as we have found. We have a client that makes CBD infused taffy and gummy bears and a new one that does brownies and other baked items - technically speaking they are running in a very grey area.

 

On the one side is a nod by the FDA that CDB is treated as a drug because it was used as a part of a bigger ingredient drug - logic is interesting here.

 

On the other side, there is no clearance for infusing it, but a number of companies are doing just that.

 

CBD as Scampi pointed out is not a food nor is nicotine - it would be what it is in that would be the food.

 

It's still a grey area an at any point one could be jumped on by the FDA and charged with violations.


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#6 Scampi

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Posted 22 January 2021 - 08:38 PM

https://www.fda.gov/...mals, is a drug.


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#7 Scampi

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Posted 22 January 2021 - 08:39 PM

Having worked in the legal landscape here, my two cents is DON'T, at least not until the legal wrangling is done insofar as CBD edibles 

 

You're risking your ENTIRE business on something that is at the very least gray and at the worst federally punishable.

 

It is currently still ILLEGAL to ship this stuff across state line..............you've been warned


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#8 Charles.C

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Posted 24 January 2021 - 05:30 AM

Acronyms unlimited.

 

No idea what vape is but I eventually deduced this is a cannabis-related topic ?. Forum moved.


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#9 Quality elf

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Posted 24 January 2021 - 04:59 PM

@Charles C

Vape is not cbd. Vape is the electronic cig juice stuff. I posted under the topic I choose bc I was wondering about the food related portion of this project.



#10 Charles.C

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Posted 25 January 2021 - 04:49 AM

@Charles C

Vape is not cbd. Vape is the electronic cig juice stuff. I posted under the topic I choose bc I was wondering about the food related portion of this project.

 

Hi QE,

 

"vape" may well be a popular term but was unknown to myself. Similarly "vaping".

 

Due ignorance I googled CBD (ex-OP)  >>> Cannabidiol = cannabis "related". Hence the Forum choice.

 

As I now understand, this general topic should perhaps be prefaced with a warning, eg -

 

https://www.hopkinsm...ow-about-vaping

 

Regardless, yr OP seems to have now been well-addressed, eg Post 6 to which I can perhaps usefully add its sub-link -

 

https://www.fda.gov/...cannabidiol-cbd


Edited by Charles.C, 25 January 2021 - 06:20 AM.
edited

Kind Regards,

 

Charles.C






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