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#1 MMG

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Posted 09 July 2021 - 01:14 PM

Currently in Canada which are the  microbiology regulation for cannabis infused baked goods like muffins and cookies? Does any one know what are the best testing method for this type of products between traditional microbiology and PCR?



#2 Scampi

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Posted 09 July 2021 - 02:29 PM

There are NONE

 

Cannabis infused anything in Canada in only governed by Health Canada not CFIA and as such is not considered food

 

 

What is your general concern?  Shelf life?  As your products are going through a kill step, and THC levels can be significantly reduced via baking, I'd be more concerned about that than general micro


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#3 MMG

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Posted 09 July 2021 - 03:14 PM

My concern is that exactly, I do QC micro in Cannabis and Cannabis infused products and is not a consensus on testing methods and the regulation are all over the place, most of the test for micro are conducted by traditional micro because due to the cannabinoid the microbial load get a delay growth, giving false positives and manufacturers are scared of PCR. 

I am seeing mostly on infused baked products that when you test for Total Aerobic Count by PCR and traditional methods the traditional method most of the time came back with a very low count while PCR produce the real count (not taking in consideration the DNA from dead organism)



#4 MMG

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Posted 09 July 2021 - 03:19 PM

Cannabis infused anything in Canada in only governed by Health Canada not CFIA and as such is not considered food

Why infused products are not consider food? most of them are consume by immunocompromised patients



#5 Scampi

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Posted 09 July 2021 - 04:03 PM

Ok, I'll give you the skinny on why I won't touch an edible. I was in Cannabis in quality for 1 1/2 years that I wish I could get back 

 

1) Cannabis, whether smoked, vaped, rubbed, swallowed or ingested are all lumped together

2) Cannabis is classified as a drug and as such is regulated by Health Canada

3) Health Canada DOE NOT HAVE A CLUE what a preventive control plan is but have been tasked with enforcing the regulations that require one (seriously, the inspectors were given next to zero training)

4) There are not ANY prescriptive measurements for anything other than THC/CBD levels----this includes such things as room/storage temperatures or temperatures for shipping vehicles

5) Cannabis companies DO NOT CARE about quality unless it's THC related. Period.

 

https://www.canada.c...s-topicals.html

 

Now, here's my opinion on why things are the way they are

 

1) The prime minister made a good faith decision regarding cannabis and legalization to try and combat the black market (plus it's a huge tax cash cow kaching)

2) Health Canada vehemently opposes this plan

3) Health Canada is in charge of the regulatory framework--makes it so rigid you can't function in it profitably 

4) Health Canada wanted to be in charge and is more than an arms legnth removed from CFIA

5) Health Canada does not care how THC/CBD potency react over time

 

Now, when my employer at the time wanted to start making chocolate-----I discovered that egads! no one could test it accurate for repeatable potency

 

Whoa----project delayed by 6 weeks while we worked hand in hand with the 3rd party lab to get the test accredited to move forward

 

Now---do you think anyone in the industry has performed shelf life studies on potency post production?!!?!?  Heck no, and why you might ask????????  You guessed it, because Health Canada doesn't require it. You just have to prove the potency at time of testing. No more, no less

 

 

So while you and I both understand that a cannabis muffin, is food with a drug in it, health canada believes it to be a drug with food around it............so since they write the rules............that's the way it is

 

I had my director of Quality tell me that "no one gives a sh** about quality---they just want to get high"   and that is my experience in cannabis in a nutshell


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#6 MMG

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Posted 09 July 2021 - 04:37 PM

I agree with you completely, right now the norm with cannabis manufacturers (mostly  in edibles) is lab hopping to see what method is more faulty and get them clean micro and high THC/CBD so they go to market with a CoA with no regard if the sample later growth all sort of microorganisms. 

 

My opinion is that Health Canada has no clue how to control the Cannabis and specially the edible market, here are no  regulations enforced  in Canada, because  USP/EP  do not fit the Cannabis industry, this regulations are mostly intended  form pharmaceuticals  and Natural health products that never were intended to have cannabis in it. Cannabis act is very vague and all is left to the reader interpretation. I do consider that CFIA should be the one regulating this type of products.

 

Agree with what you said that edibles are food with drug in it, some of them with a very complex matrix perfect for microbial contamination don't even require micro testing according to HC.



#7 Scampi

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Posted 09 July 2021 - 04:42 PM

Yes agreed 100%

 

Glad to have left that industry and hope to never return----I saw some very scary stuff

 

if I were a consumer, I'd take my chances on homemade cannabis butter and make my own before I'd ever touch a purchased anything

 

The labs all know what's going on----they are happily getting fat and not reporting

 

The director i mentioned before sent dried flower to 3 different labs..............WTH--that's fraud IMHO


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