HACCP for Cannabis cultivation - no CCPs?

Hi everyone,

I've taken about 2 hours to work through this thread:

https://www.ifsqn.co...is-be-possible/

It spanned from 2005 to recently this year and had loads of information in it. It was very helpful, but I'm still a bit uncertain.

My client cultivates Cannabis and would like to include it in their Food Safety Management System (ISO22000) (client also cultivates vegetables, but obviously different processes apply).

This is our process:

1. We maintain mother plants to propagate from

2. Propagation (clones kept in a controlled environment while developing roots)

3. Vegetation

4. Flowering

5. Primary Processing (bucking, trimming and drying)

6. Package in 200l drums and ships as is to customer

Our end-product is therefore the dried and cured Cannabis buds. These buds are then used for infusion or extraction (by an external company - not part of my client's process)

I've just completed the HACCP analysis and then read the thread in the above link and then re-completed the HACCP analysis. I cannot find any CCPs. The "severity of outcome" is a 2 across the board (illness or injury, at most requiring treatment by a medical practitioner), because we have no allergens and the other hazards that are presented are already controlled by PRPs. The likelihood of the identified hazards is at most "3 Occasional", leaving me with the highest overall risk count being 6. The HACCP plan I'm following states that a score higher than 9 requires inclusion in the CCP decision tree. 

I'm in South Africa and this is my first FSMS. I don't know how the auditors here feel about no CCPs in a HACCP plan. It sounds off the bat as though I should be having CCPs, but I'm not about to alter a score just to include a CCP.

Anyone have any insight for me that is involved in the Cannabis industry? I know it's the end of the year and we're all pooped. Maybe HACCP must wait until the new year!

Would appreciate any help! I've attached my HACCP analysis here with client information removed. Please let me know if I'm on the right track?

Thanks

Marleen

You're good

Cannabis cultivation shouldn't have a CCP

All of the chemicals (nutrients/insecticides etc) should follow the label for application withdrawl times prior to harvest aka pre harvest interval, that would be the only point at which you may want to consider a CCP

since the plant is not actually food (Canada made sure specifically that even edibles are not "food" by definition) you will not the have same constraints

Once the flower (assuming dried properly and mold/mildew free) has gone through extraction, anything that may have been present, cannot possibly survive that process. Extraction of terpenes and/or resin is very similar to the crude oil process to achieve the individual components (kerosene, deiseal, gas etc.)

You're problem is going to be getting the auditor to understand the difference between food and cannabis

Awesome, that's great help, thanks so much!

I think the auditor should be able to understand, because we're also cultivating vegetables that have a completed HACCP process with 5 CCPs. So there's a HACCP study for the vegetables and a separate one for the Cannabis, so that should help to illustrate the differences.

Thanks so much! Much appreciated! :thumbup:

I ran into the same issue—ended up identifying PRPs like sanitation, pest control, and employee hygiene as the main controls, then documented them clearly in the HACCP plan with justifications.