On February 11, Health Canada published the Cannabis Voluntary Recall Guide which provides information on the requirements related to voluntary recalls of cannabis and cannabis products under the Cannabis Act and Regulations. A recall is intended to minimize the risk associated with a problem or potential problem with the cannabis or cannabis product by removing it from the supply chain while providing important health and safety information to the public.
This guide is applicable to federal license and permit holders conducting activities with cannabis, including:
- Cultivators (nurseries, standard and micro)
- Processors (standard and micro)
- Sales
- Analytical Testing
- Research
- Importers (medical, research, hemp)
- Exporters (medical, research, hemp)
Under Section 46 of the Cannabis Regulations, license holders must establish and maintain a system of control that permits the rapid and complete recall of every lot or batch of cannabis that has been sold or distributed. This means that license holders must have documented processes with regards to maintaining sale and distribution records and carrying out recalls, which includes recall reporting.
The Cannabis Voluntary Recall Guide outlines the typical actions to be taken by a license holder in the event of a voluntary recall, including:
- Informing Health Canada
- Ceasing the production, distribution and sale of the cannabis or cannabis product
- Removing the cannabis or cannabis product from the supply chain
- Correcting or destroying the cannabis or cannabis product, if applicable
- Contacting affected supply chain customers to notify them to stop further distribution and sale of the cannabis or cannabis product
- Contacting affected clients to advise against use of the cannabis or cannabis product, if applicable
- Providing instructions to supply chain customers and clients on what to do with the cannabis or cannabis product remaining in possession
- Assessing the effectiveness of the recall
- Taking corrective measures to prevent the problem underlying the recall from recurring
Additional information on each of the points above can be found within the guide. In addition, Health Canada will post all recall notices on its Recalls and Safety Alerts website.
For a successful recall to occur, it is important that a collaborative effort is made between the license holder and all other parties involved in the supply chain. Each party should be aware of their roles and responsibilities and should communicate and share any recall information on a regular basis. Remember, a well-established procedure can make all the difference in the effectiveness and outcome of a recall.
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Cannabis License Experts offers end-to-beyond license solutions for cannabis businesses to meet federal or provincial regulations. Contact us today to discover how we can license and legalize your cannabis business.
Resources:
https://laws-lois.justice.gc.ca/eng/acts/C-24.5/
https://laws-lois.justice.gc.ca/eng/regulations/SOR-2018-144
