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Kalpna Mistry

Kalpna Mistry

What You Need to Know About Preventive Control Plans

Under the Cannabis Regulations, anyone who holds a licence for processing (standard or micro) and conducts activities in relation to cannabis extracts or edible cannabis must prepare, retain, maintain and implement a written Preventive Control Plan (PCP) for any activity they conduct in respect of the cannabis or anything that will be used as an ingredient in the production of the cannabis extract or edible cannabis.

A Preventive Control Plan is a written document that demonstrates how hazards to your cannabis product are identified, prevented, eliminated or reduced to an acceptable level. The content of your PCP depends on the activities you conduct at your site, and may include elements relating to packaging, labelling, grading, standards of identity, and food safety.

A PCP allows you to identify and describe the biological, chemical and physical hazards associated with the cannabis product (edible or extract), document how you intend to control those hazards, provide the information you used to develop your plan, and demonstrate through records that you have implemented your plan.

When conducting a hazard analysis, all hazards that present a risk of contamination to the cannabis extract and/or edible cannabis must be identified and evaluated, and a determination must be made as to how these hazards will be controlled. Your PCP should be detailed, thorough and should cover the following hazards:

Biological hazards – including microorganisms such as bacteria, viruses, parasites, fungi and molds. Examples of sources of biological hazards may include, but are not limited to:

  • Incoming ingredients, including raw materials
  • Cross-contamination in the processing or storage environment
  • Employees
  • Cannabis extract, edible cannabis, and ingredient contact surfaces
  • Air
  • Water
  • Insects and rodents

Chemical hazards – may occur naturally, or may be introduced during any stage of cannabis extract or edible cannabis processing. Examples of chemical hazards may include, but are not limited to:

  • Chemicals intentionally used in cannabis extract and edible cannabis processing, such as ingredients, including food and food additives
  • Chemicals that are by-products of processing, such as nitrosamines, chloramines
  • Chemical contamination from equipment, such as lead-soldered seams
  • Industrial chemicals such as cleaning agents, oils, gasoline, lubricants, ammonia
  • Naturally occurring toxicants such as products of plant or microbial metabolisms, including mycotoxins or histamines
  • Agricultural chemicals such as pesticides, antibiotics, fungicides, rodenticides, algaecides, and fertilizers
  • Nutrients, such as over-addition of vitamins and/or minerals
  • Food allergens such as peanuts, tree nuts, sesame seeds, milk, eggs, fish, crustaceans, shellfish, soy, mustard and wheat, sources of gluten and sulphites

Physical hazards – including many types of unwanted materials that may be introduced anywhere along the chain, from production through distribution. Unwanted materials can be introduced by anything or anyone coming in contact with the extract cannabis and/or edible cannabis, such as by people who handle the cannabis extract or edible cannabis, or during processing, distribution or storage. The unwanted materials are considered to be hazards if they can result in illness or injury to anyone who consumes the cannabis extract or edible cannabis. Examples of physical hazards include:

  • Stones, rocks and dirt
  • Metal (commonly associated with processing activities such as milling, cutting, slicing or grinding operations, as well as packaging materials or containers such as metal shards, staples and nails)
  • Jewelry and personal items (resulting from poor food handling practices)
  • Glass or other contaminants from packaging materials or containers, or from the processing environment (e.g., uncovered light fixtures)
  • Wood splinters from broken pallets or packaging material
  • Flaking paint from overhead structures or equipment
  • Insect pieces

Licence holders must have procedures for verifying that the implementation of the PCP results in compliance with the Cannabis Regulations. Licence holders must also have supporting documents to substantiate the PCP. Verification procedures and supporting documentation apply, but are not limited to:

  • Critical control points and their control measures
  • Control measures for hazards not part of a critical control point
  • Measures taken to ensure that other regulatory requirements (e.g., labelling, maximum quantity of THC, contaminants) are met
  • Monitoring procedures
  • Corrective actions procedures

Verification activities are used to confirm and demonstrate that all control measures and procedures outlined in the PCP are consistently implemented and effective in achieving the intended outcome. Every written verification procedure should answer the basic questions: who, when, what, why and how.

Preventive Control Plans require expertise in quality assurance. Therefore, your PCP must be reviewed and acknowledged by your Quality Assurance Person (QAP), who oversees the production processes and can monitor the safety of your product(s). Keep in mind, you must re-evaluate the PCP when there are changes made to any critical parameter at the time of implementation. This can include modifications to the process, components/ingredients, regulatory constraints, preparations, etc.

How we can help you

At Cannabis License Experts, we provide you with the guidance to plan your GMP-, GPP- and GACP-compliant business, acquire funding, navigate the legal requirements, and acquire the appropriate licence for your operations. As the Canadian cannabis industry develops, more and more licensed producers will be needed to meet the demands of consumers. Cannabis License Experts offers support from day one of starting your cannabis business, including strategic planning, floor plan preparation, site audits, SOPs, Preventive Control Plans and more. Our Edibles Compliance division can provide you with a solid plan for your edibles business to help get your products on store shelves. Contact us today to discover how we can license and legalize your cannabis business to meet federal or provincial regulations.

Resources

https://www.canada.ca/en/health-canada/services/cannabis-regulations-licensed-producers/good-production-practices-guide/guidance-document.html#appf

https://inspection.gc.ca/preventive-controls/preventive-control-plans/regulatory-requirements/eng/1526502822129/1526502868878

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