You may have seen the recent news about the recall of packaged flower contaminated with Aspergillus niger (black mold). The recall occurred as a result of an independent test by the Department of Cannabis Control (DCC) after the product was already on the shelves. At SC Labs, we want to be proactive in helping you understand the implications and offer reassurance that we are partners with our clients and have our own stopgaps to mitigate this risk.
In California, brands are at greater risk than ever for a potential recall, as the DCC will be making additional checks on products through their independent labs under the new regulations. We applaud the DCC’s new independent lab program, as it offers a final integrity check in the supply chain. They have a secret shopping program to test product on dispensary shelves for both accuracy in potency labeling and to identify any QA concerns that might slip through to retail (like this Aspergillus recall). Plus, this program levels the playing field for all labs with checks and balances to ensure that we’re all delivering accurate and reliable results.
The reality is that while the DCC’s standards for microbial contamination are stringent, microbiological contamination failures are actually rare. However, when a cultivation or manufacturing facility does become contaminated, especially with aspergillus, all of the product batches coming out of that facility have a high likelihood of containing some level of contamination and many of those batches will fail the state mandated batch testing. What is almost certain, is the contamination will not just go away on its own. The source of the contamination must be identified and addressed.
That’s why it’s so important that once there are signs of a contamination event—instead of looking for a different lab—you should be working more closely than ever with your lab partner. In these instances, SC Labs has a proven success record leading investigations into client’s processes, facilities, and inputs to identify and remove sources of contamination (i.e. biological control sources, substrates, etc.) and implementing microbial reduction strategies to eradicate lingering spores that can re-emerge and start the contamination process over again.
Since 2010, SC Labs has strived to set the standards for integrity, transparency, and accurate reporting that the DCC can hold all labs to. Our breadth of knowledge about compliance testing of cannabis and hemp, along with our ability to head off issues such as these, is rock solid. We have several levels of customer support that review every failing compliance test to evaluate issues, trends and patterns in client samples.
Your lab partner’s services should extend beyond just supplying you with a COA. You’ll need solutions that help you optimize product quality while mitigating risk—protecting your production processes, your brand’s reputation, and ultimately your customers.
Here are a few lessons from this event:
- The cost of reliable and reputable testing is cheaper than dealing with a recall. Fails generally mean there are issues to address. You may have to muster through a couple of micro fails but in the end, you’ll know your product is safe and compliant.
- Recalls are costly – on time, money, and a brand’s reputation. Some never recover from the upheaval. The scary part for finished product manufacturers, white labelers, cultivators, and every other producer is not the recall itself but what happens after the recall. It’s a risk you can’t afford.
- Recalls are no longer confined to the lab testing stage. This is the first time we’ve seen a brand targeted which makes it even more important to ensure that your testing partner is reliable, accurate, and vigilant. Brands are more vulnerable than ever to recalls under this new DCC model.
- Do the diligence on finding reliable partners at every step of the supply chain, including labs. A “partnership” with your lab shouldn’t prioritize avoiding fails or high potency. The choice in your lab partner should be based upon reliable, credible data so that you have the transparency to make the correct decisions.
The same conditions that are ideal for cultivation can also be ideal for the proliferation of microorganisms, bacteria, and pathogens. Microbiological contaminants can easily establish a foothold at any stage—from initial cultivation to finished product. Mitigating contamination requires a holistic approach that includes regular monitoring of the growing and processing environments—ensure facilities are clean and hygienic across your supply chain. You can further mitigate risk by utilizing R&D/quality assurance testing to pre-screen for compliance testing as well as qualify raw materials before manufacturing. Finally, ensure you engage a lab that meets the highest standards in testing, delivers thorough laboratory confirmation processes, and offers proactive data reviews, remediation strategy reviews, and root cause analysis on all failing compliance results.
Protect your investment at all costs. For most of us, the cannabis business we started and cultivated represents our entire livelihood and passion. Don’t risk your brand to save a batch. In all instances, use fails as data sets to be evaluated comprehensively and as opportunities to identify and solve issues with your processes. As margins fall and risks grow for the industry, it’s more important than ever to select lab partners who have the technical competency to earn your trust in their data, the experience to understand the intricacies of compliance and regulation, the integrity to deliver bad news, and the willingness to do the work to identify causes of your issues and implement solutions.
If you have questions or concerns about your exposure to contamination, or want to discuss any technical processes that may represent a risk to your business, please reach out to your account manager or technical customer service support. Contact us at (866) 435-0709, or email email@example.com.
SC Labs is broadly distributing this bulletin in order to bring to the attention of users of the affected SC Labs tests. SC Labs recommends that all users determine the applicability of this information to their individual situations and take appropriate action.