Compliant packaging and labeling can get tricky in a highly regulated industry like cannabis.
This became evident last month, when the Oregon Liquor and Cannabis Commission (OLCC) issued recalls for mislabeled cannabis tinctures produced by Cura CS LLC and sold under the company’s Select brand. Curaleaf, Cura’s parent company, acknowledged that the company mixed up its THC and CBD tinctures, ultimately labeling the THC drops as containing only CBD and labeling the CBD drops as containing 17.25 mg of THC per serving.
California-based cannabis operator Papa & Barkley also produces both CBD- and THC-based products, and Guy Rocourt, the company’s co-founder and chief product officer, has worked diligently to avoid this kind of product mix-up.
Here, Rocourt offers tips to streamline the packaging and labeling process when producing both THC and CBD product lines.1. Consider separate manufacturing locations for THC and CBD products.
How do you avoid mixing up THC and CBD products at your processing facility? For Papa & Barkley, the simplest solution is to manufacture the products in separate facilities—and in different states.
The company produces CBD products for its national product line at partner facilities in Oregon, Colorado and Vermont, while manufacturing its THC products at Papa & Barkley’s facility in its home state of California.
“The way we’ve been able to avoid any cross-contamination, if you will, is by simply having it in two facilities in different states, for that matter,” Rocourt says. “There’s zero chance at Papa & Barkley that we will accidentally have a CBD product labeled as a THC product or vice versa because they’re in separate houses.”2. Live by your SOPs.
Many cannabis companies may not have the ability to set up shop in different states, however, and in that case, Rocourt encourages operators to establish and follow robust standard operating procedures (SOPs) to create consistency and minimize mistakes.
“We should know, as an industry, that GMP certification is coming,” he says. “Robust SOPs, chain of custody of the supply chain, compartmentalization of these over-the-counter secured inputs—we need to have those SOPs.”
Papa & Barkley has trained its staff to respect the company’s SOPs and not cut corners, Rocourt says, and the company records its day-to-day operations separately, outside of Metrc, the state’s seed-to-sale tracking system, to build some redundancy into the process.
“If in fact I need to recall something or find something, I can find every single unit down to the gram,” he says.
Ultimately, Rocourt says cannabis processing facilities should mirror manufacturing facilities in other industries.
“Inputs, especially ones that are active ingredients like cannabis, [should be] heavily tracked, not just through Metrc with the state, but through your own internal purposes so that you render it impossible for your employees to make a mistake like having the wrong active ingredient in a differently labeled bottle,” he says.Photo courtesy of Papa & BarkleyPapa & Barkley produces CBD products for its national product line at partner facilities in Oregon, Colorado and Vermont, while manufacturing its THC products at Papa & Barkley’s facility in