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C-45 Quality Conference a Revelation

On June 7, the C-45 Quality Association hosted its Quality Summit, bringing together quality, regulatory and lab testing professionals from Canada’s cannabis industry. Billed as an event for networking and discussion to examine current trends, challenges and innovations, the Summit set a high bar. The event featured panels and educational workshops whose participants included people from cannabis labs and suppliers, QAPs, industry executives and public sector managers.

For those wanting to take a deeper dive into quality assurance and cannabis processing, and related regulatory policy the meeting did not disappoint. For example, it’s rare to witness an open exchange with government executives at an industry event, especially where three Health Canada representatives shared the stage and took questions. Wading into the Department’s presentation, Director General Benoît Séguin declared he was open to dialogue. Delegates subsequently peppered him with queries about the Expert Panel Report on the Cannabis Act Legislative Review, advertising and promotion practices, edibles limits and QAP responsibilities.

In the midst of the afternoon government panel, alert participants scanning their cell devices reported that HC had just released its proposed regulatory amendments in the Canada Gazette. After conferring with Brazeau Seller’s, Trina Fraser, Harrison Jordan of Substance Law discovered that several proposals he’d submitted to the Review had been addressed – such as his suggestions that multiple edibles containers be allowed for packing within an outermost container; and that transparent product containers be permitted.

Health Canada’s proposals would remove the 10 mg THC limit for outermost packaging to allow co-packing of multiple product containers and would permit cut-out windows on packaging of dried or fresh cannabis and cannabis seeds.

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Jordan then invited Séguin to join him in “smoking a fatty” to the room’s general merriment.

Perhaps the most popular of Health Canada’s proposals was the draft provision to increase the number of permitted alternate QAPs to “one or more” from the current allowance of “up to two,” and to allow delegation of activities while maintaining QAP’s accountability and overall responsibility for compliance. Other streamlining proposals were favourably received, such as labelling changes to improve the clarity of consumer information (e.g., simplifying potency reporting by removing the requirement for equivalency to dried cannabis statements on product labels).

Some further highlights from the day included the following:

• Federally, only 2 per cent of inspections identified critical issues. However, 24 per cent found major issues, with the GPP category showing the highest incidence of non-compliance. Overall non-compliance for licensees last year was 5 per cent.

• In Alberta, paperwork and shipment quality are major areas of non-compliance for inbound shipments to the AGLC. Other top concerns are master data errors, mislabeling, and vendor legal issues (e.g., packaged on date exceeds age threshold).

• Vapes were highlighted by both the AGLC and OCS as the subject of frequent complaints. While Alberta reported 13,067 vape returns that number represents only 0.21 per cent of the over 6 million vapes sold in the province last year. In Ontario, consumers’ top vape complaints were clogging/no vapour, leaking and disposable pen DOA.

• National testing standards garnered much interest among attendees. Whether attendees preferred voluntary measures or federal regulations was unclear but there was general agreement on impacts.

• The panel on analytical variability cited methodological differences as an issue driving the call for common standards. Panelists agreed that lab shopping, varied sampling procedures and mixed interpretations of SOPs can skew test results. In the end, variability might be good for basic research but it’s “a killer,” as Safari Flower CEO Brigitte Simons put it, where consistency and fast turnaround are needed in a highly competitive business.

• The most cathartic session was arguably QAP workplace challenges, where those not privy to the intricacies of quality assurance got a glimpse of how the sausage is made. Production bottlenecks, label printing, the harried life of co-packers, and the trauma of lost batch records triggered gasps and knowing glances.

I came away from the event with a stronger sense of the role quality management plays in cannabis operations, the risks affecting production, and of how staff at LPs work with compliance officials and provincial wholesalers. That the Summit sparked meaningful engagement and concluded on an optimistic note would seem to bode well for Canada’s cannabis industry.