Social cannabis use is taking cues from the food and beverage industry. Marijuana-infused food pairings, like wine dinners, are becoming part of the overall cannabis experience. Under this scenario, chefs or caterers may be hired to prepare meals at private residences in accordance with the jurisdiction’s laws.
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Explore This IssueAugust/September 2017
Of course, facilitators of cannabis dinners must be mindful of how the intoxicant may influence diners. They must understand how edibles are metabolized, and that the resulting intoxicating effect is different from smoking. If the cannabis dosage is not incorporated into the recipe in moderation, or if the food is improperly prepared, the meal can result in overdoses or foodborne illnesses, which could trigger potential liability.
Cannabis Food Safety
The popularity of cannabis-infused edibles may be an even greater food safety risk than catered dinners because of the number of consumers such products may reach. Companies recalling marijuana-infused edible products for ordinary food safety reasons has become a common practice. Such recalls have ranged from failing to meet packaging requirements to prevent foodborne illnesses to producing products found to contain potentially dangerous (to humans) pesticides, which are banned for cannabis cultivation. Other problems have resulted from erroneous or misleading labels that do not reflect accurate dosages, ingredients, or potency.
Third-party independent testing laboratories and standard operating procedures that incorporate Hazard Analysis and Critical Control Point, i.e. HACCP, plans and current Good Manufacturing Practices are necessary for the production of safe marijuana-infused food products. State laws and regulations are evolving to incorporate these food safety principles.
In Florida, cannabis is approved only for medicinal uses, but cannabis production facilities are still subject to food safety requirements. These new requirements mandate that licensed medical marijuana treatment centers demonstrate that their processing facilities have established a food safety Good Manufacturing Practice (such as the Global Food Safety Initiative) with oversight and inspection by a nationally accredited certifying body. Florida has taken this a step further by initiating the development of regulations tailored to these products. For example, the Florida Department of Agriculture and Consumer Services must assist the Florida Department of Health in developing testing requirements for contaminants in edibles, including sanitation rules that apply to the storage, display, or dispensing of edibles.
In April, the California Office of Manufactured Cannabis Safety released proposed rules that address food safety concerns. The rules prohibit edibles that contain potentially hazardous food, including products that must be temperature controlled, perishable bakery products that must be maintained in cold temperatures to prevent the growth of microorganisms, and dairy products. Also, no ingredients other than cannabis extracts or concentrates can be used to manufacture edibles unless they are FDA-approved. Licensees are prohibited from infusing alcoholic beverages with cannabis, and edibles cannot contain additives (like nicotine or caffeine) that would increase their potency or create an unsafe combination with other psychoactive products. The proposed rules mandate that manufacturers must ensure that all personnel complete a food handler course accredited by the American National Standards Institute.
Although these regulations are designed for the commercial production of cannabis-infused edibles, the overall food safety concerns are relevant for the unlicensed, off-site preparation of cannabis-infused meals in private settings.
Food Safety Recommendations
The FDA Model Food Code, which has been adopted across the country, is designed to ensure proper food handling and production to avoid contamination and foodborne illness. This is because such problems are generally caused by microbiological, chemical, and physical hazards that are introduced into the food before it reaches the consumer. Five major risk factors have been identified as leading to foodborne illness: 1) improper holding temperatures, 2) inadequate cooking, 3) contaminated equipment, 4) food from unsafe sources, and 5) poor personal hygiene.