What are the Fundamental Needs for Employee Training at Cannabis Operations?

I often ask employees in the cannabis industry if they would serve their cannabis products to their family. Is this product safe enough for your grandmother? Quality management systems are implemented by business owners, such as Good Manufacturing Practices (GMPs). GMPs include a number of procedures that if followed correctly, the product of the process is mor likely to be a safe product. Conversely, on the illicit market, when GMPs are not usually followed, this most likely leads a product being unsafe. To keep a business operating efficiently, quality management systems and software to track them is needed to address unique business needs. Another important aspect of GMP compliance is training for employees.

A recent book by Kathy Knutson , entitled Food Safety Lessons for Cannabis-Infused Edibles, highlights the importance of GMP implementation, specifically documentation and training. Once policies and related procedures are established it is essential to train on these regularly. The skills to correctly execute GMP procedures are perishable, and you have to continually seek improvement. Whether you are on boarding a new employee or providing a refresher training for existing staff, you must create and keep a culture of safety alive.

In the Knutson’s chapter on GMP, the author drills down to a list of “Absolutes” for training in the cannabis industry. This list seems to be so helpful in my work, that it is reviewed and summarized below, along with a few of my own recomendations:

 Training Absolutes

“The immunocompromised consumer”

In some industries, the consumer is described in a general way. When it comes to cannabis, this population is far from general, from health adults to medical patients of all ages. Edible cannabis products (ECPs) are being consumed by individuals with preexisting conditions. Dozens of State operators are knowingly making products that will be consumed by consumers who are already ill. Knutson puts it best, “When a food or edible is made and sold to populations who have weakened immune systems, extra precautions are taken.” Those extra steps as it relates to GMP and quality systems, include procedures to avoid cross contamination, as well as cleaning and sanitization of equipment and utensils. And employees must demonstrate a very proficient level of personal, sanitary hygiene, such as proper use of PPE. PPE products the product from the employee.

 “Handwashing and personal protective equipment”

Now more than ever, proper handwashing is such an important step that an employee can take to be effective in preventing cross-contamination. In my experience as a cannabis assessor, this is often a vulnerable or overlooked area for new operators or those undergoing rapid expansion or remodeling. The most common issues I have seen are also the most common observations cited by the FDA, according to Knutson. These include no dedicated handwashing sink, it is not accessible or accessed, not stoked, or not maintained. Dont assume everyone can do the proper technique, employees must be trained in proper handwashing techniques focusing on how to avoid the transfer of pathogens or allergens during handling. Handwashing, as they say goes hand-in-hand with PPE use. Employees should be able to readily identify when they need to completely remove their PPE, wash hands, and put on new PPE to prevent contamination.

 “Traffic patterns”

These are not the droids you are looking for. Restricting access and controlling foot traffic, are not a means to punish employees or create divisions amongst the ranks. Traffic patterns are important to manage because pathogens and other contaminants are located outside the facility, and they can hitch a ride on people, equipment, drains, or even surf on an air current into your facility. Knutson’s book highlights the pattern of trash bin and waste management as the best examples of why you need to manage traffic patterns. Identifying and understanding the traffic patterns of wheeled equipment and the employees pushing them, is essential for developing procedures to avoid cross-contamination. For example, if an employee is not trained on proper glove use, they may touch garbage, garbage bins, and every door handle to and from the dumpster. Wheels of equipment, such as carts and forklifts, are often overlooked when it comes sanitary procedures. Once an employee empties the waste, before entering restricted areas, washing hands and changing into fresh PPE is an example of one of the ways to achieve the benefits of GMP compliance.

 In addition to the brilliant points outlined in Knutson’s work, it is important also to emphasize the importance of training employees on how to document procedures, as well as being prepared for regulatory inspections. Training programs  can turn every employee into a “leak detector”, a valuable member of the team that can readily identify, communicate, and address issues before they become serious problem. 

To summarize, every cannabis edible manufacturer should treat their process and products as if they will be consumed by someone with a pre-existing condition or a serious-ill patient. As the best way to do that is with GMP and tracking regulatory compliance.