September 10, 2014
The American Herbal Products Association (AHPA) has published recommendations for regulators to address issues related to the safe use and responsible commerce of legally marketed products derived from Cannabis species.
Several states, including Massachusetts, Oregon, Nevada, and Illinois have considered AHPA’s recommendations in the development of state medical marijuana program regulations. AHPA’s recommendations are also the foundational documents for the Americans for Safe Access (ASA) Patient Focused Certification program, a third-party certification program that helps ensure the quality and consistency of medical marijuana products and services.
The legal status of Cannabis spp. products is in a transitional phase with many states now allowing these products to be used for medical purposes and/or adult use. AHPA chartered a Cannabis Committee in 2010 to address issues created by the legalization of cannabis in a growing number of states.
"AHPA encourages regulatory authorities in states and local municipalities where use of cannabis is allowed under local law to adopt these recommendations in order to promote the responsible commerce of this important botanical," said AHPA cannabis committee chair Tim Smale, founder and executive director of the nonprofit Remedy Compassion Center in Maine. "These best practice recommendations provide a framework for the oversight of cannabis production and distribution practices from seed to consumption."
AHPA developed the following recommendations to address four operational stages of cannabis production and distribution:
Cultivation and processing operations addresses cultivation practices, facility requirements, management of water resources, recordkeeping, and information disclosure. It also establishes best practices for operations that provide post-harvest processing of cannabis, for distribution to dispensing operations, or to manufacturing operations for the production of cannabis-derived products.
Manufacturing and related operations is generally modeled after federal current good manufacturing practice (cGMP) for foods and dietary supplements, and focus on personnel, product acquisition, physical plant and grounds, relevant controls, recordkeeping, and other factors that contribute to best practices in these operational settings.
Laboratory operations is a complement to existing good laboratory practices, these recommendations focus on the personnel, security, sample handling and disposal, and data management and reporting activities that may be unique to laboratories analyzing cannabis samples.
Dispensing operations focuses on personnel, security, product acquisition, record keeping, customer policies, and other matters that can contribute to best practice in the dispensary setting.
These recommendations are presented in the form of draft regulations to facilitate adoption and implementation. Regulatory authorities can consider the adoption of these recommendations, in whole or in part, as the basis for development of jurisdiction-specific regulations.
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