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LARA-MMFLA-ADVISORY BULLETIN July 3, 2018

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PROCESSOR REMINDERS

Applicants for processor operator licenses should take note of the following reminders via the Emergency Rules and the Medical Marihuana Facilities Licensing Act. This list is not all-inclusive and merely highlights some key areas that should be considered.

A processor of edible marihuana product shall comply with CURRENT GOOD MANUFACTURING PRACTICE IN MANUFACTURING, PACKING, OR HOLDING HUMAN FOOD (located here) to ensure safe preparation – except that refrigerated potentially hazardous marihuana product must be stored at 4.4 degrees Celsius (40 degrees Fahrenheit) or below.

The licensee shall provide employee training on safe food handling by providing either proof of ServSafe certification or documentation of employee training on food handling, including – but not limited to – allergens and proper sanitation and safe food handling techniques.

A processor is prohibited from producing an edible marihuana product that requires time or temperature control for safety. The end-product must be a stable shelf-life edible marihuana product.

A licensee shall comply with at least one of the following:

FDA Food Safety Modernization Act (FSMA)

21 U.S.C. section 2201 et seq.

Safe Quality Food-Code-Ed-7_2-Final-1-2014

International Organization for Standardization (ISO), ISO 22000/ISO/TS 22002-1

Upon licensure, the processor shall also include the following for all edible marihuana products:

  • Allergen labeling as specified by federal labeling requirements.
  • If any nutritional claim is made, appropriate labeling as specified by federal labeling requirements and these rules.
  • A statement printed in at least the equivalent of 11-point font size in a color that provides a clear contrast to the background: “Made in a marihuana facility.”
  • A processor’s edible marihuana product must comply with all the following:
  • No edible marihuana product can be in a shape, color, package, or labeled in a manner that it would appeal to minors aged 17 years or younger.
  • No edible marihuana product can be associated with or have cartoons, caricatures, toys, colors, designs, shapes, labels, or package that would appeal to minors.
  • No edible marihuana product can be easily confused with commercially sold candy.
  • The use of the word candy or candies on the packaging or labeling is prohibited.
  • An edible marihuana product must be in child resistant packages or containers.
  • Please follow this link for examples of prohibited packaging items.

Upon licensure, a processor shall prepackage and properly label marihuana-infused products before sale or transfer. At a minimum, a processor shall label any marihuana-infused product it produces or packages with all the following:

 

  • The name and address of the marihuana facility that processes or packages the marihuana infused product.
  • The name of the marihuana-infused product.
  • The ingredients of the marihuana-infused product, in descending order of predominance by weight.
  • The net weight or net volume of the product.
  • The THC level on the label along with the tag identification as required under these rules.

See the LARA – PDF Release Here

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