Denver’s Regulation of Hemp Products Kara Lavaux 5/9/18 Rocky Mountain Food Safety Conference Denver er’s Nationally ’s Nationally Ac Accredit edited ed Pub Public ic Healt Health D Depa partment ment CONNECT WITH US 311 | POCKETGOV | DENVERGOV.ORG | DENVER 8 TV
Denver Public Health & En Den er Public Health & Envir vironment nment Empo Em powering Den ring Denver’s communities t er’s communities to liv live be e bett tter er, longer , longer 5 Divisions 5 Divisions Public Health Inspections Public Health Inspections Regulat gulated Establishments d Establishments Food Service & MJ Office of the Medical 2 Division Sections • • • Examiner Child care facilities o Food Safety & • Residential health Denver Animal Marijuana • • Protection Noise o Healthy Families • Lead Environmental Quality Healthy Homes • • Body art Community Health • • establishments Public Health • Partners closely Pools • Inspections with Denver Boarding homes • Public Health Syringe access • programs
Authority Au Denver R Den Revise vised Munici d Municipal Code l Code: Chapt Chapter 23: r 23: Food & ood & Food Handler ood Handlers • o Denver is a home-rule jurisdiction- only CO locality with own food safety regs o Regulations (Ch 23, D.R.M.C.) are applied to marijuana food businesses since 2010 o Includes concentrates if ingested Chapter 2 24: Health & th & Sanita tation tion • o Promote health of city and inhabitants/visitors o Enforcement authority for hindering an investigation o Authority to conduct recalls for contamination issues
Hem Hemp v versus Marijuana us Marijuana Both are species of cannabis Hemp Hem Marijuana Marijuana Long history of industrial use Long history of psychoactive • • use More recent breeding for • CBD/therapeutic use High in THC (5-30%) • Low in THC (less than .3% by Not legal to transport across • • law) state lines Legal to transport across All derivatives must remain • • state lines? Up for debate within state-licensed MJ (and litigation) system Recent breeding for high Selective breeding for high THC • • CBD strains and CBD strains, others
CO Cannabis Legal Summar CO Cannabis Legal Summary Both are classified as Schedule I drug federal Controlled Substance Act Marijuana Marijuana Hem Hemp 2014 Farm Bill created allowances Medical use legalized in CO in • • for state hemp pilot programs 2000 via constitutional amendment Ingestible ingredients must be • Proliferation of storefronts in derived from seed, stalk, or stem • 2009-2010 after legal 2015: Colorado Dept of Ag started challenges to caregiver model • industrial hemp program Voters approved Amendment • July 2017: CDPHE allows any part 64 legalizing rec MJ in 2014 • of hemp plant to be used in food Licensed/regulated by MED •
DDPHE Backgr DDPHE Back ground with Legal Cannabis ound with Legal Cannabis 2010: Food safety inspections of marijuana food businesses begin • 2014: Twice annual inspections of all Denver marijuana infused product • manufacturers and retailers begin; first Denver MJ recall 2015: Enforcement actions for pesticide contaminated MJ products begin, • first Marijuana Management Symposium 2017: CBD product enforcement, Cannabis Sustainability Guide, Marijuana • Health & Safety Hotline, Industry meeting 2018: Cannabis Health and Safety Advisory Committee •
Concentrat Concentrates 1 es 101
BHO & CO BHO & CO 2 pr production pr oduction processes ocesses Cultivation Cultiv ation Extraction Extraction Re Refinement Winterization, Oils extracted from raw Hemp or marijuana distillation, other plant material via plants grown, “trim” methods to refine and solvent, most used for concentrates purify extraction commonly supercritical CO2 and butane Decarbo Decarboxylation ylation Final processing Final pr ocessing Decarboxylation heat Addition of terpenes, step to activate THC or cutting agents, etc. to CBD (if not achieved achieve desired flavor during extraction or and viscosity refinement)
Hazards of concentrat Hazar s of concentrate pr e production pr oduction processes ocesses Cultiv Cultivation ation Extraction Extraction Refinement Re Process dependent Solvent impurities Heavy metals, depending on grade, pesticide, mold, mites residual solvents, pesticides End Product End Pr oduct Decarboxylation Decarbo ylation Final processing Final pr ocessing Shelf stability concerns, Higher temperature Addition of ingredients C. Botulinum hazard for needed to decarb CBD that haven’t been ingested products compared to THC– evaluated for hazards not identified smoking/vaping risks
Hem Hemp Pr Products in Early 20 oducts in Early 2017 Growing popularity of CBD products • Increasing use of hemp as CBD source • Concerns voiced by some in industry about snake oil phenomenon • Hemp-derived CBD products are NOT REGULATED by anybody • Many products coming from California; CBD concentrates sourced from • Europe, China
DDPHE A DDPHE Action in April 20 tion in April 2017 • Administrative holds placed on consumable CBD products in Denver from unregulated sources o Products from 42 manufacturers held • Based in part on info from federal agencies, DEH indicates no hemp or derivative allowed from outside CO • Holds also affect MJ manufacturers adding hemp derived CBD to products • DDPHE worked with manufacturers to evaluate SOPs, equipment considerations, and individual products
Stat State in e involv lvement ement July 2017: CDPHE accepts wholesale food facility registrations for • CBD ingestible product manufacturers CDPHE allows hemp and derivatives from outside CO provided: • o Hemp is grown under a regulated industrial hemp program o Standards for ingestion/consumption are applied DDPHE aligns with CDPHE allowance for hemp grown under an • industrial hemp program with standards for consumption– even if outside CO Still no regulation or authority over smoking/vaping hemp-derived • CBD products
Shelf Stability of Ingestible Cannabis Extracts Shelf Stability of Ingestible Cannabis Extracts Plant derived oils for ingestion must be temperature controlled unless one of the following control measures are in place for c.bot spores: Plant material is irradiated • Extract is suspended in alcohol and homogenous • Thermal critical limit met • Low pH/water activity is barrier to bacterial growth • Product is labeled for smoking only • Scientific research demonstrating safety of another critical limit is provided • and approved Businesses can submit HACCP-type plan for review and shelf-stability approval
Shelf Stability of Ingestible Cannabis Extracts Shelf Stability of Ingestible Cannabis Extracts
Decarb st Decarb steps/C. bo eps/C. bot destruction t destruction -MJ plant material must be decarboxylated (“decarbed”) through heating to transform THCA (acid form) to THC that has psychoactive effect -Lucky for us, this decarb step also destroys C. bot spores -Without decarb step, ingesting plant material and derivatives has no psychoactive effect
Questions? Questions? Kara Lavaux Food Safety & Marijuana Supervisor 720-865-5399 Kara.Lavaux@Denvergov.org Denver er’s Nationally ’s Nationally Ac Accredit edited ed Pub Public ic Healt Health D Depa partment ment CONNECT WITH US 311 | POCKETGOV | DENVERGOV.ORG | DENVER 8 TV
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