MJBizMag May-June 2021 - 59

Also, MedPharm workers use white
coats when mixing ingredients that
don't have allergens such as peanuts but
use blue coats when mixing ingredients
that have allergens. Wearing specific
coats when working with allergens
helps contain them and prevent crosscontamination.
Other
procedures guide what
chemicals, nutrients and soil are
allowed, how they should be stored and
how they should be mixed. Gutierrez
said there are steps on how to properly
irrigate your grow, how to handle
runoff when it occurs, how to ensure
that mold and mildew aren't building
up and how to clean a flowering room
after it's been harvested. In the food and
product development labs, MedPharm
staffers wipe down and sanitize counters
at the end of every day but repeat the
cleanings in the morning in case any
airborne contaminants landed on the
tables overnight.
Other important GMP steps include
cleaning machinery and calibrating it
daily to make sure it's measuring correctly.
" There's a lot of different components
to it all, " Gutierrez said. " You want to
make sure you're putting standards in
place and buffering yourself to make sure
you're not letting contaminants in. "
Elias from Common Citizen agreed.
" It's not just the facility side of the
equation. To maintain your GMP
standards, you need to really drive it
within the culture. And there's a lot of
work that the humans have to engage
in to sustain it: How we touch the
product, how we move the product,
what materials we use in processing the
product-everything from what kind of
scissors you should be using to what the
tables need to look like, " he said.
It is important when creating foodgrade
products not to use any materials
that attract contaminants, Elias said,
adding that " porous materials are a big
no-no. "
" A lot of these suppliers now are
actually going out of their way to
make sure that cannabis-specific
The Galley is pursuing GMP certification for its facility in Santa Rosa, California, where workers create
cannabis-infused products such as bath bombs for client companies. Courtesy Photo
instrumentation and equipment is
GMP-certified, because we are asking
for it now. "
THE FINAL EXAM
Once an executive feels strongly that a
company's facility and processes have
reached and even gone beyond minimum
GMP requirements, they should
seek certification from an independent
GMP certifier to make it official.
In fact, some certifiers suggest running
a mock GMP audit before a real audit
to discover any shortcomings that
might have been overlooked and need
correcting.
" We had a third-party auditor come
in after we had established everything
and asked, 'OK, now what are we
missing? Where did the gap analysis
show improvements need to be made?' "
Gutierrez said. " It is possible to miss
things, and having an audit guide you
is helpful. Now, every year we just go
through renewals. And it's another audit,
but it goes pretty smoothly because we
know what we're doing. "
Audit certification renewals cost about
$5,000 to $7,000, Gutierrez said.
While prepping and going through
one's first GMP audit and certification can
be expensive, subsequent audits for renewal
are much easier because most of the
work has been done, minus updates that
need to be made because of rule changes.
" The good news is, once you've written
a couple of these, you can look at one and
base the rest of them on that. It's not like
you're reinventing the wheel the entire
time with your SOPs, " Holman said. " The
way we clean things has to be consistent,
reliable and the same. When you do all
these things and you have all these things
in place, one of the benefits is that it's
much easier to scale, " Holman said.
STAFF BUY-IN
Getting employees to abide by GMP can
be another challenge.
" We can write SOPs till I'm blue in
the face. We establish these operating
procedures that are extremely robust
and very detailed, but sometimes things
get missed or they don't get followed, "
Holman said.
To make sure GMP is being
maintained at its facility, Common
Citizen consistently has seven to 10
people who serve on an internal qualityassurance
team that makes sure GMP is
being followed.
" GMP facilitates repeatability of
process. For it to succeed, you need
to have a culture of developing and
sustaining standards. Standards are what
drive repeatability, reproducibility, to
deliver on the same quality outcomes
over and over again, " Elias said.
Gutierrez agreed. " These are all things
that are important, because as we go into
this next phase of cannabis, the maturity
of the industry is going to really increase
times 10, " he said. " We want to be ahead
of that game. That's always been our play. "
May-June 2021 | mjbizdaily.com 59

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