Most states have seed-to-sale tracking requirements for THC cannabis products. Metrc, we are looking at you! Love it or hate it, many states use it. Most often, these state mandated seed-to-sale programs lack the ability to track non-cannabis ingredients – various flavor and color additives, carrier oils, firming agents, allergen containing ingredients, flours, gelatins, primary packaging materials, etc. There seems to be a lack of state mandated THC cannabis seed-to-sale traceability programs that offers an all-encompassing traceability program. The responsibility of linking product flow throughout the supply chain falls on the manufacturing company. This is also true with hemp companies; each manufacturer is responsible for building their traceability program.
What is Traceability?
Product traceability is the capability to track movement of ingredients, final infused products, primary packaging, etc. throughout the entire supply chain. Traceability connects the entire process, from receiving, to product manufacturing, and through to distribution. Traceability is particularly important when it comes to a potential recall of a product. The stronger the traceability program is, the easier the investigations will be in identifying the root cause of concern.
Manufacturers commonly use these two methods for traceability investigations. Both methods require a robust traceability program!
- “trace-forward” documents the product’s path through the supply chain to the customer.
- “trace-back” documents the source(s) of a product that has been potentially implicated in a foodborne illness investigations, or recall.
Benefits of Implementing Strong Product Traceability Programs
In the event of a customer illness, product contamination, or quality issues, efficient product tracing ensures swift identification of the implicated product. Simple traceability measures will result in reducing consumer exposures to contaminated products or products that did not meet internal quality specification. This not only protects consumers, but also may save the production company with a slew of liability issues and negative publicity.
Unfortunately, most companies experience at least one or more recalls during their lifetime. In efforts to protect consumers, the FDA and local/state regulatory authorities publish product recalls to notify consumers of confirmed and potential contaminated products. An efficient traceability program will result in quickly identifying which products are associated with the complaints and will provide a more focused product batch recall rather than a large recall. The recalled batch could be specific to a common ingredient, common manufacturing date, equipment, staff, packaging material, etc. Having a strong product traceability program will expedite identifying which products need to be recalled and which consumers need to be notified. If traceability is not in place, the recall could expand past the identified product to include “any and all” products.
Traceability Programs & Internal Documents
You’re in luck! There are various traceability programs used throughout the industry. So many in fact, that finding a traceability program that fits your company is typically not an issue. Companies often times create their own traceability program. Various internal documents and programs that support traceability may include: approved supplier program, receiving and accepting all incoming products, allergen management, creating unique product identification, batch production records, inventory tracking spreadsheets, a unique batch ID code, etc. Many aspects of basic good manufacturing practices play a role in traceability and prevention of quality issues and potential product recalls.
Reach out to Allay Consulting for assistance on various cGMP practices, including traceability!
