• The Acheson Group

Is Black Market Marijuana Infiltrating your Supply Chain?


A recent national news headline blared: “Tests show bootleg marijuana vapes tainted with hydrogen cyanide.” What if that headline said, instead, “Tests show bootleg marijuana edibles tainted with hydrogen cyanide” … or any other pesticide or contaminant?


Would the edibles industry be reeling as the vape industry is today? Would states be banning edibles “for six months” as some are for vaping? Would edibles CEOs be resigning; states are issuing “emergency orders” … would people be dying?


Unfortunately, it’s not unreasonable to expect these very same things could happen in the edibles industry from bootleg marijuana supplies or simply a lack of food safety practices.


In a recent HashTAG Insights article, we discussed why and how retailers should assess their CBD edibles supply chain program to ensure they are in compliance with all the varying state laws as well as ensuring purchase from a reputable source. And, as the recent marijuana vape incidents show, it is critical that every link in the chain of a product that is intended to be ingested ensures that it flows through reputable and legal sources and production.


This is clearly evidenced by the testing that NBC commissioned on a sampling of THC cartridges in which it found that 87% of the black market cartridges contained a residual solvent, and 100% of those tested for pesticides were positive for the fungicide myclobutanil – which can transform into hydrogen cyanide when burned.


Not only is it just as likely for black market marijuana to infiltrate edibles as it has vapes, but the fact that marijuana has now been nationally linked with a toxin puts a target on all applications – whether it be, or go by the name of, marijuana, hemp, cannabis, CBD or THC. It brings the potential to the forefront and creates a hot button for anti-cannabis consumer groups, as well as legislators and regulators.


As the NBC article states, “FDA is struggling to police what has rapidly grown into a billion-dollar industry with a booming black market” – a comment that is just as applicable to the cannabis industry as a whole. Despite its struggles in policing, the agency isn’t just sitting back and watching. Rather the articles cite Acting FDA Commissioner Ned Sharpless as stating: "To be clear, if we determine that someone is manufacturing or distributing illicit, adulterated vaping products that caused illness and death for personal profit, we would consider that to be a criminal act." Again – a simple change of the word vaping to edibles brings the statement home.


But, while it is critical to ensure the legality of every link of your supply chain, it also is essential to realize that any unknown contaminant from any point in the process can severely impact your product. So, having processes in place that identify potential hazards, foster preventive practices, and provide for corrective action, all go a long way in mitigating risk. Such processes could include:

  • HACCP (Hazard Analysis and Critical Control Points) – focused on critical risk factors for ingestible products, and all other product offerings.

  • Food Safety Plans – development or gap analysis reviews including process controls, environmental controls to ensure products are not contaminated post manufacture, allergen and cross contamination management, etc.

  • GFSI (Global Food Safety Initiative) Program – compliance/certifications

Mitigating risk also includes that of risk to your business and reputation should an incident occur with your product or edibles in generally. Do you have a recall and crisis management plan; food safety communications; social media crisis containment? As the food industry has shown time and time again, an incident with one product in a segment (e.g., romaine lettuce, tomatoes, peanuts, etc.) impacts every application of that food. In that aspect, marijuana is no different. Are you prepared?



Contact the HashTAG Team today for more information and assistance with your supply chain, food safety, and recall and crisis management programs.

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