By In the realm of consumer safety, minimum standards form a vital safety net, providing necessary guidelines for both companies and regulators. Standards exist everywhere, from food to medicine, railroad tracks to bicycle helmets, crayons to cribs. Knowing where the lane is and how to move within it provides the structure needed to move manufacturers forward. Cannabis and Hemp Industry No exception. Why?
In this series of articles, we will be looking at specific ASTM standards that have already been developed and published by ASTM International's Cannabis Committee (usually referred to by its committee designation number D37). Due to a lack of federal clarity, states are increasingly adopting these standards directly into their regulations. And there is good reason for that. These standards have gone through an extensive and rigorous process of reaching consensus, Principles set out by the World Trade Organization These principles cover openness, balance and transparency to reduce technical barriers to trade and are one of the reasons why ASTM standards are adopted with confidence. Adopted in regulations They are set forth by the U.S. federal government, so it’s no wonder state regulators are increasingly leaning confidently toward these standards when crafting rules and regulations for cannabis industry operators.
Adopting standards has many benefits, including removing guesswork about “how” and streamlining operations, especially when companies want to scale. To bring color and context to the murky world of standards, we feature perspectives from ASTM committee members who have been involved in the hands-on process of standards development. Members include Kim Stuck of Allay Consulting, Dr. David Nathan of D4DPR (Doctors For Drug Policy Reform), and Dr. John DeVries.
“ASTM has been around for over a century, and it's common practice for governments to adopt standards created by committees. It takes so much time and effort to put together standards to create a safe and consistent product, so it makes more sense for the government to adopt standards already created from a trusted source like ASTM, rather than spending time and money to create their own standards that mimic ASTM standards. The cannabis standards we've been developing since 2017 were also written by industry experts so no part of the industry is left unregulated,” he said. Kim Stack of Arai Consultingis a strategic partner of The GMP Collective and a participating member of the ASTM D37 Cannabis Committee.
“The process ASTM employs has been proven to produce the most comprehensive and consistent standards, and I am proud to be a part of that process.” Stuck Continued. “ASTM International plays a vital role in the cannabis industry by providing comprehensive, science-based standards to guide the manufacturing, testing and distribution of cannabis products. The development and implementation of these standards ensures consistent quality, safety and efficacy across the industry, fostering trust among consumers, regulators and industry participants.”
HACCP system
The same programs developed by the U.S. Army, NASA and Pillsbury to keep astronauts from getting sick in space could be some of the best standards for cannabis operators to implement in their own operations.D37.02) recognized that and did just that. HACCP System Standardsprovides general guidance on practices to prevent, control, or minimize hazards (biological, chemical, or physical) to acceptable levels. The standard is accessible to any active ASTM member or can be purchased separately for only $63. As of publication, the standard has been adopted in three states, including Oklahoma, where it is recommended; New Mexico, where it is required for medical uses; and Colorado, where it is required for growers who want microbial reduction testing allowances as of July 2024.
“Regarding the specific HACCP (Hazard Analysis and Critical Control Points) standard that I helped develop, its application in the cannabis industry establishes a proactive approach to identifying, assessing and controlling potential hazards throughout the production and distribution process. This standardization is essential to ensure product safety, quality assurance and compliance with regulatory requirements.”
“HACCP helps industry minimize risk, prevent contamination and deliver safer products for consumers. By implementing these standards, companies can increase transparency and build consumer confidence in their products. This supports industry growth and promotes a safer marketplace while also reducing risks and preventing costly recalls and fines.”
“Regulators and legislators rely on such standards because they provide a structured, consistent framework for evaluating the industry's safety and quality. Having robust, science-based standards like HACCP establishes clear benchmarks for producers to meet, helps ensure consumer safety, and facilitates effective regulation and enforcement. Adherence to these standards gives the cannabis industry legitimacy and support from both regulators and consumers,” he added. Stuck.
Universal Symbols
The most iconic standard issued by the D37 Cannabis Committee is just that: Consumer Symbols It is recommended for use on packaging of consumer products that may contain any amount of intoxicating cannabinoids. The symbol can be stamped on edibles such as gummies and chocolates or included on the packaging. This standard solves a problem that arose from fragmented state regulatory systems. Each state developed its own symbol because they were essentially ad-hoc in enforcing rules and regulations and could not provide a universal standard. The existence of this symbol paves the way for a streamlined process for new states to legalize medical or adult-use cannabis.
Dr. David NathanA founder and past chairman of D4DPR, he was a key leader in the development of this standard, which has already been adopted by multiple states. “The International Intoxicating Cannabinoid Product Symbol (IICPS) is a uniform, universal cannabis product symbol that was developed and approved as a consensus standard. ASTM D8441 “It was approved by ASTM International with a unanimous vote of more than 200 experts and professionals from the public and private sectors. The National Technology Transfer Acceleration Act (NTTAA) mandates federal use of consensus standards, so IICPS is poised to become a national symbol for cannabis products if cannabis is legalized at the federal level.” doctor Nathan The standard can be accessed through ASTM membership or purchased for a fee of $55.
Since its introduction in 2022, the IICPS has already been incorporated into the universal symbols of four U.S. states – Montana, South Dakota, New Jersey and Vermont – and is also proposed in recent rulemaking. ArkansasSeveral other states are currently considering adopting it.” Dr. Nathan explained.
In 2023, 22 organizations representing public health, social justice, patient, consumer and industry advocacy groups signed an open letter to regulators in the United States and around the world in support of universal adoption of the IICPS. If all states where cannabis is legal were to adopt this new standard going forward, it would save significant time and money in the long run for companies looking to expand across state lines. The symbol is clear, easy to recognize, and Subject to international interpretation The decision was based on color, shape and other symbolic elements, which were evaluated through robust consumer research studies to confirm the symbol's effectiveness and intent, which were discussed in webinars available on demand. here.
In order to understand the impact of the many symbols currently in use in each state, a study was submitted to the New York State Bureau of Cannabis Control.An iconic failure of cannabis regulation” provides a variety of examples, including: Dr. Nathan He states:
“OCM’s symbol requires four-color printing and is costly, and in a regulatory space aimed at righting the failures of the War on Drugs, OCM’s symbol creates a barrier for entrepreneurs from historically oppressed communities who don’t have the capital to invest in expensive packaging.
“The OCM symbol also violates numerous consensus standards, which are technical specifications published by standards organizations such as NIST, ASTM and ISO. These are developed in an open environment with the cooperation of expert volunteers from the public and private sectors to ensure public safety and promote best practices. Standards organizations have thrived since the 19th century, and their standards apply to everything from airplanes to zippers.”
Water Activity Control
Dr. Jonathan DeVriesWho Providing food science services My expertise in regulatory and litigation matters comes from the technical personnel who helped develop the first two ASTM cannabis standards, which were developed to control the water activity of cannabis flower, directly impacting both the safety and quality of the product.
Dr. DeVries “The two methods first adopted by ASTM Committee D37 on cannabis were: ASTM D8196 Standard method for measuring water activity (circle) cannabis flowers and ASTM D8197 Standard for maintaining acceptable water activity (acircleIn the early days of ASTM D37, which was intended for growing dried cannabis flower for human/animal use in the 0.55-0.65 range, cannabis growers, processors, and users stressed the importance of controlling the water activity of cannabis flower for safety and quality. The general understanding among all involved was that too high a water activity would cause the flower to be damaged by microbial, especially mold, growth, making it unsafe (not to mention unpalatable). Similarly, cannabis flower with too low a water activity (i.e., cannabis is too dry) could lead to end-consumer dissatisfaction due to handling losses from brittleness, terpene losses due to volatiles loss from high combustion temperatures during smoking, and an overly harsh character of the smoke. Both of these standards can be accessed through ASTM membership or purchased for a fee.
“Controlling water activity to this range also makes a lot of sense for analytical, regulatory and trade purposes: cannabis that is properly dried, aged and controlled to a water activity of 0.55-0.65 will experience little change in weight due to changes in moisture (controlling to a water activity range is usually more effective than controlling moisture directly) or loss of key volatiles that are part of the cannabis experience.
“As a technical representative for ASTM D8196 and D8197, I have always been impressed with the ASTM process and, of course, how passionate the people involved in providing safe, high-quality cannabis are about the process and are eager to share their extensive knowledge and experience to create the best standard to meet their needs.”
Joint Efforts
With over 50 standards developed and published by ASTM’s D37 Committee on Cannabis and another 50 currently in development, there is a great opportunity to take the guesswork out of everything from quality management systems to devices and equipment, personnel training, evaluation and qualification, and everything in between.
Stay tuned for future installments of this article series as we explore these standards in more detail and understand their impact on ensuring consumer safety and streamlining the chaotic patchwork of imperfect regulations and practices across the industry. By adopting standardized protocols and best practices, stakeholders can increase transparency, build trust with consumers, and foster a more robust and sustainable cannabis marketplace. By working together and adhering to these evolving standards, we can pave the way toward a safer and more responsible cannabis and cannabinoid industry for all.
