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AUTHOR: Heather Allman
PUBLISHER:  CANNABIS LAW REPORT

Cannabis Sustainability: GACP and GMP

THE DISCUSSION CONCERNING SUSTAINABLE CANNABIS

On April 22, 2019, United Nations-based cannabis correspondent and global drug policy analyst Sara Brittany Somerset took advantage of our collective national climate focus to address the “cannabis carbon footprint” issue with her pertinent Earth Day Begs The Question: Is Cannabis Farming Sustainable?

Mass industrial agriculture practices are debated hotly as significant contributors to climate change. As the global cannabis industry grows exponentially, its rapidly evolving trajectory in the United States is commercial agriculture. Therefore, marijuana production is preternaturally and unequivocally contributing to climate change.

Theories abound on how to make cannabis production more sustainable. Independent farmers believe that the “marijuana Monsantos” that are muscling in are only going to make things perpetually more detrimental for the environment and the instability of the planet in the years to come. The lack of sustainability, vast amounts of water and electricity necessary for cultivation is the elephant in the room of any smoke session.

So what things factor into cannabis sustainability? Somerset answers first on cannabis agriculture and farming, specifically:

  • Types of Cultivation

Mitigating factors as to how to cultivate cannabis most ethically and sustainably are constantly in flux with the advent of new technologies, versus less harmful farming techniques. 

There are varying types of cannabis cultivation such as (a) Indoor or hydroponically grown; (b) Greenhouse potted plants using sun or sun combined with artificial lighting; or (c) Outdoor or sun-grown using just sunshine, rainwater and love.

Next, she addresses the major factors affecting the cannabis industry at large:

  • Sustainability Issues

Indoor potted cannabis cultivation consumes a massive amount of energy, due to a constant artificial daylight cycle and crop irrigation. While some outdoor, potted greenhouse cultivation can be diurnal, it also often utilizes artificial light, and consume enormous amounts of water via sprinkler systems. Sun-grown, as the name suggests, uses less artificial light and therefore takes longer to yield.

A dichotomy exists between patient adherents of organic farming principles and industrial agriculture’s shareholder-driven penchant for speeding up productivity.

  • Water Consumption & Carbon Dioxide Issues

Indoor cultivators can lessen the need for water and pesticides, two crucial detractors to farming cannabis outdoors.

Growing cannabis indoors allow control of the variables that the plant needs, which reduces water usage and controls how much water is pulled from the environment.

  • Pesticide Issues

Growing cannabis outdoors on residual pesticide-contaminated soil is a serious problem. Authorized cannabis companies offer non-competitive prices citing herb that is lab tested to be free of contaminants, including pesticides and heavy metals.

  • Craft Cannabis Vs. Big Ag

Given the rampant corruption in producing cannabis, the safest way to proceed as a consumer seems to be to eschew products from Big Ag, similarly to how farmer’s market produce is seemingly healthier than Big Ag produced crops. If DIY home-grown cannabis is unavailable, “Craft” cannabis is the farm-to-table equivalent to more robust, safer consumption.

The concept of a recent grassroots movement is to support these ideals by provoking cannabis consumers to think about who grows their cannabis, where it originates from, and its aforementioned impact on the environment.

Obviouly, the sustainable-cannabis conversation is not new to 2019, but let’s start at the beginning, so to speak. 

SUSTAINABLE CANNABIS, GACP, GMP EXPLANATION 

According to WinRich’s GACP and the Cannabis Industry:

GACP (Good Agricultural and Collection Practices) is a set of guidelines covering areas of cultivation (from seeds and propagation material), collection, harvest, processing, packaging, personnel, equipment, documentation and others for the sake of satisfying the minimum required quality assurance in plant cultivation. Together with GMP these guidelines completely define the entire process from seed to sale of all plants with Active Pharmaceutical Ingredients (APIs) to which cannabis belongs to.

In simple terms GACP states that the personnel should be adequately trained, that cultivated plants should be grown observing all local regulations on fertilizing, storage, handling, packaging etc and that the whole process should be transparent and documented. The ultimate goal is bringing a product to the market that is consistent and safe for consumption.

In addition, the World Health Organization, weighs in with their own Guidelines on Good Agricultural and Collection Practices (GACP) for Medicinal Plants

Cannabis GxP’s New Standards For Cannabis Products Quality Assurance outlines detailed steps for sustainability success in GACP in the Cannabis cultivation facility:

GACP stands for Good Agriculture and Collection Practices. The main challenge of the GACP is that the cultivation and post harvest facilities will be designed properly to minimize risks from the outer environment, to enable a correct personnel and material flow.

We want to avoid contamination of any kind, to improve the yield, to achieve the desired cannabinoid content, to optimize and control cultivation parameters and to meet the target market regulatory requirements.

Recognizable worldwide, the ISPE or the International Society of Pharmaceutical Engineering offers further insight on GMP in the Cannabis Industry:

Good Manufacturing Practice (GMP) is a system for ensuring that products are consistently produced and controlled according to quality standards. It is designed to minimize the risks involved in any pharmaceutical production that cannot be eliminated through testing the final product.

GMP covers all aspects of production from the starting materials, premises, and equipment to the training and personal hygiene of staff. Detailed written procedures are essential for each process that could affect the quality of the finished product. There must be systems to provide documented proof that correct procedures are consistently followed at each step in the manufacturing process – every time a product is made.

Available GMP Resources 

GMP Guidelines, as well as the following discussion of GMP and GACP certification implications for the cannabis industry:

Medicinal market targets treating various diseases which range from chronic pain to alleviating side-effects of chemotherapy for cancer patients. Using cannabis in medicine means its cultivation must abide strict quality standards such as the GMP (Good Manufacturing Practices) and the GACP (Good Agricultural and Collection Practices), either already or in the near future. These outline minimum requirements for growers so that they create high quality, consistent products which will later pass authorization by agencies that are in charge of licensing the manufacture and sale of pharmaceutical products.

The requirements of GMP concern handling of the products, cleaning of the machinery used to make it, packaging, quality assurance etc. while the GACP requirements outline guidelines for cultivation practices. 

Is GMP Certification required for the cannabis industry?

It is not yet enforced in all countries where cannabis cultivation is legal but it seems that it will become the norm. This is due to the fact that cannabis is considered a drug and thus must abide the same regulations that govern the pharmaceutical industry, GMP certification being one of them.

What does GMP mean in requirement and technical terms? The ISPE clarifies GMP/GACP for each of the following crucial cannabis areas:

  • Staff

The staff of the cultivation facility should be adequately educated for the jobs they are performing as well as trained in GMP requirements.

  • Equipment 

Equipment used to produce cannabis such as benches, lighting, irrigation systems, HVAC systems, containers for harvested product etc. should be made of materials that can withstand sterilization by various chemicals.

  • Sterilization

A sanitation program is to be developed which will be available to all staff members involved in the handling of the product. The sanitation program outlines the frequency and methodology of cleaning and it is part of the grow’s SOPs (standard operating procedures). The cleaning should disinfect the production areas and the equipment.

  • Cannabis Lighting

All the regulation regarding equipment explained above refers to the lighting supplier of a cannabis grow. In essence it means that luminaires need to be easily cleanable made from non-toxic materials the spectrum must of be of high quality so that yields and cannabinoid profiles are consistent, the luminaires must be of high quality so that their light output does not decay quickly and dramatically, affecting the yields, disqualifying HPS lamps from being used in GMP / GACP compliant cannabis grows.

What about the pounds of packaging? Here is the ISPE’s offering of Good Cannabis Packaging Requirements:

Packaging is the number one issue that is impacting the environment on the consumer side of cannabis. Many state regulations require cannabis be sealed in childproof packaging at the processing level. This mandate ensures proper labeling prior to distribution, and that your product has not been tampered with. It also helps speed up sales in high-traffic shops by removing the need to weigh individual products.

Eco-Friendly Cannabis Packaging Design is the Way of the Future, comprised of these four qualities:

  • Recyclable
  • Reusable
  • Durable
  • Efficient

And yes, Responsible Cannabis Framework Models Do Exist, along with these additional resources:

  1. The Global Cannabis Partnerships collaborated with members to develop a Responsible Cannabis Framework (RCF), which will act as a roadmap for members to help them go beyond what is compliant and has the potential to set an example for corporate social responsibility within the cannabis industry and beyond:
  2. Read the Responsible Cannabis Framework
  3. Fact sheet: Responsible Cannabis Framework