Quarantine & Recall
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In this lesson, Cameron discusses how to quarantine your product prior to sale and after a potential “adverse event.”
Hey, everybody! Now we’re going to talk about quarantine and recall.
Quarantine and recall are two separate concepts that have been wrapped together for the purpose of this standard operating procedure.
Quarantine takes place during the testing phase. It is used to separate your product that is being tested prior to authorization for sale. Once your product has been authorized for sale and goes out into the marketplace, should an advent event occur you can pull that product back into quarantine where it is separated and delineated from the rest of the product.
Adverse events are something that can occur after the product has been released to the marketplace. Typical example of that might be the presence of mold or mildew that may not have been detected during testing.
When that product makes way to customers they may make a complaint. And in such a case, you may have to quarantine that product so if in an adverse event happens at more than one retail facility, they might notify you the cultivator and you may have to recall that product so that’s gonna have to be pulled back in, in quarantine separated from the rest of your product until additional testing can be conducted.
Adverse events typically take place once your product has been released for sale. Generally, this is once the product starts to move, customers may have some sort of adverse reaction. For example, they may notice the presence of mold that may not have been detected during the testing process.
In such an event, if multiple reports were received of this, the product would then be quarantined and/or recalled. Which means it would come back from the retail facilities. Anything that had not been released for sale would be wrapped with that and put into the vault in a quarantine-specific spot so it is now separated from the rest of your product and additional testing can be conducted. Potentially, the product may have to be disposed of.
Quarantined product should be stored, separated from the rest of your product, and you will want to keep it boxed in something ultimately disposable so like cardboard box. So if that product has to be destroyed, everything can be destroyed along with it. Otherwise, you might want to keep it in something like a Rubbermaid plastic container. That way it can be fully sterilized and decontaminated after the recall had taken place.
So appropriate record keeping will need to take place if a quarantine and/or recall occurs. Certainly when complaints are received about a particular batch, we can go back through our compliance software and locate all the plants that are associated with that harvest batch. All the plants that may be affected that comprised that strain that makes it possible to recall all products from the dispensaries, gather it all up, have it retested and potentially either disposed of or remediated accordingly. If it can be remediated, it can be sent back through extraction and through heat and pressure. The product can then be salvaged and retested and potentially released back out to the market.
In the other case, it would have to be disposed of according to green waste policies and procedures based on the state that you’re living in. And generally that means rendering the product unusable so shredding it up and mixing it up with soil or newspaper or cardboard and then green wasting it accordingly.
So when it comes to receiving and processing complaints, generally this begins at the retail side. And customers, if they were to have an adverse reaction will reach out to the dispensary from where their product came. If the dispensary receives more than one complaint, then it is potentially substantiated, then they can reach out to the production facility and through the tracking trace software to find out where all the product has gone to, all the product can be recalled back. And customers can be notified accordingly.
Should an adverse event occur, there’s a lot of stuff that needs to be transcribed and captured including the retail location from where it came, the strain name, the batch number, and so on and so forth. But there’s a whole lot of documentation that needs to occur in order to effect a recall and quarantine.
When an adverse event occurs, it is incumbent on the facility to initiate an investigation within 24 hours of that complaint and to act accordingly based on their findings. The goal of the adverse event investigation is to see if the complaint can be substantiated.
Frequently complaints will be “my medicine or my product did not give me the desired effect.” That’s not actually a real complaint. A real complaint would be something that affects the health or integrity of the product and the whole purpose of this is not only to remain compliant but also to maintain the integrity of your cultivation facility and its product.
When a product is recalled it is possible that it can be remediated and it is possible that you may just have to dispose of it as green waste.
Thanks for learning about quarantine and recall. Please stay tuned for our next episode.
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