Last week, it was announced that Matt Regusci had been named as Technical Director of Cannabis Safety and Quality (CSQ) to take over for former Chief Technical Officer, Tyler Williams, who has been appointed as CEO of ASI, a Certification Body of CSQ. That bit of news was just the beginning of a great 2023 as the company is today celebrating a massive accomplishment as being named in the Division of Cannabis Regulation (DCR) in the recently published emergency rules as a “published standard.”
Since its launch in 2020, CSQ has relentlessly pursued cannabis facilities in order to safeguard the cannabis industry and public health in the form of continuous improvement to the safety and quality of products Their client roster boasts over 120 operators, including heavy hitters like MSO Curaleaf and Truelieve. As published last week, CSQ is the first cannabis certification program to meet GFSI Benchmarking Requirement, as well as ISO and regulatory seed-to-sale rules.
We sat down with Williams and Regusci to talk about the impact of this inclusion in the rules for Missouri and what that means in terms of operators – both current license holders and microbusiness applicants – for the implementation of a quality management system.
CSQ is named specifically in the new rules as a standard for Missouri operators for a Quality Management System. How did that come about?
“We made it a mission to attend the MoCannTrade Meetup in Springfield at the end of 2022 with the sole purpose of getting an audience with the regulators when we knew they were participating in a panel discussion,” said Williams. He continued that the governing bodies in cannabis have good intentions – they want public health, but they typically turn to “non-cannabis” methodologies that aren’t applicable or relevant to the cannabis industry. “ISO was previously the requirement for Missouri operators and while ISO is very well respected and a high standard, it’s not entirely a good fit for what we do in cannabis. Quality is great, but the main priority is consumer safety. The reason I drove to Springfield is to get the message through to regulators. Third party certification is critical, but it should be the right choice in what is most important to our industry. CSQ is more concerned with safety and consumer protection – if you’re making edibles, we have to make sure there isn’t salmonella isn’t in them, that vape carts aren’t leaching or don’t contain Vitamin E. While the department is trying to do the right thing, we’re experts in this industry and we know we can collaborate and bring value by weighing in on this.” Williams and Regusci went on to describe the openness that the department displayed in listening to their concerns, and Regusci mentioned, “It’s awesome that the MO regulators listen to us, many regulators aren’t that open to collaboration. It shows a real commitment to consumers and we don’t see that in all states with cannabis regulators.”
Are there criteria that operators can use as indicators that they need a company like CQS to put together or refine a Quality Management System (QMS)?
“I think yes, some are more obvious than others – if you’re having constant quality control failures, repeated testing failures, those are extreme examples of red flags. I would also say the less obvious is what we call cannabis culture. We conduct a survey and see how knowledgeable team members are on safety protocols and SOPs. We can determine if there are training issues or a need for more comprehensive SOPs. ASI conducts those consulting assignments, but the facilities need to look at the resources they have internally and determine if they need help or not. Larger companies can do this in-house with their resources, but smaller companies might need to call on groups like ours.
“You can get a “mock audit” or “pre-assessment” which is a practice audit and at the end of the audit we’ll tell you what we see as opportunities and how to fix them. While some sites evaluate the results and don’t want to spend the money for us to help with correction, the sites that DO work with us, see much better results,” said Williams.
Regusci was passionate about this question in particular – especially for licensing partners of larger, national or regional brands, “If you have a plant touching business in cannabis, you NEED a food safety program in place. If you’re a brand, you should really be checking to see that the producers are following and meeting the minimum standards for consumers expectations. Your brand reputation is critical and a facility that doesn’t meet expectations reflects on the brand, not the facility.”
How can already-operational license holders implement a system using you as a baseline?
“The process flow for certification with CSQ begins with the first step, visit the website and download the procedures. Execute on those internally. Whatever that program looks like, after implementation of 30-60 days, conduct an internal audit – someone at the facility goes through the checklist, as if they were an auditor. There WILL be issues and those are expected, but we want to make sure you’re actively impacting quality. After your internal audit, an external 3rd party, like CSQ can do an audit and help you implement changes. There are many smaller steps, but looking at what you have internally first is truly the start of the process,” said Williams.
Author note: While it might seem like they’re oversimplifying, they aren’t – operators can literally visit them at this CSQ link and get started – no cost, and extremely comprehensive.
Would that be different for a microbusiness? If so , how?
“We’ve done those in other states, in NY and FL, before you can operate, you’re required to have one of our certificates. We have clients in NY that are extremely small, and it’s in your best interest as an operator when you’re going through the application process, use the CSQ free checklist to plan your application and SOP build outs – that will make your application look better and it will make it easier to get certified once you win the license,” said Wiliams and mentioned the credibility that certification can add to applications in particular.
“It’s a lot easier to start from nothing than to go in and modify existing programs – easier to change the culture and mindset of new employees than long term ones. For micros, it’s easier to start at the beginning of the process. Tyler has spent a lot of time in the last 2 years helping companies that are putting together facilities that don’t meet the standards – even locating sinks or drains in the wrong location are much easier AND less expensive to implement than in an existing facility with those issues – breaking concrete, etc. Architects know buildings and layout, but they don’t know food safety standards and don’t know how to advise on those components. We’ve partnered with some great companies that build out so we can educate them on things like food safety,” added Regusci. This could be especially helpful in Missouri for those businesses who are planning to apply for micro-licenses and beginning their application writing.
What’s the best advice you can give operators in advance of adult use going live next month, in terms of their priorities?
In all seriousness, Williams asked, “Can I give 2? The first one is more of a personal one and as an advocate – don’t forget about your patients – they’ve been loyal consumers to you since medical passed, but these are the customers who built your company. Adult-use consumers are important and will come in droves, but your patients are the ones who will continue to visit you and support your business. Number 2 of course, producers will be producing a much larger volume than usual and scaling up, but the “little” things like safety and quality should be top of mind – all it takes is one slip and a black eye from an incident with safety will never leave your company or the industry. There are people waiting for a reason to attack us and they’re out there – we can’t afford the risk.”
Regusci provided his two cents on this question as well, “Just like the food industry, cannabis has specific customers. People in cannabis search out what THEY perceive to be the best, or those that seek out what is the least expensive. Both groups that consume the product don’t want to DIE. Quality is a strategy, food safety is a requirement. As a producer, remember that food safety is the bare minimum in a quality and safety program.”
“We can’t emphasize enough that certification isn’t an over-the-top expensive outlay – safety standards and certification are less expensive than most people think and with the safety of the consumer as the goal for everyone, the ROI is extremely high, as well as being written into the requirements. The ROI is so much more than just meeting the requirements, the amount of waste that you will reduce going through the process more than justifies the cost, other immediate ROIs are less failed product testing results, less impact from pests, all of these things are huge wins for cannabis operators,” began Williams.
“We don’t charge by the hour to get a call from you with questions – while you’re implementing programs, we want to support you – email or call our team, they’ll help you! We make the process as easy as possible for you – we really try to make it smooth. The last thing I’ll say is that there are several different standards, why we don’t provide everything, we do have resources and auditors all over Missouri and can help anyone anywhere,” added Regusci.
A few observations on our existing landscape and the CSQ’s role in our compliant and growing industry that we’d be remiss not to mention. The countdown to adult use is currently an out-and-out race to be sure operators are prepared – but so many of those preparations are around supply chain, ordering and logistics, and scaling up. Talking with this team and actually understanding how much advice we can find on their website – without ever spending a dime – makes it refreshing to think of what a partnership with them would look like.
Their sincerity in a commitment to quality and safety was completely obvious during our short time together and the recurring theme of being available to help but never forcing themselves on anyone is a rare find in our industry. The tenacity displayed to get an audience with DHSS is a great reminder of something those of us in the industry have known but haven’t necessarily been able to clearly articulate or execute – we have industry experts in our state and they’re completely open to collaboration with regulators – perhaps moving forward if we can harness the relations with the DCR and industry experts, we can formulate rules and recommendations collectively and collaboratively – thus reducing the time and resources for multiple versions of rules and more harmonious cannabis-applicable considerations.
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