This past week, both Colorado AND Oregon's cannabis programs saw major safety failures of products make the news. With each recall or health advisory, there is a range of issues. The details beg for more questions. Ultimately, our industry is underequipped to be able to handle failures like these, that, left unchecked, will result in a catastrophic failure. It is a matter of WHEN not IF. This is the perfect opportunity to employ a fundamental tool that is used in successful businesses all around - CAPA.
Why? Simply put - product issues, health alerts and recalls affect you FAR BEYOND the initial issue. The press associated with it can do irreparable harm to your business. But even more, it affects the reputation of the entire industry! Think of how 1 crash of a self-driving car results in large swaths of the population being hesitant to trust any self-driving car. The same thing applies to cannabis. We all need to do our part to raise the bar and show that we mean business. Time to put a system in place to reduce your errors. Oh -- and it will save you some money along the way!
CAPA stands for Corrective Action and Preventive Action. It is one tool - albeit, a very critical tool - that is used in businesses globally. It is part of the tool box that ensures Toyota reduces their errors to almost zero. The ability to identify and respond to issues - whether it be on the production floor, in the cultivation room, or the executive suite before they become systemic or are a risk to consumer health and safety is vital to maintaining compliance and achieving consumer expectations. A CAPA process is a systematic approach for documenting, identifying, and correcting existing and potential quality issues from various data sources.
CAPAs provide you with a step-wise approach to identify the true root cause of the issue. Often times, seemingly disparate issues repeat themselves within an organization because of a simple underlying cause. For example, the lack of a supplier approval program can result in someone accidentally ordering products that are not approved or safe for use. This may indeed be the case in the two situations that occurred in Colorado and Oregon this past week. Only a true CAPA investigation will shed clarity on this.
The State of Colorado recognized the importance of CAPA programs to protect and ensure consumers and patients can count on their products being one of the safest in the nation. As of January 1st, they now require ALL cannabis license holders to have CAPA and Recall plans implemented. They even created guidance documents for the industry to follow. These can be found on their Science and Policy webpage here.
There exist additional, hands on resources to get you not only into compliance, but set up to really harness the value of CAPA programs. They can reduce your internal quality challenges, and rework by over 50% in the first year when implemented correctly. At The GMP Collective, our team has created an Integrated CAPA and Recall Implementation Program. It includes SOPs, Forms, and Logs for use, as well as up to 8 hours of training to ensure that you are able to utilize them correctly. We even help you conduct your first mock recall. Think of it like an annual fire drill. You are preparing for the worst case scenario - isn't it better to practice and be prepared than blindsided? On average, we have found that companies are able to trace less than 30% of their product back through the supply chain after 2 hours. This is despite having a seed-to-sale tracking system. Trust your tools, but verify. The data will surely be eye opening. It could even save your business, or, someone's life.