Go back in time 40 years ago and ask an Average American about cannabis. They might recall their last Grateful Dead concert. Passing by vendors selling special brownies infused with the substance (though clearly illegal and under the radar), it was all part of the experience.
Now, since 2016, when Proposition 64 passed in favor of its recreational use, cannabis is finding its way into the mainstream. From topical creams and lotions to hemp oils and lip balms, the popularity of Cannabis or CBD-infused products is growing. Unsurprisingly, cannabis is also starting to permeate the gourmet food scene with the creation of “infusion food”.
A small handful of restaurants and hotels are slowly starting to incorporate this trend into their cuisine to elevate a customer’s dining experience. For example, at NoMad hotel in New York, chef Andrea Drummer, has designed a CBD-infused menu for the restaurant with dishes such as spicy meatballs and ice cream sundaes containing CBD. Similarly, Pattern Bar in LA is creating CBD-infused cocktails, like their signature cocktail, the Armani, which is made of sparkling wine, gin, and CBD oil mixed along with mint and elderflower liqueur.
Despite being accepted and approved in most states, regulations for cannabis production and manufacturing are strictly enforced. Cannabis-infused products, or CIP’s as they are known, must follow guidelines with regards to food safety from storage and sanitation, to transporting and manufacturing.
According to Steven Burton, a contributing writer for the Cannabis Industry Journal (2018) states must be attentive to contamination due to improper growing conditions, handling and storage, chemical residues on plants and edibles, pathogenic contamination from pests and improper food handling practices, and concentration levels of cannabinoids. If left unchecked, products can fall victim to mold, mildew, and disease-causing agents such as salmonella and E. coli, to name a few.
Manufacturers looking to use infusion for commercial food products must apply for a Type-N License, which allows for infusion as well as packaging and labeling cannabis products on the licensed premises. Businesses in California looking to incorporate cannabis into their products also need to follow regulations issued by the California Bureau of Cannabis Control. Here are a few regulations taken from Chapter 13 in Title 17 of the California Code of Regulations:
Subchapter 1 Article 2 Section 40115 (a): Anyone wishing to manufacture cannabis products must obtain a valid manufacturer’s license from the State Department of Public Health for each building where manufacturing operations are conducted. Licenses aren’t transferrable to other people.
Subchapter 1 Article 2 Section 40118 (3): A “Type N” license is required for manufacturers that make food products or topical products using Cannabis infusion processes. Other types of Cannabis products may be infused except for extracts and concentrates. In addition, a Type N license also allows manufacturers to package and label cannabis products at buildings that have been licensed for manufacturing. Registering and operating the licensed premises as a shared-use facility is another use that Type N licensees can undertake.
Subchapter 2 Article 1 Section 40131: This section requires applicants to submit information about the manufacturing facility and its operation methods such as type of activity conducted (extraction, infusion, packaging, labeling), types of products manufactured, whether the products are used for medicinal-use or adult-use, and contact information of the on-site individual who manages the operation of the building. A diagram of the building is also required, detailing areas where commercial cannabis activities are conducted along with procedures concerning quality control, security, waste disposal, transportation, and inventory control.
Subchapter 3 Article 3: This article details good manufacturing practices for cannabis including premises construction and design, sanitary operations and facilities, and equipment used. Construction requires protective coverings and ventilations to reduce contamination and allergen cross-contact for Cannabis. Cannabis-product contact surfaces must be sterilized and cleaned along with the equipment used for handling the products. Further measures taken towards preventing contamination include surfaces that are corrosion-resistant and made of nontoxic materials. Freezers, storage compartments, and instruments must be kept clean and well-maintained.
Subchapter 4 Article 1 Section 40305 (a) and (b): This section provides limits to how much THC will be contained in Cannabis-infused food products. Only 10 milligrams of THC are allowed per serving while 100 milligrams of THC are allowed per package. Multiple servings of a cannabis product must contain the same concentration of THC.
The Cannabis industry is growing to enormous proportions and will continue to rise. One profound example of this growth was conducted by the Colorado Department of Revenue which has shown from 2014 to March 2018 that total marijuana sales are over 4 ½ billion dollars. This is still expected to rise.
Forbes magazine lists the mainstreaming of marijuana as one of the top five food trends for 2019 noting that, “The mainstreaming of marijuana will be found in restaurants and bars – with chefs putting together CBD tasting dinners mixologists crafting CBD cocktails.
At RDC, we’ll continue to keep an eye on how this industry continues to transform from the realm of individual small producers who were part of the counter culture to a thriving industry now the realm of pop culture.