In the rapidly evolving cannabis industry, maintaining high safety and quality standards is critical. Each state has its own evolving regulations, leading to an industry that is essentially "building the airplane while flying it." As new issues arise, solutions are implemented, sometimes addressing problems that may not even exist. "Licensed producers are doing their best to adapt," says Darwin Millard, Technical Director of CSQ, an accredited current Good Manufacturing Practices (cGMP) and current Good Agricultural and Collection Practices (cGACP) certification program designed for cannabinoid herbal material producers and cultivators. "Similar to GlobalG.A.P. for agricultural cultivators, CSQ ensures that operators meet stringent compliance requirements to become Licensed Producers (LPs). Compliance is non-negotiable there are no ifs, ands, or buts," he points out.
Operating in a scattered regulatory environment
The main challenge with the cannabis regulatory framework in the US is caused by the different ways cannabis is regulated across states. In California, pesticide contamination is a primary concern, whereas Massachusetts and Connecticut focus heavily on microbial contamination. Regardless of location, indoor cultivation facilities must contend with airflow management. Plants release heat and humidity, creating microenvironments that, if not properly ventilated, can become hotspots for mold growth. While mold may be a common agricultural issue, its presence in cannabis products intended for inhalation makes contamination unacceptable.
"Regulators, sometimes lacking in-depth industry knowledge, tend to react to problems based on available information," Darwin remarks. "This reactionary approach has led to increasingly strict microbial limits. Some states, such as Oregon, are now pushing back against excessive regulation, favoring more realistic limits based on actual data rather than speculative concerns."
Many newcomers entered the cannabis industry expecting to capitalize on the "green wave," but a true boom has yet to materialize in the U.S. Unlike traditional businesses, where operators gain experience before scaling up, some first-time entrepreneurs have jumped into multi-acre cannabis operations.
Adding to these difficulties, cannabis businesses face exorbitant taxes and financial pressures due to the plant's federally illegal status. Each state regulates cannabis as a "privileged marketplace," imposing high tax burdens that are non-deductible at the federal level. "As financial strain mounts, some operators have failed to meet cGACP and cGMP standards, leading to recalls and increasing regulatory oversight," Darwin points out. "The constant pressure to lower costs to compete with hemp-derived alternatives has also led some operators to cut corners."
Complying
That's where CSQ comes into play. "As a provider of accredited cGMP and cGACP certifications, CSQ helps operators improve facility design and maintain a safe, high-quality environment. This includes ensuring that facilities and equipment are easily cleanable and well-maintained, with proper documentation of cleaning practices. Another critical factor is personnel training - employees must understand and follow proper hygiene protocols to prevent contamination."
For instance, something as simple as keeping floors clean is essential in a compliant operation. "Our more in-depth programs offer risk assessments to identify biological, chemical, and physical hazards. By implementing preventative controls and quality assurance measures, operators can more easily comply with evolving regulations," Darwin comments.
CSQ is also working on product certification programs to help operators meet regulatory requirements. "This is particularly vital for those looking to export cannabis products for medical applications, which demand strict specifications," Darwin adds. "A CSQ certification ensures compliance with cGMP and cGACP standards, providing operators with the assurances they need."
"For cultivators looking to implement compliance programs, CSQ offers mock audits, evaluates paperwork, conducts personnel training, and provides cGACP-compliant documentation packages."
One of the key challenges in the U.S. cannabis market is facility design. Many operators repurpose existing real estate for cultivation and processing, sometimes in structures that are not GMP-compliant. "Wooden infrastructure, for example, may fail to pass audits. Investing tens of millions in such facilities only to face compliance failures can be devastating," he says. "CSQ helps operators conduct sanitary evaluations early in the process, identifying potential compliance issues before construction begins. Even if full GMP implementation is not an immediate goal, a preliminary evaluation can prevent costly mistakes later."
As the industry evolves and its regulations do as well, CSQ will launch CSQ 2.0, a major update to its certification program, making it more modular and appealing to LPs in various markets. Additionally, a product certification program will be introduced to provide market assurances regarding product claims. "As cannabis markets mature, standardized product certifications - similar to organic labels in traditional industries- will become increasingly important," Darwin states.
CSQ is also developing a retail and distribution program to encompass the entire cannabis supply chain. "The retail program will feature a "deli-style" model, to provide consumer protections for those markets that allow the cannabis flower to be viewed prior to purchase and are packaged at the point of sale. Additionally, warehouse and distribution certification will ensure compliance with industry standards. These advancements will help establish clearer regulatory pathways and strengthen consumer confidence in the industry. As the cannabis sector continues to evolve, CSQ remains committed to supporting operators with robust certification programs, ensuring high standards of safety and quality across the supply chain," Darwin concludes.
For more information:
CSQ
500 Northwest Plaza, Suite 700, St. Louis, MO 63074
info@csqcertification.com
csqcertification.com