Kirk’s Corner – Recall Advice

Founder and CEO of Clarion Compliance. Clarion Compliance brings advanced compliance oversight and monitoring solutions to the cannabis industry and the sectors that serve it. Connect with me on LinkedIn
January 28, 2022

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Product Recall Incident in Nevada

On November 5, 2021, the cannabis compliance board from the state of Nevada issued a public health and safety bulletin for product recalls. The recall included 14 different edible products from one supplier that were distributed to 10 different dispensaries. The incident involved diversion and product that was not tested or entered in the state’s tracking system. The dispensaries were required to display the recall bulletin for 30 days to ensure their customers were aware of this information.

What you can do

  1. Search the records in the state that you operate in. Find information regarding cannabis product that was recalled and what the regulatory bodies processes were
  2. Contact your local and state cannabis regulatory agency and discuss this issue with them
  3. Review your due diligence processes for your vendors and consider additional requirements from them that are in line with your own risk appetite and risk tolerances
  4. Design or amend your product recall SOP’s accordingly
  5. Speak with your insurance carrier and find out if you have coverage for product recall risk
  6. Speak with your corporate attorney and get advice from them on this topic and ask them to review your product recall plan and work with you to mature it

Managing risk benefits you in many ways

Having standard operating procedures in place for a product recall is an important component of your risk management plan. As is evident in this case, the recall that affected the 10 dispensaries was the result of noncompliant activity from an edible company. This underscores the risk of product recall upstream and downstream in the supply chain. A reasonable plan of action in your product recall SOP’s, will further limit your risk as an unwitting participant within the supply chain.

As a member of ACCCE, you will have the information and education to focus best practices on the highest risks that affect your business. Join ACCCE today and start your learning journey.

Cannabis Compliance Board Public Health and Safety Bulletin 2021-2