November 25, 2020
With all the U.S-grown hemp available, it is reasonable for a brand to ask a supplier to talk to its farmer.
Further information about hemp material processing is needed beyond being told GMPs were followed.
A complete specification for the product is necessary—not just a lab CoA showing its THC concentration.
The supply chain for hemp ingredients like CBD is crowded, with the whole spectrum of quality available. At the top are legitimate, transparent sources exerting extreme care, control and expertise. At the bottom, a glut of traders and speculators who are blind to product provenance and production.
With the wide spectrum, the upside is a lot of high-quality materials are available at a reasonable price. But it can take a lot of time to separate the wheat of good suppliers from the chaff. That is, unless one knows precisely what questions to ask—and what answers are needed—to be confident in product quality.
Based on having talked to a lot of suppliers of all kinds of ingredients over the years, a typical line of questioning emerges to prequalify CBD ingredients. It is actually simple and based on common sense.
The first question may be obvious, but it’s important to ask it first, because it will eliminate many offers without wasting more time: “Where was the plant material grown?”
They may be able to identify the state or country where it is grown, and that’s a good start. But it’s important to probe to the next level: “Do you know the farmer?” and “Would we be able to talk to the farmer?”
With all the U.S-grown hemp available, it is reasonable to be able to talk to the farmer. Otherwise, what assurance is there about where and how the material was grown?
The second line of questioning—equally important as the first—is “How was the material processed?”
Expect simple answers, such as full-spectrum and GMP (good manufacturing practice). These are promising hints, but not yet sufficient to qualify. Again, the follow-up questions are important:
“Under which GMP?”
“Is it GMP certified or just GMP compliant?”
“Can you tell me more about the facility that produced it?”
“Can we interview the management team of the facility where it is made?”
“Can you send me some pictures of the facility?”
Once through the main GMP-related questions, the primary requirements for the product can be addressed:
“Does the product have a specification?”
Nearly always, the answer is “Yes, we have a certificate of analysis (CoA).” But don’t be fooled by this answer. It sidesteps the question and doesn’t fly. With this answer, the supplier is often not referring to its own “supplier COA” that is supposed to verify the entire spec. Rather, it is often referring to a testing lab report, or “lab COA,” that shows the THC concentration in the product so it’s not illegal to sell.
For certain, testing for THC to ensure legality of the product is mandatory, and must be included on the specification. But THC content is only one part of the equation. What’s actually needed is a complete specification (or spec) for the product, which all material sold will be tested to meet. The spec includes a limit for THC content in addition to other requirements, especially limits for contaminants like pesticides, heavy metals, mold and microbes. Because testing—and failing—specs is expensive, suppliers are known to play tricks with their specs, or omit important information. So it’s important to have someone well-versed in reviewing specifications, because it can mean the difference between good and bad material.
But it doesn’t stop at specifications. Before approving a purchase order, someone versed in CoAs needs to review and approve the supplier and laboratory CoAs on a lot of material before purchasing it. Again, tricks, mistakes and omitted information can mean the difference between good and bad material. It’s important to be clear about CoA expectations in advance, so no surprises come later. This is accomplished by asking:
“Can you also provide the supplier CoA with the lot we will be purchasing, along with all testing lab reports on that lot, before we purchase the material?”
It is the critical follow-up question after specifications to verify the material being purchased will meet the spec.
If all the right answers are provided at this point, a big pat on the back is warranted. Having specs—and hard proof of meeting them—is not standard practice in the hemp ingredient market. If the 10 minutes it takes to ask these questions come out right, a manufacturer may have found a supplier who values quality practices and speaks their lovely language.
From there, more work must be done … more questions to ask and documents to review. But by covering these bases right off the bat, no time is wasted in quickly finding the suppliers who came ready to play—and eliminating the ones who need to stay on the bench, where they belong.
Blake Ebersole has led several botanical quality initiatives and formed collaborations with dozens of universities and research centers. As president of NaturPro Scientific, Ebersole established quality compliance and product development services for supplements and ingredients such as ID Verified. Follow him on Twitter at @NaturalBlake.
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