With a deep understanding of food safety regulations and best practices, ASI Food Safety CEO Tyler Williams has seen many of the pitfalls that have plagued edibles manufacturers in recent years.
Williams, who has a master’s degree in food safety and a certificate in international food law, has been working with cannabis companies for about seven years, after some of the larger multi-state operators began requesting third-party food safety audits. He established the certification program Cannabis Safety and Quality in 2020 to meet the need for cannabis-specific standards.
Marijuana Venture spoke with Williams about the trend of state regulators increasingly requiring third-party audits and the importance of edibles companies implementing food safety best practices, as well as sharing thoughts on potential federal legalization and how the U.S. Food and Drug Administration might approach food safety concerns in cannabis.
ASI Food Safety CEO Tyler Williams.
Marijuana Venture: What would be the main thing you want readers to take away from reading this article?
Tyler Williams: I think the main thing we want readers to take away is that safety and quality should be in the forefront of cannabis organizations, and a lot of times it’s an afterthought. Consumer safety is important for a number of reasons. One, because we don’t want to kill people, but also it does affect your brand and your brand’s image, so it’s in the best interest of everyone that cannabis companies follow safety and quality protocols.
MV: Aside from regulatory compliance, are there ways that a third-party audit can benefit a company’s bottom line?
Williams: 100%. The biggest thing is waste reduction: the amount of product that is wasted because of failed test results or whatever. This a really efficient safety and quality program — it eliminates a lot of waste. Waste alone will cover the cost of the audit for probably the next 100 years.
It’s a very easy comparison to see: if you have one lot of product that you have to destroy, that’s a significant amount of money that could be prevented with an audit that costs you $5,000 to $10,000.
It’s a very small fee to pay to ensure that you don’t have product waste, but there are also other benefits. There are some insurance companies that look at certifications. Sometimes insurance companies will save you a little bit of money if you get that certification. It’s a box they’d like to check off.
MV: Could you explain what ASI does and what CSQ is?
Williams: ASI is a company that has several different companies underneath it, and divisions and subdivisions, etc. One of those is called ASI Global Standards, and that’s where CSQ lives. Basically, ASI Global Standards develops and administers standards. And what I mean by that is we work with industry stakeholders to create the requirements and develop the certification program — all of what I call “back-office stuff” that goes behind standards and certification. What is the lifecycle of a certificate? What is the process if someone is out of spec and you have to suspend them?
There’s a lot of behind-the-scenes stuff that goes into certifications and standard development that people don’t realize.
The CSQ division is specific to our cannabis standard. CSQ is only looking at the safety and quality of the products you produce. We’re not looking at things like OSHA requirements or anything like that. It’s very specific to products, and it’s in line with what you see in the food industry, what you see in dietary supplements and pharmaceuticals and medical devices and those types of things. Cannabis is unique in the fact that it touches all of those industries.
On the ASI side, we do auditing certification, R&D, consulting and training. We offer both accredited and unaccredited audits, and we do supplier audits. So, for example, if you’re a cannabis company getting certified, one of your responsibilities is ensuring that your suppliers are also following best practices as far as safety and quality. We do a lot of second-party audits for large manufacturers’ suppliers.
MV: Does CSQ cover more than just edibles?
Williams: Yes, CSQ is a complete seed-to-sale certification program. We have a standard for cultivation, extraction, edibles, dietary supplements, and lastly retail, which we launched in 2023. Our new Technical Director, Darwin Millard who just joined our team this month (April 1st) is also hard at work on developing a sixth standard that we are very excited about. We’ll be able to share more details about that later this year.
MV: Why should edibles manufacturers have a food safety audit conducted?
Williams: There are a couple of reasons. The most important reason is that you don’t want your product to kill anyone. That’s common sense.
You can implement food safety best practices without getting an audit. An audit verifies that you’re doing the right thing. I always give the example that you’re in your operation every single day, and you might know that operation very well. But you’re looking at things as though you have blinders on. You don’t see what you don’t see. That’s what third-party audits do. They provide verification that you’re doing what you’re supposed to be doing, that you’re compliant to regulations and that things you might not have seen, because you’re in the grind day to day, we’re able to identify and help companies continuously improve.
But the big thing is you want to make sure you’re doing the right thing and staying compliant.
MV: Could you give an example of one of those hidden risks a manager might overlook, but an auditor would help identify?
Williams: A lot of times, companies will put cleaning products into what we call a secondary container. That container needs to be labeled to whatever that chemical has, but it also needs to be controlled — an employee might not see anything wrong with having a bottle of chemicals next to where they’re producing edibles. All it takes is one person to accidentally spill that bottle, or to use it incorrectly because it’s not labeled properly.
In the grand scheme of things, you may have somebody new come in and they’re not trained on what chemicals are in that bottle and that’s where you have issues. That’s a really small example, but it’s a common example and we have to regularly educate quality assurance people on why this is a requirement.
MV: It seems that more and more states are requiring third-party audits in their regulations. Is that accurate? And do you think that’s a trend that will continue?
Williams: I believe so. Right now, there are five states that require it in some way, shape or form: New York, Michigan, Maryland, Missouri and Florida. This is a trend we’re seeing, and I think it will continue.
It might even go into the FDA regulations if cannabis ever gets federally legalized or descheduled or rescheduled. The FDA doesn’t have enough resources to audit every food facility every three years like they’re supposed to. It’s a very well-known fact, and it’s one of the many reasons why every single large retailer requires suppliers to be audited. I’m talking about Walmart, Costco, Whole Foods, etc. They require you to have a third-party audit before you can sell products in their store. So one of the things the FDA is starting to do now is work with companies like ASI and have that private-public relationship. So some suppliers are allowed to be certified by third parties instead of being audited by the FDA, and they see that as equivalent. If the FDA is smart with cannabis, they’re going to need to rely on some private-public relationship similar to what we’ve been doing on the food side.
MV: Wouldn’t any company that is looking to continue operations in a federally legal landscape be better off getting ahead of regulations and future-proof their business?
Williams: 100%. And that’s how we are selling it now. In the food industry, audits are required. You’re hardly going to find a manufacturer or a retailer that you can sell your product to without having a third-party audit. Cannabis obviously isn’t there yet.
The demand is coming from the exact notion you just said: future-proofing your business. It helps you become compliant to state regulations because our standards go above and beyond the minimum requirements. But it is also foreshadowing what we are expecting in the future with FDA regulations, from what we know of other industries that we’re in, like food, like dietary supplements, etc.
MV: As we see the cannabis industry develop, it’s likely that retailers operating in, say, 10-15 states will have a footprint in at least one state that requires a third-party audit. And that retailer, looking at the bigger picture, will likely want all suppliers to meet a certain level of certification.
Williams: Absolutely. When we were developing CSQ and getting the big MSOs on board, that was our thought process. Some of the large MSOs are already requiring suppliers to get a third-party audit, in order to supply either their dispensary or their manufacturing facility.
We’re also seeing that with brands that are contract manufacturing. There are some big gummy brands out there, and they don’t hold licenses in every state. But what they do is say, ‘We’re going to work with this license holder, and for you to be approved by us, we want you to go through this third-party audit.’ That’s a way for them to verify they’re using somebody to contract manufacture their products and make sure they’re compliant with their expectations.
On the CBD side, we’re seeing it as well. Big distributors that supply gas stations or wherever are requiring companies to get audited to dietary supplement requirements for CSQ. So it’s already happening. but not happening at the level that we see in food or dietary supplements.
MV: From your perspective, how crucial is consistency for an edibles brand? And how do ASI and CSQ help companies achieve consistency, whether that’s in terms of product quality, experience for consumers, shelf life, potency, etc., etc.?
Williams: To answer your first question, how important is it? I think it’s very important, especially now that there are edibles products on the market in all different shapes and forms. If you look at gummies, every company has a gummy line. So how do you stand out from your competitors? Obviously, branding and marketing is one way, but consistency and quality are the biggest things for me.
Wyld is a company that I think does it very well, where they are very consistent throughout the different states that they’re in and part of that is because of the emphasis on quality and consistency. There are other companies that do that too, but Wyld is just my personal favorite.
One of the benefits of getting a third-party audit is it gives you that structure to do things repeatedly, over and over again the same way, ensuring the amount of active ingredients you’re putting in the product are the same, that your potency is within certain variable limits, etc. All of that is built into the CSQ standard in various requirements.
MV: In an interview with Marijuana Venture, one person brought up consistency and the importance of consistency for the entire sector, not just an individual company because we know the bad press that comes along with anybody who has a bad experience with edibles. In the social media world we live in, they’re not just telling their friends but they’re sharing it with the world, and it can have a compounding negative effect, not just for the individual company that produced that edible, but the edibles sector as a whole.
Williams: I agree. One of the things I preach all the time is that we want cannabis companies to implement these best practices because exactly what you said: if one person screws up, that’s a black eye for the entire industry.
Cannabis has gained a lot of momentum, but it is still volatile. It’s important not just for the edibles side, but the entire cannabis industry to ensure they’re doing the right things for the entire industry’s sake, if not their own companies.
I’ll give you another example: every time there’s a recall for lettuce, people stop buying lettuce for a period of time. Consumers don’t care about the brand of lettuce. They just stop buying it altogether once they see there’s been a recall. We see that with peanut butter too. It’s a perfect example of how people tend to see things in black and white, not as they really are.
This interview has been edited for length and clarity.