When you add cannabis oil to a batch of brownies, it doesn’t stop being food. And when a can of soda has 10mg of THC that doesn’t mean it is no longer a refreshing beverage.
“These are food and the only thing that makes them not foods in the eyes of other people is that you put a novel ingredient (cannabis) in them. But if you take out the ingredient, the seltzer water is still seltzer water, your gummies are gummies and your chocolate is chocolate,” Darwin Millard told Rootwurks.
“I’m of the opinion that when you manufacture consumer products that contain cannabinoids, that are ingestible, you should be following food rules.”
Known as “the Spock of Cannabis,” Darwin Millard has some strong opinions about the varying levels of quality management in cannabis, and how it can look to food industry standards as a model.
“I am an advocate that we should be as clean as food at a bare minimum. We should consider ourselves a food product.”
In 2020 Millard founded TSOC LLC to consult cannabis companies with project planning as well as cannabinoid product manufacturing services, market analysis, product development, designing, and engineering services, among others.
He is also an Executive Committee Member of ASTM International’s Technical Committee on Cannabis.
Today, Millard works as the Chief Science Officer for Final Bell, a cannabis manufacturing, packaging, and extraction company. Altogether he has more than 15 years of experience working with cannabis at every stage of production.
The “Spock of Cannabis” nickname is a reference to the logic-driven Vulcan played by Leonard Nimoy on Star Trek and it has a pretty clear point of origin in Millard’s consulting days earlier in his career.
“I have a tendency to be rather straightforward when it comes to my answers to client questions. I have a habit of telling them what they need to hear rather than what they want to hear,” he said, adding “I guess I have a habit of being pretty blunt and straightforward with my clients in respect to letting them know that maybe their aspirations were foolhardy, to say the least.”
He added that over the last 18 years, he has “built myself a reputation as being someone who knows their s**t and won’t blow smoke up your ass.”
Millard has spent his entire career in cannabis and his devotion to product quality standards is largely personal: he loves hashish.
“I got into the industry because I wanted to smoke a lot of hash and I saw that there was a need for quality control.”
Millard describes how he helps clients as “they say I grew all this weed, what do I do now?”
A big part of the job is simply helping people understand how complex the various extracts made from cannabis are and which steps they should take to optimize product quality.
“It’s about helping that client figure out and understand what their end goal is so that we can put in place the appropriate processing and manufacturing methods.”
He cited examples of helping pharmaceutical companies incorporate full or broad-spectrum extracts into their formulations and also helping clients “who had no idea what they were doing to make isolate.”
Cannabis companies have made some novel edible products in recent years, but anyone who has been paying any attention has noticed that gummies and chocolates dominate the cannabis edibles market, and third place is a far way off.
Millard described how though cannabis producers can make all types of compelling and whimsical craft edibles, at the end of the day, the market just demands gummies and chocolates.
“That’s what the consumer wanted and it took a long time for the manufacturer to realize that there are no margins in this and we need to make something that’s quick and easy.”
Millard said much of the ease of these products has to do with the fact that you can make mistakes with chocolate or gummies and still recover the product. With products like cannabis hard candy though, there are various steps like the hard-crack stage where things can go wrong and recovery is not an option.
Hazard Analysis and Critical Control Points (HACCP) is a management system used by countless companies to identify and mitigate biological, chemical, and physical threats to food safety. HACCP plans are also used by companies outside of the food industry, including in cannabis.
Millard said having a HACCP plan in place is “critical for any operation.”
He stated that “there are several areas along the production and manufacturing process where hazards need to be identified and controlled. And whether that is on the flower side where that can be an indoor grow, a greenhouse or an outdoor grow, there are microbial concerns pesticides, heavy metals, other surface, and chemical contaminants that need to be controlled.”
Millard used the example of pre-roll manufacturing and the need to understand how to control dust with both engineering control and personal protective equipment to help protect employees and the products.
“Being aware of physical hazards, both intrinsic and extrinsic to your manufacturing process is important so that you can catch not only defects but also prevent the release of products that may potentially be harmful,” using a logical approach to product safety and good manufacturing practices that would make Spock proud.