GMP hash lab: zones, flows, and batch release
This paper gives the GMP requirements for a hash facility: the cleanroom grade zones, the flows of product and personnel, and the batch release. A batch must go through seven groups of tests and three release gates to get a signed Certificate of Analysis.
Purpose and scope
Good Manufacturing Practice (GMP) is a system with written records and audits. The system shows that a product agrees with its label, and that no dangerous material went into the product during production. A GMP hash lab makes purified resin concentrates (bubble hash, rosin, live resin, distillate) from cannabis biomass, with full control of contamination.
Extraction can increase the concentration of a contaminant, decrease it, or change where it is. The effect is different for each analyte, process, and mass yield[9]. A flower result that is in the limits does not show that the finished concentrate agrees with the requirements. Do a test of the incoming material and of the finished batch. Then use the two sets of results to calculate the transfer for each process. Material goes to the next step only when the release data show that it is safe and that its label is correct.
Two sets of regulations give most of the requirements for the facility. EU-GMP Annex 1 gives the cleanroom classifications and the contamination control strategy. The U.S. cGMP regulations in 21 CFR 210/211 give the production controls, the records, and the authority of the quality unit to release product[1]. This paper is a reference model. It is not legal advice. The limits and grades are different in each jurisdiction.
‘If there is no record, the task did not occur.’ GMP is a system with documents and validation, and an inspector can examine it. An auditor does not accept a very clean room that has no records. An auditor accepts a basic room that has full, signed records.
| Standard | Content | Area of the facility that it controls |
|---|---|---|
| EU-GMP Annex 1 | Classification of cleanrooms and the contamination control strategy | Each room that has a cleanroom class |
| cGMP 21 CFR 210/211 | Production controls, records, and the authority of the QC unit to release product | All the plant, and QA |
| ICH Q7 / Q9 / Q10 | Quality system, risk management, and lifecycle | Quality management system |
| ISO 14644-1 | Particle-count classes of cleanrooms (ISO 5/7/8) | Classification of air |
| GACP | Good Agricultural and Collection Practice for biomass | Goods-in and intake |
| NFPA 30 / C1D1 | Flammable liquids, and classified electrical areas | Solvent extraction room |
Definitions
These terms occur many times in this paper. The paper gives the full information about each term where the term first occurs.
QA is the Quality Assurance function. QA makes the last release decision, and QA operates independently of production[1]. This difference between QA and production is the primary part of the system. The personnel who send product out of the facility must not give the approval for their work.
Evidence and limitations
We want each paper to be correct. Thus we examine each paper for information that is not solid. This information comes from the view of one grower, from a small number of sources, or from grower methods that have no controlled test. We identify this information, and we do not show it as solid.
Frequently there is no paper for the decision that you must make. Then we use the reports of other growers and the methods that work in the rooms that we know. This information can help you, but it is not the result of a laboratory test. Use the methods that work for your plants, for your room and for your meters. If a table does not agree with your crop, use the data from your crop and record the difference.
- A concentrate can have a higher concentration of residues than the input biomass. The difference changes with the extraction yield and the partitioning.
- Systems that you can examine, with records, CAPA and genealogy, are the primary part of GMP.
- Procedures for room flow, for gowning and for batch records, in facilities that a regulator controls.
- ICH values for residual solvents as the limits of your cannabis license. The limits are different in each jurisdiction.
- EU Annex 1 Grade A or B for all hash. The grade changes with the product and with the license.
- A list of seven mandatory groups of tests that ignores the panel of your regulator.
If you find an error, make a report. We will correct it. Make the report on GitHub, with the name of the paper and the information that is incorrect. If you have a source, include it: Make a report of an accuracy problem. The regulations, labels and licenses of your area always override each procedure in these papers. The label weak in a paper shows the points where the risk of an error is highest.
Zones and cleanroom grades
The building is a set of shells of cleanliness. Each shell is in the next shell. The dirty tasks are intake, milling, and waste. They are at the outer edge. The clean tasks, with the highest cleanliness, are the collection, the fill, and the packaging of open product. They are in the inner zone.
The flow requirement is easy, and you must always obey it: Product moves to the zones with more cleanliness, to the inner zone. Personnel and waste move to the dirty edge. Do not let the two flows go through the same area without control. Between each pair of shells there is an airlock, and the grade changes by one step.
In EU-GMP Annex 1, Grade C agrees with ISO 7 and Grade A agrees with ISO 5[8]. Most hash facilities for recreational cannabis and for medicinal cannabis use grades D to C. They use Grade C for the fill point, with local protection. A full Grade A or B is necessary only for sterile dose forms or pharmaceutical dose forms.
| Room | Grade | ISO class | Air changes each hour (ACH) | Task |
|---|---|---|---|---|
| Goods-in and quarantine | CNC | , | 4 to 6 | Personnel receive and hold the biomass. |
| Milling and dispensing | Grade D | ISO 8 | 10 to 20 | Personnel make the biomass smaller and weigh it. |
| Wash and extraction | Grade C | ISO 7 | 20 to 40 | Personnel remove the trichomes from the plant material. |
| Freeze-dry and press | Grade C | ISO 7 | 20 to 40 | Personnel dry the material and press it to make rosin. |
| Solvent recovery | Grade D (C1D1) | ISO 8 | 10 to 20 | Personnel recover the solvent and do an LEL purge. |
| Open-product fill | Grade A | ISO 5 | unidirectional | Personnel fill open product (pharmaceutical use). |
Pressure cascade, HVAC, and gowning
The primary medium for the movement of contamination in a cleanroom is air. Air flows from a high pressure to a low pressure, and not in the opposite direction. A positive-pressure cascade uses this effect.
The clean rooms have a higher pressure than the adjacent dirtier spaces. Thus air always flows out from clean to dirty. When you open a door, clean air flows out. Dirty air cannot flow back to the product.
The pressure increases in steps, from shell to shell. EU-GMP Annex 1 recommends that the difference between adjacent classified zones is approximately 10 to 15 Pa[8]. This difference gives these values: 0 Pa (CNC), +15 (D), +30 (C), +45 (B), and +60 (A). The solvent room is different: its pressure is negative, approximately -15 Pa. As a result, the flammable vapor stays in the room and flows to the LEL exhaust. It does not flow into the building.
Personnel are the largest source of particles and microbes in a cleanroom[5]. Thus entry is a one-way sequence of airlocks, and the gowning increases when the grade increases.
Filtration also changes with the grade. The milling and dispensing rooms have F9 pre-filters. The wash and dry rooms have H13 HEPA filters. The fill point has H14 HEPA filters. An H14 HEPA filter stops a minimum of 99.995% of the particles at the most penetrating particle size[4]. Thus this filter is at the point with the highest cleanliness.
Do not let a person with an open wound, a respiratory illness, or gastrointestinal symptoms go into the cleanroom. Do a health check at the entry, and record each person that you stop. Each airlock has an interlock. Thus the two doors cannot open at the same time.
| Grade | Temperature | Relative humidity (RH) | Filtration | Pressure difference (ΔP) | Air changes each hour (ACH) |
|---|---|---|---|---|---|
| CNC | ambient | less than 70% | F7 | 0 Pa | 4 to 6 |
| Grade D | 18 to 24 °C | 45 to 60% | F9 | +15 Pa | 10 to 20 |
| Grade C | 18 to 22 °C | 45 to 55% | H13 HEPA | +30 Pa | 20 to 40 |
| Grade A fill | 18 to 22 °C | 45 to 55% | H14 HEPA | +60 Pa | unidirectional |
| Solvent (C1D1) | 18 to 24 °C | less than 55% | F9 | -15 Pa | 10 to 20 |
Hash manufacturing process flow
Two processes start after the weigh-in. The solventless process removes the trichome heads (the resin glands) mechanically. The solvent extraction process dissolves the resin and then recovers the resin. The two processes make the same type of product, but their hazards are very different.
In the solventless process, personnel agitate fresh-frozen biomass in ice water. They sieve the resin through a stack of screens (220 to 25 micron). They freeze-dry the resin and press it to make rosin. The process has four critical control points: wash temperature (≤4 °C (39 °F)), water quality (RO, <10 CFU/mL), water activity (Aw ≤0.55), and press temperature (≤90 °C (194 °F)). A water activity of approximately 0.55 to 0.65 or less prevents the growth of microbes and fungi[3].
Solvent extraction is a closed loop that uses butane, propane, ethanol, or CO₂. In this process, the primary hazards are flammability and residual solvent. Residual solvent is the trace of extraction solvent that stays in the product. The action limits for residual butane and propane are approximately 2000 to 5000 ppm, and the limit is different in each jurisdiction[2]. Ethanol is an ICH Q3C Class 3 solvent, and the usual limit for ethanol is approximately 5000 ppm[2]. Each batch must go through a headspace GC-MS test for residual solvent before the release of the batch.
Do butane and propane extraction only in a C1D1 room (NFPA classification). The room must have LEL (lower explosive limit) gas sensors with an automatic purge. It must have explosion-proof electrical equipment, a two-person rule, and pressure vessels with an ASME rating. This area is the most dangerous area in the building. One source of ignition can cause very large damage.
In the solventless process, water is an ingredient and not a utility. The water uses a loop that is only for water. The water goes from the mains to a carbon and sediment pre-filter.
Then it goes to RO/DI. Then it goes to a UV unit and a 0.2-micron last filter. Then it goes to a sanitized ice hopper, and then to the point of use. Personnel get samples at three points. Water that is out of specification goes to the quarantine area immediately.
Testing, sampling, and batch release
Personnel do tests at three stages: the incoming biomass, the process, and the release. The tests are at four sampling stations along the value stream. Personnel keep retained reference samples until 1 year after expiry. If a complaint occurs after the release, personnel can examine the kept material.
The release panel for finished goods is the legal gate to the market. The panel has seven groups of tests: potency, residual solvents, pesticides, microbials, heavy metals, mycotoxins, and water activity and moisture[3]. Personnel measure the heavy metals (lead, cadmium, arsenic, mercury) with ICP-MS, the standard method[3]. The mycotoxins in the regulations are aflatoxins B1/B2/G1/G2 and ochratoxin A. They are carcinogens, and their limits are in parts per billion.
Extraction changes the distribution of the contaminants[9]. Thus a raw flower result in the limits does not make sure that the finished concentrate is in the limits. Make the release decision on the finished concentrate. Use the input results and the output results of the same batch to set the carryover factors for each process.
| Group | Analytes | Method | Used for |
|---|---|---|---|
| Potency | THC, CBD, total cannabinoids | HPLC-DAD | Label accuracy |
| Residual solvents | Butane, propane, ethanol | Headspace GC-MS | Solvent safety |
| Pesticides | State pesticide list | LC-MS/MS, GC-MS/MS | Chemical safety |
| Microbials | TYMC, TAMC, E. coli, Salmonella, Aspergillus | Plate or qPCR | Pathogen control |
| Heavy metals | Pb, Cd, As, Hg | ICP-MS | Limits for toxic metals |
| Mycotoxins | Aflatoxins, ochratoxin A | LC-MS/MS | Carcinogen control |
| Water activity | Aw, moisture | Aw meter or KF | Mold prevention |
Then QA, and not production, operates three gates one after the other. If the result of a gate is ‘no’, the batch goes to remediation. Only a batch that all three gates accept gets the release. The release has a QP/QA signature and a Certificate of Analysis that QA gives[1].
- 1Gate 1: RecordsMake sure that the batch record is full and signed from start to end (ALCOA+). If it is not, the batch cannot go to the next gate.
- 2Gate 2: ResultsMake sure that the results of all seven groups of tests are in the specification, with no pathogens. Each result out of specification (OOS) goes to an investigation.
- 3Gate 3: DeviationsMake sure that all deviations of the batch have the status Closed, with a CAPA. A critical deviation with the status Open stops the release.
- 4ReleaseWhen all three gates accept the batch, QA writes its signature and QA gives the CoA. Then the status changes to Released.
Deviations, CAPA, and troubleshooting
When the process is different from the approved process, the deviation system finds the difference. ICH Q10 gives the pharmaceutical quality system, with CAPA and change control, and this loop is part of it[6]. Each deviation has a CAPA loop of five stages. The deviation does not get the status Closed until the last effectiveness check gives a correct result.
The severity of the deviation sets the time limit and the person who gives the approval. A critical deviation has a risk to the safety of patients or a risk of a recall. It goes to the QA director, and containment must occur in less than 24 hours. A major deviation goes to QA in a specified time. A minor deviation goes to a supervisor, and the supervisor examines the trend. Root-cause tools, for example 5-why and Ishikawa (fishbone) diagrams, are the standard methods to find the cause of the problem[6].
- You use the biomass CoA for the concentrate. You think that the raw flower result shows that the concentrate is safe. You do not do a test of the concentrate. The important result is the result for the concentrate.
- You release a batch with a result for residual solvent near the limit. Do not release the batch. Do the test again, do the purge again, or reject the batch. Record the decision for the batch.
- The status of the material and the status in the system are not the same. Keep quarantine stock in a locked cage or on a controlled rack. The system and the shelf must always show the same status.
Expected results and limitations
Compliance is a continuous process that personnel measure with data. It is not a task that you do one time. Management review monitors a small number of KPIs.
The target for the right-first-time release rate is a minimum of 98%. The target for the deviation rate for each batch is less than 5%. The target for the median time to close a CAPA is a maximum of 30 days. The target for the results of environmental monitoring (EM) in the limits is a minimum of 95%. The target for the retrieval time in a mock recall is less than 24 hours.
Equipment must have a qualification before it makes product for release. The qualification follows the validation V-model: DQ (design), IQ (installation), OQ (operation), PQ (performance). Each of these stages makes sure that the stage on the opposite side of the V-model is correct.
The qualification follows the IQ, OQ, PQ sequence[7]. Only then does the process validation start. Usually, it is three batches, one after the other, that agree with the specification. They show that the process gives the same result each time[7].
Cleaning validation also uses a calculated MACO (Maximum Allowable Carryover) limit. Personnel measure the carryover with a swab sample or a rinse sample, with TOC or HPLC, and they use microbial acceptance criteria. ‘Looks clean’ is not an acceptance criterion.
Select the gowning, the monitoring, and the grade for the process that you use. Grades D to C are usual for most hash operations. If Grade A or B is not necessary for the product, a facility with these grades is a waste of capital.
| Interval | Items for review | Owner |
|---|---|---|
| For each batch | Batch record, release results, deviations | QA reviewer |
| Each week | EM trends, open deviations, OOS log | QA lead |
| Each month | CAPA status, KPI dashboard | QA manager |
| Each three months | Management review, supplier performance | QA director |
| Each year | Product Quality Review (PQR), self-inspection | Quality and operations |
A compliant facility is not a building without faults. It is a building with evidence. In this building, each batch has traceability. For each limit, the result was in the limit, or the deviation had the status Closed.
An inspector can find all the events of the batch in the records only. The limits and grades are different in each jurisdiction. Before you make the facility, make sure that it agrees with the conditions of your license.
When the system operates, most faults start on the contamination side. Next, read the paper mold risk for that side of the facility.
References
- U.S. Food and Drug Administration. 21 CFR Part 211, Current Good Manufacturing Practice for Finished Pharmaceuticals (esp. 211.22 Responsibilities of quality control unit; 211.165 Testing and release for distribution; 211.192 Production record review). Code of Federal Regulations, Title 21. (source not from a journal, for example from a manufacturer) https://www.ecfr.gov/current/title-21/chapter-I/subchapter-C/part-211
- International Council for Harmonisation. ICH Q3C(R9) Guideline for Residual Solvents (Step 5), reproduced by European Medicines Agency, 2024. EMA/CHMP/ICH/82260/2006. (source not from a journal, for example from a manufacturer) https://www.ema.europa.eu/en/documents/scientific-guideline/ich-q3c-r9-guideline-impurities-guideline-residual-solvents-step-5_en.pdf
- Seltenrich N. Cannabis Contaminants: Regulating Solvents, Microbes, and Metals in Legal Weed. Environmental Health Perspectives. 2019;127(8):082001. doi:10.1289/EHP5785. https://ehp.niehs.nih.gov/doi/10.1289/EHP5785
- Camfil. EN 1822 and ISO 29463 HEPA filter factory test (EN 1822-1:2019 filter classes; H14 minimum efficiency 99.995% at the Most Penetrating Particle Size, MPPS). (source not from a journal, for example from a manufacturer) https://www.camfil.com/en/insights/standard-and-regulations/en-1822-and-iso-29463-hepa-filter-factory-test
- Meng H, Shiue A, Wang C, Leggett G. Particle and bacterial colony emissions from garments and humans in pharmaceutical cleanrooms. Journal of Building Engineering, 2024;96:110...; ScienceDirect S2352710224023970. https://www.sciencedirect.com/science/article/abs/pii/S2352710224023970
- Enhancing Pharmaceutical Product Quality With a Comprehensive Corrective and Preventive Actions (CAPA) Framework: From Reactive to Proactive. Cureus, 2024. PMC11490658. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC11490658/
- U.S. Food and Drug Administration, CDER/CBER/CVM. Guidance for Industry, Process Validation: General Principles and Practices. January 2011 (Revision 1). (source not from a journal, for example from a manufacturer) https://www.fda.gov/files/drugs/published/Process-Validation--General-Principles-and-Practices.pdf
- Pharmaceutical Engineering (ISPE). Pharmaceutical Cleanroom Design & ISO 14644-16, Sep/Oct 2021, air-change-rate optimization for classified cleanrooms. (source not from a journal, for example from a manufacturer) https://ispe.org/pharmaceutical-engineering/september-october-2021/pharmaceutical-cleanroom-design-iso-14644-16
- Luca SV, Roehrer S, Kleigrewe K, Minceva M (2020). Approach for simultaneous cannabidiol isolation and pesticide removal from hemp extracts with liquid-liquid chromatography. Industrial Crops and Products 155:112726. doi:10.1016/j.indcrop.2020.112726. https://doi.org/10.1016/j.indcrop.2020.112726
Each citation in the paper, for example [1], refers to an item in this list. Each item is a primary source or an instruction from an authority, unless the item shows a different type. The results of cannabis tissue culture change much with the genotype. Before you use the dilutions, hormone doses and local regulations, make sure that they agree with the primary sources.