MMPR Grow op: Small Scale

Discussion in 'Canadian Patients' started by maximum, Mar 7, 2013.

  1.  
    maximum

    maximum Active Member

    Health Canada has stated the Final Changes to the MMPR will be announced in the Summer 2013.

    I will be constructing a small scale MMPR approved grow op. Well, at least attempting one.

    If successful, I will have this location up and going for a VERY affordable budget. Im talking a small scale 20 light facility. After consulting with my lawyer, we currently see no reason why we can't have a SMALL scale operation with 2 people running it. I argued we can do it with ONE but my lawyer said we may need at least TWO due to the part where it says we require a "witness" to monitor disposal of any "extra".

    I will share my progress with everyone here. And then share the steps needed and any hurdles I had to jump through so its easy sailing for everyone else. Hopefully!! Just waiting for the FINAL changes to the mmpr to be announced. One thing we are a little nervous about and dont have info on is that the License cost could be something that is out of reach.

    If all of us have an easy tutorial on how to get going on a small scale then we wont lose Canadas beautiful cottage industry of Cannabis that we all benefit from. Ive been a legit legal grower and I can't afford a large scale setup. Nowhere close. And I know lots of us are in the same boat.

    Licensed Producer Information

    Official MMPR, the regulations:
    http://gazette.gc.ca/rp-pr/p2/2013/2...ors119-eng.php

    Application Form For Licensed Producer:
    http://www.hc-sc.gc.ca/dhp-mps/marih...emande-eng.php

    Guidance Document:
    http://www.hc-sc.gc.ca/dhp-mps/marih.../guide-eng.php

    Security Clearance Application Form:
    http://www.hc-sc.gc.ca/dhp-mps/marih...ecurit-eng.php

    Third Party Security Clearance Consent Form:
    http://www.hc-sc.gc.ca/dhp-mps/marih...partie-eng.php

    Food and Drugs Act Applies to us
    http://laws-lois.justice.gc.ca/eng/acts/F-27/

    Directive On Physical Security Requirements For Controlled Substances
    http://www.hc-sc.gc.ca/hc-ps/pubs/pr.../index-eng.php


    Consumer Information:


    Accessing Dried Marihuana for Medical Purposes under the Proposed Marihuana for Medical Purposes Regulations
    http://www.hc-sc.gc.ca/dhp-mps/marih...access-eng.php

    Information on the Use of Marihuana for Medical Purposes
    http://www.hc-sc.gc.ca/dhp-mps/marih...mateur-eng.php
  2.  
    maximum

    maximum Active Member

    Sent out 50 emails to landlords that are trying to lease out a warehouse/commercial/industrial space. I got 2 replies within minutes. Saying NO. My email simply said: "Hi, Im a licensed medical cannabis cultivator, would you allow me to cultivate legally at your location?"

    I live in Alberta. I can't afford to buy a property.

    I will update if anyone agrees.
  3.  
    maximum

    maximum Active Member

    Got one reply for $4500/month lease. Sounds willing to see what its all about. I will check it out and see if it leads anywhere.
  4.  
    MrGrower1

    MrGrower1 Member

    it's interesting that a lawyer feels that you don't have to follow HC regulations.
  5.  
    maximum

    maximum Active Member

    Is he wrong about the minimum staff? I gave him a copy of the proposed changes.
  6.  
    MrGrower1

    MrGrower1 Member

    I thought there was minimum of three.......the proprietor, qualified quality control, and something like an executive in charge (can't remember exactly what they called it now)
  7.  
    MrGrower1

    MrGrower1 Member

    then of course all the other approvals from the municipality, building department, fire department, local police department........maybe there were more approvals necessary. It was a long article, I just tried to focus on the requirements.

    Personally, I believe the dedicated growers have already been decided. But I hope I'm wrong
  8.  
    redi jedi

    redi jedi Active Member

    I've thought about doing something similar. Whats very affordable in your opinion?

    As I understand, the minimum people required would be two. The grower/owner/"senior person in charge" and a QC person. And I would like to know where your gonna find a "qualified" anyone when it comes to cannabis? The QC person could also be your witness.

    I believe when they talk about the disposal of product, they're referring to pot that is unfit for consumption. Having mold or such. There would be no extra production as a commercial producer, not having to adhere to a plant count.

    I'm hesitant to get any plans rolling at this point...you could build an operation now but what happens if you dont get a license or cant afford to buy one?

    There's also the possibility, come 2015 and Harper's ass gets kicked to curb, the incoming dictator could axe the whole program....
    R.Raider likes this.
  9.  
    maximum

    maximum Active Member

    Do you need approval from the local authorities or just notify them?
    http://gazette.gc.ca/rp-pr/p1/2012/2012-12-15/html/reg4-eng.html

    Notice to local authorities

    23. (1) Before submitting an application to the Minister under section 24, the applicant must provide the following persons with a written notice containing the information referred to in subsection (2):

    • (a) the local police force or Royal Canadian Mounted Police detachment that is responsible for providing policing services to the area in which the site referred to in paragraph 24(1)(b) is located;
    • (b) the local fire authority of that area; and
    • (c) the local government of that area.
    Content of notice
    (2) The notice must contain the following information:

    • (a) the name of the applicant;
    • (b) the date on which the applicant will submit the application to the Minister;
    • (c) the activities referred to in subsection 11(1) for which the licence is sought, specifying that they are to be conducted in respect of cannabis; and
    • (d) the address of the site and of each building within the site at which the applicant proposes to conduct those activities.

    @redi jedi
    Yea I dont want to commit to to a lease yet neither. But a lease is cheaper than buying a building. If you already have existing equipment you wont need to spend too much on equipment. Thats a big expense thats reduced right there. Either way you cant grow with your gear after 2014. So moving it to the leased building is cheap.

    We should have the final draft from health canada in a month.

    Regarding the lease, only one person replied to me from an industrial area. Thats a little disappointing.
  10.  
    redi jedi

    redi jedi Active Member

    I believe you only need to notify them. You dont (normally) need to ask the police and fire department's permission to open a small business. I would register your business and such before you notify your municipality of your intent. Hopefully not hitting a snag there.
  11.  
    maximum

    maximum Active Member

    In the mean time, I think getting the security clearance over with would be a good idea. So I downloaded this form.

    http://www.tbs-sct.gc.ca/tbsf-fsct/330-60-eng.asp

    Doesnt look to tough. I know security clearance was an issue people are worried about and thought it was hard. But from the looks of this form, its pretty standard. Ill update when I mail it off in case I learned something important about it. Or if anyone reading this knows certain details about the security clearance form please chime in.
  12.  
    CdnSimon

    CdnSimon Active Member

    Hi Maximum,
    I'm in Edmonton Alberta and I'm looking to do something very similar, on a similar scale. Currently a DPPL and looking to go commercial.

    I am interested in cooperating with other small producers in the area to help each other get off the ground. As small producers, it might be helpful to cooperate on some things, instead of compete...my ambitions are modest like yours, and come more out of love for growing than a desire to go huge.

    The cooperation could include things like:
    - moral support, trading notes on the application process early on
    - sharing a facility (I have a 3000 sqft heated workshop on offer for $3000/mo, 15 minutes south of the city, Ag zoned!)
    - offering more strains and products to customers, by trading with each other
    - exchanging genetics
    - co-paying a shared QA specialist on contract, I have a couple of leads on contract personnel that might fit the qualifications

    With the right mix of people, after testing the waters, I am also open to pooling resources and being full blown business partners.
    If you want to talk more about it just post a reply here or PM me...that goes for anyone in the region who is interested in teamwork.
    Meanwhile I will enjoy your posts on your progress, thank you for sharing!
  13.  
    spiritmedicine

    spiritmedicine Member

    Thanks for this thread. I am considering this as well, on a similar scale (in central BC, btw). Lots of questions about the new set up rules. With regards to surveillance and monitoring, is this to be real time monitoring by a security company, or just recordings that can be reviewed later? Wondering too about the quality control, will we be seeing individuals or companies specializing in this that growers can hire? And what qualifications would be needed, would there be specialized and expensive lab equipment involved? It would be great to see some businesses sprout up dealing with QA, packaging and labelling, setup and security consultations, etc., so that not every grower has to deal with all of this on their own.

    Hopefully this will all be within reach of small business types, and not biased towards large operations who have the capital to start with. There is enough big-business BS going on in the world and this seems to be a pretty business-friendly step in this industry (sadly at the expense of patients).

    Cooperation is good! Synergy is the basis of healthy ecosystems, and should be the basis of healthy business environments.

    Please do keep us up to date, it is appreciated!!
  14.  
    CdnSimon

    CdnSimon Active Member

    Maximum, if you prefer we can take this general talk about obstacles and process elsewhere since it is not directly on your topic!

    Spiritmedicine, regarding QA. As I read it, the QA person designs, implements, approves good manufacturing practices on site.
    In our business, I think this would include everything from growing to harvesting, processing, storing, testing, packaging, shipping.
    The QA report will have to detail a protocol for every one of those steps, to show that it has been designed with hygiene, safety, security in mind. Take a look at this guidance from the natural health product regs:
    http://www.hc-sc.gc.ca/dhp-mps/prodnatur/legislation/docs/gmp-bpf-eng.php

    There are QA experts in the food, pharma, and natural health product market to hire as consultants. I don't see why an NHP QA company would turn away business for legal MJ production in most cases, so that could be a place to start.

    I suggest, if you want to collab on this front, that we can work on the same protocols in so far as our growing methods are generic (e.g. no pesticide is used, input water is clean and potable, etc.) and come up with a master document to tweak on our own. The master doc would outline all of the protocols for each task that needs QA. We can then send the master doc for approval by a paid QA person, to make sure it is in line with federal regs like FDA.

    There will still have to be a QA person ongoing long term at each business but this would put us in a good position to have licenses approved.
    Just brainstorming!

    Despite all the complaining I hear about QA being out of reach, too many requirements for security, records, destruction of product, etc....I don't see any real barriers so far, to small business. The kind of diligence that they are asking for, does not appear to be any worse overall than a mom and pop restaurant would have to follow. They need food safety training for all staff, a responsible person in charge, a QA/inspection process checklist regularly, detailed records...

    Having researched the natural health product licensing process somewhat, myself, this is actually a lot easier than e.g. bringing a new herbal drug to market to sell at a herbal medicine store. We don't need to prove efficacy with scientific studies, or conduct trials, or get HC site licenses for the facility. We just have to follow normal life safety rules and good practices, which makes me feel a lot safer when I eat at a mom and pop restaurant, so I won't grudge HC for applying the same standard to MJ.
  15.  
    CdnSimon

    CdnSimon Active Member

    Regarding security and video.

    I plan to hire a regular security company for monitoring and response. I plan to rig up my own video surveillance with IP cameras on a network switch and a server running open source camera software, to upload images to a remote server, and do motion detection. The software can sms, email, etc. if you arm it when you're not there. I don't think I could afford video surveillance from a company, live, that must be a pretty serious cost!
  16.  
    maximum

    maximum Active Member

    I dont have much time today to reply but Im very excited to see that we have like minded people in our community willing to work together. Im just running out to get into my room before my lights go off.

    I did read on another forum people discussing the camera and security issues
    http://forums.cannabisculture.com/forums/ubbthreads.php?ubb=showflat&Number=1767053#Post1767053

    http://www.x10.com/homepage.htm <----- They refer to this site. I bought from them like 13 years ago nice to see them still making great cameras at a very low cost.

    And yes, lets use this thread to discuss all the details so its all together and organized. I like that idea.
  17.  
    MrGrower1

    MrGrower1 Member


    lol, I bought from those x10 guys once too, it was a long time ago though. The security system we run now was professionally installed, and a lot more expensive.

    I'm glad to see some people think the new requirements are within reach. We meet a lot of the requirements already, but the number of named staff and quality control personal was a concern
  18.  
    CdnSimon

    CdnSimon Active Member

    I have also delved into x10 gear, it's fun but I would advise going with a bonded company for security install and response. Even if the regs don't specify, chances are your insurance coverage will either demand it, or make it worth your while by lowering costs. I don't feel I have a choice in the matter; the facility will be outside town and 20 minutes from where I live, I will be traveling sometimes, and I don't want staff and helpers to be responding to DIY security alerts! Neither do I want to depend on RCMP to respond to calls if I get an alert on a cell phone. So it will be a regular commercial security company, who does not necessarily have to know exactly what kind of business is on the premises.

    MrGrower1, I agree that the named staff and quality control are pivotal here. I am just speculating based on experience in other industries. But my speculation is that basically all issues of quality, safety, and best practices are being bottom-lined by the QA person, in place of very specific rules that you see e.g. in the food industry.

    I believe the QA person's initial report will be the key to getting an application approved, and to staying in business once you are running. So anyone who is expecting to submit an application with a QA person who has vaguely related qualifications, like just having a degree in biology or something, you may be in for a rough time getting them past the application process. Quality Assurance and Quality Control almost comprise an industry in itself, and there are companies and independent contractors that are certified by bodies to do this work in various industries; it's this type of person that I think you should seek out.

    My QA person most likely won't be an employee, he will be a contractor who will visit on a semi regular basis, maybe every 2 months to check that all of the checklists are being followed, inspect for good practice and good conditions, and approve the batch as it goes out of cure/storage and into packaging. I'm hoping to contract for $120/hour, for a four hour visit every 60 days, something along those lines. As an example of qualifications, the guy I am talking to has an MSc, and 20 years' experience in quality control and quality assurance in the pharmaceutical and natural health product areas. He is willing to certify his work and stand by the approvals that he gives, or else help bring me in line if there are problems and he doesn't approve. He will approve the plans I draw up for floor plan, handling protocols, growing method, etc. in the initial application. His name will go in to the MMPR application as my QA, which addresses that big aspect of the application.

    I want to do all of the CBD/THC testing, microbial contaminant testing, etc. myself with approved testing kits, and have the QA person approve that process too, and check my checklist, if you know what I mean. That way I am not paying him to be there for 2 days doing all the tests for a high rate.

    If anyone else that is local wants to use the same guy and follow the same pattern, I think it will be a more stable arrangement to have a few companies contracting him for visits and reports; it will be more worth his while to learn the industry and stay connected.
  19.  
    CdnSimon

    CdnSimon Active Member

    I believe that it is theoretically possible to run an MMPR approved business as a one man op, if you are a QA qualified person yourself. Since that's unlikely, I think you can still run it as a one-man operation, with outside QA on contract. If anyone sees anything in the regs that contradict this, please let me know.

    You can be the Senior Person In Charge (SPIC) and the Responsible Person In Charge (RPIC) at the same time. For destruction, you need two witnesses total, who are SPIC, RPIC, or Alternate RPIC, or someone providing services or working "in a senior position". So, your QA service provider could witness destruction when he visits. I have a business partner who will be working in a senior position so we can witness together. But I think a one man business is possible, with an outside QA provider working on contract to do what's required in that role. Just consider it another business expense like electricity!
  20.  
    maximum

    maximum Active Member

    I can`t edit my main thread. So here are some resource links that Ive been using.

    Licensed Producer Information

    Proposed Changes
    http://gazette.gc.ca/rp-pr/p1/2012/2012-12-15/html/reg4-eng.html

    Product Quality
    http://www.hc-sc.gc.ca/dhp-mps/marihuana/future-avenir/specification-eng.php

    Food and Drugs Act Applies to us
    http://laws-lois.justice.gc.ca/eng/acts/F-27/

    Directive On Physical Security Requirements For Controlled Substances
    http://www.hc-sc.gc.ca/hc-ps/pubs/precurs/dealers-distrib/phys_securit_directive/index-eng.php

    Building and Production Security Requirements
    http://www.hc-sc.gc.ca/dhp-mps/marihuana/future-avenir/securit-eng.php#a52


    Consumer Information:

    Accessing Dried Marihuana for Medical Purposes under the Proposed Marihuana for Medical Purposes Regulations
    http://www.hc-sc.gc.ca/dhp-mps/marihuana/future-avenir/access-eng.php

    Information on the Use of Marihuana for Medical Purposes
    http://www.hc-sc.gc.ca/dhp-mps/marihuana/future-avenir/consumer-consommateur-eng.php

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