MMPR Grow op: Small Scale
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I just want to add, QA and QC methodologies are similar in every industry. Statistics are a pillar of QC and is actually are the a main reason of its development. Obviously QC from a production environment is most easily transferrable to this industry but it would be foolish to completely overlook QC experience from others. IE finance.
Thanks again for the response,
I agree its really hard to find a balance between how much detail to put into the documents. One hand you want to cover every last detail and make HC happy, on the other you dont want to have a document that is too unrealistic. Just as a side note we're in Ontario as well, in the GTA. How did you fund your QAP? Was it someone you knew? I do in my network know someone who currently does QC/QA for a juice making company east of Toronto. She would be perfect for this role, takes samples, test for poisons, heave metals, etc etc instead of marijuana she test juice after production. Im a little conflicted with asking as the industry still has a lot of taboo around it.
woodsmaneh!
Well-Known Member
FIRST CANNABIS rE-CALL
maybe GreenLeaf they had Bank QA expearence on hand, lol
Well we get to see how well the re-call system HC has been insisting all LP's have works. 63 patents were impacted by the re-call. I think we will know what the root cause is in a while. It could be anything from bad lab work but they said production issues so contamination from the production run or after packaging. My guess is mold in the packaging. Now we get to see in real time how it's handled and if customers will forgive and forget, or punish GreenLeaf.
Remember this is a new industry and start up issues are bound to happen like this. The system works HC caught this during an inspection and shut them down. I'll tell you one thing the good people at GreenLeaf are doing some serious sole searching and I hope some heads roll (the price of failure) and the industry as a whole learns something. The other thing I'll tell you, when GreenLeaf comes back they will be the safest Medical Cannabis Company in Canada, why? There will be no second chance if they blow it again. I would buy from them when they comeback. There are ways to prevent this from happening and maybe start using HACCP guys! All the best.
maybe GreenLeaf they had Bank QA expearence on hand, lol
Well we get to see how well the re-call system HC has been insisting all LP's have works. 63 patents were impacted by the re-call. I think we will know what the root cause is in a while. It could be anything from bad lab work but they said production issues so contamination from the production run or after packaging. My guess is mold in the packaging. Now we get to see in real time how it's handled and if customers will forgive and forget, or punish GreenLeaf.
Remember this is a new industry and start up issues are bound to happen like this. The system works HC caught this during an inspection and shut them down. I'll tell you one thing the good people at GreenLeaf are doing some serious sole searching and I hope some heads roll (the price of failure) and the industry as a whole learns something. The other thing I'll tell you, when GreenLeaf comes back they will be the safest Medical Cannabis Company in Canada, why? There will be no second chance if they blow it again. I would buy from them when they comeback. There are ways to prevent this from happening and maybe start using HACCP guys! All the best.
woodsmaneh!
Well-Known Member
Yes I have one.
woodsmaneh!
Well-Known Member
I work with a real good QA in TO who has been qualified by HC. drop me a PM and I'll let you know who he is and you can deal with him.
woodsmaneh!
Well-Known Member
I could not agree more with you that they are transferable skills and over time you would develop into a good QAP for the MMPR but that would be logical thought. But I'm here to say even if you got a red ribbon for being the best QA if the Banking world HC does not give a shit and your not qualified. Come to think about it I'm glad they don't let just anyone make the grad as a QAP, wonder if GL is re-thing the qualifications for their QAP now that they have a re-call. Shows how important the positions is.
Agracan
Well-Known Member
Yes I would definitely ask this contact of yours. She sounds like she has the hands on experience with QC, this is what HC wants.
We also knew our QC on a personal level.
Stigma: perhaps but we now have the former Ontario minister of health getting into the business, that should change perceptions even further.
woodsmaneh!
Well-Known Member
wait till you hear some of the other big names getting into this, real big names. Lots of LEO and lawyers getting in also.
Agracan
Well-Known Member
Yeah eh...I guess it will be another reason the mmpr is here to stay in one iteration or other
Adam@AC
Member
Woodsman, do you recommend following up with Health Canada during the application process if there hasn't been contact for a couple weeks after submitting revisions? Ive been sticking to the "we'll notify you when something is needed" policy they have, just curious if its beneficial to try and get updates.
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woodsmaneh!
Well-Known Member
ask away at least one or twice a week. This does a number of things
1 if they answer, they have your right Email, that's a good thing
2 shows your interested
3 shows your keeping track of time
4 all-ways follow up when you send information to them and ask whats next.
5 all-ways ask what's next how can you help them
keep every email they send you every single one!
woodsmaneh!
Well-Known Member
So HC has gone ape shit on QAP's, if you have paper in than start working on your QAP's experience and Bio, heavy on the what have you done lately part. They will ask for it, trust me.
Food for Thought
Hello,
Thank you for your interest in becoming a licensed producer under the Marihuana for Medical Purposes Regulations (MMPR).
Please note that only one person can be the Quality Assurance Person for a given licence. The Quality Assurance Person that is designated under section 10 of an application cannot delegate any responsibilities under Division 4 to another individual. Currently, it is unclear who in your application is responsible for quality assurance. Please clearly submit the name of your proposed Quality Assurance Person and provide a more detailed description of the person's training, experience and technical knowledge relating to the activities to be conducted and the requirements of Division 4. In particular, please address how the qualificatiosn ensure compliance with sections 53 to 63 of the MMPR. As per paragraph 23(4)(h) of the MMPR, the proposed quality assurance person must also sign and date the quality assurance pre-licensing report.
Additionally, the proposed quality assurance person must be able to conduct all activities as per Division 4 which includes understanding the analytical results performed to determine the level of microbial and chemical contaminants in the licensed producer's dried marihuana product in order to assure it's quality before it is available for sale. Also, the quality assurance person must be able to understand how to validate methods as required by sections 53(2) and 54(2) of the MMPR. Plus, the quality assurance person must be able to ensure that the equipment, premises, and sanitation program are accurately followed and that the licensed producer's procedure are meeting the requirement of the MMPR as per sections 55, 56, and 57 of the MMPR.
Please note that the quality assurance person must be able to investigate any complaints received by the licensed producer. If you decide to have a quality assurance person who is only available part-time, you will need to demonstrate in your application how the quality assurance person will be able to investigate complaints in a timely manner, if any complaints are received by the licensed producer. Additionally, if a recall is executed, the quality assurance person is responsible for conducting the recall and will need to advise the Minister on the reason for commencing it. This responsibility requires detailed verifications and a clear understanding of all aspects of Division 4 of the MMPR.
As a reminder, the duties of the quality assurance person are to ensure that the quality of the products at all steps of the production process and to certify that all processes were conducted as per Division 4.
It is important to provide as much details as possible when describing the proposed quality assurance person to demonstrate that the chosen quality assurance person has the proper training, knowledge and technical expertise to conduct this mandate. Please note that Health Canada does not provide recommendations for quality assurance training. It is on the onus of the licensed producer to demonstrate that the selected quality assurance person is qualified and will be able to conduct their duties as listed under Division 4 of the MMPR.
The information requested must be submitted by April 30, 2014. If you do not respond by this date the Minister must refuse to issue a producer's licence pursuant to section 26 of the MMPR and your file will be closed.
Licences and Permits Division
Office of Controlled Substances
Health Canada
Food for Thought
Hello,
Thank you for your interest in becoming a licensed producer under the Marihuana for Medical Purposes Regulations (MMPR).
Please note that only one person can be the Quality Assurance Person for a given licence. The Quality Assurance Person that is designated under section 10 of an application cannot delegate any responsibilities under Division 4 to another individual. Currently, it is unclear who in your application is responsible for quality assurance. Please clearly submit the name of your proposed Quality Assurance Person and provide a more detailed description of the person's training, experience and technical knowledge relating to the activities to be conducted and the requirements of Division 4. In particular, please address how the qualificatiosn ensure compliance with sections 53 to 63 of the MMPR. As per paragraph 23(4)(h) of the MMPR, the proposed quality assurance person must also sign and date the quality assurance pre-licensing report.
Additionally, the proposed quality assurance person must be able to conduct all activities as per Division 4 which includes understanding the analytical results performed to determine the level of microbial and chemical contaminants in the licensed producer's dried marihuana product in order to assure it's quality before it is available for sale. Also, the quality assurance person must be able to understand how to validate methods as required by sections 53(2) and 54(2) of the MMPR. Plus, the quality assurance person must be able to ensure that the equipment, premises, and sanitation program are accurately followed and that the licensed producer's procedure are meeting the requirement of the MMPR as per sections 55, 56, and 57 of the MMPR.
Please note that the quality assurance person must be able to investigate any complaints received by the licensed producer. If you decide to have a quality assurance person who is only available part-time, you will need to demonstrate in your application how the quality assurance person will be able to investigate complaints in a timely manner, if any complaints are received by the licensed producer. Additionally, if a recall is executed, the quality assurance person is responsible for conducting the recall and will need to advise the Minister on the reason for commencing it. This responsibility requires detailed verifications and a clear understanding of all aspects of Division 4 of the MMPR.
As a reminder, the duties of the quality assurance person are to ensure that the quality of the products at all steps of the production process and to certify that all processes were conducted as per Division 4.
It is important to provide as much details as possible when describing the proposed quality assurance person to demonstrate that the chosen quality assurance person has the proper training, knowledge and technical expertise to conduct this mandate. Please note that Health Canada does not provide recommendations for quality assurance training. It is on the onus of the licensed producer to demonstrate that the selected quality assurance person is qualified and will be able to conduct their duties as listed under Division 4 of the MMPR.
The information requested must be submitted by April 30, 2014. If you do not respond by this date the Minister must refuse to issue a producer's licence pursuant to section 26 of the MMPR and your file will be closed.
Licences and Permits Division
Office of Controlled Substances
Health Canada
Looks like the PK recall was due to "good production practices and oversight — this includes residues from use of unregistered pesticides, unsanitary production conditions, concerns with testing standards and/or control of plant materials.”
http://ww2.nationalpost.com/m/wp/blog.html?b=news.nationalpost.com/2014/04/23/purple-kush-recall-another-road-bump-after-new-medical-marijuana-rules-rolle
http://ww2.nationalpost.com/m/wp/blog.html?b=news.nationalpost.com/2014/04/23/purple-kush-recall-another-road-bump-after-new-medical-marijuana-rules-rolle
torontomeds
Well-Known Member
Where is Koot? I have not seen her post in a few. Hey Koot when you got denied because it was attached to your home, did they mention a distance that will be acceptable or just that it needs to not be part of a dwelling?
Kootenaygirl
Active Member
First post under the new format!
Health Canada is not in the business of education.
They just declared it in a dwelling place. Though clearly not in at all.
We learned nothing from the experience, only reaffirmed all we knew already.
HC does not like cannabis or those that do!
HC does everything in it's power to stop the spread of marihuana!
The best part of this is HC's predictability.
Becoming an LP is going to take a lot of weed, will and deep pockets.
Health Canada is not in the business of education.
They just declared it in a dwelling place. Though clearly not in at all.
We learned nothing from the experience, only reaffirmed all we knew already.
HC does not like cannabis or those that do!
HC does everything in it's power to stop the spread of marihuana!
The best part of this is HC's predictability.
Becoming an LP is going to take a lot of weed, will and deep pockets.
Devil Lettuce
Well-Known Member
Hello everyone, and a MASSIVE thank you to all that have contributed to this amazing thread. Like most of you here, I am currently about to start navigating through the HC application process to become a legal producer under the new MMPR. Here is where we are currently at with things: my partner and I are looking to start a very small one-or-two man operation. We have a solid business plan, access to start-up capital, and are working on obtaining our facility. We are in the process of incorporating, and are just waiting for the approval from Corporations Canada.
I have 2 main questions pertaining to what has been discussed here:
1. I would like to know what my chances of HC approving me as the qualified QA person would be. We are trying to remain small and streamlined, so the idea is to design an operation I could do 100% myself in the initial stages (with the exception of lab testing which will be outsourced, and scheduled visits by my business partner to fulfill the witness obligations when destroying excess material.) My background: I have an Environmental Technologist diploma, which included studies in microbiology, chemistry, soils, auditing practices, plant biology and dendrology, pests and insects, water treatment, etc. A large portion of my studies were based on laboratory work, quality assurance, and developing and following SOPs. For the past 5 years, I have been working for my local municipality as a Water Treatment Technologist. I am a level II certified drinking water treatment operator who is responsible for safely providing a major centre with safe drinking water. The biggest portion of my job is conducting lab-work to verify that all drinking water meets Environment Canada standards before being sent out to customers.....pretty much everything I do could be directly applied to QA from medical marijuana standpoint. So basically, between my job and my educational training, I have been working with quality control in a lab environment for 7 years. The aren't many things that are more strictly controlled and regulated than drinking water, so I am hoping this bodes well for me. I would like to know if those in the know think that this would be enough to qualify myself as the QA person.
2. Upon submitting an application, how long does it take to receive an initial yes/no, permission to construct? Because the property needs to be leased or purchased before applying, we are trying to figure out how many lease/mortgage payments we will be making while waiting for HC to review our initial application.
Any info from those with knowledge/experience would be greatly appreciated. Thanks!!!!
I have 2 main questions pertaining to what has been discussed here:
1. I would like to know what my chances of HC approving me as the qualified QA person would be. We are trying to remain small and streamlined, so the idea is to design an operation I could do 100% myself in the initial stages (with the exception of lab testing which will be outsourced, and scheduled visits by my business partner to fulfill the witness obligations when destroying excess material.) My background: I have an Environmental Technologist diploma, which included studies in microbiology, chemistry, soils, auditing practices, plant biology and dendrology, pests and insects, water treatment, etc. A large portion of my studies were based on laboratory work, quality assurance, and developing and following SOPs. For the past 5 years, I have been working for my local municipality as a Water Treatment Technologist. I am a level II certified drinking water treatment operator who is responsible for safely providing a major centre with safe drinking water. The biggest portion of my job is conducting lab-work to verify that all drinking water meets Environment Canada standards before being sent out to customers.....pretty much everything I do could be directly applied to QA from medical marijuana standpoint. So basically, between my job and my educational training, I have been working with quality control in a lab environment for 7 years. The aren't many things that are more strictly controlled and regulated than drinking water, so I am hoping this bodes well for me. I would like to know if those in the know think that this would be enough to qualify myself as the QA person.
2. Upon submitting an application, how long does it take to receive an initial yes/no, permission to construct? Because the property needs to be leased or purchased before applying, we are trying to figure out how many lease/mortgage payments we will be making while waiting for HC to review our initial application.
Any info from those with knowledge/experience would be greatly appreciated. Thanks!!!!
torontomeds
Well-Known Member
I am not in any means trying to discourage you, but you need at least 12 months lease, or just own the prop, because I know people that have started in Sept and are still awaiting inspection, I know people that have not even got the letter to build and have already gone back and forth with HC for months.Hello everyone, and a MASSIVE thank you to all that have contributed to this amazing thread. Like most of you here, I am currently about to start navigating through the HC application process to become a legal producer under the new MMPR. Here is where we are currently at with things: my partner and I are looking to start a very small one-or-two man operation. We have a solid business plan, access to start-up capital, and are working on obtaining our facility. We are in the process of incorporating, and are just waiting for the approval from Corporations Canada.
I have 2 main questions pertaining to what has been discussed here:
1. I would like to know what my chances of HC approving me as the qualified QA person would be. We are trying to remain small and streamlined, so the idea is to design an operation I could do 100% myself in the initial stages (with the exception of lab testing which will be outsourced, and scheduled visits by my business partner to fulfill the witness obligations when destroying excess material.) My background: I have an Environmental Technologist diploma, which included studies in microbiology, chemistry, soils, auditing practices, plant biology and dendrology, pests and insects, water treatment, etc. A large portion of my studies were based on laboratory work, quality assurance, and developing and following SOPs. For the past 5 years, I have been working for my local municipality as a Water Treatment Technologist. I am a level II certified drinking water treatment operator who is responsible for safely providing a major centre with safe drinking water. The biggest portion of my job is conducting lab-work to verify that all drinking water meets Environment Canada standards before being sent out to customers.....pretty much everything I do could be directly applied to QA from medical marijuana standpoint. So basically, between my job and my educational training, I have been working with quality control in a lab environment for 7 years. The aren't many things that are more strictly controlled and regulated than drinking water, so I am hoping this bodes well for me. I would like to know if those in the know think that this would be enough to qualify myself as the QA person.
2. Upon submitting an application, how long does it take to receive an initial yes/no, permission to construct? Because the property needs to be leased or purchased before applying, we are trying to figure out how many lease/mortgage payments we will be making while waiting for HC to review our initial application.
Any info from those with knowledge/experience would be greatly appreciated. Thanks!!!!