MMPR Grow op: Small Scale

romulanlover

romulanlover

Active Member
Any thoughts on zoning guys. Sounds like we are at the mercy of municipalities, most of whom haven't addressed any form of zoning regarding cannabis ops. Would be a nightmare to set up and then be zoned out down the road. I suppose the letters to officials may alleviate some concern in that regard?
 
maximum

maximum

Active Member
Will a greenhouse be allowed under the mmpr? (Odd answer was given to me. I sent in a question last week regarding pre-inspection. They answered that question again. And also replied to me newer email regarding a greenhouse.)

Thanks for you questions.

To answer your question on the setup prior to a pre-inspection. Pre-Inspection will be conducted to ensure that you satisfy all the building security requirements under the Marihuana for Medical Purposes Regulations.

As for your question on the usage of the greenhouse. Your facility must meet all the building security requirements stated under the Marihuana for Medical Purposes Regulations.

Hope this answers your questions.

If you have any additional questions, please do not hesitate to contact us.

Thanks

Licences and Permits Division
Office of Controlled Substances
Health Canada
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So this is all I could find under the proposed changes regarding a greenhouse:

Guidance: Glazing Panel Security

Appropriate use of glazing panels can assist in ensuring that unauthorized access to your site is prevented.
For example, any glazing panels used in roofing (in a greenhouse for example) should be attached directly to the roof structure in such a manner as to preventing removal from the outside.
Building security can be further ensured by using appropriate electronic equipment to monitor glazing elements, including sensors that can detect breakage of glazing panels.
Mechanisms that can provide secure monitoring of glazing elements include one of the following:

  1. Glass-break sensors of sufficient number may be appropriately installed to provide 100% coverage of the glazing area.
  2. Electrically conductive foil or wire can be incorporated in the glazing elements to provide detection of breaks.
  3. Volumetric or beam-break detection systems can be employed to provide 100% coverage of the interior surface area of the glazing.
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http://www.hc-sc.gc.ca/dhp-mps/marihuana/future-avenir/securit-eng.php#a52
 
redi jedi

redi jedi

Well-Known Member
romulanlover said:
Any thoughts on zoning guys. Sounds like we are at the mercy of municipalities, most of whom haven't addressed any form of zoning regarding cannabis ops. Would be a nightmare to set up and then be zoned out down the road. I suppose the letters to officials may alleviate some concern in that regard?
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You should call your local by-law officer or the administrator in charge of zoning in your region. I inquired about "indoor agriculture" and the person I was talking to was pretty much stumped as to what zoning regs indoor agriculture would fall under. Leads me to believe this is something they haven't encountered before and probably dont have specific rules for.

I'm guessing later on down the road, you might have issues with fertilizer in the sewer system. Meaning you wont be able to drain a hydroponic system into the sewer. You will have to keep spent fertilizer in a holding tank and then dispose of in a approved manner.
 
redi jedi

redi jedi

Well-Known Member
maximum said:
Will a greenhouse be allowed under the mmpr? (Odd answer was given to me. I sent in a question last week regarding pre-inspection. They answered that question again. And also replied to me newer email regarding a greenhouse.)



So this is all I could find under the proposed changes regarding a greenhouse:


http://www.hc-sc.gc.ca/dhp-mps/marihuana/future-avenir/securit-eng.php#a52
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That will be the downside of growing in a greenhouse. What you save in setup cost will be made up in security costs.
 
maximum

maximum

Active Member
I emailed security companies in my city. Here is my email and reply I got.

Do you offer protection for greenhouses? This is the criteria I require:


  1. Glass-break sensors of sufficient number may be appropriately installed to provide 100% coverage of the glazing area.
  2. Electrically conductive foil or wire can be incorporated in the glazing elements to provide detection of breaks.
  3. Volumetric or beam-break detection systems can be employed to provide 100% coverage of the interior surface area of the glazing.



Monitoring
$19.95 to $125 /month (From $50 up, it enrolls you in the ULC program, at $125 it includes a lot of features and equipment)

Equipment
$50 to $10,000 ($10,000 would be surprising, it would be if you required a vault protected along with the greenhouse and everything would be at the maximum level of protection)

From experience if the requirements are not too stringent, the range would be closer to $500 - $2000
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Kootenaygirl

Kootenaygirl

Active Member
Anybody else not receive the advanced copy of the regs from hc? I asked in under 6 hours from the announcement when they gave the email address.
 
maximum

maximum

Active Member
Kootenaygirl said:
Hey there, have been following your forum from the start and I am very grateful for it. I am also interested in becoming a licenced production grower, just trying to figure out what size to aim for like you. I am enjoying the positive spin on this forum, as it seems everywhere else is just negativity. I applied for my R&D on January 29 as per HC's instructions (letter of interest and criminal check). On Feb. 14 I received an actual application form from HC . My only problem with the application was what my "legal supply of seeds or marihuana" were. After waiting 2 weeks for a response from HC, I called their office. The guy I talked to said he was "assistant to the director" and that I should email another request. I asked him for the email address just to make sure, and told me he would have to call me back with it and explained that he had only worked there for 2 weeks. He did call me back and of course gave me the email address I already had. So I emailed HC again for the 4th time about a legal supply of seeds. No Response ........ until yesterday when I got what looks like a standard email stating that in light of the new regulations coming out on June 19, did I wish to continue to pursue my R&D or would I just be applying to become a Licenced Producer. Seems like the knuckle draggers are now dragging their heels too. I had no idea that HC could be so incompentent. WOW. We all better prepare from some hoops, long delays, and incompetence. During this delay though, I was able to get a prescription and have now obtained my PUPL (4 weeks from the date MMAP received my application) , which I consider to be my R&D for the moment. My PUPL has an expiration date of June 6, 2014. I think I will skip the whole R&D process with HC too, and just apply for the production licence. I will also post my progress and any info I get, and I promise my posts will be much shorter.

Thanks to Maximum, I have been reading the new Regs. It appears that HC did not listen one bit to our concerns and have stuck to their guns. Do you guys see any real changes from the proposed Regs in December? Thanks again for this forum and all the posts.
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Great that your on board. I really want to read everyones updates because then we are all learning at the same time. And yes I agree with you, I was shocked by how little health canada knows about anything. Calling them to ask a question usually just means they look at a computer screen and try to find a question closest to what you just asked. They then call you back. They asked me what time should they call back. I told them evening. They called early morning. I missed the calls.

At least if we swim in a pack its harder to get lost.
 
S

scmo

New Member
hey I've been following this thread. we are also looking at applying to become LP's in bc. Wondering if anyone has any information on testing thc and cbd percentages? also for microbial and chemical contaminants? it just says analytical testing and validated methods? anyone know what testing methods would be ok. or what are all you others planning to do for that? send samples of every batch to a lab? I've read liquid gas chromatography is the only way to get accurate #'s but the machines are 30k +! the new regulations also say your QA needs to approve every batch. what are you all planning to do for that?
 
maximum

maximum

Active Member
scmo said:
hey I've been following this thread. we are also looking at applying to become LP's in bc. Wondering if anyone has any information on testing thc and cbd percentages? also for microbial and chemical contaminants? it just says analytical testing and validated methods? anyone know what testing methods would be ok. or what are all you others planning to do for that? send samples of every batch to a lab? I've read liquid gas chromatography is the only way to get accurate #'s but the machines are 30k +! the new regulations also say your QA needs to approve every batch. what are you all planning to do for that?
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Im going to use Dr.Hornby.
http://www.ic.gc.ca/app/ccc/srch/nvgt.do?sbPrtl=&prtl=1&estblmntNo=234567013105&profile=cmpltPrfl&profileId=501&app=sold&lang=eng

As far as I understand you can outsource the testing. Dr.Hornby hasnt yet confirmed he is ready to go for the mmpr but he currently does mmar. In my opinion he will be doing mmpr testing. Since he is setup for this stuff. He knows his Cannabis. He is also the maker of Big Bud.
 
Gquebed

Gquebed

Well-Known Member
After reading the entire thread, it seems evident by the experiences people have had with HC and whatever other regulatory agencies is that all of their policy has yet to made. Many of the specific questions that people have been asking are going unanswered because nobody has the answers... or rather the answers haven't been made up yet. It also seems obvious is that HC and the regulatory bodies are being overwhelmed by the inquiries. Bottom line, the first movers in this are going to be driven crazy by this situation. And it's going to be a long, long while before it gets sorted out. At least long enough that none of it will come to fruition simply because Harper and the Conservatives will be voted out in the next election. And both of the alternatives to the PCs have straight-up legalization in their policies... So... I'll guess there where all of this ends up is a situation similar to beer/wine, which is what makes the most sense for all involved. And the sooner we get there the better...
 
redi jedi

redi jedi

Well-Known Member
maximum said:
Im going to use Dr.Hornby.
http://www.ic.gc.ca/app/ccc/srch/nvgt.do?sbPrtl=&prtl=1&estblmntNo=234567013105&profile=cmpltPrfl&profileId=501&app=sold&lang=eng

As far as I understand you can outsource the testing. Dr.Hornby hasnt yet confirmed he is ready to go for the mmpr but he currently does mmar. In my opinion he will be doing mmpr testing. Since he is setup for this stuff. He knows his Cannabis. He is also the maker of Big Bud.
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Dr. Hornby(Hedron) could do the lab work but you will still need someone to fill the QA role. It doesn't say in the regs this person needs to be an employee but it reads that way in the LP application. The QA will need to approve each crop. Before they approve the crop they will have to approve the method used to produce is sanitary, meets good production practices, and the sanitation procedures used at the facility.

So unless Hedron can send someone to your operation every harvest and before your pre-license inspection. You will have to hire someone to fill this requirement.
 
redi jedi

redi jedi

Well-Known Member
maximum said:
I emailed security companies in my city. Here is my email and reply I got.

Do you offer protection for greenhouses? This is the criteria I require:


  1. Glass-break sensors of sufficient number may be appropriately installed to provide 100% coverage of the glazing area.
  2. Electrically conductive foil or wire can be incorporated in the glazing elements to provide detection of breaks.
  3. Volumetric or beam-break detection systems can be employed to provide 100% coverage of the interior surface area of the glazing.





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When asking for the quote, did you give them dimensions of the greenhouse?

Being the simple fact its a building made of glass, it will cost more to secure it to the same level as a building made from bricks/mortar.
 
maximum

maximum

Active Member
2,000 square feet. Yea there was some banter back and forth because they wanted to come out and look. I asked for a ballpark figure on 2000 square feet. I said Im still trying to see if its the route I want to go before buying the greenhouse.
 
maximum

maximum

Active Member
redi jedi said:
Dr. Hornby(Hedron) could do the lab work but you will still need someone to fill the QA role. It doesn't say in the regs this person needs to be an employee but it reads that way in the LP application. The QA will need to approve each crop. Before they approve the crop they will have to approve the method used to produce is sanitary, meets good production practices, and the sanitation procedures used at the facility.

So unless Hedron can send someone to your operation every harvest and before your pre-license inspection. You will have to hire someone to fill this requirement.
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Hedron could do analytic only. Looking at the new info I found the following

In order to achieve purity and quality of the finished dried marihuana product, Good Production Practices as outlined in the MMPR must be followed at all stages of production, packaging, labelling and storage of the marihuana.
As specified in the MMPR, each batch or lot of dried marihuana must be approved for release by the LP's Quality Assurance person, who must have the training, experience and technical knowledge relating to the activity conducted and the requirements of Division 4 of the MMPR. This means that the Quality Assurance person must have the ability to evaluate the operations of the LP to ensure compliance with Division 4, and the technical knowledge to be able to assess analytical testing results in order to be able to make the determination of whether the dried marihuana is suitable for sale. The Quality Assurance person is also responsible for investigating quality-related complaints and taking corrective and preventive actions, if necessary.

Visual inspection should confirm the absence of pests or extraneous substances. There is no requirement to mill or irradiate the dried marihuana, although LPs may choose to do so.
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Training and experience and technical knowledge relating to what? Specifically cannabis?

Section 10: Quality Assurance Pre-Licensing Report

A licensed producer must have an employee designated as a quality assurance person who is responsible for assuring the quality of the dried marihuana, before it is made available for sale. This employee must have the training, experience and technical knowledge related to the proposed licensed activities and the requirements of the MMPR.
The applicant must submit a document signed and dated by the quality assurance person that includes:

  • a description of the quality assurance person's qualifications in respect of the proposed licensed activities and the requirement of the MMPR; and
  • a report establishing that the buildings, equipment and proposed sanitation program to be used in conducting the proposed activities referred in the MMPR comply with the regulatory requirements.
The accuracy of the information contained in the report will be verified by Health Canada inspectors during the pre-licence inspection of the proposed site.
For more information on quality requirements, please refer to the Guidance Document - Technical Specifications for Testing Dried Marihuana for Medical Purposes.
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Great but thats pre-licencing, what about post licensing?

Did you guys ever find anything specific thats a criteria for the qa person? Education level? Experience? A specific title ? Do you guys know any other business using a QA? cdnsimon predicted using a QA person. Good call Simon. Any more info on who this person is? And where we find said person? canadian simon suggested that we work together as LP's and find someone that we can share. "co-paying a shared QA specialist on contract, I have a couple of leads on contract personnel that might fit the qualifications" So Im optimistic if we push we can get this hurdle jumped over.

When I emailed Health Canada it seemed that they cared about security/sanitation only for pre inpsection. They gave the feeling like the grow gear doesnt have to even be in the building. But reading the quote above it says "equipment" has to comply with regulatory requirements. But I dont find any regulatory requirements for lights and hoods and pumps, etc....
 
redi jedi

redi jedi

Well-Known Member
Thats just it. There are many industries that use quality assurance and the training and education needed to perform QA would vary with whats being inspected. For example some QA techs might need to have an engineering degree (chemical, electrical or mechanical) and some might only need employer provided training.

I really don't think there's anyone, as of now, that is qualified to do what Health Canada requires.

If there's anyone out there that thinks they might be qualified to perform the task, please speak up.
 
maximum

maximum

Active Member
redi jedi said:
Thats just it. There are many industries that use quality assurance and the training and education needed to perform QA would vary with whats being inspected. For example some QA techs might need to have an engineering degree (chemical, electrical or mechanical) and some might only need employer provided training.

I really don't think there's anyone, as of now, that is qualified to do what Health Canada requires.

If there's anyone out there that thinks they might be qualified to perform the task, please speak up.
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Im on the same page as you Redi.

Did you by any chance see anything in there about the QA person also being the Senior person in-charge or does it have to be a different person? If they wanted specific education level they should have stated the requirements for the QA person. I wonder if its left vague because there is no criteria. And at the risk of sounding snarly here, you me and any other grower thats been doing this for years is the expert in the field. We are the experts here.
 
redi jedi

redi jedi

Well-Known Member
The QA person could be the alternate person in charge or maybe the responsible person in charge, but I dont think they could be the senior person in charge because that could be a conflict of interest. I'm just guessing though.

I totally agree, if there is anyone qualified to do the job, it would be an experienced grower. The product is going to be analyzed in the lab anyways.
 
maximum

maximum

Active Member
redi jedi said:
The QA person could be the alternate person in charge or maybe the responsible person in charge, but I dont think they could be the senior person in charge because that could be a conflict of interest. I'm just guessing though.

I totally agree, if there is anyone qualified to do the job, it would be an experienced grower. The product is going to be analyzed in the lab anyways.
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lol the QA person needs to read the lab results to us.
 
oakley1984

oakley1984

Well-Known Member
this is just becoming more and more hilarious, everything i said was dead on accurate.

Yet again I proposition the question, What happens when you sink all this money into being a licensed producer, And NOBODY buys from you.
The entire system is setup to fail from the patients perspective. And I laugh at the previous comment saying, just the same as always, diverted to black market
As I had said before there will be 24/7 visual monitoring in All areas! So Alas... you're going to create bills for yourself that you will be unable to pay. If you attempt selling to the black market, Harpers got a jail Just for you!
This massive money sink will be dissolved by the next regime in power Anyways. Im officially retiring from the inet and going back to being illegal...
Sadly... Its safer!

Gluck to you all and sending yourselves into bankruptcy... Really should have a contingency plan if you all decide to go forward with this, cause it is pretty much an assurance that you're Fucked.
 
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