QA requirement

Just interviewed someone on the phone for the QA position we listed and although this person was looking for immediate/permanent employment (something we can't afford before before HC approval), she did provide me with some insights on the inspection process. She attended a recent conference-workshop by HC on MMPR and apparently the intention is to put every site though the ringer( no surprise there), she also said the inspection would last for 3 days!!! and one has to absolutely have a qualified QA person on board on the application with solid academic credentials in the field and 5 yrs of QA experience!!! I am wondering if anyone who got the "authorize to build" green light from HC can shed some light on this. Meanwhile the search for a solid QA person continues...

I never heard of a HC conference-workshop on MMPR. Perhaps she was referring to the Greenline seminar?

Hire me, problem solved.

You're qualified Brian?

Neither have I, and I don't think she was referring to Don Shultz's Greenline gigs either! She did contract work for HC in the past and by the sounds of things she kept in touch with some contacts there.

If you're qualified and willing to join us in the Colbourne area, then pm me!

Hey guys, I am also interested in starting a small legal grow operation. I have emailed HC about the QA position. They first provided me with the info we all know from the archives. Then, I specifically asked about education and was told there are no formal education criteria needed for the QA position.

It is my understanding that QA person and responsible persons are the management structure of the business in order for HC to keep tabs on everything and point the finger if something were to happen.

This is supposed to be a free market and a company for any other growing endeavour would be free to choose any QA person they see fit. I currently grow vegetables and we have a QA person with lengthily experience growing and producing food crops with a great record for quality. How would they not be qualified for this too? Of course I could be wrong and miss-informed. It all could be different once we hear back from our applications.

This is the least understood part of the MMPR, welcome to the wannabe club, put up a few posts so you can private message.

Your Quality Assurance Person is the most important person in Health Canada's eyes IMO. Your not saying anything new here, your idea and mine of what is necessary to appease HC are similar.

Most wannabe's here, are going out of their way for special training or to hire special people who claim to be experts. Some are spending upwards of 30K towards this unknown. Where does it say that greenline is even recognized by Health Canada?

Our thinking is closer to yours and we don't want to spend the 30K unless we absolutely have to. Who knows about our quality assurance better than us, quality assurance is what we do, it is all we do in our grow rooms.

If you are an educated grower and can talk confidently about all aspects of growing and processing marihuana, and can learn new tricks like shipping, and government relations, then you really should be the quality assurance person IMO. How is some person that drops in every week or month going to assure the quality? Common sense says that we are the experts in growing and processing marihuana.

I am definitely in the minority opinion on this one. But because we are not doing anything but what the rules say we have to and not an inch more, we will learn what HC needs, trust me, and so will you.

We have a highly qualified horticulturist on staff, (my husband) who will work when I tell him (just kidding), he will do whatever is required to be the QAP, (or else). If you have a QAP for a food crop already, then it sounds like you should go with them. Hopefully you are getting as good a deal as me, meaning in house, lol.

I've said it before, your head grower in a small operation should be your QAP. If your head growers shouldn't be the QAP, then they really shouldn't be the head grower either IMO. If your responsible enough to look after all aspects of a crop from start to finish and from seed to dried marihuana, as a patient, that's who I want my quality assurance person to be .

Growing is not a 9-5 job, this is a 24/7 commitment. In a small operation, this decision could be everything financially too. What does your outside QAP earn, what work are they responsible for? If things go wrong is the QAP insured? It sounded like this "qualified person" was expecting a full time job? Who is getting up in the middle of the night to figure out why the temp alarm in # three is going off? I'm guessing that would still be me.
Was marihuana part of the "professional" QAP's experience?

Will someone speak up about their QAP training or a general description of a QAP that they hired, job description, experience, etc. Can somebody speak about their greenline experience.

Anybody with a proposed small operation using an outside QAP?

Convince me that HC needs QAP training or people to give you a license. So far we are not convinced, the training is unaccredited, and an outside QAP makes little sense for quality. I'm not saying it is a scam, but am not sure that it is not. Opinions welcome.

Kootenyagirl, I have been reading your posts throughout the changes to MMPR especially those in the small scale grow op and my thinking aligns most closely with yours. I really hope that HC approves your application.

You are correct Kgirl, if your assumption as a patient that the QAP should also be the lead grower, then the rest of it makes sense i.e. Not a 9-5 job, intimately linked to the operation etc., but I don't believe that HC sees it as organically as you do. In fact, I don't think they care that growers produce good quality Cannabis as long as it's tested and safe. Ultimately, in a free market patients will vote with their feet so to speak. PPS had no incentive to better their stuff thanks to their market monopoly position. Agreed, there's no doubt that some growers are able to produce the best of Cannabis out there through years of experience with trial and error. That being said, most of the wannabe LP's myself included don’t have the scientific background (unless political economy counts lol). Does HC require rigorous academic background, I don't know but my common sense tells me if you can find someone it certainly wouldn’t hurt your application prospects. This is what the person I interviewed said. The other experience which seems to confirm this is that of the Peace Naturals Project with a PhD on board as a full time QAP. Both Cannimed and Mettrum are secretive about their people.
Yes, the person was looking for a permanent full time job which we can't afford as a small scale wannabe LP before HC's approval. I am intrigued to know if the folks who received the "authorize to build" did insource or outsource their QA on their application. Is it a money grab? Not if someone is looking for decent employment by using their skills and joining a team. The same can't be said for the mushrooming consultancy industry. I can't see how otherwise GreenLine charges $1700 for one day workshop. Someone mentioned in a previous thread that 200+ attended in one day in Toronto. At this rate, Don Schultz only needed 3 solid days to become the 1st MMPR millionaire without even securing an LP licence lol

GreenEra2013, I did email HC and asked specifically about QA education requirements and the reply confirmed that there are no education requirements for QA persons. People are having a hard time with this question. I'll dig up that email and quote it sometime soon. so everyone can see exactly what HC said.

trip96, I've gotten the same response from HC a while ago, and quite frankly I can't see how HC could have legally made it a requirement in the application to have an education degree for 2 reasons: 1st, the MMPR is new, there's no professional Cannabis QAPs regulatory body yet to lobby for standards of the profession as do pharmacists or accountants per se. 2nd: HC is not doing the hiring, the LP's are. That being said, by leaving this area in the grey, HC has given themselves more latitude in reviewing the applications.

And how will HC use it's latitude? Probably without remorse, and probably not with any commonsense you or I might be able to recognized. This is where we really need to learn where that line is.

I am in complete agreement with how kootenaygirl and greenera are viewing the QAP.

There is no formal education or training for what is required in to be an effective QAP in regards to medical cannabis cultivation and processing. There are relevant and similar area's, but none specifically for cannabis.

Found this on HCs Natural Health Products pages: http://www.hc-sc.gc.ca/dhp-mps/prodnatur/faq/question_industry-industrie-eng.php#a16

See items 15 - 25 (esp. 16). Full of legalese, using a whole lot of words to say very little, but might help to clarify a bit of what they are looking for. Still seems grey to me, but they do talk about education and credentials (without actually stating what that means).

Any thoughts on Greenline's course? I emailed HC to ask if this would give the credentials, but am expecting another standard cut and paste reply referring to the regs. Would the course credentials appeal to other producers who are looking to hire out?

Frustrating how grey the regs are and how little they give with their answers to simple questions.

spiritmedicine said:

Any thoughts on Greenline's course? I emailed HC to ask if this would give the credentials, but am expecting another standard cut and paste reply referring to the regs. Would the course credentials appeal to other producers who are looking to hire out?

Frustrating how grey the regs are and how little they give with their answers to simple questions.

Click to expand...

What credentials were obtained by attending the Greenline seminar?...how much time was devoted to QA in the seminar?

Kootenaygirl said:

And how will HC use it's latitude? Probably without remorse, and probably not with any commonsense you or I might be able to recognized. This is where we really need to learn where that line is.

Click to expand...

This will be very interesting. I believe HC will clear up this ambiguous area in the future.

Kootenaygirl said:

If you are an educated grower and can talk confidently about all aspects of growing and processing marihuana, and can learn new tricks like shipping, and government relations, then you really should be the quality assurance person IMO. How is some person that drops in every week or month going to assure the quality? Common sense says that we are the experts in growing and processing marihuana.

Click to expand...

It's ME again. I just registered on forum, and your posts are so informed and I like your opinions that I have commented on several. (Not a Stalker, NOT a STALKER!)

I TOTALLY see your point about how Master Grower is perfect QAP. I see 2 caveats to that though, and likely Health Canada is thinking of the first.

Firstly, it's a "back seat driver", or "Inspector 12", a second pair of QUALIFIED eyes. Their actual role is somewhat of an accountant, as another post of text from HC indicates. It would be great if the QAP was "compliance" oriented but could also farm, is that you?

Secondly, I suspect that the QA role in the long run will be very demanding, more so in the beginning. Master Grower is an equally or more demanding role. Plus I suspect since you're a couple, that you will each be RPIC or ARPIC, and one of you will be SPIC, which comes with duties of their own.

There was a post on the main "wannabee" thread explaining how QA was different from QC, which I hadn't realized. I believe they said that QC was SOP's and lab tests, set up in advance, and that QA must be boots on the ground, VERIFYING that everything is within spec and done following SOP's (hope I don't have that backwards). I think I'm like you in thinking that your QAP really must be onsite. I can't imagine paying $150 hourly, and wait for someone to come in to sniff a batch I might already know isn't worth selling. Nor that all the boxes are "tickied" on the QAR.

As long as the QA is capable of interpreting the microbial and analytical results you will be fine. One needs to demonstrate their ability to do this ,hence scientific background is an advantage.