Some good information here. As for lawyers I have 4 that I am helping with out with there apps. The only people HC hates more that applicants is Lawyers, lol.
Everyone thinks they have this figured out. Truth is HC does not even have it figured out so no one else has a clue. All we can do is keep beefing up the applications and keep answering questions. HC is just getting started on everyone, guys you have not seen anything yet compared to what's coming just as you get close to the finish. HC has some show stoppers they have reserved for you, and your just going to shake your head and say why not tell us this at the start so we don't waste our time? HC is kind of like the I Robot movie you have to ask the right question, the right way, and maney times. Keep going stay strong and have plan B.
Just so you know a LTB is not worth the paper it's written on, even if you have it you can still me told "NO" after you have built it out. HC will not tell you that you move forward at your risk. HC can stop anyone with just one word and they is no one who can stop them.
By the way all the early applicants are being re-visited because of all the changes and decisions HC is making on the fly. So back last summer when we put our first app in we sent HC a canoe (Coles Notes version) today we submit the largest cruse ship in the world (
Allure of the Seas) to Health Canada on behalf of our clients. It has everything in it.
All this goes back to HC doing the least they can to inform applicants, and this is by design. good example is saying you need GPP, what the fuck is that? It was developed for feed lots and is meant to make you think it's not a big deal. Well now everyone is finding out it is a BIG DEAL. But what HC is not telling you is it's really GMP they want, but if you knew that your application would be 1,500+ pages as you would know what they want. HC is dicking everyone around, I have told everyone this from the start. Us GMP and you will be fine.
this is from Manual of Good Practices for the Feed Industry, Google it!
Section 3 - Production, processing, storage, transport and
distribution of feed and feed ingredients
The production, processing, storage, transport and distribution of safe and
suitable feed and feed ingredients is the responsibility of all participants in the
feed chain, including farmers, feed ingredient manufacturers, feed compounders,
truckers, etc. Each participant in the feed chain is responsible for all activities that
are under their direct control, including compliance with any applicable statutory
Bullshit just dishonest Bullshit! GMP look at the list below and think whats wrong with this picture. But than you have to wonder why our government would mislead us right from the start.
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