MMPR Grow op: Small Scale

[BigBhuda]

Just started following this thread and it is awesome. Just what we need.

For the record I am currently a small dg with only 3 lights, but on a relatively remote acreage with a 30 x 40 shop and would like to expand as part of the new regulations.

Excellent questions. I can't see how we can go ahead and invest in the security and video monitoring before knowing if they will approve it. I hope we can submit a detailed plan and know that when it passes inspection we will be authorized.

Also what has not been clear is if greenhouses will be possible. I would think with a secure chainlink / barbwire fence it should work in rural areas.

Finally I would like to suggest something that may be an option on a big scale. The main idea here seems to be small producer cooperation. What if we actually formed a formal producer coop. It may even be possible that producers could sell in bulk to the coop which would handle all of the quality control, packaging and client order fulfilment. The coop could set the quality control standards and perform producer inspections as required. The coop would pay producers a fair but reasonable amount and charge the clients on an equally fair basis. Any excess could be paid out as patronage dividends.

It would also be possible to have client memberships that could share in the dividends. The necessary capital would be raised by selling the membership shares. I would hope maybe $1,000 for a producer member and $100 for a patient member. There could also be investment shares that would pay good interest for investors. I think patients would jump all over this instead of super large greedy corporate producers.

 

[BigBhuda]

As far as Revenue Canada is concerned, I would say yes. For the regulations I am sure you would have to follow the quantities in the patient prescription. The interesting part under the current rules is that if you purchase from a designated producer you can use it as a medical expense on your tax return. The costs to produce yourself are not eligible.

 

[maximum]

Health Canada replied to my first email:

"Before applying, does the proposed production site need to be equipped with all the grow equipment? Or can I apply with the empty building and then add my equipment once I am licensed?"

Good day,

All security measures must be in place before an inspection is conducted and a licence is issued.

Regards,

Licences and Permits Division

Guys, how do you take this email? He doesnt mention the grow lights and gear, does he just not get it or he is saying we only need to do security on the building before inspection? I wonder what exactly the inspector is looking at.

I sent off another email to health canada (yea I'll be harassing them with emails and questions. I dont care)

"Will a greenhouse qualify under the new mmpr?"

 

[redi jedi]

They dont care about the grow equipment, they're concerned about the security of your location.

 

[BigBhuda]

Max:

What is the email address that you are getting responses through. Is it " consultations-marihuana@hc-sc.gc.ca " ??????

The question is " Will they provide feedback on building construction, security and Quality Control plans before construction begins. "

 

[maximum]

MMPR-RMFM@hc-sc.gc.ca

Thats the email that I send questions to. They are replying within days.

I got another reply!

"Will there be a fee similar too a liquor license fee to obtain a cultivation license under the new mmpr? Or some sort of yearly compliance fee?"

The Application Form to Become a Licensed Producer, Guidance Document for Applications to Become a Licensed Producer, and Security Clearance Application Form for parties interested in applying to become a Licensed Producer of marihuana for medical purposes will be posted to the Health Canada website on June 19, 2013 when the regulations are published in the Canada Gazette, Part II.

There is no fee related to obtaining a producer license.

A licence can only be issued when the proposed facility security measures are in place and after a pre-licensing inspection is conducted, and once all key personnel have been security cleared.

Thanks

Licences and Permits Division
Office of Controlled Substances
Health Canada

 

[BigBhuda]

It certainly appears that security is their only concern. Perhaps the whole quality control thing is smoke and mirrors to make it appear that they give a shit about the patients. It will be interesting to see how detailed the guidance document will be. Perhaps we are paranoid but after years of dealing with them doing everything in their power to slow down and reject authorizations it is hard to believe they will work with us like any other government licensing department.

 

[Kootenaygirl]

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.

 

[MMPRmonkey]

Very interesting idea...would you care to share your plans for QA?

We are working with a consultant that has come up with QA systems for supplement companies. We plan to have an onsite lab to determine heavy metal, mold, and pesticide levels through a gas chromatography machine.

 

[redi jedi]

We are working with a consultant that has come up with QA systems for supplement companies. We plan to have an onsite lab to determine heavy metal, mold, and pesticide levels through a gas chromatography machine.

This consultant, what did they do before that makes them qualified in respect to cannabis?

 

[redi jedi]

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.

You can legally buy seeds already. From any of your usual sources.

 

[MMPRmonkey]

This consultant, what did they do before that makes them qualified in respect to cannabis?

He will not be our official QA person, however will help us build a system that will be compliant with the standards of quality outlined in the regulations. The official QA person has extensive experience in the cannabis industry and is seeking further consulting and training from industry professionals in California, Colorado, and Washington.

 

[R.Raider]

You can legally buy seeds already. From any of your usual sources.

Ok so just to make sure I have this straight, will LP's be able to use any seeds and strains they want?

 

[redi jedi]

Ok so just to make sure I have this straight, will LP's be able to use any seeds and strains they want?

Yes. If you have a strain you've developed you could sell it to the LP.

 

[redi jedi]

He will not be our official QA person, however will help us build a system that will be compliant with the standards of quality outlined in the regulations. The official QA person has extensive experience in the cannabis industry and is seeking further consulting and training from industry professionals in California, Colorado, and Washington.

Interesting...So currently this QA person is not qualified? as per Health Canada? What type of system is your consultant recommending? Those standards focus on cleanliness more than quality.

 

[maximum]

Great questions redi jedi. I would like to know too.

 

[redi jedi]

Theres so many forms of QA. I know two people with the job title of QA tech. One guy performs NDE on landing gear components the other inspects plastic parts for the automotive industry...who holds a qualification to inspect cannabis?

 

[maximum]

Just started following this thread and it is awesome. Just what we need.

For the record I am currently a small dg with only 3 lights, but on a relatively remote acreage with a 30 x 40 shop and would like to expand as part of the new regulations.

Excellent questions. I can't see how we can go ahead and invest in the security and video monitoring before knowing if they will approve it. I hope we can submit a detailed plan and know that when it passes inspection we will be authorized.

Also what has not been clear is if greenhouses will be possible. I would think with a secure chainlink / barbwire fence it should work in rural areas.

Finally I would like to suggest something that may be an option on a big scale. The main idea here seems to be small producer cooperation. What if we actually formed a formal producer coop. It may even be possible that producers could sell in bulk to the coop which would handle all of the quality control, packaging and client order fulfilment. The coop could set the quality control standards and perform producer inspections as required. The coop would pay producers a fair but reasonable amount and charge the clients on an equally fair basis. Any excess could be paid out as patronage dividends.

It would also be possible to have client memberships that could share in the dividends. The necessary capital would be raised by selling the membership shares. I would hope maybe $1,000 for a producer member and $100 for a patient member. There could also be investment shares that would pay good interest for investors. I think patients would jump all over this instead of super large greedy corporate producers.

Do you think it would be legal to have that middle entity in between the producer and the customer? It sounds like they intend us to sell direct. Is the coop like a middle man? How is it different from a dispensary. Im not too familiar with the coop setup. I know I see it with farms but I dont know much about it. How did you picture it working? Usually a middle man gets the profits and the customer and producer gets shit on.

 

[BigBhuda]

From what I read it looks like it will be allowed to sell product to other licensed producers. I think essentially dispensaries will still exist. They just won't be allowed to have storefronts. All sales are supposed to be only mail order. The idea of a coop is that it is owned by the producers or patients. A board of directors is elected by the members and the board hires mgmt to run it. Any profit is reinvested or distributed to the members. If they screw us over they get booted out at the next election. The capital to get it going is raised by selling the memberships. I foresee getting together to run the expensive lab, processing, packaging and sales functions.

 

[romulanlover]

The middle entity would basically be an LP, but with little to no focus on producing and all focus on logistics - importing from other LP's, handling the client list (the most challenging and valuable part) and mailing out to clients. I see your point, to avoid being screwed the "middleman" would have to be a corp with the shareholders being all the LP's who provide to it.


Edit: Woops, didn't see BigBhuda already posted what I wrote