MMPR Grow op: Small Scale

torontomeds said:

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.

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Hi, and thanks for the reply! My partner and I have some excellent leads on some locations....we will be located in Northern Manitoba and are currently looking at some 3000-5000sqft facilities that are being sold for extremely cheap by some desperate owners. We are exploring possibilities of a lease-to-buy arrangement where we will lease the property for a set amount of time, and then purchase it outright pending the approval of our application and getting the green light to build.

When you say that you know people that started in Sept, do you mean they started to build in sept, or that they submitted their application in Sept?

We have been planning for a while now, and have financing and a business plan in order. I am the one with the growing experience/qualifications/know-how, and my partner is the business/money guy. He's a very close friend who is the a senior manager and part owner of a large successful company in an unrelated field. He will be providing much of the start-up money and collateral, but also has some valuable contacts in our proposed area as he'd had dealing with various levels of government through his other company. We have not yet put out any notices (as we still need to secure a location), but with his contacts and reputation as a reputable businessman, we are hoping to not face any resistance from the local authorities.

Right now, I'm trying to find as much information as possible on approximate/expected wait times to get security clearances, and how long it is now taking for HC to approve/issue a permit to construct after they get the initial application. I'm seeing all sorts of numbers and conjecture around the web, so I'm looking for some concrete info on this from anyone in the know.

I also have some questions about the QA person and whether I would qualify, but found a great post in another thread where someone posted a reply directly from HC........based on what HC stated in that reply, there are no specific requirements necessary for the QA person, but that the onus is on the applicant to provide an in-depth explanation of how the QA has 5 years of experience which directly qualify him/her to fulfill the job's requirements under the MMPR. If that is the case, then I am hopeful that I will qualify based on my educational and work experience.

torontomeds said:

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.

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I have seen lots of good QA's get denied over the last 10 months, I even had two PhD's they said no to. It's all in how you respond to them. When the PhD's came to me I re-wrote the section and they are approved. The whole app is like that you have to say the right things or bye bye. This sounds self serving as I am a MMPR consultant but you don't stand a chance of getting through the door with out Pro help and I mean someone who has done this many times. The system is broken and HC has 700 apps to deal with. HC is circling the wagons and if you are thinking of doing this you better get at it because soon your chance will slip away. The day of tossing in a application is going away fast. Most applications are being refused at the door if they find a couple things wrong with them. This is not 2013 anymore and we have educated HC so sloppy or incomplete apps are a thing of the past. Put your best foot forward and you will get in, lets hope you get it done before they close the door.

Mmpr613 said:

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

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It was a paper mistake, nothing wrong with the meds. People are just guessing and speculating.

Kootenaygirl said:

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.

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Pisses me off because I know of residences that are 30 to 300 feet from production facilities.??? If only they applied an even hand to everyone. About the only thing they do to everyone is HATE them the same. It's starting to get personal with HC answering emails and shouting at clients. Here is an example of a reply from HC. This is un-touched right from the letter, and HC was wrong the information was there, just like all the other information.

2. The address when unemployedmust be provided. This note means "WHERE WERE YOU LIVING WHEN YOU WERE UNEMPLOYED"provide that information in section 4 as per RCMP requirement. - Date Sent:April 25, 2014

They know better to pull this crap on me, that's why I got involved in this application. HC is out of control. Any one care to comment?

I can see how someone on their end can be a little annoyed with several hundred dumbass applications. However, as a public institution they should keep a professional demeanor when speaking with applicants. HC is in the drivers seat right now so they could literally tell you to fuck off in the letter and unless you were willing to give up the application you'd have to eat it.

The process is just incredible I mean if you step back from it and look at it from a point of view of someone that has nothing to do with it, it boggles the mind. I would not be surprised that sooner or later someone who has all their t's crossed and i's dotted will snap and we'll see a gigantic class action aimed at HC for unfounded delays, costing business' hundred of thousands etc. etc.

well how many have failed or been denied is a good questionÉ
and I don't see anything wrong with them spelling out that some people have a made a lot of dumb mistakes,
600+apps in and only 200 accepted so far, what about the other 580 appsÉ

Most of the apps are split between the waiting room and the question room. Very few are waiting for approval, 13 I believe is the last number I got from HC.

woodsmaneh! said:

Pisses me off because I know of residences that are 30 to 300 feet from production facilities.??? If only they applied an even hand to everyone. About the only thing they do to everyone is HATE them the same. It's starting to get personal with HC answering emails and shouting at clients. Here is an example of a reply from HC. This is un-touched right from the letter, and HC was wrong the information was there, just like all the other information.

2. The address when unemployedmust be provided. This note means "WHERE WERE YOU LIVING WHEN YOU WERE UNEMPLOYED"provide that information in section 4 as per RCMP requirement. - Date Sent:April 25, 2014
They know better to pull this crap on me, that's why I got involved in this application. HC is out of control. Any one care to comment?

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Hi Woodsmaneh,

Do you know which LPs are 30 to 300 feet from residences? I know Tweed is close to residences, but I'm not too sure about any others. My company is fighting with HC now because even though we are zoned commercial, they are having issues with our property because we are "in close proximity to residential homes".

Thanks for your help.

Kootenaygirl said:

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.

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Hey, when you going to come out for a visit?

(From Health Canada: “If an individual wishes to purchase a variety of strains that are not all available from one licensed producer, the MMPR will permit the individual to do so by obtaining a new medical document. They will have to discuss this with their health care practitioner. The health care practitioner will have to divide the daily quantity between multiple medical documents.”)

Health Canada has just said no part time QA's.

woodsmaneh! said:

Health Canada has just said no part time QA's.

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Thanks for sharing! I'm not sure how people thought they would get away with part time QA's, HC states that the QA is responsible for ensuring QA protocols and procedures are being followed for every step of the propagation, growing, harvesting, drying and curing processes, which would be impossible to achieve with a part-time QA. The QA person is far more important than the head grower in HC's eyes, you can't have 1 or more people dedicated to growing and then only a part-time QA person that isn't even on site a lot of the time.

Allowing part-time QA people would be like HC saying QA is only a part-time job, and inviting people to cut corners.....there was no way that was going to fly.

what do you thing the QA person will be doing for 40+hrs a week in a 10ksqft siteÉ standing thereÉ i wont be paying them to stand there.

rnr said:

what do you thing the QA person will be doing for 40+hrs a week in a 10ksqft siteÉ standing thereÉ i wont be paying them to stand there.

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There is no reason a QA person cannot also be one of the growers taking care of the operation. In the set-up we are proposing in our application, I will be involved in all aspects of the operation as the QA person. HC wants the QA person to be as involved as possible in the process, as this is how to ensure proper QA procedures are consistently being followed, and potential issues are identified immediately. I've worked in the QA industry for some time now, and I know what happens as soon as the QA person isn't around and on top of things.....people slack and you have issues.

Another requirement of the QA person is to be in charge of an efficient and effective program to handle patient complaints and any recalls in a timely manner. Every complaint and adverse reaction needs to be immediately investigated and documented.....this side of the job in itself will take time in order to meed the requirements set out in the MMPR, and not something thtat can be handled on a part-time basis.

QAP and SOP development is also not finished once you are approved, it is an ongoing process of evaluation, self-audit and adjusting to operational needs......you can't just hire a QA person part-time to have them pop in every time you have a crop come ready for harvest. There are many stages of the perpetual cycle which need to be constantly overseen by a qualified QA person. For example, how are you verifying that proper cloning SOPs are being followed if the QA person is never around when clones are being taken? Or what do you do when HC pops in for a surprise audit/inspection and you have a facility worth of plants and product in various stages and not a single qualified QA person onsite???? HC has already made it clear that being a 'master grower with x number of years experience' does not give you the qualifications to oversee QA-related activities or to make such verifications. I know first-hand that proper QA is a round-the-clock job in any health-sensitive manufacturing process, it is not just giving the thumbs up every time a batch is ready and then twiddling thumbs the rest of the time.

then they need to allow the growers that have been around mj for 20+ to become part of the team, we know a lot more about the issues, than a QA does. how many actual QA have ever dealt with mj... not a lot. and if the gmp, sops is set up, and most rooms are controlled anyway, things will work every day the same for yrs, minor clitches but if you have your safety kill switches set up there should be no issues. and staff monitoring the rooms, keeping spotless clean, and doing daily what is needed, the lab tests insure the flower is not contaminated in any way & %s.
and for tweed to already have so many issues, shows this is bs for the QA side 10000% they have fucked up so bad imo they should be shut down for stupidness, bugs, buying wet weed, and whatever else has been braught up. that needs to be stopped now, they... don't have a clue. $$ don't grow weed, street smart growers do

Devil Lettuce said:

There is no reason a QA person cannot also be one of the growers taking care of the operation.

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rnr said:

then they need to allow the growers that have been around mj for 20+ to become part of the team, we know a lot more about the issues, than a QA does. how many actual QA have ever dealt with mj... not a lot. and if the gmp, sops is set up, and most rooms are controlled anyway, things will work every day the same for yrs, minor clitches but if you have your safety kill switches set up there should be no issues. and staff monitoring the rooms, keeping spotless clean, and doing daily what is needed, the lab tests insure the flower is not contaminated in any way & %s.
and for tweed to already have so many issues, shows this is bs for the QA side 10000% they have fucked up so bad imo they should be shut down for stupidness, bugs, buying wet weed, and whatever else has been braught up. that needs to be stopped now, they... don't have a clue. $$ don't grow weed, street smart growers do

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I'm sorry my friend, but you are now producing a licensed and controlled health care product for the masses. It is no different for anyone producing ginseng, ginko or other medicinal herbs, or even food for that matter....to put it in perspective, in a large commercial bread-making facility, the licensed QA person is not a baker. Not to mention, how the heck does anyone provide HC with a resume and prove that they have been exclusively working with MJ for 20+ years?! "Yeah, I was sorta breaking the law for about 10 of those years, but can you still give me my license anyway?"

I do not want to discourage you or come across as rude, but I do not think you are aware of what developing and running an entire QA program involves. That has been my career for the past 6 years, as well as growing. It is a major process that needs to meet all sorts of regs set out in various acts, not just the MMPR. It takes the schooling and the know-how to run a proper QA program, not just street smarts. We are growing medicine here, not recreational MJ, and it's a whole different ball game.

HC wants to see a full-time QA person that has experience with the production of a controlled product, and that has experience dealing with regulating bodies. They also want someone that has worked in a lab setting and is comfortable with all of the best practices, techniques and terminology associated with lab work as the QA person is responsible for interpreting all lab data received from batch testing, as well as data collected and measured on site. Street-smart growers cannot provide that......it is MUCH more complex and involved than just keeping things clean and following directions. There is no specific educational or work experience requirement to qualify as a QA person, but HC has stated that it is up to applicant to provide a full and detailed explanation of both the proposed QA person's education and work experience, and how they directly apply to that person being able to fulfill each of the requirements of the position set out in the MMPR. I have been looking into this extensively for the last week, and now know this to be the case. I also know that anyone with relevant education and work experience is already making $60,000-$100,000 in the regular workforce, so this is what you are going to have to pay someone full time (and/or make the QA person a partner) if you do not have a qualified person in house already. One advantage of making the QA person a part owner is stability.....as a small LP, what do you do when you spend a bunch of time and money to find the perfect QA person that gets your application approved, only to have them up and quit after a couple of months, or before you even begin production? It is also going to be a serious challenge trying to hire people for a job that may or may not be available based on the success of the LP's application, has no definite start date, as well as a host of other uncertainties. The vast majority of people with adequate qualifications already have jobs with a pension and benefits, or have a lot safer job prospects with established companies.

I am having a go at becoming a small-scale LP myself, but if I'm unable to make that happen for whatever reason, then I will definitely be shopping my services/qualifications to other prospective LP's needing a QA person. Knowing how critical (and expensive) a qualified QA person is to a smaller-scale LP, combined with my growing experience, it is unlikely that I would entertain any job offers that did not include a percentage stake in the company. If any prospective LP's are in a bind on this front, feel free to get in touch with an offer. I am still early enough in the planning stages of my own LP that I would be willing to listen if the right offer came my way to join forces with someone else who is already progressing through the application process. I am squeaky-clean for the security clearance, and I would be happy to provide all of my education and work experience.

Our application will have approx. 150 pages dealing exclusively with QA and SOPs. I don't want to get into the boring details of QA, but a simple wikipedia search will give you an idea of everything that goes into a legitimate QA program. We are dealing both with HC and with our patient's health, so EVERYTHING needs to be done 100% the proper-way......there is no half-assing anything if you want a legitimate shot at getting approved, especially as a smaller-scale LP.

woodsmaneh! said:

Health Canada has just said no part time QA's.

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Where did you hear this? Is there a link to it? Also - in your opinion is there a difference between on-call and part-time?

Princess of Pot said:

Where did you hear this? Is there a link to it? Also - in your opinion is there a difference between on-call and part-time?

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Hey Princess of Pot,

From what I have been reading, have been told, and understand, HC was accepting there being a qualified QA part-time/on-call (these are the same thing IMO) during the application and build stages, but that a full-time QA person is required once production starts. I'm not sure if Woodsmaneh meant no part-time QA's once production starts, or no part-time QA's period and that you now must have a full-time QA person in order to apply......hopefully he will pop back in and clarify for us.

What I can tell you from years of school and work experience pertaining to QA, is that there is zero chance you will be able to produce with only a part-time or on-call QA person. For the reasons I listed a bit earlier in this thread, a QA person will be required to be onsite and involved with all growing operations regardless of the LP's size. LP's will have to play by the same rules as pharmaceutical, herbal health, and food producers, who are all required to have QAPs in place which adhere to industry standards, as well as have a qualified QA person(s) onsite during all production hours. Neither HC or patients can just take a "master grower" at their word that they did everything according to company and industry standards/regulations, a QA person needs to be there every step of the growing process to verify this, from seed/clone to the curing jar....not just a final "thumbs up". They also need to be available full-time to receive and investigate all patient complaints and to issue any necessary product recalls, both of which are major requirements of the position under the MMPR.

Princess of Pot said:

Where did you hear this? Is there a link to it? Also - in your opinion is there a difference between on-call and part-time?

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No it was a letter sent to apps who have consultants as QA from labs and the like. I think ExperChem people should be getting this letter also.I have part time QA people on some of my clients apps and HC just sent out a letter to them. Just another way HC is screwing with everyone. Time to scramble for a lot of people.