MMPR Grow op: Small Scale

Shawns said:

This is almost exactly what I was thinking. The new law has only made way for the large corporations like pharmaceutical and tobacco companies they will be the only ones that will be able to meet Health Canadas requirements. Juat think of the cost of the facility alone Sterile environment a testing lab a packaging area not too mention the ventilation and on and on your not going to find a building out there to meet the criteria so you'd have no choice but to build new.
I'm not trying to judge or anything maybe some of you do have millions to invest in this I would love to do this myself I could probably get the money from family I just think we all have to start thinking straight and realize this is just the first step for the government to take over the growing of Marijuana

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This really isnt any different, or more costly, than starting your own business. Maybe a few more hoops to jump through but still pretty much the same. I firmly believe, the big money players will sit back and let the little guy blaze the trail. If they were interested in doing the trail blazing, they could have got an R&D permit 6 months ago and be running by now. They have the resources to make it happen but as of now, no one is licensed. The licensed LP's will be listed on HC website.

There's no conspiracy... just regulations written ambiguously so as to leave things wide open to the discretion of the regulatory bodies that will be over-seeing this. What I haven't seen in this thread is any discussion about the Food and Drug act...there will have to be compliance to that regulatory body as well. Again, those stipulations in this act are vague and ambiguous, but are quite detailed in the Food and Drug act. Compliance with their regs is going to be another huge cost. Bottom line... HC lost control of the program because they weren't big enough to manage it. It is far easier and cheaper to just limit the growers, rather than increase the manpower of HC to watch us. That means big operations growing to meet demand... and when big Phrama gets into it they will only buy from huge operations that can met their demand, rather than picking up a few pounds here and there from small ops. Like I said, no conspiracy...just big business is moving in. That's all. We'd all be far better off to start pushing for recreational use in a system like beer and wine rather than hide behind the medical angle (no offence meant to legit patients, as I am one). Harper called that bluff with these new regs...that's all...

Can you show me the part in the food and drug act that you think is a huge expense please?

redi jedi said:

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.

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We plan to meet whatever is needed in regards to official regulatory compliance of the Food and Drug Act. In terms of a cannabis related system of QA, we plan to create a custom system that goes above and beyond the FDA requirements and is geared to maintain the high standards the quality and potency that is definitive of medical cannabis. Further consulting, especially with those operating under similar regulation in US medical states, paired with software, monitoring and testing systems, will be needed to develop a plan that is going to abide by any interpretation of the regulation.

MMPRmonkey said:

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.

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No offense, but you should get a second opinion. You can not do all of those tests with a GC, you will need a much more comprehensive lab with several (expensive) pieces of equipment. You would need a microbiology lab for the fungi, etc, an ICP-OES for heavy metals, an HPLC or GC for pesticides and cannabinoids, and an HPLC or microplate reader for the aflatoxins. On top of that, you have to follow validated methods.

We are thinking about setting up a lab, but it is an expensive proposition. Fortunately, it looks like producers will be able to send material to others for analysis so hopefully we will be able to provide these services on contract to recoup the costs.

Kron3007 said:

No offense, but you should get a second opinion. You can not do all of those tests with a GC, you will need a much more comprehensive lab with several (expensive) pieces of equipment. You would need a microbiology lab for the fungi, etc, an ICP-OES for heavy metals, an HPLC or GC for pesticides and cannabinoids, and an HPLC or microplate reader for the aflatoxins. On top of that, you have to follow validated methods.

We are thinking about setting up a lab, but it is an expensive proposition. Fortunately, it looks like producers will be able to send material to others for analysis so hopefully we will be able to provide these services on contract to recoup the costs.

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It can be expensive. Yes. So you providing a service like this could really help the small grower.

Gquebed said:

There's no conspiracy... just regulations written ambiguously so as to leave things wide open to the discretion of the regulatory bodies that will be over-seeing this. What I haven't seen in this thread is any discussion about the Food and Drug act...there will have to be compliance to that regulatory body as well. Again, those stipulations in this act are vague and ambiguous, but are quite detailed in the Food and Drug act. Compliance with their regs is going to be another huge cost. Bottom line... HC lost control of the program because they weren't big enough to manage it. It is far easier and cheaper to just limit the growers, rather than increase the manpower of HC to watch us. That means big operations growing to meet demand... and when big Phrama gets into it they will only buy from huge operations that can met their demand, rather than picking up a few pounds here and there from small ops. Like I said, no conspiracy...just big business is moving in. That's all. We'd all be far better off to start pushing for recreational use in a system like beer and wine rather than hide behind the medical angle (no offence meant to legit patients, as I am one). Harper called that bluff with these new regs...that's all...

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The regulations are vague. And indeed HC lost control of the MMAR program. Firemen policemen the public bitched. So they come out with new ones. Just beacuse they don't want you throwing up a makeshift op in your moldy basement with your cat hair and dreadlock dandruff floating around in the air doesn't mean the new sanitary and security regulations are a scheme to prevent you from doing business and all the while letting thier "big phama" cronies in the back door.

Restaurant owners complain about food regs from time to time but I'm sure theyre not bitching about how foodsafe measures are a government plot to let McDicks take over the industry. /End rant

I'd like to see more people go for it and obtain their commercial production lisences. Especially if they have their nursing credentials. (Nurse Practitioners starting a new pathway for themselves.)

If the government lays down these regulations shouldn't that then legitimize it as a business and shouldn't the banks then accept business loan applications for commercial businesses? Does anyone know or are we still speculating?

Oh, the Food and Drugs Act. (not the regulations which is too big to read or print)
I think we are exempt from the Food and Drug Regulations, but not from the "Food and Drug Act".

On another topic, I believe that becoming an LP is attainable as a small business person and that there will be a market for our medicine. With that said, I also believe that staying a small business will be a death sentence to us as other LP's can reduce there prices with larger and larger production sites. I also think that the market really doesn't merit a huge operation now giving us little guy's a real chance to get established and grow our operations with the market.

The real question is can we join our voices and cash together as "small LP's" to get some lobbyists of our own. Big pharma will. We need to act in time, before the market is large enough for Big Pharma (3-5 years is my guess not factoring in possible legalization). There are ways for smaller producers to have large voices like the way small farmers all got together on our prairies (Canadian Federation of Agriculture founded 1935). They were even able to get reduced crop insurance costs which more than paid for their contributions to the original cause.

All of us small guys really need to unite, it will not only help us in this hoop jumping now but later on when we are in business. We should "as a group" be able to out produce all others and set the price, all the while using our voice like Big Pharma would to help our cottage industry. We should own our own shared roving lab(s), sharing as many resources as possible to help us keep the "minimum size for success" as minimum as possible without letting our competition out price us. It would be possible for us all to share the same website even giving us the selection that would be unbeatable. How do you get more than 3 people to agree on anything? Business Profits and Stability. Is that a co-op? LOL

@romulanlover I agree with you. I think its this simple. And Im sick of growing in a basement too. I look forward to getting out of here. Its been years and years of addons. Fresh start, new setup with my current knowledge excites me. Well said romulanlover.

@Kootenaygirl, Well said. Seriously Im in agreement with everything you said. Im all in. You can count on me to be in. Lets not lose our momentum. Having shared resources that we can use instead of it being added into our sites is going to save us lots of money. And like you brilliantly stated, we have the power if we are united as small growers. And we keep the cottage industry. And we keep the uniqueness that comes from that. Its brilliant.

buckets said:

I'd like to see more people go for it and obtain their commercial production lisences. Especially if they have their nursing credentials. (Nurse Practitioners starting a new pathway for themselves.)

If the government lays down these regulations shouldn't that then legitimize it as a business and shouldn't the banks then accept business loan applications for commercial businesses? Does anyone know or are we still speculating?

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Can't remember where I read it, but I believe there will be a limit to the number of the licenses that will be issued. If I recall, that number is 60. That alone is the biggest clue to how large the operations will have to be. Then again, I may be wrong or the number may have changed

maximum said:

Can you show me the part in the food and drug act that you think is a huge expense please?

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Ahhh... no. It's a huge document that I don't have the time or the will to even peek at. What I do know from what our company has to go through to comply is unbelievable and every expensive, aside from the salaries. What I will do is point to the passage in the MMAR Act (quoted below)... that is so troubling. It alone implies a major cost, since the person will have to be working on site and I suspect that the person will be required to possesses suitable qualifications, which means a degree in something. Or maybe they can just get away with having a thorough knowledge of the F&D Act requirements, I don't know. But either way a salary for a person like that will likely be in the 'hood of $70K per year, then add 30% more for benefits and WCB costs. "22. (1) A licensed producer must designate

• (a) one senior person in charge to have overall responsibility for management of the activities carried out by the licensed producer under their licence at their site — who may, if appropriate, be the licensed producer; and
• (b) one responsible person in charge to work at the licensed producer’s site and have responsibility for supervising the activities with respect to cannabis conducted at that site by the licensed producer under their licence and for ensuring that the activities comply with the Act and its regulations and the Food and Drugs Act — who may, if appropriate, be the senior person in charge.

Also.... there are other such passages that are just as vague, which also imply the requirement for educated, on-site employees, which are a huge expense. Read the act again carefully. These nuggets are everywhere. The vagueness will be, as I said, right where the regulatory body will have complete discretion... to define what is required and what is not in an arbitrary and maybe even individual case basis. I would go so far as to say, even, that the LIMITED number of licenses that are available have already been decided...and likely were long before this ACT was even written.

buckets said:

I'd like to see more people go for it and obtain their commercial production lisences. Especially if they have their nursing credentials. (Nurse Practitioners starting a new pathway for themselves.)

If the government lays down these regulations shouldn't that then legitimize it as a business and shouldn't the banks then accept business loan applications for commercial businesses? Does anyone know or are we still speculating?

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................................ Absolutely yes. But for that you will need to put a business plan together, which is not an easy thing. You will have to do a lot of market research and hire an accountant/statistician to actuate probabilities for insurance considerations and such. To put a good business plan here that a bank would take seriously will likely cost you well over $10K.

Now that I think of it...the biggest hurdle in this for the small guy will likely be insurance. That will certainly be required. IF you can find somebody to insure such a business it will be huge expense too. Probably too much for a little guy. Meanwhile, the big corps won't even need it. They will able to just post a bond for a few million dollars...

We are trying to keep this thread factual. All of your replies are "probably" and suspicion and opinion. Your spreading very wrong and bad information.

1) There is no 60 license limit. The coalition for repeal misquoted the mmpr on their website. They removed it after realizing there is no limit on the amount of licenses issued.

2) " I suspect that the person will be required to possesses suitable qualifications, which means a degree in something" Yes you suspect lots of things. But you offer no proof of anything. No references. Neither the senior person in charged or the responsible person is required to have a degree in anything. Nothing like this is stated anywhere. If you find it please post. I plan on working as the Senior person in charge. And I have a responsible person as well. Both of us will take a minimal cut. Or no cut at certain times. We are building a business here. We are willing to sacrifice. If you chose to hire staff and pay them $70k then thats what your doing. This isnt a fact written in stone like you try to make it sound. The only part where I saw a diploma or anything thats proving education is for the QA person. But even then, the FAQ for the QA person states that nothing is checked or verified. I have questions about the education of the QA person. So I need more info there.

3) No you dont have to hire statisticians and market research firms. You need a business plan. I have experience putting a business together. It never cost me $10k to put a business plan together. Also, if you decide to hire an accountant in my opinion you could wait until your business is up and going and then when the tax deadline is coming up have someone hired. By then you have an income. An accountant wont be part of the initial burn.

If you are trying to be helpful in this thread why dont you call some insurance companies and get some quotes and real numbers. Ill eventually be at the point where I am getting insurance. I will be posting quotes and numbers and who I spoke with. Im doing this because it helps other people. Your not helping. I get what your saying. (The mmpr is for big business. Everything is out of reach for a small producer. ) But you can`t post any proof or references. If you want to help, you need to post facts, links and info. You dont come across like your well intentioned. Or well informed.

Many people in this thread are well informed, motivated, and willing to reach out. We haven`t hit any major hurtles yet. And if you read the 18 pages, man we learned a lot and put a lot of bad rumors to rest.

Maximun:................" We are trying to keep this thread factual. All of your replies are "probably" and suspicion and opinion. Your spreading very wrong and bad information ."
I don't see how that is possible, when there are no facts. There is just the MMPR doc that the gov released, which, as I have said many times, is vague and ambiguous. So what I have offered is my opinion, which is what forums are for.

2) " I suspect that the person will be required to possesses suitable qualifications, which means a degree in something" Yes you suspect lots of things. But you offer no proof of anything." No I don't. As this is a new act for what will be a new industry there are no references. Just the MMPR doc, which has been left open to interpretation. So I offer my opinions, as I have some expertise in federal regulatory matters, particularly where they pertain to Tort law and corporate operations. If anyone is serious enough they can seek other advice to corroborate or dispute my views.

Meanwhile, I don't see anybody else offering any facts or proof of anything here either.

" I plan on working as the Senior person in charge. And I have a responsible person as well. Both of us will take a minimal cut. Or no cut at certain times. We are building a business here. We are willing to sacrifice."
Do the simple math then. Decide what you two require for living expenses only and then add the insurance premium, because that part is a FACT. And that fact will be EXPENSIVE, which is also a FACT, simply because in a new industry there are no references to go by so any potential insurer will charge like hell to figure out what a PROFITABLE premium will be. Once you have that, then you know what you will need to grow to cover expenses (equipment and regulations) and your take. You will soon find that even on a shoestring budget with all costs minimized you are looking at $250K for crop #1. Yes that's just my opinion, but the math is not hard to duplicate on your own.

"If you chose to hire staff and pay them $70k then thats what your doing. This isnt a fact written in stone like you try to make it sound."
Here you contradict yourself. You whine about me using terms like probably and likely and then say the above?

"No you dont have to hire statisticians and market research firms. You need a business plan."
100% correct. I never said anything about market research firms. I suggested might want to pay to get a pro to do a business plan that's all. I recommend hiring a statistician for the business plan because most of the data you will require does not exist and will have to be actuated, which requires certified qualification, in a very rare and expensive field. Check it out. If the bank sees that you have gone that far you are more likely to get the money you need. But for a bank to risk money in a BRAND NEW INDUSTRY you will have to do a LOT of CERTIFIED RESEARCH. That is FACT...and you should know this if you truly have business experience.

"If you are trying to be helpful in this thread why dont you call some insurance companies and get some quotes and real numbers."
Phhh... why don't you? You're the one that seems to be going for it here...so you will eventually need to. But you will find that you won't get quotes for this business, because as this is a new industry there is no reference material to base premiums quotes on. That will have to be developed. So the insurance company will take their staff actuaries and crunch some numbers and those dollar figures will blow you away. A new industry that has the direct attention of organized crime, subjective regulations and laws to be written. If you know anything about business then you know you will get raped hard on your premiums.
" I get what your saying. (The mmpr is for big business. Everything is out of reach for a small producer. ) But you can`t post any proof or references."
References to what? The industry hasn't been created yet. I am helping by pointing out the many obstacles and hidden expenses that most people haven't thought about it any business, never mind the unique ones to this business. It seems to me that you're just sour that your dream may be harder to attain that you thought.
You want a FACT? Here it is... $250K will not be enough to get you through your first crop profitably. Simple math will prove that when insurance is figured in. Now I ask you to follow your own demands and provide facts or proof that contradict mine.

maximum said:

We are trying to keep this thread factual. All of your replies are "probably" and suspicion and opinion. Your spreading very wrong and bad information.


Many people in this thread are well informed, motivated, and willing to reach out. We haven`t hit any major hurtles yet. And if you read the 18 pages, man we learned a lot and put a lot of bad rumors to rest.

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Okay.... ignore me entirely, except for one thing: take a copy of the MMPR doc to a business lawyer and spend a few bucks to get an expert opinion on legal requirements, liability and such, in relation to the doc as it is written. If you are serious about this that should be your first move.

2) What do you mean this is a new industry there are no references. When you say things like 60 companies a year will get a license, where did you find that information. You can post a link. Thats what Im talking about. Not your opinion on how the mmpr will unfold.


3) “Meanwhile, I don't see anybody else offering any facts or proof of anything here either. “ If you read the thread people have posted helpful links to things like what a qualified person is. Emails with health canada about what qualifications are required for the qa person. We got quotes on security costs on a greenhouse that meets health canada specifications. Much lower than what you quoted. And you quoted without any reference just a personal opinion passed off as a fact. We discussed cost of security equipment and posted some specific links regarding doing the video monitoring really cheap. There is a member that is putting together a facility which would be a multi-unit facility, with security and onsite lab, that will lease to other growers. Thats in early stages and still pending legal opinion. But my point is that we are navigating through the system and finding ways to cut costs along the way. We had questions answered from health canada regarding pre-inspection setup, where a fear was building everything only not to be approved. But we discovered they will assist you before you even get to the building stage. We are just getting started here. You know they just released those mmpr final regulations so, discussion really is just getting going.

4) The cost of paying me and the other person. Common man. Look, Im already a grower. So is the other party. We already are taking a cut. We are just changing locations to a newer legal facility and complying with the new needed requirements as cheaply as possible. Which will mean we take less of a cut at first.

5) Remember Im trying to do this on a small budget. Involving a bank is one of my bottom options. Certainly not planning on using one for any type of loan related to business. Perhaps a mortgage. As far as statisticians, I guess its a useful suggestion and will help your business. But you make it sound like this is a mandatory expense and it costs tons therefore the cost of starting into the mmpr are very high. You dont make it sound like your giving just a suggestion. Maybe Im reading you wrong man.

6) I will be calling insurance companies. And I said that. But you brought up insurance and if you want to say its expensive and costs soo much that nobody can get into the business with less than $250k mainly due to insurance then you should post the cost of insurance. Especially if you say , simple math will prove it. I agree. So post what the insurance company told you not what you think they will say. Because lots of the things you think, so far, have been very off base. Flat out wrong, or over estimated. Like you did with the security. You where between 2.5-50 times higher than what the real cost was. Thats why I say post your numbers with some kind of reference. I know you trust your estimates, but at the end of the day you give general numbers like security alone is minimum $25k. Well you cant say that. Security for what size setup is $25k, and is it a greenhouse or not a greenhouse. When I emailed a security company, I told them a 2,000 square foot greenhouse and I gave them the security requirements. They replied to me with an estimate for that size greenhouse with the Health canada security requirements could cost between $500-$10k if you wanted a vault in there. Now those are real numbers we can work with. We can squeeze and trim them.

Gquebed said:

Okay.... ignore me entirely, except for one thing: take a copy of the MMPR doc to a business lawyer and spend a few bucks to get an expert opinion on legal requirements, liability and such, in relation to the doc as it is written. If you are serious about this that should be your first move.

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Because I want to sit down with the lawyer after already having informed questions. Not wasting time asking things that we already can figure out by reading and discussing. You know I cant show up and say, hey there how can I be one of those sixty companies to get in the door and how can I be one of harpers buddies so I can get it.

Gquebed said:

Okay.... ignore me entirely, except for one thing: take a copy of the MMPR doc to a business lawyer and spend a few bucks to get an expert opinion on legal requirements, liability and such, in relation to the doc as it is written. If you are serious about this that should be your first move.

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What type of insurance are you referring to? Crop insurance?