Missbell81, have you checked out www.rpc.ca located in Fredericton, NB. They are fully committed to helping LPs with all QC and training needs.
MMPR Grow op: Small Scale
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westcoast420
Well-Known Member
You don't need any training, there are no specific requirements. HC has even said they don't even verify the credentials of the QA person.
Just because they don't specify any requirements dosn't mean there are not any. In fact, by not specifying requirements they have made it easier to reject applications based on this aspect and made it harder to appeal their decision due to the subjectivity.
Rather than laying out specific requirements they have left it to the QA person to justify their credentials. I'm sure you could make things up here, but I dont think I would make that gamble personally.
By allowing a QAP to justify not their credentials, but their abilities to conduct all requirements of their position as outlined in the regulations the system will be fair and accessible to anyone competent. An LP's SOP's and Sanitation Program would be quite indicative of a QAP's knowledge and understanding. While yes there is room for subjectivity I think leaffans post in the other thread about QAP contradictions is relevant. Until there is more proof that HC is trying to stifle applicants I lean towards them just trying to cover their asses.
I didn't mean to imply that they are trying to stifle applications, just that the QAP requirements is an area that will allow them to easily reject applicants that are not up to their standards. It is pretty easy for them to reject you by saying that your QA report and/or QAP's background are insufficient. As for credentials, I suspect that HC will want evidence that you are qualified to oversee the SOPs, sanitation program, and interpret the lab results. Anyone can hire a third party to write a QA report; why dont you think they would want evidence that you are qualifies to carry it out (ie. credentials)?
The moral of what I was trying to say is not to take this section too lightly by assuming that sicne do not provide a list of requirements they do not have certain expectations.
Those specific credentials or training simply do not exist, this is a unique instance of an unregulated and not standardized product being opened to the market in a unique manner. No group, institution or body has the authority or validity to offer credentials in the respect to cannabis production.
In my experience HC will not reject something as insufficient without means of explanation or remedy.
leaffan
Well-Known Member
I think what HC is concerned about is the liability factor in approving non phds or bscs or whatever accredited "professional".
It's just an opinion...
Lets look at a hypothetical scenario;
LP ABC is running a sloppy ship. Some of their employees haven't been screened very well. One employee has a vendetta against the MMPR. He or she decides to poison some of their product. The tainted product goes out and people get sick. Now I know this could happen to any company, this is a stretch...
So now the lawsuits are launched. If LP ABC has their own HC approved QAP who happens to be just an accomplished grower, versus a "professional", then I can see potential problems for HC from a liability situation. I'm not a lawyer, so I could be way off base here. By approving only "professionals", HC has covered their asses in this area. I know there are no QAP "professionals", but I hope you get the jest of what Im saying.
It's just an opinion...
Lets look at a hypothetical scenario;
LP ABC is running a sloppy ship. Some of their employees haven't been screened very well. One employee has a vendetta against the MMPR. He or she decides to poison some of their product. The tainted product goes out and people get sick. Now I know this could happen to any company, this is a stretch...
So now the lawsuits are launched. If LP ABC has their own HC approved QAP who happens to be just an accomplished grower, versus a "professional", then I can see potential problems for HC from a liability situation. I'm not a lawyer, so I could be way off base here. By approving only "professionals", HC has covered their asses in this area. I know there are no QAP "professionals", but I hope you get the jest of what Im saying.
HC requirements for sterile drug production for their equivalent positions only require the personnel to have taken microbiology class or equivalent, no PHD or Bs.
That is for sterile drug production.
They might have a difficult time making it the same or more stringent for Cannabis Production.
Besides HC has stated to many people that there are no specific requirements!
That is for sterile drug production.
They might have a difficult time making it the same or more stringent for Cannabis Production.
Besides HC has stated to many people that there are no specific requirements!
Kootenaygirl
Active Member
I don't know, it seems to me that rules and regs get adjusted/ updated as an industry grows and as problems come up, I can't think of any lawsuits against HC or other governing bodies for other industries, the individual business pays the suits from the end users.
The regs will get adjusted on a case by case basis for awhile until things get resolved and then probably yearly after that, IMO. If I read that no training, experience, or education was required then your point would be stronger, but their ass is covered, and I bet they will never clear this up with actual requirements, they like their power.
The government isn't paying for asbestos or lead, which are/were clearly regulatory issues gone wrong.
Still think that owners need to be the QAP in a small LP due to cost factors alone, never mind logistics, and reality. How often is an outside QAP going to visit your 5000sqft facility, and how will they stop the "poisoning from an employee"? Is your outside QAP insured or liable? Who has chips in play to lose?
It is ridiculous to think at the end of the day, that you, the small grower is not the QAP, you are, weather it is official or not. Just my 1 peso worth opinion.
Nothing common about marihuana growers.
The regs will get adjusted on a case by case basis for awhile until things get resolved and then probably yearly after that, IMO. If I read that no training, experience, or education was required then your point would be stronger, but their ass is covered, and I bet they will never clear this up with actual requirements, they like their power.
The government isn't paying for asbestos or lead, which are/were clearly regulatory issues gone wrong.
Still think that owners need to be the QAP in a small LP due to cost factors alone, never mind logistics, and reality. How often is an outside QAP going to visit your 5000sqft facility, and how will they stop the "poisoning from an employee"? Is your outside QAP insured or liable? Who has chips in play to lose?
It is ridiculous to think at the end of the day, that you, the small grower is not the QAP, you are, weather it is official or not. Just my 1 peso worth opinion.
Nothing common about marihuana growers.
leaffan
Well-Known Member
I'm just trying to relay some of HC's concerns that I am aware of, not specifically QAP.
I couldn't agree more with you. Regs will keep getting adjusted. I don't think an outside QAP will ever be acceptable. No question I agree that the owner should be allowed to be the QAP for a small operation. I really hope HC shares this desire.
This" owner as QAP "is another good example of where a type of co-op could be beneficial.
I couldn't agree more with you. Regs will keep getting adjusted. I don't think an outside QAP will ever be acceptable. No question I agree that the owner should be allowed to be the QAP for a small operation. I really hope HC shares this desire.
This" owner as QAP "is another good example of where a type of co-op could be beneficial.
Most of the QA requirements are lifted almost verbatim from the NHP regulations, a well established industry. Almost all NHPs recently went through the same process of transitioning from an unregulated, non-standardized product just as Cannabis is now. The only major difference between Cannabis and other NHPs is security. As such, there are many people with highly related backgrounds and credentials to back them up as well as precedent for QAP requirements. To assume that marihuana is somehow different, especially from a QA perspective, is flawed IMO.
When HC has hundreds of applications, many of which have very qualified QAP, why would they not set the bar high? Only time will tell, but I believe that QA will be a major reason some people are rejected.
That section says they do not need to have a degree in microbiology, but must have taken university level courses in microbiology. This would allow pharmacists and people with other related degrees to supervise, but does not imply that you dont need any training.
NHP is a good reference, but not the MMPR. Some area's overlap and are very relevant others, the vitally important ones, such as anything to do with indoor cultivation, as well as the storing and processing of cannabis are not. Even so QAPs for NHP's do not required any specific training or education, its worded just like the MMPR, vague. Most training and education for such things would be to do with GMP training, certs and such, not university level classes.
The regs are very clear that the QAP has training, experience and technical knowledge relating to the activities conducted and required under the GPP section of the MMPR.
Time will tell, I completely understand your argument or line of thinking, I just dont think it will be an issue for anyone who is actually competent and trying to become and QAP, HC has stated no PHD or specific education or training is required, ill take their word for it.
3 years of cannabis cultivation should be required for all QAP's.
The regs are very clear that the QAP has training, experience and technical knowledge relating to the activities conducted and required under the GPP section of the MMPR.
Time will tell, I completely understand your argument or line of thinking, I just dont think it will be an issue for anyone who is actually competent and trying to become and QAP, HC has stated no PHD or specific education or training is required, ill take their word for it.
3 years of cannabis cultivation should be required for all QAP's.
I dont think they will require a PhD or advanced degree, but just growing under the MMAR alone would not be sufficient IMO. There was no oversight in the MMAR and I am aware of larger growers under that system that used pesticides and had pretty serious mold issues. This is one of the main advantages of the new system, patients will have some level of quality assurance. Growing a plant does not really ensure that you have the background to assess mold counts, run a proper sanitation program, etc., especially for scaling up to commercial production levels.
As long as you have a head on your shoulders and can justify why you are qualified I think you would be ok. I just dont think this section should be taken casually.
Agreed 100%!
Grow it Organic
Well-Known Member
So is the general consensus to be outsourcing all the QA work or to train your own staff (responsible person in charge or senior)?
I read about www.rpc.ca, http://www.iqasoftwaresolutions.ca, can't really decide who I'd choose. If anyone has any other recommendations, please...let me know!
I read about www.rpc.ca, http://www.iqasoftwaresolutions.ca, can't really decide who I'd choose. If anyone has any other recommendations, please...let me know!
Kootenaygirl
Active Member
Appoint yourself QAP, make your own QA Pre License Report (easy), then wait and see what happens, your app is not in yet obviously so your in for a good long wait. When we learn more facts we will share, if you need greenline you'll have time, save your money. Troy isn't going anywhere. Spend what you have to, but only when it is necessary. We have been more than 3 moths in the review phase, plenty of time to take a course or hire a company. Others have had their QA questioned by HC, we have not, our QAPLR is basic.
just caught up on this wannabe LP circle jerk of a thread, and this was the truest post.
90 days and counting, your palms must be starting to sweat..
meanwhile those "consultants" are probably spending your 20k cheques on some MMAR kush from the weedman up the st. LOL
the blackmarket will prevail people, it's overgrown