MMPR Grow op: Small Scale

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bcbud11

Member
woodsmaneh! said:
Well HC have changed their mind about burning again. I got this back last week.

As previously stated, under the MMPR, you will not be allowed to destroy marihuana by burning as this would result in people being exposed to marihuana smoke. The marihuana and/or cannabis material is considered destroyed when it is altered or denatured to such an extent that its consumption is rendered impossible or improbable. The method of destruction is up to the licensed producer. One way is to blend the marihuana with water and then mix it with cat litter to mask the odour. This can then be placed in the garbage. It is recommended that you speak with your local government regarding disposal options that may be available in your area.
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Hi woodsmaneh... did you propose an incinerator or just burning the product? To use cat litter for the volume of cannabis plant waste that needs to be destroyed at a production facility would be unreasonable.

everyone else - what is your proposed method of destruction that you used for your application? We are proposing a dual stage incinerator that is odourless.
 
B

bcbud11

Member
LOL - true.. its not waste, but according to HC it is.

We thought about CMC compost, but for our operation it would take up too much space, as leaves, trim, etc are consider a controlled substance until its "destroyed".
 
Missbell81

Missbell81

Member
Just when we thought we were seeing the light HC throws us another request. We tried to list our SPIC as our QCP and it seems he doesn't have the qualifications despite 15 years of experience growing. I am reaching out to you guys for any leads or advice with regards to this part of the app. I am in the okanagan in BC. Congrats to those who are making progress, this process has not been an easy one!!
 
R.Raider

R.Raider

Well-Known Member
Missbell81 said:
Just when we thought we were seeing the light HC throws us another request. We tried to list our SPIC as our QCP and it seems he doesn't have the qualifications despite 15 years of experience growing. I am reaching out to you guys for any leads or advice with regards to this part of the app. I am in the okanagan in BC. Congrats to those who are making progress, this process has not been an easy one!!
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I am literally dealing with that exact same issue myself Missbell81. Just found out today as well....fuck.
 
I

ispice

Well-Known Member
What did they say? What are the qualification he did not meet??? PM me if you dont want to say openly please.
 
R

rookwood613

New Member
Stark Raving said:
Rook, there are companies like Triqsoft that have already done this. You may want to check them out. There's definitely more than a couple of these systems already on the market.
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Hey Raving, thanks for the heads up. Its always good to know who the competition is and I hadn't heard of them. I will say that there product seems to be more process and compliance oriented. Looks like they do provide some temperature monitoring, and distributed access.

I'm looking to build something focused more on complete environmental monitoring and control. There are some companies with this capability, from what I've seen they're based on a older tech.
 
Missbell81

Missbell81

Member
Following a preliminary review of file ****, it has been determined that the proposed Quality Assurance person does not meet the requirements of the Marihuana for Medical Purposes Regulations (MMPR). The training, experience and technical knowledge of ***** are not sufficient to demonstrate compliance with Division 4 of the MMPR.


Please submit a more detailed description of the training, experience and technical knowledge of the proposed quality assurance person or submit an alternate proposed Quality Assurance person, and include a detailed description of the person's training, experience and technical knowledge relating to the activity conducted and the requirements of Division 4. If you are submitting an alternate Quality Assurance person, please also submit a new quality assurance pre-licensing report, signed and dated by the new Quality Assurance person.
 
woodsmaneh!

woodsmaneh!

Well-Known Member
People you should have discovered this before you sent your application in, shame on you, you look dumb now go back and read the GMP and you will find it there, read the documents they give you because that's what they will use against you. I would post the info here but you would not learn anything. Hers a bit of why your being rejected.

Interpretation
1. The individual in charge of the quality control department of a fabricator, packager/labeller, tester,
importer, and distributor; and the individual in charge of the manufacturing department of a fabricator
or packager/labeller;
1.1 holds a Canadian university degree or a degree recognized as equivalent by a Canadian
university or Canadian accreditation body in a science related to the work being carried out; Like Organic Chem!:hump:
 
Missbell81

Missbell81

Member
woodsmaneh! said:
People you should have discovered this before you sent your application in, shame on you, you look dumb now go back and read the GMP and you will find it there, read the documents they give you because that's what they will use against you. I would post the info here but you would not learn anything. Hers a bit of why your being rejected.

Interpretation
1. The individual in charge of the quality control department of a fabricator, packager/labeller, tester,
importer, and distributor; and the individual in charge of the manufacturing department of a fabricator
or packager/labeller;
1.1 holds a Canadian university degree or a degree recognized as equivalent by a Canadian
university or Canadian accreditation body in a science related to the work being carried out;
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No need to be rude.. I'm sure I can speak for everyone in saying that its easy to get lost in the endless documents revolving around the new regs. But thanks for the enlightenment.
 
I

ispice

Well-Known Member
Harsh and I do not believe correct. First there is no GMP for or mention of them in the MMPR. GPP not GMP.

"in a science related to the work being carried out" the work being carried out is the cultivation of cannabis, the analytical work does not have to be done by the QAP or the LP. The production of cannabis to ensure the purity of the dried marihuana is what the QAP does.

As HC said "please submit a more detailed description of the training, experience and technical knowledge of the proposed QAP. No where does it say degree.
 
Missbell81

Missbell81

Member
I miss the like button. Our description of his qualifications outlined his work in MMAR facilities and consulting over the last 15 years. He has studied pharmacology and the effects and benefits of marihuana on individuals and patients. How can you be any more qualified?
 
C

CannaBliss Liberty

Member
The QA side of this is not in relation to growing knowledge or how it works on the body or even how to manage a team of individuals or lab work ect. Its about GMP's and SOP's and their understanding of how to collect data from all your programs and sensors and workers and patients, and then implement LEAN/6 Sigma ect.. understand Division 4 and have protocols/procedures to constantly monitor and improve production and processing... and have it be done in a manner that is compliant with WHO, European/British Pharmacopeia, American Herbal Monogram ect acceptable limits (pest/pathogns/metals/toxins). Its not about how big or small (although costs to get started would affect your minimum size), its about how you can lay out in writing step by step all your procedures and protocols for EVERYTHING. Its about implementing strategies and methods to always be improving and preventing/dealing with issues. They want to know that you know how a manufacturing process works.. They want to see the same LEAN principles that hospitals and automotive and aerospace industries use. And its easily possible for us to learn these principles and concepts and implement them. These concepts are not related to Cannabis per say (although you will be using Cannabis data/info to alter your SOP's ext).

That IQA QA seminar in Kelowna was very helpful in putting this into perspective. Then meeting a QA expert in the aero/aut industries for the last 25 years AND who happens to breed and grow cannabis for longer then that. After getting to wait in the airport for a few hours with him.. i learned a lot about what is required. Between the seminar and him and all the material i received at the seminar... its clear what HC is wanting and although it requires either work/knowledge or $$$, it is possible for us to do it.


Please don't think that i think i "know it all", as i am learning everyday. But it does seem that what we were thinking as being "qualified" is not the problem. They may be the best growers and even be botanists and bio-chemists BUT if they don't understand recognized GMP's and have SOP's to follow.... and don't understand LEAN principals ect...and can't read a lab printout ect.. and can't provide HC with the appropriate info when requested ect ect ... then they won't be recognized by HC for QA. With that said... no university degree is needed (there are classes for QA in University and in Colleges), so if an individual had experience with the plant and knowledge on the plant and production ect AND they expressed GMP and LEAN knowledge and all SOP's were done properly... then there is a large chance that will be all you need (assuming everything else is in order).


A company called "ExperChem" has a QA guy you can "hire" and they will do it all for you and have there head guy be your QA guy along with providing other services i believe.


Here is a list of things i have seen on this forum and elsewhere... and in relation to MMPR. Been following for a while and finally have stuff to contribute.


MMPR Turnkey Greenhouses:
http://www.ggs-greenhouse.com/marijuana/Medical-Marijuana-MMJ-Cannabis-Growing-Warehouses-Greenhouses-Equipment
http://www.greenhousetechnologies.ca/index.html


Fireplans:
http://www.emtmanagement.com/index.php/plans/fire-safety-plans


QA Software and Consulting:
http://www.iqasoftwaresolutions.ca/#!software-demo/cxao
http://experchemlab.com/


Labs:
http://www.rpc.ca/english/services.html
listed again: http://experchemlab.com/
http://www.qctest.com/


Growing/Seed to Sale software:
http://www.triqsystems.com/
[FONT=arial, sans-serif]http://www.biotrackthc.com[/FONT]
http://www.quantum9.net


random pdf with a bunch of info MMPR related:
http://www.slideshare.net/shawntedder/mmpr-frequently-asked-questions


Dutch Cannabis Manual
http://www.cannabis-med.org/data/pdf/2003-02-4_0.pdf


GMP/QA info
http://www.greenbuddha.us/resources/2010-Quality-Assurance-for-Medical-Cannabis.pdf
GMP's from HC: http://www.hc-sc.gc.ca/dhp-mps/compli-conform/gmp-bpf/docs/gui-0001-eng.php
WHO: http://www.hc-sc.gc.ca/dhp-mps/compli-conform/gmp-bpf/docs/gui-0001-eng.php


EPA Guidance Doc for SOP construction:
http://www.epa.gov/QUALITY/qs-docs/g6-final.pdf










i will post more when i dig it up. Thanks
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