MMPR Grow op: Small Scale

We had our file pulled from RCMP and it was processed within 3 days in August. We received a note about clearance being done about a month and a half ago. So from the time RCMP sends their report to HC and the time it's processed can be months and months (in the mean time we had some adjustments and clarifications that HC wanted to our file.) As for buildout, we're 2 or so weeks from completion anyhow since our building was pretty much ready to go from the get go. However there was a small issue with our file (not to do with security) that I had to clear up about 3 weeks ago, that was done and the wait began again. Please note we're a corporate applicant, so I don't know how this relates to non corporate applicants.

It took Tweed 8 months (minimum) to get approved. I really don't think anyone is playing favourites, but many producers are being backed by investors with deep pockets. If you aren't, and you want to be, please connect with me.

From what I understand, you don't "fail" if one of your officers can't pass clearance, but I expect you would have to replace them if you wanted to keep going with the process. Fail only happens if you refuse to make required changes to your application and operations.

From the conversations I've had with LP's and from the landscape I'm seeing there is room for Tweed type operations who will cater to a certain market, guys in between like PNP (although they are closer to Tweed then the other way) and smaller niche market players like some guys from the west coast. Its natural market segmentation and each member has a place within that. So depending on what you're going for you may need deep pockets, however for more niche market producers that is not really necessary. Although I have to admit that it never hurts to have more money than needed.

Agracan said:

We had our file pulled from RCMP and it was processed within 3 days in August. We received a note about clearance being done about a month and a half ago. So from the time RCMP sends their report to HC and the time it's processed can be months and months (in the mean time we had some adjustments and clarifications that HC wanted to our file.) As for buildout, we're 2 or so weeks from completion anyhow since our building was pretty much ready to go from the get go. However there was a small issue with our file (not to do with security) that I had to clear up about 3 weeks ago, that was done and the wait began again. Please note we're a corporate applicant, so I don't know how this relates to non corporate applicants.

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I'm sorry but I don't fully understand ! This is the list of 5 phases that I've been going by ;

1. Screening: the application is verified to make sure all relevant information has been provided, and required documents attached. If information is missing, the application may be returned to you.
2. Reviewing: the application will be reviewed to validate the information and documents provided. Security clearance forms will be sent for processing. Physical security plans will be reviewed and assessed.
3. Ready to build: Once the application is deemed satisfactory, Health Canada will issue a notice informing the applicant that, if built to the specifications on the proposed plan, the security measures would meet the requirements of the MMPR. Applicants must then build the security measures if this is not already done.
4. Pre-licence inspection: Upon confirmation from the applicant that the security measures are in place, a pre-licence application will be scheduled. Upon completion of the inspection, the applicant must address any deficiencies identified.
5. Issuance: Once the inspection is deemed satisfactory, the licence will be issued.

So has your company received this "ready to build notice" as stated in phase 3 and are now waiting a pre licensing inspection? or did you guys just decide to go ahead and start the buildout once you guys had been informed of being security cleared?

We like to share!!!

No we have not received what you refer to as a the phase 3 directive. But as I mentioned our premises are ready to go. The only thing holding us up was a regulatory technicality, which we've now met. So a build directive in our case is a 2 week project

You can build without their explicit ok, but you're doing it at your own risk. If you feel your building and plans will meet or do meet the security directives then there is nothing preventing you to go ahead prior to a nod. Again it's a risk that a lot of people have taken in the hopes that this will cut down on the down time between application approval and final inspection.

Mmpr613 said:

Hey thanks for sharing.

Just to be clear are you saying that you were informed that you had passed security clearances months ago and still have yet to receive a buildout letter?

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No, they sent an email saying we had begun the security clearance procedure in October, then in December they said the same thing. The most recent letter said we were done the review and they had just sent in our forms for security clearance and were awaiting word from the RCMP and that it could take a few months from now to hear back. We sent an email back asking which one of the emails saying our security clearance had begun was true. The response was it was sent in 2 months ago. We aren't really sure what to think to be honest.

rnr said:

its a deterent for the small guys, they have to jump hoops, they quit. the security checks are not done by computer! if they are running a basic criminal check ya sure, but the L,P checks are done threw the U,N if you have any issues, the second L.P application has ties to crime syndicates so they are dead locked. no you can not just delete said bad person from the application. you will be denied. you can repeal but you cannot reaply for 5 yrs

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where did you get the information about not being able to remove someone from the app. if they fail security clearance and that you wouldn't be able to reapply for 5 yrs?

Mmpr613 said:

where did you get the information about not being able to remove someone from the app. if they fail security clearance and that you wouldn't be able to reapply for 5 yrs?

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mmpr regs #98
so if minister denies or cancels your app, you cannot just remove them and add another employee, it says make sure your staff will pass security check some were in the mmpr.
imo why would you have a employee that is a criminal anyway????

Marginal note:
New applications
98. If the Minister refuses to grant or cancels a security clearance, an applicant may submit a new application only if

• (a) a period of five years has elapsed after the day on which the refusal or cancellation occurs; or
• (b) a change has occurred in the circumstances that led to the refusal or cancellation.

Agracan said:

No we have not received what you refer to as a the phase 3 directive. But as I mentioned our premises are ready to go. The only thing holding us up was a regulatory technicality, which we've now met. So a build directive in our case is a 2 week project

You can build without their explicit ok, but you're doing it at your own risk. If you feel your building and plans will meet or do meet the security directives then there is nothing preventing you to go ahead prior to a nod. Again it's a risk that a lot of people have taken in the hopes that this will cut down on the down time between application approval and final inspection.

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Thanks for clarifying I get it now.

We too feel that our app. is strong and well put together, we own the building, we have zoning approval and we've met or are ready to meet all of HC's requirements and I get your point about going forward with everything so you're ready to rock ASAP because this essentially is a big race to make HC's LP list but we're still very reluctant to keep spending until we have received some form of confirmation.

Good luck with everything and please keep us updated on your situation.

we like to share!!!

rnr said:

mmpr regs #98
so if minister denies or cancels your app, you cannot just remove them and add another employee, it says make sure your staff will pass security check some were in the mmpr.
imo why would you have a employee that is a criminal anyway????

Marginal note:
New applications
98. If the Minister refuses to grant or cancels a security clearance, an applicant may submit a new application only if

• (a) a period of five years has elapsed after the day on which the refusal or cancellation occurs; or
• (b) a change has occurred in the circumstances that led to the refusal or cancellation.

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I'm not sure but I think they are referring to a security clearance application and not the application to become an LP. Check again tell me what u think.

Mmpr613 said:

Thanks for clarifying I get it now.

We too feel that our app. is strong and well put together, we own the building, we have zoning approval and we've met or are ready to meet all of HC's requirements and I get your point about going forward with everything so you're ready to rock ASAP because this essentially is a big race to make HC's LP list but we're still very reluctant to keep spending until we have received some form of confirmation.

Good luck with everything and please keep us updated on your situation.

we like to share!!!

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Yes, I'll defiantly let you know what's up down the road and I look forward to creating a sustainable, transparent and accountable industry with you.

rnr said:

and your marveled how fast tweed got threw??? $$$$ talks and bs walks! hes a liberal insider, he has friends,$$$, lobbists, people to deal with, theres ways the ritch get shit done, don't be so blind to $ & power. the small guys are struggling or delayed cause its how the system works lol

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Exactly

I currently have two LP's waiting for inspections that were scheduled by HC and than cancelled without any reason. I also have 5 that are in different stages of review. I will be speaking to the head of the MMPR program next week to find out what is going on with the delays. My personal thought is that HC is waiting for an risk assessment on the impact of the Manson injunction on the MMPR before they start inspections again.

QA is becoming a black hole as HC learns from the submissions and see's some of the same names on applications. One of the big Exper QA companies has been told that they can't be everyone's QA and to stop it. They are just taking money and not doing a great job from what I have seen. My clients have been left in a jam by this company and that's why they came to me.

I just had another of my QA's associates approved by HC this week, the only issues we are dealing with is when they will be on site and for how long. YOU DO NOT NEED A QAP FULL TIME as of this writing.

People can reach me at pipedreemz at hushmail dot com, my team and I can help.

This is one of many HC letters I have addressed for my clients successfully and I have a pile of them, lol


Hello,

Thank you for your additional information regarding your quality assurance person, received April 2 2014 in regards to your application # 10-MM0003.

The quality assurance person that is designated under section 10 of the application can not delegate any responsibilities under Division 4 to another individual. This person is responsible to ensure quality at all steps and must ensure that dried marihuana is produced, packaged, labelled and stored in accordance with the SOPs developed, using the proper equipment and within the sanitation program established and all items under Division 4.

Currently the proposed schedule for QAP is unclear. Given that Mr. QAP is a Consultant, and that the production of marihuana usually extends over a long period of time from sowing of the seeds to drying the product and that production, packaging and labelling may be conducted on daily basis, your proposal still lacks in demonstrating how it will maintain the quality of all dried marihuana before it is made available for sale as per the requirements of Division 4 of the MMPR. Please submit a more detailed description of the work schedule of your quality assurance person to ensure that all steps detailed above will be sufficiently overseen by this person.

As per section 58 of the MMPR, dried marihuana must be produced, packaged, labelled and stored in accordance with standard operating procedures that are designed to ensure that those activities are conducted in accordance with the requirements of this Division. As per section 60, the quality of the product is the responsibility of the Quality Assurance person. Please confirm whether the quality assurance person is full-time or part-time and please provide additional information to demonstrate how they will be able to ensure the quality of the product at all steps.

The information requested must be submitted by April 24 2014.

If you have any additional questions, please do not hesitate to send us your questions by email at MMPR-RMFM@hc-sc.gc.ca.

Licences and Permits Division
Office of Controlled Substances
Health Canada

What does it take to get this done, plain and simple MONEY! How much money does it take, well lets look at a small operation with 4,000 sq feet.
Equipment will cost around 60 to 100,000$ for growing.
Electrical fit up min. $60,000 and up and you need an ESA certificate
Security system for 5 rooms that will have cannabis in them, veg, flower, trimming, drying and vault = $90,000+
Vault door $3,000 +
Vault 10 to $15,000
Construction costs ???? $50,000+ to meet GMP standars

so we are over $250,000 and we don't have a building in there yet ++

Plus you will sit on your investment for months before any hope of a return and you will also need operation costs = &50,000+

I'm not trying to scare anyone just let you know what your in for besides months of waiting and waiting.

The current government does not support the Medical Cannabis program and will only do the bare minimum to get this done, everything the Feds are doing has been mandated by the courts because the current government is playing silly bugger, because they can. The more confusion in the market the better for the feds. Here is a site that has some interesting information on the Canadian MMPR process.

http://www.linkedin.com/groups/Canadian-Medical-Marihuana-Licensed-Producers-7447792?trk=my_groups-b-grp-v

well after reading that, medijean in a university lab guy. changing it to suit there knowledge instead of working with the L.P. imo if you have grown for 15+ yrs, then we can do the Q.A for the whole site, better than some lab guy. they have text book knowledge.
if trained by a text book guy we could do the job better, imo
but HC has made the rules basic, sounding, but in reality the Qa person is responsible for the entire site, start to finish for everything, not the L.P. My QA is part time and has shown how he will do the work weekly and be around 24-7

sib said:

It took Tweed 8 months (minimum) to get approved. I really don't think anyone is playing favourites, but many producers are being backed by investors with deep pockets.

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How do you mean it took Tweed 8 months? The earliest they could have submitted an application was June 19, 2013 and they were licensed in December, 2013, just six months!

MarijeJane said:

How do you mean it took Tweed 8 months? The earliest they could have submitted an application was June 19, 2013 and they were licensed in December, 2013, just six months!

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Just shows you how a team of the best can get a licence done if they do it right the first time. 20 million can do that for you.

Lots of reasons for delays but the big one is LP's not sending in all the information correctly. HC is not fucking around with this, you better have every name in box letters and start and end dates, there are so many small things that slow you down. I reviewed one app and it had 19 mistakes in 15 pages, WTF! that just says your careless and don't pay attention to detail!

They don't send your security docs off till your app is complete and moves on to the content review.

If they ask you questions don't take the 2 weeks they give you to answer Get-R-Done and back to them, it's your time your burning. Buy the way you can ask for extra time if you need it.

Just shows you how having connections in the right places can get a licence approved.

if all you think that there are people who would pay other people to OK them for a price.

You'd be correct!

Well here is what I really think...
It's a no brainer you need a good clean application, goes without saying.
You need the right team and resources. QAP is a key component.
You need your municipality to be on your side, not just a notification.
A good lawyer is highly recommended.
Connections with the government trumps everything.
Most of what is required is not offered by a consultant.