MMPR Grow op: Small Scale

maximum

maximum

Active Member
oakley1984 said:
this is just becoming more and more hilarious, everything i said was dead on accurate.

Yet again I proposition the question, What happens when you sink all this money into being a licensed producer, And NOBODY buys from you.
The entire system is setup to fail from the patients perspective. And I laugh at the previous comment saying, just the same as always, diverted to black market
As I had said before there will be 24/7 visual monitoring in All areas! So Alas... you're going to create bills for yourself that you will be unable to pay. If you attempt selling to the black market, Harpers got a jail Just for you!
This massive money sink will be dissolved by the next regime in power Anyways. Im officially retiring from the inet and going back to being illegal...
Sadly... Its safer!

Gluck to you all and sending yourselves into bankruptcy... Really should have a contingency plan if you all decide to go forward with this, cause it is pretty much an assurance that you're Fucked.
Click to expand...
A part of me thinks these thoughts at night when I try to sleep. But Im going to try and go the legal route using all possible options I have. If we can get through the short term burn, collaborate and minimize the immediate set backs, then I think long term it looks good. Its worth the fight. I rather not get jailed, and have a criminal record which might exclude me from future markets that are easier to participate in.

And it is a real fear of mine. Can I sell enough from day 1 to keep up with my costs? At this moment, I could make a big list of things I have to fight through. The whole things a fight man. I wish you the best legal or not.
 
BigBhuda

BigBhuda

Well-Known Member
redi jedi said:
Thats just it. There are many industries that use quality assurance and the training and education needed to perform QA would vary with whats being inspected. For example some QA techs might need to have an engineering degree (chemical, electrical or mechanical) and some might only need employer provided training.

I really don't think there's anyone, as of now, that is qualified to do what Health Canada requires.

If there's anyone out there that thinks they might be qualified to perform the task, please speak up.
Click to expand...
Appears to be nothing but vague answers from them. Looks like we won't know until the inspections start and we can share our experiences. I also asked about QA qualifications and got this reply. Looks like we should all start trying to be our own QA and justify why we are qualified. Only way to find out what they accept and don't.

"Thank your for your email concerning the new Marihuana for Medical Purposes Regulations (MMPR).

In response to your questions below, Health Canada is responsible for carrying out inspections under the MMPR, and will be done by existing personnel. At this time, there are no job posting for inspectors.

There are no existing guidelines for wait times for inspections. Pre-licence inspections are scheduled with applicants in advance, and once a licence has been issued, follow-up inspections can be done at any time.

A chartered accountant could be considered an appropriate Quality Assurance person, provided that he or she has the adequate training, experience and technical knowledge relating to the activities conducted; this includes having the ability to evaluate the operations of the LP to ensure compliance with Division 4, and the technical knowledge to be able to assess analytical testing results in order to be able to determine whether the dried marihuana is suitable for sale. The Quality Assurance person is also responsible for investigating quality-related complaints and taking corrective and preventive actions, if necessary. "
 
maximum

maximum

Active Member
BigBhuda said:
Appears to be nothing but vague answers from them. Looks like we won't know until the inspections start and we can share our experiences. I also asked about QA qualifications and got this reply. Looks like we should all start trying to be our own QA and justify why we are qualified. Only way to find out what they accept and don't.

"Thank your for your email concerning the new Marihuana for Medical Purposes Regulations (MMPR).

In response to your questions below, Health Canada is responsible for carrying out inspections under the MMPR, and will be done by existing personnel. At this time, there are no job posting for inspectors.

There are no existing guidelines for wait times for inspections. Pre-licence inspections are scheduled with applicants in advance, and once a licence has been issued, follow-up inspections can be done at any time.

A chartered accountant could be considered an appropriate Quality Assurance person, provided that he or she has the adequate training, experience and technical knowledge relating to the activities conducted; this includes having the ability to evaluate the operations of the LP to ensure compliance with Division 4, and the technical knowledge to be able to assess analytical testing results in order to be able to determine whether the dried marihuana is suitable for sale. The Quality Assurance person is also responsible for investigating quality-related complaints and taking corrective and preventive actions, if necessary. "
Click to expand...
Well division 4 is all the "Good Production Practices", pest control products, equipment, premises etc... How is a chartered accountant appropriate for this?
 
D

DRCFL

Member
maximum said:
A part of me thinks these thoughts at night when I try to sleep. But Im going to try and go the legal route using all possible options I have. If we can get through the short term burn, collaborate and minimize the immediate set backs, then I think long term it looks good. Its worth the fight. I rather not get jailed, and have a criminal record which might exclude me from future markets that are easier to participate in.\

And it is a real fear of mine. Can I sell enough from day 1 to keep up with my costs? At this moment, I could make a big list of things I have to fight through. The whole things a fight man. I wish you the best legal or not.
Click to expand...
Oakley, I can see where you are coming from (in a short term perspective), and I agree with Maximum, I think this too, but then I ask myself the question... Out of the 22,000ATP 10% of them currently by crap weed from PPP, 60% are PUPL, 20% DPPL, 10% unaccounted. I can conservatively estimate 6,600 people will be involved in the program regardless of hating harper and the system...

The rest 15,400 hate harper, HC, PPP, MMPR ect and will not join the new system because they don't want shitty mail order weed at 8.80/grm. The only thing unsaid here, is that MJ will not be selling for 8.80/grm, it will be MUCH CHEAPER!!! ATP holders WILL buy from LP's when they start to see that the LP's are providing high quality product, mostly grown by ex MMAR program participants who have experience, and are selling at 3.50/grm including shipping.

I know my costs, and this is what I will be selling at. AS us baby boomers grow older, we become more aware of pharm companies side effects, and prefer herbal remedies. Baby boomers are a LARGE part of the Canadian Population. Diseases that medicinal marijuana can help with are more prevalent everyday as we learn more about the products positive (and to be fair negative) effects.

LP's will be working with the FDA immediately to create a DIN for the product so it can be covered by health care. Organizations working and spending money to fight the MMPR would serve their supporters better by putting their efforts and energy towards ensuring provincial governments ALLOW NP's to prescribe, and supporting clinical trials that can create a DIN for the product hence giving all their supporters free medicine over the long term, as opposed wasting their money and energy fighting the government on a new system that they will NOT change regardless of the success of it.

These are my thoughts.... We will not give up, as we believe we can help people through becoming an LP.
 
BigBhuda

BigBhuda

Well-Known Member
The whole quality assurance thing is about coming up with adequate policies and documenting your compliance. You will need to come up with a procedure manual and checklists to prove that it is being followed. Chartered Accountants do this all the time when auditing any procedure. This was only one example. I think the moral of the story is that anyone can be qualified with a little training. An accountant would be able to confirm that policies are being followed. Just may need some horticulture or Quality Management courses specific to the natural product regulations.
 
BigBhuda

BigBhuda

Well-Known Member
There may be hope, I asked this question:

"When a detailed security plan is submitted with an application what feedback will be provided regarding weaknesses in the plan prior to construction and implementation of the plan and before final inspection."


"We will be reviewing your proposed plan before you build and give you an idea of what may be missing."

Regards,

Licences and Permits Division
Office of Controlled Substances
 
maximum

maximum

Active Member
BigBhuda said:
There may be hope, I asked this question:

"When a detailed security plan is submitted with an application what feedback will be provided regarding weaknesses in the plan prior to construction and implementation of the plan and before final inspection."


"We will be reviewing your proposed plan before you build and give you an idea of what may be missing."

Regards,

Licences and Permits Division
Office of Controlled Substances
Click to expand...
Wow is that what they said?! Nice job BigBhuda, thats a great bit of info there man. "Before you build", this answers the fear of building something only to get rejected.

Your the man. See, we are all getting ahead. Level heads prevail.
 
maximum

maximum

Active Member
Email to Health Canada

"Can the Quality Assurance person be the same person as Senior Person or Responsible Person in Charge?"

Thank you for your interest in becoming a licensed producer under the New Marihuana for Medical Purposes Regulation (MMPR).

There is not restriction under the MMPR to retain a Senior Person or Responsible Person in Charge to also be the Quality Assurance person.

The LP’s Quality Assurance person must have the training, experience and technical knowledge relating to the activity conducted and the requirements of Division 4 of the MMPR. This means that the Quality Assurance person must have the ability to evaluate the operations of the LP to ensure compliance with Division 4, and the technical knowledge to be able to assess analytical testing results in order to be able to make the determination of whether the dried marihuana is suitable for sale. The Quality Assurance person is also responsible for investigating quality-related complaints and taking corrective and preventive actions, if necessary.

Hope this answered your questions.

If you have any additional questions, please do not hesitate to send us your questions by email at MMPR-RMFM@hc-sc.gc.ca or call us at 1-866-337-7705.

Licences and Permits Division
Office of Controlled Substances
Health Canada
Click to expand...

Now Redi posted the link to "Drugs and Health Products" Where they talk about using a quality assurance persons. Unless they define things different for cannabis then here are some definitions for the following: "training, experience and technical knowledge/education "
http://www.hc-sc.gc.ca/dhp-mps/prodnatur/faq/question_industry-industrie-eng.php#a15
21. How does Health Canada define education, training and experience?

Education, training and experience are defined in the Good Manufacturing Practices Guidance Document for Natural Health Products.


Education refers to "The act or process of imparting or acquiring knowledge or skills; the learning of information by instruction, training, or study can be testified to by a degree, certificate or diploma


Training is defined as "To make proficient with specialized instruction and practice".


Experience refers to "Active participation in events or activities leading to the acquisition of knowledge or skills; the knowledge or skills retained from personally observing, encountering, or undergoing something.
Click to expand...

 
maximum

maximum

Active Member
BigBhuda said:
The whole quality assurance thing is about coming up with adequate policies and documenting your compliance. You will need to come up with a procedure manual and checklists to prove that it is being followed. Chartered Accountants do this all the time when auditing any procedure. This was only one example. I think the moral of the story is that anyone can be qualified with a little training. An accountant would be able to confirm that policies are being followed. Just may need some horticulture or Quality Management courses specific to the natural product regulations.
Click to expand...
I agree with you. I think you have a really good understanding here. Its consistent with my business experience and dealing with government. Hope you keep posting man.
 
Gquebed

Gquebed

Well-Known Member
From another thread .... Originally Posted By: ivankov4
Nothing says it has to be a big 1/4 million dollar startup.


That's right. Nothing says that. But when you read between the lines of what is required and start adding up the numbers you'll soon figure it out.

Just to meet security requirements is going to cost you $15-25k. You will need two employees, which will cost you $50k each minimum, plus benefits and WCB and so on. You've already spent $125K and you haven't even germinated a seed. How do you pay for that? Grow a shit load of plants, obviously. So now you have buy equipment. And to pay for that equipment you will have to grow even more plants. That equipment is going to cost you $10's of thousands.

Furthermore, the security stipulations are vague and subject to change. Anyone who has dealt with government in an emerging industry knows these sorts of things will be amended on the fly, costing you more. Welcome to the world of corporate business.

So the security/staff requirements were put in place deliberately to drive up start up costs and thereby eliminate pretenders, dreamers and every jackass who thinks he can grow.

Now that I think about it $250k won't even get you to the end of your first crop.
 
Gquebed

Gquebed

Well-Known Member
ivankov's reply to Gquebed........Im a literal thinker. I dont read between lines. I just read lines.

Security wont cost $25k. How? Have you called a security company? I called a couple and gave them the health canada guideline information. Maybe you own a massive building or something?

Two employees which will cost me $50k each? Nope. Maybe thats what you would need but thats you. Your costs. Not mine. Im one employee and my wife is the other one. Done. I didnt spend $125k at all yet. You did. Obviously you can. I can't. Are you going to be part of your business? Why dont you count yourself?

Equipment costs 10's of thousands? Yea It does. And it did when I bought it over the years. But, I already have lots of equipment. Why do I need new equipment? My ballasts are already to code. I have carbon filters, fans pumps, Im already doing this. So thats one less expense.

Security stipulations are not really vague. Read the new guide that was released, its pretty helpful actually. Gives info on greenhouses too.

For me the hardest part is the real estate. Thats where my costs are going to be high. Unless I find a good place to rent. Rent is based on square footage and location. Not the density of the concrete walls. So its easier finding something in the industrial where there is already a fence up and buildings made to the suggestions in the guidance documents.

I dont get the big deal here man. Yea you can pay $250k, $2.5million or more or way less. Depends on lots of stuff. I would argue strongly against entry into the mmpr costing $250k minimum.
 
Gquebed

Gquebed

Well-Known Member
Gquebed's reply to Ivankov..... That's the problem...just reading the lines isn't enough. Those who have experience dealing with government agencies and the way they write laws and regulations KNOW VERY WELL that what isn't written is just as important, if not more important, than what is written. Ask any lawyer to look at the doc we've been reading and they will roll their eyes at all the ambiguities.

Security won't cost 25K? I can't believe you believe that. You don't need to call a security company. Equipment costs (cameras, recorders and networking) alone will run you that much for a small operation, never mind one of any consequence, which is to say one that any product buyer (Big Pharma) will deal with (volume).

Your wife is one employee and you are the other? You think that's going to cut it? Really? This where you have to read between the lines. Read what it says the employees must be responsible for. Then notice what it doesn't say. The arbitrary nature of that passage will give the regulatory body a huge amount of discretion as to who they will or won't approve.

Now I'm glad you mentioned real estate because I forgot last time. Never mind anything else, this alone will be huge dollars. IF you can find somebody to lease a site to you for this venture (and that's a big if)it will have to be of a size that will be able to produce the kind of volume that Big Pharma will bother purchasing and that...well... that alone could go to millions simply because of multiple year leases, insurance and so on.

The legislation as it is written leaves it open to any body with a clean record to apply and to be approved. But again, anybody who has dealt with federal licensing regimens knows only too well how arbitrary and discriminating it can be. They can find any excuse to decline and overlook anything they want in order to approve.

But while anybody "may" be eligible to grow, very few are going to be able to afford it. That was the whole point of this legislation!! Make it too bothersome/complicated for organized crime to get licensed (although I don't rule that out) AND make it way too damned expensive for Joe Shmo to have a chance.

I mean really... packaging and labeling will be regulated which is a huge expense. Then there's product testing that will have to be done. Do you have any idea what a single chemical test costs!!?? and that has to be done at random intervals through the whole product run.

Again, this legislation is about handing the business over to corporate interests. There's billions at stake. Guys like us won't even get s sniff...unless we get hired as growers or trimmers or something. That's the reality of it...

I mean, you may get a license, but you won't be able to operate at a volume level that can compete unless you spend millions...and if you don't spend millions then you won't be able to compete at a price that's competitive. It's that simple.

The best thing we can do know is stop playing the bullshit medical card and do what Colorado did and start bucking for legalizing recreational use... and hope that we can get to where beer and wine is.
 
maximum

maximum

Active Member
DRCFL said:
Oakley, I can see where you are coming from (in a short term perspective), and I agree with Maximum, I think this too, but then I ask myself the question... Out of the 22,000ATP 10% of them currently by crap weed from PPP, 60% are PUPL, 20% DPPL, 10% unaccounted. I can conservatively estimate 6,600 people will be involved in the program regardless of hating harper and the system...

The rest 15,400 hate harper, HC, PPP, MMPR ect and will not join the new system because they don't want shitty mail order weed at 8.80/grm. The only thing unsaid here, is that MJ will not be selling for 8.80/grm, it will be MUCH CHEAPER!!! ATP holders WILL buy from LP's when they start to see that the LP's are providing high quality product, mostly grown by ex MMAR program participants who have experience, and are selling at 3.50/grm including shipping.

I know my costs, and this is what I will be selling at. AS us baby boomers grow older, we become more aware of pharm companies side effects, and prefer herbal remedies. Baby boomers are a LARGE part of the Canadian Population. Diseases that medicinal marijuana can help with are more prevalent everyday as we learn more about the products positive (and to be fair negative) effects.

LP's will be working with the FDA immediately to create a DIN for the product so it can be covered by health care. Organizations working and spending money to fight the MMPR would serve their supporters better by putting their efforts and energy towards ensuring provincial governments ALLOW NP's to prescribe, and supporting clinical trials that can create a DIN for the product hence giving all their supporters free medicine over the long term, as opposed wasting their money and energy fighting the government on a new system that they will NOT change regardless of the success of it.

These are my thoughts.... We will not give up, as we believe we can help people through becoming an LP.
Click to expand...
$3.50/grm Can you ship something that cheap? With tracking?
 
D

DRCFL

Member
Hey Maximum,

No I cannot ship that cheap with shipping included if someone buys one gram.
I should have been more specific, There will be a minimum quantity purchase required for free shipping...
3.50 - 5.00 will be the range of prices depending on flowering times and input costs...
 
R.Raider

R.Raider

Well-Known Member
I know I said this before but what a great thread. I've learned a ton from this thread and see the thread itself constantly making progress. I literally check this thread several times a day. Thx a lot to everyone contributing and keep up the excellent work fellas.
 
Shawns

Shawns

Active Member
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
Gquebed said:
Gquebed's reply to Ivankov..... That's the problem...just reading the lines isn't enough. Those who have experience dealing with government agencies and the way they write laws and regulations KNOW VERY WELL that what isn't written is just as important, if not more important, than what is written. Ask any lawyer to look at the doc we've been reading and they will roll their eyes at all the ambiguities.

Security won't cost 25K? I can't believe you believe that. You don't need to call a security company. Equipment costs (cameras, recorders and networking) alone will run you that much for a small operation, never mind one of any consequence, which is to say one that any product buyer (Big Pharma) will deal with (volume).

Your wife is one employee and you are the other? You think that's going to cut it? Really? This where you have to read between the lines. Read what it says the employees must be responsible for. Then notice what it doesn't say. The arbitrary nature of that passage will give the regulatory body a huge amount of discretion as to who they will or won't approve.

Now I'm glad you mentioned real estate because I forgot last time. Never mind anything else, this alone will be huge dollars. IF you can find somebody to lease a site to you for this venture (and that's a big if)it will have to be of a size that will be able to produce the kind of volume that Big Pharma will bother purchasing and that...well... that alone could go to millions simply because of multiple year leases, insurance and so on.

The legislation as it is written leaves it open to any body with a clean record to apply and to be approved. But again, anybody who has dealt with federal licensing regimens knows only too well how arbitrary and discriminating it can be. They can find any excuse to decline and overlook anything they want in order to approve.

But while anybody "may" be eligible to grow, very few are going to be able to afford it. That was the whole point of this legislation!! Make it too bothersome/complicated for organized crime to get licensed (although I don't rule that out) AND make it way too damned expensive for Joe Shmo to have a chance.

I mean really... packaging and labeling will be regulated which is a huge expense. Then there's product testing that will have to be done. Do you have any idea what a single chemical test costs!!?? and that has to be done at random intervals through the whole product run.

Again, this legislation is about handing the business over to corporate interests. There's billions at stake. Guys like us won't even get s sniff...unless we get hired as growers or trimmers or something. That's the reality of it...

I mean, you may get a license, but you won't be able to operate at a volume level that can compete unless you spend millions...and if you don't spend millions then you won't be able to compete at a price that's competitive. It's that simple.

The best thing we can do know is stop playing the bullshit medical card and do what Colorado did and start bucking for legalizing recreational use... and hope that we can get to where beer and wine is.
Click to expand...
 
maximum

maximum

Active Member
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
Click to expand...
I hear this kind of conspiracy every day. Post your math and make a list so you can show us how it costs millions. You list off expenses but then you dont put numbers behind it and then say, in conclusion it costs millions. Common man. I dont want to get into the conspiracy of why this new system is here. I only want to work within its frame work to setup a small scale garden that meets the criteria. And after 16 pages of input from people that have gone out of their way to look things up, price things out and share, Im very optimistic.

If you read our thread we have addressed cost of facility, lab testing doesn't have to be done on site it can be outsourced, what you figure a packaging area costs? Whats the cost of your ventilation? No choice but to build new? Why? Did you read the requirements for the building? Lots of buildings meet the criteria. Even a greenhouse qualifies. We actually priced out a greenhouse thats 2000 square feet with the glazing glass and other requirements health canada has listed on the website and the security company estimated low end to high end $500-$10,000. I posted the email from the company and a link to them so people can verify. Nowhere near the $25k quoted above. And by the way the $25k posted above didnt even bother to break it down or post links to anyone or quote from any source. Its just a random number thrown out. The costs are variable. They can be changed, manipulated and played around with. And you still meet the criteria without spending lots. Unless you want to spend lots. Then you can. If you have a big budget you can go big here. I dont have a big budget. So I have to squeeze things.

The whole point of this thread is not to spend millions. We post our math, cost estimates, and we are trying to read and understand the rules and regs. We email health canada, and post replies. We discuss the confusing wording on things. Just participate in the thread and you could find opportunity. Let me give you an example. You think the price of real estate is so high that you cant afford to construct something that meets the requirements. Lets say you couldnt even find a lease for cannabis cultivation friendly site. Your still not out of luck. We have posters in this thread like Canadian Simon. Canadian Simon is building a multiplex facility which will house his grow but also have space available to lease for small growers. He may have an onsite lab as well which we would have access too. Security, building requirement, packaging, already in the box for you. Even if Canadian Simon goes another route,or the laws dont allow this kind of setup, man we are just getting started here.

Edit, isnt your current setup sterile!?
 
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