MMPR Grow op: Small Scale

Kron3007 said:

It would be a few hundred for the cannabanoids, but you also need to test for various microbes, aflatoxins, and heavy metals. Given that all tests need to be conducted in triplicate (or more), $2000 would be reasonable and I wouldn't expect to see much lower. That being said $2000 per batch isn't that big an onus given the value of the crop, it just means that you need each crop to be large enough to support it. For what it's worth, most of these tests are required to sell any herbal product in Canada so these regulations are not putting any unusual requirements on this crop in particular.

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Would you need to test for heavy metals for every harvested crop? Please correct me if I'm wrong, but those metals would be coming from either the water used or the fertilizer. So if the water source and fertilizer used never changes, is that test really necessary?

Does anyone know if your MMPR grow has to be in a commercial/industrial zoned area or could you conduct this type of business on an ALR(agrucultural land reserve) zoned area?

mikethegrower said:

Does anyone know if your MMPR grow has to be in a commercial/industrial zoned area or could you conduct this type of business on an ALR(agrucultural land reserve) zoned area?

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Best advice is to call your municipality and ask them

How many licenses are to be issued? Is this business going to be profitable with security, utilities, lease/taxs, payroll, accounting, shipping/postage, packaging materials, hardware, lights, nutrients and all the number of rediculious pre-addmission requirements? I dont believe this will be a send paper work in and get the gold seal paper work back in a xpress post envolope. This time around there will probably be a big failure rate the first go around and i wouldnt imagine there is unlimited licenses being signed. How many licenses were initially signed with mmar back in 2001/2002? i believe it hit a few years before 500 people were signed and on mmar, obvisouly that will be alot faster this time but not exactly a 100% transition. I think it is only 11% buying from PPS, i hope all the new LPs dont have to send the product ground up.

I have no idea how many licenses will be issued but if you do the math, 30,000 current MMAR users x the new maximum prescription amount of 150g/month
= 4,500,000 grams needs to be ready to go, come March 2014. So Health Canada needs to have as many LP's as it takes to produce 4.5 metric tonnes/month. And that doesn't take into account for new users.

Your absolutely correct, they do need a massive inventory ready to go at day 1. I wouldnt imagine people actually paying 40-50$ a day for medication. If i had to guess i would say almost everyones license is generous and over prescribed a daily amount. I just hope the court battles go in our favour.

Don't forget to factor in the patients that are going to challenge the new MMPR and continue to grow themselves.......

redi jedi said:

I have no idea how many licenses will be issued but if you do the math, 30,000 current MMAR users x the new maximum prescription amount of 150g/month
= 4,500,000 grams needs to be ready to go, come March 2014. So Health Canada needs to have as many LP's as it takes to produce 4.5 metric tonnes/month. And that doesn't take into account for new users.

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Evidence of a maximum prescription amount being imposed please, cant see how that would even be legal.

oakley1984 said:

Evidence of a maximum prescription amount being imposed please, cant see how that would even be legal.

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Read the regulations, I'm not making this up....

Kron3007 said:

We are planning on offering these tests once we are up and running, but that does very little for people currently applying....

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I think if you could do testing on behalf of other, you should have good business just for that, since most of us don't have the know how and the money to pour into this testing..

However what do you think the price range of such test will cost each time when someone comes to you and usual turn around time?? Because if it is too high in pricing most of the small LP still may find it out of budget to get started.

redi jedi said:

Would you need to test for heavy metals for every harvested crop? Please correct me if I'm wrong, but those metals would be coming from either the water used or the fertilizer. So if the water source and fertilizer used never changes, is that test really necessary?

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You are correct regarding the sources of contamination, but the way the Pharmacopoeias are worded it looks like it needs to be tested for each batch. I guess this would be up to the QA person to decide, but that is how it reads to me.

You may use the same brand of fertilizer every time, but they have to formulate it and there is no way to know if it is really the same. This requirement is a little silly for Canadian producers IMO, but from what I can see it is a requirement. It makes sense for man herbal products that are imported from China, etc., that are often grown in contaminated soils and can accumulate heavy metals.

mrfssd said:

I think if you could do testing on behalf of other, you should have good business just for that, since most of us don't have the know how and the money to pour into this testing..

However what do you think the price range of such test will cost each time when someone comes to you and usual turn around time?? Because if it is too high in pricing most of the small LP still may find it out of budget to get started.

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We wont be able to work out the prices until we are up and running, but the reality is that these tests are expensive in nature. However, I assume that once the new system is in place there will be several groups offering these services and the pricing will need to be competitive.

The $2000 number that has been floated around here sounds fairly reasonable from my experience, especially since each batch will need to be sub-sampled and tested as replicates. This means that each batch will need to be sufficiently large to support the tests, there really is no way around this. I would anticipate losing a pound off the top of each batch to cover these cots (assuming $5/g). Even if several growers establish a co-op type lab for these tests as has been mentioned, the tests would not be cheap. There is still a couple hundred thousand dollars of equipment that would need to be re-couped, a qualified lab tech would need to be paid, there would be a lot of start up costs during method development, and there are continual maintenance and operation costs. I'm not discouraging people from doing this, but I wouldn't expect it to be dirt cheap regardless. The reality is that the tests are expensive because they are expensive to setup and run, not because analytical labs have gigantic profit margins.

Kron3007 said:

You are correct regarding the sources of contamination, but the way the Pharmacopoeias are worded it looks like it needs to be tested for each batch. I guess this would be up to the QA person to decide, but that is how it reads to me.

You may use the same brand of fertilizer every time, but they have to formulate it and there is no way to know if it is really the same. This requirement is a little silly for Canadian producers IMO, but from what I can see it is a requirement. It makes sense for man herbal products that are imported from China, etc., that are often grown in contaminated soils and can accumulate heavy metals.

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Every batch has to be tested, it says so in the regs. And a sample of every batch has to be kept for 2 years.

redi jedi said:

Read the regulations, I'm not making this up....

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I have, you have obviously misinterpreted them to be saying this, clearly under section 5 it lists this.


it uses a chart that goes up to 5 grams, to display a maximum of 150 grams per month, but NOWHERE within the regulations does it say that a MAXIMUM prescription amount for a patient will suddenly be imposed reducing all to a maximum of 5 grams per day, Stop spreading misinformation.

If they gave mmj a DIN (drug identification number) i say go for it and allow the mmpr, sick people and disabled aswell as people that just cant simply afford it would be able to have there insurance cover it or obtain insurance for it.

Me and mrfssd have been emailing, anyone else in the ontario region that's interested? I'm about a quarter way through finished a business plan.

Do we need the patients before we can apply for the Producers License? I'm assuming so because it asks for their information in the license application?


my emails: adamjasar@live.com

oakley1984 said:

I have, you have obviously misinterpreted them to be saying this, clearly under section 5 it lists this.

1.

paragraph 5(a)

(a) in the case of dried marihuana obtained from a licensed producer in accordance with a medical declaration, 30 times the daily amount specified in the medical declaration;

it uses a chart that goes up to 5 grams, to display a maximum of 150 grams per month, but NOWHERE within the regulations does it say that a MAXIMUM prescription amount for a patient will suddenly be imposed reducing all to a maximum of 5 grams per day, Stop spreading misinformation.

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You right, there is no maximum daily prescribed amount, but there is a possession and shipping limit of 150g..misinformation clarified.

bigmanc said:

If they gave mmj a DIN (drug identification number) i say go for it and allow the mmpr, sick people and disabled aswell as people that just cant simply afford it would be able to have there insurance cover it or obtain insurance for it.

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The DIN # will take time but as of right now you claim medical cannabis on your tax return, if you have receipts. An LP would issue a client a receipt.
10 medical tax deductions that can save you money - Business - CBC News

What's your angle Redi Jedi? If we can't ship more than 150 g's per month what difference does it make how big the prescription is? In fact the way I read it, if the order is larger than 150 grams we are supposed to refuse to sell any to that client. This is all true, but then the left part of my brain is saying to me "just look at the f'n loophole dumbass".

So if a client has an extreme prescription say, 40 grams a day (typical BC prescription lately). They can give it to an LP who can ship a maximum of 150g's per order. Remember the patient also has a possesion limit of 150g's. This patient would require 1200 g's per month. So as the LP I can send the patient 8 shippments of 150 g's, spread evenly over the 30 day period. (every 3.75 days). If this pateint continues to bathe in it, lol, using up the marihuana, in theory, no rules get broken.

Thankyou for making me get my mind around this. Any body disagree with this interpretation? It's really not even a loophole, just poorly written in three different spots.

Doctors and Nurses can prescribe any amount, in theory, we can ship any amount divided into 150g packages as long as it does not exceed 30 times the daily prescription limit. Note: the scenario above would cost the patient $6000 per month plus shipping at 5$ a gram, and 40 - 30 gram containers a month, wow.

Waiting for Maximum's update. The suspense is killing us.

My angle? I'm not sure what your asking me, but your interpretation is correct.

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

Yes. A medical user with a daily prescribed amount of 10 grams of marihuana/day would be able to purchase a 150g supply of marihuana on the 1st of the month, and can arrange to purchase and have another 150g of marihuana shipped for the 15th. This ensures that the client remains under the maximum possession limit of 150g, while having enough medication on hand to meet requirements.

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