MMPR Grow op: Small Scale

Princess of Pot

Princess of Pot

Well-Known Member
I just got a letter from HC too asking me to elaborate on my QA's credentials. I was given 2 weeks to reply back to HC. Did anyone else get a time limit?
 
I

ispice

Well-Known Member
Sorry just got up, quick comment for now.

These guys hiring out QAP's, some may have growing experience, but what happens when these guys are dealt some PM. Do they have SOP's that are of actual use in such a case?

Peace Naturals set the bar with their CEO waddling through their plants sticking them in his nose, great stuff!

Seems like HC is hoping to scare the smaller LP's who aren't willing to use some hired schmuck who may be knowledgeable and have some good GMP's and SOP's for cars or pills, but when it comes to growing pure cannabis indoor or in a greenhouse I would be willing to put my methods and knowledge against anyone in the traditional GMP world, the fact that I dont have a certificate or a job reference to prove this is bull shit.

That being said, we've known this is an area of contention as their vague and broad definitions and wording make it possible to pick and choose at their discretion.

Hope more people chime in with their experience on this matter here, as this is the first attempt at the culling of the small LP's.


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How many groups who got the QAP elaboration email sent in samples of your SOP's?
 
leaffan

leaffan

Well-Known Member
I agree that this is a culling. It shouldn't come as a surprise though.
I don't think you can bury your head in the sand on this issue.
Play the game, whistle the song, don't let your pride or frustration get in the way of the ultimate goal.
Your vast experiences with growing , ppl, dppl, isn't going to do it.
Face reality.
Now do something about it. Consider the importance of this position. Find an appropriate person that fits the job description. Recruit !!
It's going to cost you, but without all the boxes checked you will be spinning your wheels.
Consider a very lucrative salary or bonus structure or better yet a fair equity position for your newest team member.
 
WHATFG

WHATFG

Well-Known Member
I still maintain that small scale LP's' ( which I will admit I like better than big bullshit) aren't the goal of this project. And it seems....I don't know what the word is...but anyone who was here and has been authorized, hasn't really been back to provide any info to the rest you about how they got there. What happened to helping each other out? Like the person who started this thread...did they get authorized or just give up and why? What will happen if this all gets set aside through the SC? Tic toc, only 24 more days to lift off!
 
woodsmaneh!

woodsmaneh!

Well-Known Member
ispice said:
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.
Click to expand...
You are right and wrong. Your right GMP is not in the MMPR and so are 3 other acts you have to follow. Your mistaken about my information.

It will take to long to list all the links but in a nut shell;

the MMPR is the mother ship and everything comes from her. The Food and Drug, the Narcotics Act, Pesticide act and so on. You need to read all of the pieces to get the whole picture and how they tie in together. Here is the title of one of them. Health Products and Food Branch Inspectorate, Good Manufacturing Practices (GMP) Guidelines – 2009 Edition, Version 2.

The other real important place to read is your pharmacopoeia that's where your real GMP and setting your SOP's comes from. Your pharmacopoeia sets the minimum standards you have to meet for everything from harvesting to packaging, cleaning ect.

You can find a free copy at WHO= world health organisation GPM herbal remedies
 
Kootenaygirl

Kootenaygirl

Active Member
WHATFG said:
I still maintain that small scale LP's' ( which I will admit I like better than big bullshit) aren't the goal of this project. And it seems....I don't know what the word is...but anyone who was here and has been authorized, hasn't really been back to provide any info to the rest you about how they got there. What happened to helping each other out? Like the person who started this thread...did they get authorized or just give up and why? What will happen if this all gets set aside through the SC? Tic toc, only 24 more days to lift off!
Click to expand...
I think Maximum figured out the cost of starting an LP and decided the better of it like thousands of others, I wish he were still posting here but I respect the silence too.
LP's cannot post here and face you lot, they would get shredded, the atmosphere of trying to understand has had the oxygen sucked out of it.
It is pretty easy to criticize the LP's, and it would be a lot of work to try to influence them for the patients benefit.
Too many people making this about sides, choose the side of marihuana and patients, not more marihuana propaganda.
Experchem was treated rudely immediately and was only offering to answer our questions, fucking bully's getting in the way of learning for everyone.
What has happened is that the transparency that we all wished for has been scared away, and now most of the conversations are not open forum any longer.
LP's are helping the wannabes, wannabes are helping wannabes, and this is all happening behind closed doors instead, too bad in my opinion but we should all be grateful for people like Ispice, Leafan, Kron, and most recently the Woodsmaneh!, for providing much needed ideas and resources, and shinning the light for patients too.
At the end of the day, IMO it will be these kind of people that will help the most patients by a huge margin.
LP's are here to stay and will become an important part of the marihuana supply choices, regardless of what Conroy wins or loses.
The government is going to set aside MMPR/big pharma.....yah right lol.
No, I believe there is plenty of room for personal grows too, hopefully, if Conroy can make that happen, everybody wishes for that, that is freedom, plain and simple.
 
P

PunkyDorrie

Active Member
Your posts are such a refreshing bit of light into these dark corners, Kootenaygirl. I'm so tired of the "LP bashing", as if everyone on here doesn't charge for their own services. I don't criticize my current 'dealer' for charging me for weed, why would I begrudge this to an LP?. Let's put our energy into getting personal grows re-allowed, and pushing towards a sensible legalization framework, not attacking people willing to work within the system.
 
woodsmaneh!

woodsmaneh!

Well-Known Member
WHATFG said:
I still maintain that small scale LP's' ( which I will admit I like better than big bullshit) aren't the goal of this project. And it seems....I don't know what the word is...but anyone who was here and has been authorized, hasn't really been back to provide any info to the rest you about how they got there. What happened to helping each other out? Like the person who started this thread...did they get authorized or just give up and why? What will happen if this all gets set aside through the SC? Tic toc, only 24 more days to lift off!
Click to expand...
I'm not sure why more don't come back to help but from my perspective, they don't have time or they gave up.

The SC will not change the MMPR they might give people the right to grow as that is the question being asked of the SC.
There will not be a shortage on Medical Cannabis come April 1 or April 25 or the next month after that. HC has stockpiled MM so that does not happen, anyone who thinks otherwise is delusional.
 
WHATFG

WHATFG

Well-Known Member
woodsmaneh! said:
I'm not sure why more don't come back to help but from my perspective, they don't have time or they gave up.

The SC will not change the MMPR they might give people the right to grow as that is the question being asked of the SC.
There will not be a shortage on Medical Cannabis come April 1 or April 25 or the next month after that. HC has stockpiled MM so that does not happen, anyone who thinks otherwise is delusional.
Click to expand...
They've stockpiled the shit that nobody wanted to buy. Have you ever tried that crap? It is absolutely terrible...I have tried it and it was the biggest waste of money because I couldn't return it. I hope you are wrong and the Supreme Court comes through for those patients who can't afford their meds and want to grow. The future 420000 patients can pay for this program and I will carry on my merry way.
 
woodsmaneh!

woodsmaneh!

Well-Known Member
WHATFG said:
They've stockpiled the shit that nobody wanted to buy. Have you ever tried that crap? It is absolutely terrible...I have tried it and it was the biggest waste of money because I couldn't return it. I hope you are wrong and the Supreme Court comes through for those patients who can't afford their meds and want to grow. The future 420000 patients can pay for this program and I will carry on my merry way.
Click to expand...

I hear you, HC has been stockpiling the PPP shit but they also bought tons from the Netherlands and it arrived 3 weeks ago. HC is not going to have any shortages of MM come April 1, you can count on it.
 
G

german1

Member
woodsmaneh! said:
I'm not sure why more don't come back to help but from my perspective, they don't have time or they gave up.



The SC will not change the MMPR they might give people the right to grow as that is the question being asked of the SC.
There will not be a shortage on Medical Cannabis come April 1 or April 25 or the next month after that. HC has stockpiled MM so that does not happen, anyone who thinks otherwise is delusional.
Click to expand...
If you research the laws before mmpr you will find that there was a group that had their medicine grandfathered from the early 80s to the late 90s before they all died off.

The same thing will happen here, the courts will grandfather the current system and the govt will allow it to run its course as people will pass away and less of the mmpr licenses will be out there.

The govt never wanted to make these decisions as they don't have the expertise or caring to actually make this program effective so by letting the courts decide the fate of mmpr they can satisfy both sides and use the excuse "the courts made the decision we didn't "

HC doesn't care about mmpr either way they want the revenue from the LPs and that is what they will get. There are already signs such as Vancouver PD not enforcing new rules etc.

Anyone who thinks LPs are here from HC for the greater good they are naive and really don't have a clue how big business and the political system sleep in the same bed.
 
Princess of Pot

Princess of Pot

Well-Known Member
Hi Guys - I wrote HC and asked them what they were looking for specifically with QA qualifications. This is what I got back:

The selected person for the position of quality assurance must be able to conduct all the activities under Division 4 which includes understanding the results from the microbial and chemical contaminants. Also, the quality assurance person needs to ensure to understand how to validate methods as required by section 54(2) of the MMPR. Plus, the person must be able to ensure that the equipment, premises and sanitation program are followed and that the programs in place for these items meeting the requirement of the MMPR.

Each file is evaluated separately. This is why it is important to provide as much details as possible to allow us to ensure that the quality assurance person selected is having the proper training, knowledge and technical expertise to conduct is mandate. Health Canada does not have any recommendation for the training etc. It is the licensed producer responsibility to demonstrate that the selected person will be able to conduct the duty listed under Division 4 of the MMPR.

Note that being a current grower does not qualify you as being able to conduct all the activities under Division 4. Also remember that the quality assurance person needs to be able to investigate any complaints received by the licensed producer. If you decide to have a quality assurance person only as part-time, you will need as part of your application to demonstrate how, if any, complaint is received the quality assurance person will be investigating it in timely manner. Also, if a recall is executed, the quality assurance person is responsible for conducting it and will need to advise the Minister on the reason for commencing it. This requires a lot of verification and a clear understanding of all the aspect of Division 4 of the MMPR.

As a reminder, the duties of the quality assurance person are to ensure the quality of the products at all steps. This person is responsible to act if any situations occur at any step of the growing stage such as, for example, problems with plans, problems with bugs etc. The quality assurance person needs to be able to assess every step of the products and certify that it was conducted as per Division 4.

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. In particular, please address sections 55, 56, and 57 of the MMPR. 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.

If you have any additional questions, please do not hesitate to send us your questions by email at [email protected] or call us at 1-866-337-7705.

Licences and Permits Division
Office of Controlled Substances
Health Canada​


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Kootenaygirl

Kootenaygirl

Active Member
Geez, that is a pretty good answer for a direct question to HC, everyone should print that off for the files, they must be slowly figuring it out.
 
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