MMPR Grow op: Small Scale

[MMHot]

Thanks! Happy to be part of this!

I think HC did not change the rules on the fly but advise all applicant (like me). That a QA can only be for one single site.

I was able to talk to one of the employee last week due to many QA request. I was told that they decided to ensure that each QA person is only for one site. As for been part time or full time, I ask that precisely and the answer was "the MMPR is not discussing this" and it was a business decision.

Plus it seems Experchem was told the same thing. One QA per site. You cannot be the same QA for different site. Which make sense also to protect business secrets that could be disclosed from one site to the other site by the QA person been the same for many site.

A friend which was working with Experchem was advise of the same impact and Experchem dropped his site as the QA person. After many money put toward their proposed Experchem QA business. Very sad!

 

[Devil Lettuce]

Which make sense also to protect business secrets that could be disclosed from one site to the other site by the QA person been the same for many site.

This is another thing that I have thought of and that LP's should be considering. Even if part-time QA's were allowed, are you really willing to trust your entire business to someone that only works for you part time? Your entire license and application depend on having a proper QA person in place, what happens if they quit during or after the application process, or when they jump ship when they get a better offer?

Another great point you make is regarding the protection of proprietary secrets. Do you really want a QA person onsite that has very little allegiance to you or your company? This person could be associated with multiple LP's, and collecting and passing on all sorts of information. Not to mention there would be a HUGE opportunity for those with questionable morals to employ sabotage against the competition. There will be those that are willing to find the lowest-paid, part-time QA they can and pay them a bunch of $$$$ to introduce mites, or whatever else to the competition.

The QA's will also be the people responding to all patient complaints.....regardless of how great your company is, there will always be complaints. It is impossible to respond to complaints in a timely manner when you are only a part-time employee. This QA person is going to be part of the face of your business as they will be interacting with all patients that have concerns or complaints. IMO, you want to put some consideration into who deals with your patients and represents your company in this regard.

When you consider all of these things, it is in the LP's best interest to have a dedicated QA person that they trust regardless of what HC dictates. People are investing huge amounts of money and taking huge risks to become a LP, why would they want to try and cheap out/cut-corners on an integral part of their team? If they do, LP's are opening themselves up to all sorts of business risks.

 

[rnr]

yes experchem has lost a lot of l.p due to trying to do q.a for them all, lol
I agree PT is safe and fine if you have a small site and can prove what and when the QA will be there or how fast they can get there and being on call 24-7. if they are just working for you.
HC can not allow some PT then say no more, or disallow accepted PT QA and change rules mid application. its unlawful, keep pushing forward and doing what they want in allowed 2 week time lines

 

[Northernboyz]

This is another thing that I have thought of and that LP's should be considering. Even if part-time QA's were allowed, are you really willing to trust your entire business to someone that only works for you part time? Your entire license and application depend on having a proper QA person in place, what happens if they quit during or after the application process, or when they jump ship when they get a better offer?

Another great point you make is regarding the protection of proprietary secrets. Do you really want a QA person onsite that has very little allegiance to you or your company? This person could be associated with multiple LP's, and collecting and passing on all sorts of information. Not to mention there would be a HUGE opportunity for those with questionable morals to employ sabotage against the competition. There will be those that are willing to find the lowest-paid, part-time QA they can and pay them a bunch of $$$$ to introduce mites, or whatever else to the competition.

The QA's will also be the people responding to all patient complaints.....regardless of how great your company is, there will always be complaints. It is impossible to respond to complaints in a timely manner when you are only a part-time employee. This QA person is going to be part of the face of your business as they will be interacting with all patients that have concerns or complaints. IMO, you want to put some consideration into who deals with your patients and represents your company in this regard.

When you consider all of these things, it is in the LP's best interest to have a dedicated QA person that they trust regardless of what HC dictates. People are investing huge amounts of money and taking huge risks to become a LP, why would they want to try and cheap out/cut-corners on an integral part of their team? If they do, LP's are opening themselves up to all sorts of business risks.

Frankly, it isn't about whether or not we prefer a part time QA, it is that the requirements they will be fulfilling will not be a full time job if you are doing it properly. Setting out the SOP, ensuring practices are held to those procedures and auditing on an ongoing basis are the primary QC tasks and the QA will eventually be primarily dealing with test results and interpretations. Responding to a recall is hardly something that a telephone can't handle.

My point is that it is not reasonable but we still have to comply, which will make every small lp have to reconfigure their business model to ensure their capacity can pay for an extraordinary expense, which will definitely cull the flock. And our problem is we will all be hunting for the same "experts" in a two week timeframe. We have already put in a request for a reasonable extension and we will let you know if they allow it. If not, we scramble scramble!

 

[MMHot]

They have disallowed my QA but I went back with more information and it was accepted after two attempts. You just need to show them item by item how your QA person is the proper person for all these items (analytical, validation, SOPs, sanitation, complaint, recall, adverse). If you do that properly, they will not be able to refuse your QA person. Like the employee told me:"if you don't give us enough info then we cannot assume on your behalf. Plus we don't have you beside us when we read your documents. Ensure that we can assign each info to the right section of the MMPR". I have to say that this is a good advise!

As for the delay of two weeks, yes sometime it is very hard to meet. I requested more delays from time to time and got it. So you just need to ask. At least for me I was able to send an email and say I will send the info on that date and got an email from them saying thank you for the info it will be noted in your file.

 

[Devil Lettuce]

Frankly, it isn't about whether or not we prefer a part time QA, it is that the requirements they will be fulfilling will not be a full time job if you are doing it properly. Setting out the SOP, ensuring practices are held to those procedures and auditing on an ongoing basis are the primary QC tasks and the QA will eventually be primarily dealing with test results and interpretations. Responding to a recall is hardly something that a telephone can't handle.

My point is that it is not reasonable but we still have to comply, which will make every small lp have to reconfigure their business model to ensure their capacity can pay for an extraordinary expense, which will definitely cull the flock. And our problem is we will all be hunting for the same "experts" in a two week timeframe. We have already put in a request for a reasonable extension and we will let you know if they allow it. If not, we scramble scramble!

Good luck with the extension, and send me an email if you are needing someone.

For anyone looking for a qualified QA person with growing experience, I have decided to abandon my own LP plans and will instead be offering my services as a qualified QA person. I would be happy to provide details of my education and experience upon request. I am currently in Alberta, but I am willing to relocate if the right opportunity presents itself. I am currently employed in the QA field, so I am flexible with start times and such based on needs and the right opportunity. I also have some creative and flexible solutions that would benefit the needs of a small-scale LP facing this obstacle. If you are looking for someone, send me an email and we can go from there : CannabisQA @ mail.com

Good luck everyone!

 

[woodsmaneh!]

I think you are right that you can have a PT but than they can't be QA for any other company. What ever their logic? The letters our clients received says they can not use a PT QA, nothing about not doing it for more than one company. I feel it is just another tacit to weed out applicants. So now 5 companies need to find new QA's and that is just us. I know ExperChem has at lest 30 companies and only a few QA's. What about all the other companies like ExperChem? That leaves lots of people looking for QA's and they will lose their app if they don't find a replacement in two weeks. This effects all the little companies and does not effect big companies. Good time to be a QA. This is still changing the rules as everything was fine till last Friday. So now the price of QA just doubled or tripled or just is not an option for some they will be eliminated because of this ruling.

Unlawful, Health Canada, never. HC can do what ever they want and there is nothing anyone or any court can do.Law has nothing to do with this, HC makes the rules. Try to find any court judgement against HC from any business that has won, even when they are wrong they are still right. Now HC and the Charter is a whole different ball game.

Than again I have letters from HC saying LP's can not sell anything like grinders or vaporizers, but lots of sites are doing just that. I have a letter saying burning is an acceptably way to depose of cannabis, I also have one that says burning is not allowed. One thing for sure HC will keep us guessing for a long time.

 

[rnr]

imo woodsman, its location for burning, if your close to buildings prob no, if on large acreage prob allowed, in the middle of no were for sure.

 

[Agracan]

I have a very high up friend working with HC and the system, his #s are
765 apps in so far,
360 withdrawn or rejected
405 to deal with
-??? to cut due to PT- QA
we will see.......

these #s are hear say to me, from a good source so dought them or whatever......

Sounds very plausible.

 

[Mmpr613]

I have a very high up friend working with HC and the system, his #s are
765 apps in so far,
360 withdrawn or rejected
405 to deal with
-??? to cut due to PT- QA
we will see.......

these #s are hear say to me, from a good source so dought them or whatever......

These numbers are pretty accurate. The numbers we got are approx the same.

We would like to hear from more people that were rejected/denied. Sounds like there's a lot of you out there! Tell your story, what happened and why? And how far along we're you in the process ?

We haven't heard much from HC since our " done printed and filed" email a few weeks ago but whatever happens we will share.

[email protected]

 

[rnr]

im surprised they gave you any #s. I never got any when I asked, they said it was private info.
so far im still in the system, security checks stage.

 

[Mmpr613]

im surprised they gave you any #s. I never got any when I asked, they said it was private info.
so far im still in the system, security checks stage.

I got the numbers from my lawyer, not HC directly.

 

[Devil Lettuce]

Nice to see the RIU site back up and working, was beginning to think that the mega-producers and HC teamed up to have this thread shut down

 

[woodsmaneh!]

By the way if you got caught by HC in the part time QA net, if you get a new QA you have to submit a new QA report signed by the new QAP to HC.

 

[woodsmaneh!]

imo woodsman, its location for burning, if your close to buildings prob no, if on large acreage prob allowed, in the middle of no were for sure.

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.

 

[rnr]

well we will se what happens, im so far from anyone they should not have reason to deny me the rights to burn it when im 30km min from anyone or house.

 

[oddish]

well we will se what happens, im so far from anyone they should not have reason to deny me the rights to burn it when im 30km min from anyone or house.

They will have an issue with it due to your employees themselves being exposed to the burning or product.
Just spray it with something disgusting and dispose of it.

 

[Devil Lettuce]

They will have an issue with it due to your employees themselves being exposed to the burning or product.
Just spray it with something disgusting and dispose of it.

A mixture of kitty-litter/soil, water, and ground up plant material has been deemed an acceptable method of destruction. Cheap and easy, why not just go that route and not have to deal with burning? Once you start burning you have to deal with other regulating bodies and more red tape in many cases. You also have to address the chance of inhalation by the person/people doing the burning.

 

[itsmehigh]

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.

We will be using a bokashi process for our disposable, the benefit of this all our waste will be usable organic nutrients to reapply to our plants. No waste will leave the site, the city loves that fact.

Itsme.

 

[oddish]

Was the bokashi process approved by HC?