Contradict Much?...HC QAP Training Requirements.

[R.Raider]

Yeasterday I sent HC an email : "Hello, could you please provide me the specific details of training, experience and technical knowledge that the Quality Assurance Person must have?"

They sent me back :"Hello, Thank you for your interest in becoming a licensed producer under the Marihuana for Medical Purposes Regulations (MMPR).

Please note that there is no specific educational background or training required for a Quality Assurance Person by Health Canada."

Then their next sentence says: "As specified in the Marihuana for Medical Purposes Regulations (MMPR), each batch or lot of dried marihuana must be approved for release by the Licensed Producer’s Quality Assurance person, who must have the training, experience and technical knowledge relating to the activity conducted and the requirements of Division 4 of the MMPR."

What a bunch of ass clowns. I sent back the highlighted areas like I have here and asked "What exactly does this mean than?" No surprise I haven't heard back from them yet. Willing to bet it's likely because they don't know. I'll let you guys know what they say when I do here back though...idiots.

 

[WHATFG]

I'll take a stab at it!! LOL While they have no specific educational qualifications they require, it would appear that this person will have some kind of experience/education to be able to fulfill the requirements of the QAP. Having said that, if you can find someone to train you, you would most likely have the required training to fulfill the position. It appears as though the QAP is the person who is going to be responsible for what is going out the door. You do know this is all meant to frustrate, confuse, piss you off, so that you will throw your hands up and say enough of this madness!!

 

[Jack Harer]

I had to get a certificate of competency ($90 fee) to renew my business license years ago. That would usually involve paying the fee, taking a test and walking away being able to prove my competency. Come to find out, there WAS NO TEST to determine my competency in my line of work, so the clerk said Pay the fee, we'll renew you!.
I offered my "expert" services to write a test for the county (for an 80,000 consultation fee) after which I'd be happy to pay the fee and take the test.
They renewed my license, no test, no fee and unfortunately no consultation fee.

Seems like the same scenario!!!

Fuckin' gummint!!!

 

[R.Raider]

You do know this is all meant to frustrate, confuse, piss you off, so that you will throw your hands up and say enough of this madness!!

Yeah I do know but I'm going to try my best to make them give me more black and white answers. I know that's climbing a tall mountain but since all it's going to cost is effort, time and some emails I see nothing really to lose by trying.

 

[Jack Harer]

Establish your credentials and qualifications, and offer your professional services as a paid consultant to help them outline and devise a program to ascertain the qualifications of a QC specialists. $80, 000 was my price back in the early 90's....

 

[leaffan]

Yeasterday I sent HC an email : "Hello, could you please provide me the specific details of training, experience and technical knowledge that the Quality Assurance Person must have?"

They sent me back :"Hello, Thank you for your interest in becoming a licensed producer under the Marihuana for Medical Purposes Regulations (MMPR).

Please note that there is no specific educational background or training required for a Quality Assurance Person by Health Canada."

Then their next sentence says: "As specified in the Marihuana for Medical Purposes Regulations (MMPR), each batch or lot of dried marihuana must be approved for release by the Licensed Producer’s Quality Assurance person, who must have the training, experience and technical knowledge relating to the activity conducted and the requirements of Division 4 of the MMPR."

What a bunch of ass clowns. I sent back the highlighted areas like I have here and asked "What exactly does this mean than?" No surprise I haven't heard back from them yet. Willing to bet it's likely because they don't know. I'll let you guys know what they say when I do here back though...idiots.

Hey Raider,
I know you and others are very understandably frustrated with HC over the QAP issue.

One thing to keep in mind is that this is new for HC. They are trying to figure things out as they are processing applications. You won't hear it from them, but I believe their own possible liability is a key consideration (example provided further down). There are no certified QAPs for growing marijuana. The closest ones that would meet HC's designs would come from the Netherlands. So HC has to determine who is appropriate for this new designation. I believe they are being very cautious here. To date, I don't know of any applications that have got the ready to build authorization that are using an in house, non academic as their QAP. It seems HC wants to start with having an academic with lots of letters following their name as a QAP. I am sure HC will refine this ambiguous area in the future.
I'm not going to get in to a debate that the grower is the most qualified person for this role. There's two sides to a coin. Rather, I am saying what I think HC is looking for, and who they don't want to put in that position. I think liability is an issue.
I know of a few applicants that have received ready to build, and all have accredited academics as their QAPs. I know a couple very professional looking applicants that are trying to use themselves as their QAP, and they have not the green light, and worse communication with HC has been poor to say the least.
Asking applicants who have their ready to build approvals what they did for their QAP would be very useful information.

I believe HC is being very careful with their answers. They consider all aspects of liability before answering.
I know of an application that has been delayed because of some new security issues that were submitted, and not previously considered by HC. HC confirmed that this was the reason for the delay. They had to check with their lawyers, review all other applications, and come up with a response.

So hypothetically, lets say an applicant has stated that as part of their security measure they are going to install a smoke machine and a strobe light in case of a break in (yes those things do disorient people and buys time). HC hasn't seen this proposal from anybody else. They start by looking at their own liability concerns. If they approve those security measures, and there is a break in, and the person that broke in has a heart attack and dies, who is liable? If the security measures are approved and do prevent a break in, should all LPs be now be required to use these measures?...Liability is a very key issue.
I made up that scenario, but I hope it helps with understanding how HC views everything involved with the MMPR.

 

[R.Raider]

Hey Raider,
I know you and others are very understandably frustrated with HC over the QAP issue.

One thing to keep in mind is that this is new for HC. They are trying to figure things out as they are processing applications. You won't hear it from them, but I believe their own possible liability is a key consideration (example provided further down). There are no certified QAPs for growing marijuana. The closest ones that would meet HC's designs would come from the Netherlands. So HC has to determine who is appropriate for this new designation. I believe they are being very cautious here. To date, I don't know of any applications that have got the ready to build authorization that are using an in house, non academic as their QAP. It seems HC wants to start with having an academic with lots of letters following their name as a QAP. I am sure HC will refine this ambiguous area in the future.
I'm not going to get in to a debate that the grower is the most qualified person for this role. There's two sides to a coin. Rather, I am saying what I think HC is looking for, and who they don't want to put in that position. I think liability is an issue.
I know of a few applicants that have received ready to build, and all have accredited academics as their QAPs. I know a couple very professional looking applicants that are trying to use themselves as their QAP, and they have not the green light, and worse communication with HC has been poor to say the least.
Asking applicants who have their ready to build approvals what they did for their QAP would be very useful information.

I believe HC is being very careful with their answers. They consider all aspects of liability before answering.
I know of an application that has been delayed because of some new security issues that were submitted, and not previously considered by HC. HC confirmed that this was the reason for the delay. They had to check with their lawyers, review all other applications, and come up with a response.

So hypothetically, lets say an applicant has stated that as part of their security measure they are going to install a smoke machine and a strobe light in case of a break in (yes those things do disorient people and buys time). HC hasn't seen this proposal from anybody else. They start by looking at their own liability concerns. If they approve those security measures, and there is a break in, and the person that broke in has a heart attack and dies, who is liable? If the security measures are approved and do prevent a break in, should all LPs be now be required to use these measures?...Liability is a very key issue.
I made up that scenario, but I hope it helps with understanding how HC views everything involved with the MMPR.

Good answer thx man. Although I can't help but feeling for something as important as this that they should of had these details worked out before making the final announcement.

 

[Beaches Compassion]

Good answer thx man. Although I can't help but feeling for something as important as this that they should of had these details worked out before making the final announcement.

There are a lot of things they should have considered before putting in the MMRP but the government was under the gun to get something out , or all growing weed would be legal and we couldn't have that....so now these are all areas John Conroy can pick apart to have the program delayed in April.

 

[R.Raider]

There are a lot of things they should have considered before putting in the MMRP but the government was under the gun to get something out , or all growing weed would be legal and we couldn't have that....so now these are all areas John Conroy can pick apart to have the program delayed in April.

I gotta be honest I highly doubt that's going to happen but with that being said I certainly hope it does.

 

[ispice]

Its crazy, there is video evidence of the Peace Naturals facilities and it is operating under conditions that I believe easily contravene the MMPR. With exposed wooden roof rafters in one of their cultivation rooms, and their CEO sticking his nose directly on the top of a flower, gag inducing, how can the CEO, SPIC, and QAP defend or justify that?

 

[Kootenaygirl]

Another great find. Does R&D change the rules? That was real encouraging, we are light years ahead of that mess, wear a hardhat, but put your nose right on the bud? I would not have shown that to cameras, simply embarrassing, unbelievable, and they were proud of that. The marihuana that was showing was not even "happy to see me", and if you are a grower you will understand. And they are the best the LP's have to offer so far? That did not paint the sterile environment that I assumed HC would insist upon. That looked worse than some gorilla grows I've seen. They better pull up their panties fast if they want to compete.

 

[Beaches Compassion]

I gotta be honest I highly doubt that's going to happen but with that being said I certainly hope it does.

I just can't see how as of April 1st they are ready to pull the switch. The approval process for the LP's is taking longer then HC expected or planned on. Therefore will not be access for all Canadians needing MMJ as of April 1st. HC will have to formally extend the MMAR program past April 1st or risk the entire thing failing. Just my two cents.

 

[Kootenaygirl]

I agree, extend the deadline, but, HC will tell you there is plenty of marihuana for patients, just call the Pulp Pushers Syndicate, PPS/Cannimed.