MMPR Grow op: Small Scale

Hi, I have not been to this forum for a long while and only until recently with the new MMPR I am interested to read more about it and when back here. After reading the new MMPR and all 24 pages here, I learned a lot more and I wanted to thank you, I also see some interesting cost analysis, however I have 4 questions and two issues concern me .

1. Do anyone have more info or links to the directive about the greenhouse restriction?
2. The MMPR talk a lot about license dealer... who is license dealer if you are suppose to just mail it to direct user?
3. When one apply for the license they have to state how much quantity of marihuana they are storing.. and does that only for dried marihuana, or does it include cannabis, seed and other?
4. I don't recall, but do we needed someone there 24 / 7 or just camera and a alarm company?

The first concern is the testing procedures. For THC/CBD testing, isn't it only be doable accurately by GS/MS or something similar? Well one suggestion is to send out to a lab, however that is not possible according to the directive unless they have a license. As the directive stated

Testing of dried marihuana can only be performed by the holder of a producer's licence under the MMPR or of a dealer's licence

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see http://www.hc-sc.gc.ca/dhp-mps/marihuana/info/techni-eng.php
So unless one could get the money for that and someone smart enough to do the test in house... or send to somewhere with license (who have such a lab) what is the other option for cheap?

Also the test needed "validation method". The directive stated : Validation means establishing documented evidence that will provide a high degree of assurance that the testing methods must consistently and reproducibly lead to the predetermined specifications and quality results in dried marihuana. Appropriate reference standards and controls should be included in each testing protocol, and LPs must maintain records summarizing testing protocols followed and detailed testing results for each batch or lot of finished dried marihuana.

So does the cheaper way if any, could be reproducibly?

But another question is for the rest of the test, could it be done on outside lab? Since the statement of only LP could test is only under THC / CBD test??

Second Concern is the security. According somewhere in MMPR, it say the Security have to also follows the security requirement of NCR or something.. (which is this directive http://Directive On Physical Security Requirements For Controlled Substances) so based on that it said it is considered Cannabis as $10,000/kg and your building have to be security based on the total amount in dollar of that substance in storage. However does this security consider only dried marihuana? Is the cannabis, seeds and stuff that you are growing in this weight too? If so isn't dried stuff much heavier? Also are we talking about stuff that is fully being stored, or even those that are waiting for the courier to pickup? And does this security measure including the area of the grow room? Because if it does, don't that mean you can't have greenhouse, since you can't have a opening of more than 6 inch at a time?

Just to add to this Q&A person.. according to the Drug and Health directive, this is what it said Q&A person mean.

Section 47 states
"Every natural health product shall be manufactured, packaged, labelled and stored by personnel who are qualified by education, training or experience to perform their respective tasks."
Section 51(1) states

1. "Every manufacturer, packager, labeller, importer and distributor shall
   • have a quality assurance person who
     • is responsible for assuring the quality of the natural health product before it is made available for sale, and
     • has the training, experience and technical knowledge relating to the activity conducted and the requirements of this Part; and
   • investigate and record every complaint received in respect of the quality of the natural health product and, if necessary, take corrective action".

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[FONT=.HelveticaNeueUI]Maybe a consultation company such as this may be of some help:[/FONT][FONT=.HelveticaNeueUI]
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[FONT=.HelveticaNeueUI]http://www.dsaconsultants.com/default.aspx[/FONT]
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[FONT=.HelveticaNeueUI]Not sure if they provide services regarding MMPR, but their website may provide some more info as to what the government may want/require[/FONT]

Greenhouses can be used with appropriate security. Openings only have to be secured. Physical barriers like bars, cameras, etc. Greenhouses can be secured. Just cost more.


Licensed Dealer might be a pharmacist.


Storing of marihuana “only drugs and drug formulations requiring storage in a vault or safe need to be used in the calculation” this is regarding the physical security of the controlled substance, under the Directive on physical security requirements for controlled substances(PSRCS), not your building which must follow the MMPR and the guidance document building and production security requirements for MMPR .


Crop value (while growing) is not calculated and therefore does not affect your security. Value of what is in your safe vault does. Marihuana value is based in weight dried. Seeds are valued at what strain and quantity. Reduce it to it`s value for (PSRCS) calculation.


24/7 monitored alarm system only, that calls a central monitoring station depending on security company. No human needs be onsite.


You do not need to have your marihuana tested to receive a production licence, only to sell it. Does the “test facility” need to have an LP or LD to handle the marihuana? Best question you asked. I dunno. Lol Still unsure of acceptable tests for HC too.


I assume that large facilities will do their own in-house testing. Even the largest current compassion clubs in California do their own testing.


I still think your looking at your QAP when your brushing your teeth unless your taking this on from zero experience or don`t brush your teeth.


Drug and health directive? We are subject to “the Food and Drug Act” not the “Food and Drug Regulations”. See Marihuana Excemption (Food and Act) regulations.


Hope my interpretations are right and that this helps you and others.

Hi Kootenaygirl, thanks for the information.

So based on what you said is that the building is needed to be secure based on the MMPR and only dried Marihuana needed to be stored in vault or safe.

As of the Drug and Health directive and the description of Q&A person in that directive is just a idea of what a Q&A person really should mean..

However I do understand that you don't needed to test to receive a license, however As the directive in previous post (see link in my previous post) does show that only people or company with LP or LD license could test THC and CBD before they are approved for sell... So I don't see anyway around it. It also needed to be reproducible, I guess for audit purpose?

Don't bother asking HC about the taxing of mm. They told us to ask revenue canada, of coarse. So spent the morning on speaker phone with Robert, Nicky and Karen and another guy I couldn't make out the name of, and all of their perspective automated machines, all from different tax branches. Isn't Canada Great.

First at Revenue Canada I was told by Robert (Ruling Officer) that it was taxable and that I should charge each provinces and Territories Federal tax (HST/GST). Seemed straightforward enough, though I already smelled something, it was a little too simple for tax code.

So I phoned the BC tax place, (whats it called), and talked with Nicky who told me that if a prescription was needed with the purchase then no provincial tax need be collected. If no prescription like from a sale from LP to LP then PST would be applied. Karen seemed pretty sure and we agreed with her interpretation.

So it made me think that the Federal Gov, might be the same, just that i didn't think to ask about prescriptions specifically. So I tryed to phone Robert back and got Karen instead, who I then explained everything to and she read us some stuff that made us think it would not be taxed as a prescription, but would be taxed everyother way of transacting it (like bc). Though she would not say it like I just did.

Now I am supposed to fax GST/HST Rulings and ask for a ruling. Are we really the first plow truck through again!!! This is getting old and we should expect it but we lose faith in all our gov.'s with every conversation. Waiting for our dedicated phone line to get hooked up for the security, so we can hook up the fax for awhile...fax really? What I realized was that to ship to another province we will have to get an answer from them too, how many p/t's are their?

Maybe you guys can help get an answer from your perspective p/t's about how they will tax and if a prescription has an affect on it. Post your results here for everyone and save us a few calls too. LOL.

Not sure what D H directive is. Help us, help you.

I would assume that these test places are all over this and that they know how to get within the rules , maybe they might become the Licensed Dealer LOL....

Please fax GST/HST Rulings at 604-658-8666 for me if your curious too. Ask them this:

As a Licensed Producer(LP) under the Marihuana for Medical Purposes Regulations(MMPR), when do I charge HST/GST on Medical Marihuana? As we interpret the federal rules, we should not charge GST/HST when sold with a prescription from a doctor or nurse practitioner, but should collect GST/HST when no prescription is involved, ie a sale between LP's or LP to pharmacist. We are asking for an official ruling on this matter, and want to thank you for your time in advance.

I would realy appreciate it if someone would fax this for me as this is my current website development hurdle, and I don't expect a faxline any time soon.

Also what does your p/t say about how they wiil tax in regard to prescriptions? Post your responses.

Talked to our regional district today. Was told they required no information from a LP. That I was to deal directly with HC. I also got called by BC Safety Authority. Need to have a Electrical Operations Permit. I thought the Electrical Contractor had done it when he applied for the Electrical permit. It can be cancelled if you no longer need it. I am sure everyone has their's as well!

I am talking about this http://www.hc-sc.gc.ca/dhp-mps/marihuana/info/techni-eng.php, this was the testing procedure for the MMPR

under number 5 and under MMPR s53 (2) it say only LP and LD can do the test

BTW anyone knows the destruction procedure?

As far as testing goes at the front of the regulations it states which people can possess cannabis and it says a analyst for purpose and connection if their employment.
Doubt they would risk it but its in their.

I think what you referring is this line

a person who is employed as an inspector, an analyst, a peace officer, a member of the Royal Canadian Mounted Police or a member of the technical or scientific staff of a department of the government of Canada or of a province and who possesses the cannabis for the purposes of and in connection with their employment;

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What I understand from this line is if the those people are part of the government like an analyst for the government.. not a private analyst. Technically the line should be read like this

a person who is employed as an inspector, an analyst, a peace officer, a member of the Royal Canadian Mounted Police or a member of the technical or scientific staff

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of a department of the government of Canada or of a province and who possesses the cannabis for the purposes of and in connection with their employment;

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Anyone wanted to comment on this?

I think you might be right but it does have or after RCMP which would indicate everything before it a list not relevant to theafter mentioned subject.

Kootenaygirl said:

Please fax GST/HST Rulings at 604-658-8666 for me if your curious too. Ask them this:

As a Licensed Producer(LP) under the Marihuana for Medical Purposes Regulations(MMPR), when do I charge HST/GST on Medical Marihuana? As we interpret the federal rules, we should not charge GST/HST when sold with a prescription from a doctor or nurse practitioner, but should collect GST/HST when no prescription is involved, ie a sale between LP's or LP to pharmacist. We are asking for an official ruling on this matter, and want to thank you for your time in advance.

I would realy appreciate it if someone would fax this for me as this is my current website development hurdle, and I don't expect a faxline any time soon.

Also what does your p/t say about how they wiil tax in regard to prescriptions? Post your responses.

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Please correct me if Im wrong, But are not all prescription medications taxed? I have a drug plan through my work so I cant even remember the last time I paid for medication.

Are you familiar with Ted Smith of the Cannbis Buyers Club and the ordeal he went through with CRA? To be safe, I would be charging tax on all sales for patients and dealers/LP's alike.

mr.weeds said:

As far as testing goes at the front of the regulations it states which people can possess cannabis and it says a analyst for purpose and connection if their employment.
Doubt they would risk it but its in their.

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Any lab that wishes to perform testing in regards to cannabis will have to get a license, instead of for the purpose of production, it will be for in-vitro(?) analysis.

According to my pharmacy bill for other meds.... There are no tax for the prescription drug, that is including the drug itself and the dispense fee.. You just pay the sum of both combined..

Anyone know if the shipping procedure have to follow the same fashion as other Control Substances? Like for example label with Control Substance, notify the shipping company that it is a drug and etc.

If that is the case, I was told by my friend who works in FedEx, it cost more for the shipment than regular shipment.

westcoast420 said:

So before people start getting all mad about my comment, it was more of a joke, obviously.. but in all seriousness the whole part about a QA person is a joke! I have read the regs, several times. I find it funny how they say this QA person should have the training and knowledge to assess the product and test it etc and yet they dont list any requirements this person needs to have. Honestly I believe HC is just putting up a front like you need to have scientists as QA person when in actuality someone with general growing experience and can use a THC test kit will be fine. I believe all they truly care about is your security measures. Even the part about testing for pesticides makes no sense, they say it must be below exceptable levels as laid out in the FDA, except there are no specific levels for medical marijuana as its a health product not a food product. Wow HC makes me mad

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This is what I was talking about way earlier in the thread.... it's a very vague directive and meant to be because it leaves the door wide open for approving or declining applications. It's a old trick found in a lot of government guidlines , where they need to be judicious... Eventually, one people find out that they've been discriminated against (as word spread fast in small communities like this) the gov will be made to spell out in great detail what is required, but until then it will be a tool they use... standard MO shit...

Kootenaygirl said:

I did go to my insurance broker about 2 months ago and she already had companies that would insure me. What we found was that in the fine print the insurance covered very little. No theft, no crop insurance, no water damage, really all it covered was the building and liability. The insurance was expensive, we insure this building, (empty) now for about 300 per year ( not exact because it is tied to our home insurance currently). We would expect the same building to cost with a business over 5000 per year up and running. The building we have is about 3000 sqft and not a greenhouse.

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Your responses are very well thought out Kootenaygirl. I am in the insurance industry. If you have a quote that covers liability and the building, to me, those are the two most important coverages. Everything in between wouldn't matter to me. If I mess up a cycle due to my own error, I'm willing to absorb that myself. If I was sued and found liable for making someone sick, it might be difficult to absorb a lawsuit of that magnitude.

Gquebed said:

This is what I was talking about way earlier in the thread.... it's a very vague directive and meant to be because it leaves the door wide open for approving or declining applications. It's a old trick found in a lot of government guidlines , where they need to be judicious... Eventually, one people find out that they've been discriminated against (as word spread fast in small communities like this) the gov will be made to spell out in great detail what is required, but until then it will be a tool they use... standard MO shit...

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If you are going for your LP app - You'd want to make sure to hire a QA that would have "reasonable" experience so they can't decline it - There are plant based QA people out there