When I started writing I didn't realize there was no limit to an LP, and wanted to show the thought process behind my understanding for others. "Angle" was not meant in a derogatory way, only to help me and others get a grasp.
Hey Kron, seems like the labs have alot to say about QA, why is that? What did you mean when you said the QAP could decide if a test was necessary? One Lab offered to be our QAP and/or train one for $20,000. Does this seem right from your perspective? We've had estimates ranging from 25g samples for $2400 per test to 100g samples for $6000 with pesticides test. What would all be up to the QAP in regards to the testing? Sounds like the 3rd degree it's not, I would say you do know what your talking about from all of my own findings and really just want to understand this part better.
Well a really good carbon filter system, assuming the airflow in the area is created properly,
oh and this is for any readers:
I just finished completely reading through the MMPR and tbh under my understanding it is very well put together and will be a very large benefit to Marijuana producers and consumers in the future, it is also beneficial to people who are not affiliated with marijuana.
In terms of problems getting a grow op up and running: Security, Testing, Quality Assurance.
Security in being construction of a vault, implemantation of secruity systems which can be found online or companies available to install systems which need to cover the exterior perimeter, the interior of the entire compound, motion sensors in vault room, MORE IS BETTER, padlocks, access for authroized personel only.
6.2. Secure Environs (Vault)
6.2.1 . Walls
Cement Block
30 cm (12") high density cement blocks with cores filled with type "M" mortar and reinforced to meet structural codes, or
Solid wooden door wrapped with 1.5 mm (16 gauge) steel and a 1.9 mm (14 gauge) metal frame.
Secured with an approved padlock (See Appendix E) and hasp. A multibolt lock system may be considered equivalent by the Bureau.
Testing, according to people there are solutions and there most definatley is, and in the future march 2014++ there will hopefully be many more solutions to it.
Quality Assurance, here's a tuffy because there are no set guidlines as to whom is deemed worthy, but it is also a pretty general topic to be covered, if steps/plan/method, is created in a form of a template covering all aspects of the Licsenced Producer with a measuring system of efficiency, sanitation, documentation. From my understand of going through the MMRP thats all that seems to be required and all in all the terms of it seem pretty laid back.
My question: After reading through I've seen nothing mentioning which zoning etc is needed or required, but instead look to your municipality. Just wondering if anyone here knows what type of zoning you're confined to etc...
Are these the requirements for where the vault or safe would be or for the growing facility? If that`s for the growing facilities that would sure suck. That would eliminate barns, pre-fabs, quonsets and etc. Would pretty much have to build than. Just finding one with proper zoning would be pretty hard I imagine.
No, this is what the vault has to be constructed of. From what I've read it seems like they want it to be like fresh, clean, SECURE, strong, supervized area, IDK if a barn on a farm would pass unless its renovated.
A bunch of quonsets would be so amazing, surrounded by barb wire fencing.
Also I put a vault there, because if you plan on having 55lbs in storage you would have to build concrete walls around the safe+cage/fence, i think this way you can avoid having to build big concrete walls to surround the safe+fence/cage.
Also I put a vault there, because if you plan on having 55lbs in storage you would have to build concrete walls around the safe+cage/fence, i think this way you can avoid having to build big concrete walls to surround the safe+fence/cage.
Yeah that`s totally understandable. I was worried that those were requirements for the growing facility, in which case I`d be fucked and have to consider throwing in the towel.
51 commercial grow op are being licensed from what I've read on their site. Do the math for 30,000 people, Grow ops will be the size of warehouse's and will support 600 patients. Prairie Plant here in Sask. supplies HC now for all of Canada, is approx. the size of a regulation football field and they are planning on expanding to meet the need. I'm not sure what the thought pattern is here but if you think you will get a license in a smaller operation you will be sadly mistaken. HC has written it this way to muddy the waters so to speak. if your not planning on 600 patients then don't waste your time, effort, and money because that is exactly what our government wants...to side track you while they bend you over.
51 commercial grow op are being licensed from what I've read on their site. Do the math for 30,000 people, Grow ops will be the size of warehouse's and will support 600 patients. Prairie Plant here in Sask. supplies HC now for all of Canada, is approx. the size of a regulation football field and they are planning on expanding to meet the need. I'm not sure what the thought pattern is here but if you think you will get a license in a smaller operation you will be sadly mistaken. HC has written it this way to muddy the waters so to speak. if your not planning on 600 patients then don't waste your time, effort, and money because that is exactly what our government wants...to side track you while they bend you over.
Plus that "51 grow ops" thing was proven to be false months ago. Sir ganga obviously hasn't been keeping up to date with things even though he talks outta of his ass like he is. Lots of misinformation from him regarding MMPR lately. The worst part is he acts like his misinformation are facts rather than his own opinions. Easy to see how rumours get started that's for sure.
Plus that "51 grow ops" thing was proven to be false months ago. Sir ganga obviously hasn't been keeping up to date with things even though he talks outta of his ass like he is. Lots of misinformation from him regarding MMPR lately. The worst part is he acts like his misinformation are facts rather than his own opinions. Easy to see how rumours get started that's for sure.
Hey Kron, seems like the labs have alot to say about QA, why is that? What did you mean when you said the QAP could decide if a test was necessary? One Lab offered to be our QAP and/or train one for $20,000. Does this seem right from your perspective? We've had estimates ranging from 25g samples for $2400 per test to 100g samples for $6000 with pesticides test. What would all be up to the QAP in regards to the testing? Sounds like the 3rd degree it's not, I would say you do know what your talking about from all of my own findings and really just want to understand this part better.
I would be a little hesitant to have a third party lab be your QAP. I say this mainly because the QA person has to write the QA report that includes a lot of details that would be difficult to know unless you were intimately involved. I guess if you were to go this route you would have to write it and just get them to review and approve it, as for the SOPs etc. Personally, I would be much more comfortable having the QA person on site and a little more involved. As for the training cost you mention, I dont really know what the going rate would be so I cant really comment. I would definitely ask for more details about what would be covered in the training though.
As for the role of the QA person choosing what tests are needed, it is the role of the QAP to interpret the requirements listed in the pharmacopoeia (whichever text you select from schedule B) and ensure that appropriate tests are done. In the pharmacopoeias, they state that other methods can be used if they are shown to be sufficiently accurate and reproducible. The QA person could select to use an alternate test than the one listed in the pharmacopoeia, but they are responsible for this decision. An example from one of my previous posts is the Aflatoxin test. In the pharmacopoeias, they describe an HPLC method for the quantification of aflatoxin B, but we are leaning towards an immunochemical ELISA assay. We have made this decision for a couple reasons; 1) the ELISA test comes with pre-formulated standards. The HPLC test would require handling the pure compound to make your own standards. These are highly carcinogenic compounds so we have decided to minimize employee contact by using this method, 2) it uses a microplate reader so it does not tie up the HPLC that is also needed for THC/CBD, 3) the HPLC method requires post column derivitization which adds extra components and technical challenges (derivitization can be problematic). Ultimately, the SOPs, tests, etc. all have to be signed off by the QAP who is ultimately responsible for them. You will also notice that the pharmacopoeias are written in a fairly vague manner regarding what tests are needed, especially in this case as there is no monograph specifically for Cannabis in any of them. HC has pretty much washed their hands of responsibility by directing you to the schedule B documents and putting the onus on the QAP to ensure that you meet these requirements. The vagueness of these documents leave a lot of room for interpretation, and it is not always clear if and which tests are really required. There are several areas where multiple choices are valid and some would be better in different situations; this is why the QAP needs to be "qualified" to ensure that an appropriate method is used.
Regarding the prices you have been quoted, you need to find out what methods they are using and if they meet the requirements outlined in the schedule B document you have selected to use. Each of the tests in the pharmacopoeia will state how large the samples need to be, so if you add them up you should get a sense of how much they should need. You would also need to send sub-samples of each batch for the statistical side of things, which I believe are described in the documents. One thing you should ask is what pesticides they plan to test for. The reality is that there are thousands of "pesticides" and there is no single method that tests for them all. In the case of Cannabis, there are no registered pesticides, and from my interpretation there is currently no need to test for residues. If pesticides are registered later, then you may need to test for the specific compounds, but if you dont use them you may not need to test for them given that it has been produced using GAP that is fully documented. If a company offers to test for pesticides in such general terms without asking which kinds you are looking for I would be concerned. They may have a method that tests for a wide range of common ones, but it seems to me that they are just trying to run extra tests for you as a cash grab IMO.
Here is a link to the World Health Organizations "Quality control methods for herbal materials", which is listed in the pharmacopoeia internationalis (international pharmacopoeia), a schedule B document for some guidance on sampling etc.:
thanks kron, still digesting what you said and trying to read some of the link. 139 pages of the dryest reading available. This will take me awhile. lol.
