Micro-class licensing webinar is pretty basic so far (not unexpected) but useful. It would be vastly more efficient (IMO) for @GovCanHealth to do one session in English and one in French. Jumping back and forth between languages to repeat things really disrupts the flow.
Health Canada confirms that new licencees can bring starting materials (eg, genetics/seed) in their possession into the legal system, irrespective of how those genetics were acquired.
No specific number of “starting materials” allowed - each applicant has to describe what they plan to bring in and @GovCanHealth will make a decision. Intention is starting material not (my example) fully mature plants.
Site of micro-license can also be your personal grow but must meet all regulatory requirements and must show how the personal/commercial are separated to satisfaction of Minister. (My assumption is that “site” is property not actual same physical building)
Only 30 micro licenses are in the queue now. Get your application in quickly to get reviewed quickly. No prioritization of submissions based on status of site/build.
Conversion from micro licensing to standard licensing would be a site change, new application required. Not restricted from doing it but some classes of licenses can’t be combined so have a look at that.
Biggest reason for slow processing is gaps in applications. Hard for HC to say where most are incomplete (due to few micros in) but in other types usually clear demonstration that applicant meets regulatory requirements (physical security, good production practices, record-keep).
First French question! Kindly asked in English too - is it 6 months to process micro applications? Benoit from HC says no specific timeline, each site/applicant different. Good quality application equals faster processing. Security clearances also not in them which can take time.
Ask about approved nutrient list: There is none. Go back to CFIA (fertilizer act), which has no specific cannabis class. Cannabis regulations also govern how things can be applied. Comply with both but there is not a list of approved nutrients.
Max output for micro-cultivator? HC: none. Area is regulated (200m2, indoor/outdoor/split, applies to only where plants are, but all plants including clones/moms).
Research class: how many application submitted and any reviewed? About 34 specific to research. (!) They are under review currently.
HC doesn’t tell you how to design your security; must restrict access.
Can person at location A apply for micro there and also apply at separate location? Yes. That person can’t have two micros at same site though; would need two locations.
No cap on number of licenses being issued.
No cap contemplated at this time. (KT: subtle reminder that elections matter).
There are guides being prepared for various aspects of the regulations. Not for SOPs because they are general - approved by QAP. There will be guidance in the good production practices guide.
Security clearance costs and how often need to be renewed? $1644 per application (per person, in other words) payable within 90 days of submitting. Validity period generally up to 5 years but can vary.
Last question: is painted drywall and painted concrete floor acceptable for micro? HC: materials not specified, up to applicant who must demonstrate ability to meet GPP and regulatory requirements including section 87 of regulations (re; hygiene/cleanliness)....
Questioner asks (paraphrasing): well if your product tests clean why does any of that matter? HC: it isn’t just about testing its about meeting GPP from A to Z. GPP/GMP are about systems and ensuring quality controls - can’t rely on testing only to identify all risks.
And that’s a wrap. Really commend @GovCanHealth on doing this. Suggest that the Q/A was the most valuable portion and it would be really incredible to have a longer session of dialogue/QA. Both applicants and HC would benefit from understanding each other’s challenges/goals.
