So, you’re interested in starting a cannabis business and you’ve secured a facility for your operations. You might now be asking yourself, “What’s next?”. While there are still quite a few steps before you are up and running, obtaining a cannabis licence from Health Canada is a big one. A major part of the application criteria is demonstrating that your site is compliant with Good Production Practices (GPP). You will have to demonstrate your sites’ GPP compliance on paper and visually through a “Site Evidence Package”. This is a combination of video and photographic evidence. If you’re wondering what GPP is and why it’s such a big deal, the experts at Cannabis License Experts can help explain.
Good Production Practices is the current standard required by Canadian Licensed Producers of cannabis under Part 5 of the Cannabis Regulations. Part 5 of the Cannabis Regulations requires licence holders to follow GPP to help ensure cannabis is produced consistently and that all activities conducted by licence holders with cannabis meet the appropriate quality standards. GPP requires Licensed Producers to have a quality system in place which includes written Standard Operating Procedures (SOPs), a sanitation program, recall procedures, properly maintained and calibrated equipment, trained and qualified employees, and more. Facilities must also be constructed to meet GPP standards to ensure cannabis is produced in a contamination-free environment so that will maintain its quality.
With this in mind, we’ve put together a list of our top 10 GPP considerations for building out your cannabis facility to help you stay compliant with the regulations and successfully obtain a cannabis licence for your business.
1. ROOMS AND SPACES
Before starting any kind of construction, you should have a plan and/or design of what you want your facility to look like, including the various rooms and spaces that will be present. Some rooms and spaces will vary based on the licence type, while others will be the same, regardless of the licence type or activities you will be conducting. For example, some common areas that all cannabis facilities will need to include are a shipping/receiving area, a non-cannabis storage room, a secure storage room, wash-up/cleaning station(s) and a mechanical/IT room. However, those who are looking to grow cannabis and seeking a cultivation licence (standard or micro) will need rooms/areas for cloning, mothering, vegetation, flowering, trimming and drying. Those who are looking to process cannabis and seeking a processing licence, standard or micro, may need rooms/areas for packaging, extraction, and manufacturing cannabis products such as edibles or topicals. It’s important that you consider all of the different spaces you’ll need so that you can plan ahead and have an efficient, well-designed facility.
2. PRODUCT AND PERSONNEL FLOW
When considering the design of your facility, two important things to keep in mind are product flow and personnel flow. Once you know which rooms and areas your facility will need, you will need to consider their placement. Your facility should be designed in a manner that allows orderly workflow and adequate space for the movement of cannabis products and employees. For example, if you are planning on cultivating cannabis at your facility, it wouldn’t make sense to have vegetation rooms at one end of your facility and flowering rooms at the other end of your facility. Rather, these rooms should be in close proximity as you want to minimize the distance plants have to travel from one room to the next throughout the production process. Your facility design should also provide sufficient storage space to keep all areas neat and orderly. This will minimize the risk of any contamination or mix-ups.
3. SURFACES (WALLS, FLOORS, CEILINGS)
Once you start building out or retrofitting your facility, you’ll want to pay close attention to all of the surfaces within your building as well as doors, windows, pipes, light fittings and ventilation points. Floors, ceilings, and walls of all GPP/production areas must be hard and non-porous, chemically resistant to degradation from disinfectant chemicals, non-absorbent, free of cracks and crevices, sealed, durable/non-shedding and cleanable. Some material and coating options for achieving this include clean room/refrigeration panels, fibre-reinforced plastic, polyvinylchloride (PVC), stainless steel, polyurethane, and epoxy coating. Bricks and/or cement blocks are permitted in the GPP/production area but must be sealed with a non-porous/non-shedding material such as epoxy coating. Also, cleanroom coving can be used for wall-to-wall, wall-to-ceiling and wall-to-floor junctions to create a continuous surface that allows for effective room cleaning. Sealed doors should be used to separate the GPP/production and non-production areas. When it comes to other items such as pipes and exposed air ducts, we highly recommend you cover them up with a wall/ceiling if possible. They are potential sources of contamination and if they are not covered, you will need some strict sanitation procedures in place to explain how they will not effect your product!
4. HVAC AND AIR FILTRATION
A good HVAC/air filtration system is crucial for protecting your cannabis from contamination as well as maintaining its quality. The building or part of the building used for production, packaging, labelling and storage of cannabis must be equipped with an adequate ventilation system that is capable of maintaining the air quality within it. Furthermore, the HVAC/air filtration system must eliminate any airborne contamination in the form of mould, yeast, bacteria, pests, or pollen and prevent the escape of odours from the building. All air entering the cannabis production areas of the facility should be filtered using HEPA filters. All air exiting the cannabis production areas should be filtered through strategically placed activated carbon and HEPA filters to remove odours. Air quality throughout the building should be controlled through the use of general air handling units.
In order to additionally reduce the risk of contamination or extraneous substances being added to the cannabis, all cannabis production rooms can be kept at positive pressure. Air intakes will be located away from sources of contamination such as exhaust. Controls for temperature, humidity and lighting must be in place and must be monitored using calibrated monitoring devices.
5. PEST CONTROL
Preventing pest entry is the most effective means of control. Therefore, when building out or retrofitting your site, ensure all areas are designed and constructed to minimize the possible entry of pests. In addition to good design, an effective pest control program will need to be in place to prevent the entry of pests to any part of the building (e.g. glue boards and fly lights placed around the non-production areas of the facility and building perimeter), to detect and eliminate pests and to prevent the contamination of cannabis.
6. WATER SUPPLY
Your facility’s water supply will be used for many different activities, including irrigation of plants, sanitation of your facility and equipment, and processing. Thus, it’s very important your water is clean, safe, and will not contaminate your cannabis product. Therefore, when designing and building out your facility, you must ensure there is a potable water source that is available in sufficient volume to support the sanitary operation of the facility. Keep in mind that if the source of water is not municipal water, you will need to provide evidence to Health Canada that the water is appropriate for the activities being conducted in the facility. Some additional measures you can take to ensure your water is potable and of drinking quality includes adding a UV light and/or reverse osmosis water filtration system. The water supply must be appropriate for the intended use and must be of a quantity and pressure sufficient for the operational needs of the site.
Lights are a big part of any cannabis business, especially for cultivation. There are many different options on the market right now, such as CFLs (compact fluorescent lights), HPSs (high pressure sodium lights), MH (metal halide) lights, and LED lights. No matter what type of lights you’re using, it’s important they are not a source of contamination to your cannabis product. When applying for your cannabis licence, you will need to demonstrate that your lights are either constructed with shatter resistant materials or are shielded with safety covers in case of breakage. Furthermore, you will need to demonstrate said light fixtures can withstand repeated cleaning and sanitizing to prevent contamination of the cannabis. It’s important you consider this when building out your facility to ensure your lights are compliant with GPP standards and Health Canada’s requirements. This requirement applies to all lights used in the GPP/production area, not just lights that are used for cultivation of cannabis.
When planning and designing your cannabis facility, another important thing to consider is the placement of your production equipment. Production equipment must be designed, constructed, installed, and maintained to facilitate cleaning, sanitizing, and inspection of the equipment and surrounding areas. As well, equipment must be stored in clean and dry conditions that optimize the flow of material while minimizing the movement of personnel. Some pieces of equipment will certainly be larger than others (ex. extraction equipment that will be used to produce cannabis extracts or manufacturing lines and conveyances). Other smaller pieces of equipment can be stored away in non-cannabis storage and can be transported to the operations area as needed. Take some time prior to building out or retrofitting your facility to decide on the placement and organization of equipment. Ensure the placement of each piece of equipment makes sense with personnel flow and product flow, and that the equipment is accessible for cleaning and for inspectors to examine.
Having a sanitation program in place is a key part of GPP. Your facility, along with your equipment, is subject to follow a strict and regular sanitation regimen. How your facility is designed and constructed can play a big role in the ease or difficulty of following this regimen. For example, constructing your rooms with floor drains and traps can save a significant amount of time and work when cleaning, as surfaces such as floors and walls can be mopped down quickly and excess water squeegeed down the floor drain. Additionally, constructing your facility so that things such as air ducts and pipes are hidden will not only save you time and effort, but it will also save you from answering questions during the application review process and inspection, as you will not have to explain how all of those pieces will be cleaned. By covering them up with a wall or ceiling, you simply follow the same procedures as for regular room cleaning. Your facility should also be constructed with adequate hand cleaning and sanitizing stations for personnel, as well as sinks and wash stations for equipment.
10. WORK WITH AN EXPERT TO HOLD A GPP AUDIT OF YOUR SITE
Once your site is built out and ready to go, a third-party pre-assessment or mock audit can be very helpful to test the preparedness of your site before the actual audit by Health Canada. In a third-party pre-assessment or mock audit, an external company would visit and evaluate your site to the specific GPP standards, and provide a formal report listing any deficiencies found during the assessment, as well as guidance on how to fix them. The purpose of bringing in an external company is to provide an unbiased perspective on your site and its current practices. The ultimate benefit of a third-party audit is for you to gain an understanding of where your team stands in terms of compliance, and address any concerns in regards to the facility design and construction, prior to submitting your licence application to Health Canada. The experts at CLE offer site audit services and can help guide you to ensure your facility meets the necessary GPP standards.
There you have it – our Top 10 GPP considerations for building out your cannabis facility. Contact us today for a free consultation and let us help you get started on the path to securing your licence!