Good Production Practices (GPP) are the rules that you must follow to produce cannabis products in a safe and sanitary environment. They’re designed to ensure that your facility stays clean, safe, and secure for both you and your employees. Having GPP protocols in place is essential for maintaining compliance with Health Canada regulations.
What are Good Production Practices?
Good Production Practices (GPP) are a set of rules that apply to growing, processing, and packaging cannabis products. They’re designed to ensure that cannabis products are produced, packaged, and stored in a way that minimizes contamination and keeps the product safe for consumers.
Health Canada’s GPP program requires licensed producers to:
Ensure the quality of their product from seed to sale;
Establish programs for quality control testing throughout the production process;
Follow strict sanitation procedures at all stages of production;
Good Production Practices – What Does Health Canada Look For?
Federally regulated holders of a licence under the Cannabis Act must meet the requirements of Part 5: Good Production Practices (GPP) of the Cannabis Regulations. GPPs cover activities in the operations which may be points where possible contamination can be introduced into processes and ultimately compromise product quality and safety.
When it comes to Good Production Practices in a facility, Health Canada looks for two things.
- Is there a written program for the required GPPs?
- Is the written program being followed and properly documented?
Is there a written program for the required GPPs?
Different license classes and different classes of cannabis products have different GPP requirements. There are general GPP requirements for sale, distribution and export of cannabis. There are additional requirements for processing activities to produce for sale, distribution and export. There are testing requirements for products prior to release for sale.
Appendix A and B of Health Canada’s Good Production Practices Guide summarizes GPP requirements by license class and cannabis class. Not all GPPs are required for each type of license class, only those that are applicable. For example, all license classes require GPPs for Standard Operating Procedures (SOPs), storage, distribution and air filtration system but Sale for Medical Purposes License class does not require a sanitation program, equipment and conveyances and separation of incompatible activities.
A GPP report is submitted during licensing stage which identifies the GPPs necessary for your license class and cannabis products. As written programs such as GPP reports are living documents, it is important for program customization to fit the form, function, and flow of your approved building and operations.
Is the written program being followed and properly documented?
It is not enough to have a written program on file. Once you are operating, Health Canada inspectors will verify whether GPPs written are implemented in day-to-day operations, and are properly recorded following Good Documentation Practices.
If a program is implemented but not documented, this will be non-compliant. If a program is not implemented as described, this will be non-compliant. Health Canada will expect you to implement what you wrote in your program.
Good Production Practices program implementation:
Program implementation and documentation pose challenges during operations. Often, record keeping becomes onerous and GPPs are viewed as hindrances to success instead of tools to ensure compliance and product safety. A burdensome GPP program is an indication that the program is not tailored to fit your operations. Anything that does not fit eventually leads to problems. In this case, required GPPs cannot be consistently followed and documented.
Time should be taken to review and streamline the program accordingly to avoid and overcome these situations. A well-written, tailored program for your cannabis operations will assure safe and compliant products, safeguard your cannabis license and make operations efficient.
Rules for Good Production Practices
The Nurseries, Nursery Stock, and Floriculture Production Regulations prohibit the sale of certain plants that have not been grown in accordance with the regulations.
These regulations state that growers must use proper cleaning and sanitizing practices for all equipment used in propagating, growing, or packaging plants. All waste materials must be disposed of properly to avoid contamination of growing areas (such as the floor drains). Waste materials may also include used plant pots and any other items used during production or packing operations. Plant waste includes crop residues such as leaves or stems that are removed during harvest but not used as part of a composting operation.
Health Canada requires a preventative measures program (PMP) to be in place for all operations that are considered high-risk. A PMP is an approach to managing hazards and controls that are designed to prevent food safety risks from occurring or continuing.
A PMP can include a variety of activities, such as:
Establishing documented procedures and programs throughout your supply chain to ensure food safety at each step along the way;
Training employees on ways they can help prevent food safety issues;
Creating policies and procedures related to GMPs, product recall management plans (PRMPs), traceability systems, and other tools that help you reduce risk in your facility.
Contamination control is a key part of GPP. You can think of it as preventing contamination and cleaning up after contamination.
But keep in mind: contamination control isn’t just about cleaning up after contamination. It also involves preventing the spread of pathogens, which means keeping them from your product in the first place!
Record keeping is an important component of good production practices. You should keep records of all your activities, including:
The actions you take to prevent contamination.
How you monitor your facility and its conditions at different stages of production.
How you monitor employees’ personal hygiene practices, such as hand washing before entering a clean room or changing into sterile clothing before entering the clean room.
How you test products for contamination prior to release from your facility (for example, by testing product samples in which small amounts of pathogenic organisms are added).
Maintaining a Clean Facility
Maintaining a clean facility is an important part of good production practices. Health Canada will be inspecting your facility to make sure it’s easy to clean and the equipment is in good condition.
Cleanliness is also important for preventing the contamination of cannabis products. The last thing you want to happen is for someone at the store to pick up their favorite strain of weed only to find out it has been contaminated with bacteria or mould because your facility wasn’t clean enough!
Here are some tips on how to keep a clean facility:
Understanding the rules for Good Production Practices can help keep your cannabis facility compliant with Health Canada.
The term “Good Production Practices” (GPP) refers to a set of rules that are designed to keep your facility and products safe. GPP is intended to prevent contamination, ensure cleanliness and prevent product diversion. In addition, your employees must be trained in GPP so that they understand what is expected of them, both as part of their job and when interacting with other employees or clients.
How We Can Help?
It is important to understand that GPP is a requirement for every licensed producer and it is their responsibility to follow these rules. Understanding how this process works will help you make sure your company stays compliant with Health Canada regulations.
Cannabis Licensing Experts can assist you in gap assessment, program review, and program development customized for your cannabis facility and operations.