The success of a Cannabis Processor relies heavily on their Quality Assurance Person (QAP). Under the Cannabis Act & Regulations, a holder of a licence for processing must retain the services of one individual as a Quality Assurance Person who has the training, experience and technical knowledge related to the requirements of Part 5 of the Cannabis Regulations (otherwise known as “Good Production Practices”).
- The QAP is responsible for assuring the quality of the cannabis product before it is made available for sale;
- and investigating every complaint received with respect to the quality of the cannabis;
- as well as taking any necessary corrective and preventative measures;
- The QAP is also responsible for the implementation and maintenance of the overall Quality Management System (QMS) at your facility.
Clearly, the QAP is responsible for a significant portion of business operations. Therefore, it’s important that the chosen QAP has a strong educational background with relevant hands-on training. At minimum, they should possess a degree in a field of science related to the work to be carried out (agriculture, biology, chemistry, etc.).
The degree should have been awarded by a Canadian university or, if granted by a foreign university, that it is recognized by a Canadian university or a Canadian professional association. Furthermore, they should have additional training or education on quality assurance operations. This can be achieved through post-graduate certificate programs, such as the one offered by Seneca College in Toronto (Pharmaceutical Regulatory Affairs and Quality Operations), or through training programs and seminars, such as those offered by the Academy of Applied Pharmaceuticals Sciences (AAPS) in North York. The more supporting education and knowledge they have, the better!
Another important point to consider is that your QAP should have applicable experience which relates to the product classes and activities under your cannabis licence. For example, if you are making edibles, you will need an individual who has experience with Food Safety and Preventive Control Plans (PCP). Likewise, if you are producing cannabis extracts, your QAP should have the technical knowledge and experience required to conduct extractions.
Preventive Control Plans:
Preventive Control Plans require expertise in quality assurance. Therefore, your PCP must be reviewed, acknowledged and approved by your Quality Assurance Person (QAP), who oversees the production processes and can monitor the safety of your product(s). Keep in mind, you must re-evaluate the PCP when there are changes made to any critical parameter at the time of implementation. This can include modifications to the process, components/ingredients, regulatory constraints, preparations, etc.
The Quality Assurance Person needs to be a great leader:
Ultimately, your QAP will be in charge of ensuring the quality of your cannabis products before they are made available for sale. This means they will be leading your team in quality and compliance throughout the entire production process. Therefore, it is crucial they are able to demonstrate good leadership and problem-solving skills. The ideal QAP will have experience leading and/or training a team of individuals in quality assurance or quality control. Furthermore, the QAP will often have to make tough decisions based on opinions that may differ from the ones upper management has. This will involve strong critical thinking and problem-solving skills, and your QAP should not be afraid to speak up and voice their opinion.
What else is the Quality Assurance Person responsible for?
Here are some of the key duties of a Quality Assurance Person in a cannabis processing business:
- Stay current with all relevant regulations and guidelines from health authorities, such as Health Canada, and ensure the company’s operations are in full compliance.
- Develop and maintain a deep understanding of the specific regulations and requirements that pertain to the cannabis industry.
Standard Operating Procedures (SOPs):
- Develop, implement, and maintain detailed Standard Operating Procedures (SOPs) for all aspects of production, processing, packaging, and labeling to ensure consistency and quality.
Quality Control Measures:
- Establish and oversee quality control measures and protocols at every stage of production to ensure that products meet established specifications and quality standards.
Batch Testing and Analysis:
- Coordinate and oversee the testing of cannabis products at various stages to ensure they meet potency, purity, and safety requirements. This includes collaborating with external laboratories for testing.
- Define and maintain product specifications, including criteria for appearance, potency, purity, and other quality attributes.
Documentation and Record-Keeping:
- Maintain accurate and detailed records of all production processes, test results, and quality control measures. This documentation is crucial for regulatory compliance and traceability.
- Conduct regular internal audits to evaluate the effectiveness of quality assurance processes and identify areas for improvement.
Supplier and Material Qualification:
- Establish criteria for selecting and qualifying suppliers of raw materials and packaging materials. Ensure that all materials meet quality standards before being used in production.
Training and Education:
- Provide training to employees on quality control procedures, good manufacturing practices (GMP), and other relevant aspects of quality assurance.
Health and Safety:
- Collaborate with health and safety personnel to ensure that all production processes adhere to safety protocols and guidelines.
Recall and Corrective Actions:
- Develop and implement protocols for handling product recalls and implementing corrective actions in case of quality issues or deviations from standards.
- Continuously monitor and analyze processes to identify opportunities for improvement in quality control and assurance procedures.
- Maintain clear communication with management, production staff, and other relevant stakeholders regarding quality control issues, updates, and improvements.
When selecting a QAP for your business, take your time and ensure due diligence by reviewing their credentials and previous work experience. Engage potential candidates for a face-to-face interview whenever possible, so that you’re able to gain an understanding of their personality and identify if they have the necessary skills and traits you’re looking for. These small actions can make all the difference and will ensure your cannabis processing business is a success!
How we can help you
At Cannabis License Experts, we provide you with the guidance to plan your cannabis business, acquire funding, navigate the legal requirements, and acquire the appropriate licence for your operations. As the Canadian cannabis industry develops, more and more licensed producers will be needed to meet the demands of consumers.
Cannabis License Experts offers support from day one of starting your cannabis business, including strategic planning, floor plan preparation, site audits, SOPs, Preventive Control Plans (PCPs) and more.
Our Edibles Compliance division can provide you with a solid plan for your edibles business to help get your products on store shelves.
Contact us today for a free consultation, and let us help you get started on the path to obtaining a processing licence and running a successful cannabis business!