Did you know that applicants for a Processing (standard or micro), Cultivation (standard, micro or nursery) and Sale for Medical Purposes with Possession Licences are required to submit a site evidence package with visual evidence demonstrating the completion and functionality of their facility, in addition to documents submitted as a part of their CTLS application? If this is news to you, keep on reading to learn more about what exactly a site evidence package is and why it’s extremely important to put together a complete and accurate package when submitting your application to Health Canada.
What is a Site Evidence Package?
Health Canada requires new applicants for cultivation, processing or sale for medical purposes licences to have a fully built site that meets all the requirements of the Cannabis Regulations at the time of their application, as well as satisfying other application criteria. Therefore, a site evidence package is a compilation of visual evidence (videos and photographs) which demonstrate to Health Canada the completion and functionality of your cannabis facility. This site evidence package must be submitted in addition to the paper documents that are uploaded as part of the CTLS application. Applications will only be processed once both the document portion of the application is submitted within the CTLS and the site evidence package is submitted to Health Canada.
What Information is Covered in a Site Evidence Package?
The requirements for the site evidence package differ based on the licence that is being applied for.
Standard Processing, Standard Cultivation and Sale for Medical Purposes with Possession Licences
- Guided video tour of entire site (including both indoor and outdoor areas), highlighting all security features of the site perimeter, operations areas (including all grow areas) and storage areas. All devices must correspond to their location as indicated on the site plan and all floor plans.
- Guided video tour of entire site (including both indoor and outdoor areas), highlighting all GPP features of the building, including all operations areas (including grow areas) and storage areas.
- A video of an individual entering and moving through different areas of the facility demonstrating the intended production process flow through the facility.
- Photographic overview of each side of the defined site perimeter.
- Close-up images of the surfaces (including walls, floors, ceilings and joints) of all operations areas (including grow areas) and storage areas demonstrating that they meet the requirements of section 84 of the Cannabis Regulations.
- Visual recording device footage that includes the front, back and sides of the defined site perimeter (e.g., east, west, south and north walls). Complete coverage may be best demonstrated by displaying multiple visual recording device feeds that capture an individual walking around the perimeter.
- Footage from all visual recording devices in each operations areas (including the entry and exit points of the grow areas) and all storage areas.
Micro-Cultivation, Micro-Processing, and Nursery Licences
- Guided video tour of entire site (including both indoor and outdoor areas), highlighting the entire site perimeter and all storage areas.
- Guided video tour of entire site (including both indoor and outdoor areas), highlighting all GPP features of the building, including all operations areas (including grow areas) and storage areas.
- Visual footage showing entire physical barrier for the site and all storage areas.
- A video of an individual entering and moving through different areas of the facility demonstrating the intended production process flow through the facility.
- Photographic overview of each side of the defined site perimeter.
- Close-up images of the surfaces (including walls, floors, ceilings and joints) of all operations areas (including grow areas) and storage areas demonstrating that they meet the requirements of section 84 of the Cannabis Regulations.
How is the Site Evidence Package Submitted to Health Canada?
Historically, site evidence packages were required to be submitted to Health Canada electronically using USB storage devices that were delivered via mail/courier service. Site evidence package submissions must be received by Health Canada within 10 business days following the submission of their application in the CTLS.
While the above still remains an option, Health Canada has recently introduced a new method for submitting site evidence. The new method involves electronic file transfer via a platform called “LiquidFiles”. To submit a site evidence package via LiquidFiles, the CTLS portion of the application should be submitted as normal. After submission, the Responsible Person listed on the application will receive an email with a secure link and additional submission instructions to upload Microsoft Word and/or PDF documents and video and/or photographic evidence package materials directly. This new method of submission will likely be preferred as it is quick, easy and reduces transit delays.
What if my Application is Indigenous Affiliated?
The CTLS includes an opportunity to self-identify your application as Indigenous affiliated. Indigenous affiliated applicants are able to request a two-stage review that allows a licence application to be submitted without a fully built physical site. A two-stage process would involve an in-depth paper-based review by Health Canada and upon completion of this review, Health Canada would issue a Confirmation of Readiness letter with a request for a site evidence package. After the build is completed and the site evidence package is received and reviewed by Health Canada, the application could be approved or refused.
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At Cannabis License Experts, we provide you with the guidance to plan your GMP-, GPP- and GACP-compliant 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 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 to discover how we can license and legalize your cannabis business to meet federal or provincial regulations.
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