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PREVENTIVE CONTROL PLAN

The Cannabis Act and Regulations now permits the sale of edible cannabis, cannabis extracts and cannabis topicals. Businesses interested in securing a processing licence to produce edibles containing cannabis and cannabis extracts must, in accordance with the Cannabis Regulations, prepare, retain, maintain and implement a written Preventive Control Plan (PCP) for any activity they conduct in respect of the cannabis or anything that will be used as an ingredient in the production of the cannabis extract or edible cannabis. A well-documented and functioning PCP can take anywhere between 6-9 months to develop and even longer for a complicated process, so it is important to start planning early!

A PCP is a written document that demonstrates how hazards to your cannabis product are identified, prevented, eliminated or reduced to an acceptable level. The content of your PCP depends on the activities you conduct at your site, and may include elements relating to packaging, labelling, grading, standards of identity, and food safety.

A PCP allows you to identify and describe the biological, chemical and physical hazards associated with the cannabis product (edible or extract), document how you intend to control those hazards, provide the information you used to develop your plan, and demonstrate through records that you have implemented your plan.

When conducting a hazard analysis, all hazards that present a risk of contamination to the cannabis extract and/or edible cannabis must be identified and evaluated, and a determination must be made as to how these hazards will be controlled.

When preparing to produce or distribute edible cannabis or cannabis extract products, a major consideration should be food safety as the product is intended for human consumption. Cannabis manufacturers should enact a number of environmental controls to reduce the risk of contamination. These controls could include, but are not limited to the following:

  • Managing suppliers
  • Proper cannabis storage & handling protocol
  • Food allergen control
  • Equipment and facility cleaning
  • Regimented sanitation practices (e.g., employee hand washing and clothing regulations)
  • A pest control plan to prevent fecal/pathogen contamination
  • Facility design for floor drainage to prevent standing water
  • Proper air filtration & pressurized
  • Food consumption areas be physically separate from toilet facilities
  • Labels and packaging be stored in organized fashion to reduce labeling errors
  • Food safety procedures should be implemented and regularly monitored (e.g., written logs or computerized data logs)

Similar to traditional food manufacturers, a good PCP must include good manufacturing practices, in addition to, identifying potential hazards (biological, chemical or physical) in your edibles or extracts production process. One of the ways this can be achieved is developing a HACCP compliant program.

Cannabis License Experts offers expertise in developing Preventive Control Plans for all food manufacturers. Please contact us for more information on how to get started.


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