Cannabis Processing License Requirements

1. The holder of a Processing license must hold a security clearance. In addition, key personnel required under the Processing license (e.g. Responsible Person, Head of Security, Quality Assurance Person), as well as any directors, officers and key investors, are also required to hold a security clearance.
2. The license holder must retain the services of one individual as the Responsible Person, who has the authority to bind the holder. The Responsible Person will be accountable for the license holder’s activities and should have an adequate understanding of how the Cannabis Act and Regulations apply to the licence holder. They are also required to hold a security clearance. The license holder may designate one qualified alternate Responsible Person (who is also required to hold a security clearance).
3. The license holder must retain the services of one individual as the Head of Security who is responsible for ensuring that the applicable physical security measures set out in Part 4 of the Cannabis Regulations are complied with and that implements the organizational security plan of the licence holder. One qualified alternate Head of Security may be designated. The Head of Security, and any alternate, must hold a security clearance.
4. Processing license holders are required to retain the services of one individual as a Quality Assurance Person (QAP) who has the training, experience and technical knowledge related to the requirements of Part 5 (Good Production Practices) and Part 6 of the Cannabis Regulations. The QAP is responsible for assuring the quality of the cannabis product before it is made available for sale, and investigating every complaint received in respect of 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). The license holder is permitted to designate 2 alternates, but they must be identified and approved in advance by Health Canada. The QAP and any alternates are required to hold a security clearance.
5. The license holder’s facility must have any on-site storage and operations areas surrounded by a physical barrier in order to safeguard against unauthorized access. It should be possible to demonstrate how the barrier’s construction, as well as the required access controls on the exit and entry points, are able to achieve this goal. Access to all storage areas must be restricted to authorized personnel only.

Additional Standard Processing Requirements

1. Access controls are required around operations areas, and a record must be made of everyone who exits and enters from storage areas.
2. The site perimeter, operations areas, and storage areas are required to be monitored by visual recording devices at all times to detect and record any unauthorized attempts, successful or unsuccessful, to access the site.
3. The site perimeter, operations areas, and storage areas must have an intrusion detection system operating 24/7 to discover any unauthorized attempts to access the site or tamper with the system. It must also be possible to detect unauthorized movement within operations and storage areas.
4. The intrusion detection system is required to be monitored at all times, and the license holder is responsible for determining what measures are appropriate in response to any incidents. In cases of an incident, the holder must retain a document that contains the date and time of the occurrence, how it was responded to, and the date and time of when that response took place.