Cannabis Processing License Requirements
- The license holder needs to have an individual in their employment who can act as their “responsible person”. This person is considered accountable for the license holder’s actions and should have an adequate understanding of how the Cannabis Act and Regulations apply to the holder. Should they have to, this person also has the authority to bind the license holder. They are required to have a security clearance.
- Personnel must include a Head of Security who is responsible for ensuring that physical security measures comply with part 4 of the Cannabis Regulations, as well as the enactment of an organizational security plan. One qualified alternate may be designated, and both must have a security clearance.
- Processing licenses require that holders employ a Quality Assurance Person. This person is required to have good experience and knowledge regarding proper production practices as laid out by the Regulations, and is responsible for assuring the quality of cannabis ready for sale, as well as for investigating and responding to any complaints made about the quality of the cannabis. Two alternates may be designated, but they must be identified and approved in advance by Health Canada. All are required to have security clearances.
- The 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
- Access controls are required around operations areas, and a record must be made of everyone who comes and goes from storage areas.
- 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. Entry and exit points on grow areas must be visually monitored as well.
- 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.
- 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.