Edibles Manufacturing

Class: Processing

Subclass: Standard or Micro

Edibles Licence (Processing Licence)

A Standard Processing Licence authorizes its holder to purchase and possess cannabis, and process cannabis extracts (i.e., extraction to oil using CO2, ethanol and petroleum products). Other permitted methods in

clude physical extraction such as a hot press for rosin, kief and butane hash oil. The licence permits the manufacture of cannabis products, including pre-rolls, vape cartridges and pens, edibles, beverages and topicals.  Licenced standard processors can also package cannabis products, including dried and fresh cannabis, plants, seeds and oil, apply excise stamps and sell to sales licence holders. This licence class also allows sale of bulk-packaged cannabis to other licence holders.

Key personnel

Key personnel who must be identified and obtain security clearance are the Licence Holder (who has overall responsibility for the licence), Responsible Person (responsible for activities conducted by the Licence Holder), Head of Security (Responsible for ensuring that the physical security measures comply with Part 4 of the Cannabis Regulations and for the Organization Security Plan), and the Quality Assurance Person (QAP).

The QAP is responsible for assuring the quality of the cannabis before it is made available for sale. The QAP also investigates complaints about cannabis and takes steps to mitigate risks. The Licence Holder must retain a QAP who has the training, experience and technical knowledge related to the requirements of Parts 5 and 6 of the Cannabis Regulations. Where a QAP lacks the expertise to process edibles, the Licence Holder must retain an Alternate who has the needed training, experience and technical knowledge. Up to two individuals may be hired as alternate QAPs if they are qualified to replace the primary QAP.

Security Clearances

Security Clearances are needed for key investors, directors and officers of the corporation or cooperative (if the Licence Holder is a corporation or cooperative); for any person who exercises, or is in a position to exercise direct control over the corporation or cooperative; any individual who is a partner in a partnership that exercises (or is in a position to exercise) direct control over the entity; and typically, the Responsible Person, Head of Security, QAP and designated Alternates of key personnel.

Physical security

Physical security is another key element of a successful application. An important part is submitting an Organization Security Plan (OSP) with SOP priority areas summarized. SOPs—or Standard Operating Procedures—are used to detail site operations. The application will list and briefly describe these. The OSP covers four areas: Security Clearances and adverse information about employees; Physical Security; Security Awareness & Training; and Record-Keeping, Reporting and Testing.

Physical security requirements

Physical security requirements are quite detailed. The site perimeter must be clearly defined by a fence or building envelope. The footprint of any buildings must also be identified, along with the location of all storage areas. Any areas, including buildings, not used exclusively by the applicant or that are used to conduct unrelated activities must be outside the proposed site perimeter.

Site evidence package

A site evidence package, comprised of a guided video tour of the full site (indoors and outdoors) and highlighting the site perimeter, photographic overview of the perimeter, and all storage areas must be submitted. The application package includes additional information detailing physical barriers and site design, visual monitoring and intrusion detection measures, restricted access and logs, monitoring and response plans. This will include details on the types, specifications and locations of surveillance cameras and access control devices (e.g., proximity card readers and electric door strikes), as well as how authorized personnel will be provided access.

Good Production Practices (GPP) report

A Good Production Practices (GPP) report is another important requirement for this licence class. The report must describe how and where cannabis and anything used as an ingredient will be stored, including storage conditions (temperature, humidity). The storage procedure must be fully disclosed, e.g., for in-process, bulk storage, containers, samples and materials awaiting destruction. The report includes a building description detailing surfaces, filtration and ventilation systems, air exchanges, water supply, lighting, sanitation, cleaning/maintenance and other aspects. Visual evidence must also be submitted, including guided video tours and photographs of the site to highlight GPP features of the building and operational areas. Finally, a GPP attestation is completed to round out the report.

Applicants must also file a key investor report, which is required if the entity’s shares are not publicly traded. Cannabinoid extraction by supercritical carbon dioxide requires a processing licence.