Obtaining a cannabis micro cultivation licence allows a licensee to obtain and possess cannabis and cannabis plants or seeds by propagating, cultivating and harvesting. A licensed micro cultivator may also alter cannabis properties for testing purposes, and sell or distribute dried and fresh cannabis, and plants or seeds, to other classes of licence holders. The exception is cannabis nursery licensees, to whom only plants and seeds may be sold or distributed. A micro cultivation licence holder may also sell and distribute cannabis products to a licensee authorized to sell cannabis for medical purposes or a person authorized to sell cannabis under provincial/territorial statute. All licensees may conduct ancillary activities (e.g., drying, trimming, milling, etc.).
Cultivation Limits
Limits for cultivation exist. The canopy space is not to exceed 200 square meters (m²) of canopy space for the cultivation, propagation, and harvesting of cannabis plants. All surfaces for the canopy must be counted, such as those arrange above one another to calculate the total surface area permitted. This works out to a total area of 2,153 square feet (sq. ft.) or approximately 1/8th of a hockey rink. Any plants including clones and plantlets will contribute to this total.
Physical security
The physical security systems for micro-cultivators is limited to four main requirements: That the site is designed to prevent unauthorized access, at a minimum by surrounding it with a physical barrier; and that each storage area is surrounded by a physical barrier preventing unauthorized access. Also, access to storage areas is restricted to persons whose presence is required in order to conduct their duties. A site design is needed to address these requirements, highlighting all areas within the defined site perimeter. Health Canada recommends that applicants consider the “rings of protection” concept, which requires the construction of rings or barriers around protected items and areas. The idea is that an intruder is detected when they try to surmount the first barrier, providing time for police to arrive and prevent the theft.
Typically, cameras are not required at micro cultivator site. This is important because network video recorders (NVRs) servers for visual surveillance retention of high-definition cameras is largest costing line item in s security system install, followed by the cameras themselves, though Health Canada can request additional security at any site. Access control on the doorways that lead to the operation space and the secured storage are required. The minimum level of security required is a key system, however, a fob/pin system is generally recommended in any site where cannabis will be present, especially when there are more than three (3) employees present or the site is located close to a large city.
Good Production Practices (GPP) report
The GPP report is an important requirement to obtain this cannabis licence. 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. A building description detailing surfaces, filtration and ventilation systems, air exchanges, water supply, lighting, sanitation, cleaning/maintenance and other aspects is part of the report. 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. A GPP attestation is completed to round out the report.
Key personnel
The personnel required for this licence are the Responsible Person, a Master Grower and a Head of Security. Applicants must show that personnel have the knowledge, qualifications, experience and ability to fulfill applicable responsibilities. The requirements of the Responsible Person are noteworthy as this individual will have the authority to bind the licence holder; has overall responsibility for activities conducted by the licensee; and must know the Cannabis Act and Regulations provisions applying to the holder of the license. The Responsible Person also serves as the official point of contact with Health Canada. The Head of Security must ensure that the applicable security measures set out in Part 4 of the Cannabis Regulations are complied with, and they are responsible for the Licence Holder’s security plan.
Security Clearances
Clearances are required for key investors, directors and officers of the corporation, partnership or cooperative for any person who exercises, or is in a position to exercise, direct control over the entity; and typically, the Responsible Person, Head of Security, Master Grower, and designated Alternates of key personnel.
Site Evidence Package
A site evidence package is 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. Additional information detailing the cannabis cultivation facility physical barriers, site design, visual monitoring and intrusion detection measures (if any exist), restricted access and logs, and monitoring and response plans are part of the application package. This will include details on the types, specifications and locations of surveillance cameras (if any) and access control devices (e.g., proximity card readers and electric door strikes), as well as a description of how authorized personnel will be provided access.
