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A cannabis Nursery Licence allows its Licence Holders to possess cannabis; to propagate, cultivate and harvest cannabis plants and seeds; to conduct ancillary activities; and to alter the chemical or physical properties of cannabis for testing purposes. The licence also allows sale and distribution to other licensees and to sell and distribute cannabis plants and seeds to licence holders authorized to sell cannabis for medical purposes, or under provincial/territorial legislation.
Restrictions and conditions of this licence concern seed production, harvest limits and destruction of plants. For seed production, a total surface area of no more than 50 meters squared must contain all the parts of budding or flowering plants. A maximum of 5 kg of flowering heads may be harvested from plants, with the exception of seeds. The Licence Holder must destroy the flowering heads (with the exception of seeds), leaves and branches of the plants within 30 days of harvesting.
Aside from the above-mentioned limits on flowering cannabis, there are no further restrictions on cultivation space, facility size, with minimal security requirements.
Indoor or outdoor cultivation is permitted.
Key personnel with security clearances required are the Licence Holder (as an individual), Responsible Person, Head of Security and Master Grower. 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.
There are four priority security areas that all applicants and licence holders will be expected to address through SOPs. The number of SOPs is the applicant’s decision, but all four—Security Clearances, Physical Security, Security Awareness & Training, and Record-Keeping, Reporting & Testing—must be included.
Physical security requirements to be addressed focus on site design, physical site barrier, a physical barrier for storage areas and restricted access by personnel to storage areas. As with other licence classes, an Organizational Security Plan must be developed as part of the application.
Security Clearances are a critical requirement, for all key site personnel, directors and officers of the corporation and all main investors in the enterprise. An organizational chart is needed with the package to show the structure of the enterprise, with names, titles and reporting relationships, including management positions and any other roles that influence strategic business and operational decisions, and the movement of money or cannabis.
The Nursery Licence application includes
Good Production Practices (GPP)requirements but not as many as for processing licences. Key GPP requirements include: SOPs, pest control, storage, distribution, filtration and ventilation systems, sanitation and others. Excluded are competencies and qualifications, temperature and humidity control, incompatible activities and others (see Health Canada: GPP Requirements by Licence Class Guidance Document; Appendix A.).
The Nursery Licence may be combined with three other cannabis licences, i.e., Sales for Medical Purposes, Analytical Testing, and for Cannabis Research.
Applicants must also file a key investor report, which is required if the entity’s shares are not publicly traded
A Business Plan for the proposed operation is needed to help secure this licence. The plan should describe the applicant’s business model indicating the products they intend to sell and the activities that will be conducted. Attention will be paid to any affiliations or business relationships the operation will maintain with other companies.
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. Additional information detailing physical barriers and site design, visual monitoring and intrusion detection measures, restricted access and logs, monitoring and response plans are part of the application package. This will include details on the types, specification and location of surveillance cameras and access control devices (e.g., proximity card readers and electric door strikes) if any exist, as well as a description of how authorized personnel will be provided access.
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179 John Street, Toronto, Ontario M5T 1X4, Canada
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