A Very Simple Question for All Federal Election Candidates

 

I Could Not Believe It.

I am TheSmeeGoanGuy

Marijuana Blogger and Loudmouth

I am also a member of the Liberal party of Canada and I am going to the Liberal Leadership Debate in Vancouver next Sunday.  $20? I couldn’t pass it up

You can imagine my delight as an attendee to get an e-mail from the party inviting me to submit a question that I would like to get answered by the candidates What did I want and expected from the leader candidate to earn my vote. This was a sort of competition and a winner of the submissions might be invited to actually get of the podium and address the audience and ask his question and why he posed it. Any of you followers realize that there was NO way this honey bear could avoid getting his head stuck into the pot.

I sat down and wrote a brilliant summation of the catastrophe coming from any increase in the price of Medical Cannabis. I described the currents situation, I predicted what I foresaw coming that amounted to a complete destruction of the ability of the people who needed it most: to afford their daily medical requirement. I backed it up with facts, valid estimates and statistics wrapped in a presentation of arguments analysis that could be followed and what I thought was common sense reasoning. I finally came to the end of my 1500 odd word presentation and the most pleasant surprise End of the Rainbow reward:

I boiled that entire head scratching down to a final realization of what my goal in all this controversy is about. My concluding question to the Leadership Candidates was one statement and question. I stated the ultimate objective of my advocacy and I asked what they would do to help all me get there.

I sat with pride and went to the place to submit my question only to find out  that I hadn’t read the fine print and Cannabis or Medical Marijuana were not one the topics accepted for discussion. Bummer. Total waste of %$#&$% time!!

I sat and sulked for a while and had a couple of major tokes to get over the shock of losing the opportunity to ask anyone in the party where they stood and I came to a brilliant realization! The leadership of the parties really were not the ones who whom it should be asked. It should be asked of every candidate for a seat in parliament because given 20000 licensees divided by 308 = 65 sick voters / candidate. There is some Medical Marijuana Licensee or applicant voter in each riding who deserves a direct answer from the person who is asking for his vote. It acknowledges the problem of a constituent and advises what assistance he and his office can render. Failure to respond deserves the consequences and I have many in mind.

Accordingly I readdressed this message to every one of the Federal Candidates to remind them of their responsibility to equally consider the plight of all their electorate as individuals with a right to protection;

I have modified my statement to address each of you as a member of the collective pool of candidates and present you with my question as to how you would represent me as a constituent needing Medical cannabis in the event o the successful implementation of your goals re Cannabis management in the future. It is asked of all of you regardless of party on behalf of a very vulnerable group of voters

Unfortunately you now have to read the 1500 words of argumentation and logic I wrote before I reveal my concluding question to them and the end result I want to obtain.

What I want from my MP

To All the Federal Candidates regardless of party affiliation

Gentlemen and Ladies:

I have a problem with all of the Federal Parties on the matter of Medical Marijuana.

1.     Hypocrit Harpo: The Fearless Leader now in power, is determined to ram through the Marijuana for Medical Purposes Regulations in defiance of all common sense or reason.

2.     The Opposition Candidates are becoming unified in an effort to go even further. All propose to legalize or decriminalize cannabis and garner the benefits of the increased economic potential in Hemp production and product innovation in terms of employment and commercial benefit. The primary goal is the gold at the end of the rainbow: the huge influx of revenue that will be realized from the production and taxes of a legal recreational drug market.

This is wonderful stuff, rosy projections of all the future benefits: totally oblivious to the fact that successful implementation of any of your plans will completely eliminate the possibility that anyone needing Cannabis for Medical purposes will be able to obtain it. The worst problem of the current system is not the legality or criminality involved. It is the simple fact that if it is not from a PPL/DPL source, virtually all Licensees are unable to purchased the amount they currently require and are authorized to buy. The Government at least has the honesty to admit a price increase will be inevitable but projected the price for Medical cannabis will stabilize around $8/gram compared to the ridiculous $1.80-$5.00/gram range they claim is the current cost. I question the source of that $1.80 figure. He had to be smoking Health Canada pot: I’ve never witnessed criminal stuff being quite that polluted with hallucinogenic contaminants.

Regardless of the size of the forthcoming increase it is simply unacceptable.

As historical background The Marihuana Medical Access Program was a brilliant and compassionate idea that never ever had a chance of succeeding from the start. The Government as usual, failed to consider the financial position of the clientele they were trying to help. No one knows or has determined what the demographics of the Licensees are, but I think we can safely conclude that given the fact they have been sick long enough to warrant a License, they are probably at the poverty level and mostly dependant on Pension or Welfare income. 

The bureaucracy in its infinite wisdom decided to set the price of Legal pot at 50% of the $10/gram street price
Statistics Canada defines the "poverty line" (or low-income cut off) for a single person living in a major city in 2007 as $21,666 (before tax), or $1805/month. The majority of all Licensees are single individuals’ dependent on fixed pension income from the Government. Licensees are all sick and either retired or disabled, or one of the very few still able to earn an income. These single individuals have only OAS and CPP as income and in the best possible income is available only to a retired recipient who is collecting maximum OAS of $537.97, who is so physically destroyed by illness to qualify for the maximum CPP Disability of $1,153.37. These fortunate individuals qualify for $1691.34/month before tax and almost make it to the poverty line: Almost but not quite. The worst damage is to those Licensees with dependants. Without the Old Age Security pension the only Federal Government assistance available is the CPP Maximum. There is no provision for support of dependents and they fall into the Welfare pit of their Province.

The government issues Licenses to Possess for daily use of amounts from anywhere from a minimum of 1 gram/day to more than 50 grams. Regardless of the number authorized, a one gram minimum plus HST costs $168 for a one month 30 gram supply. This is more than 10% of the maximum income available to Licensees from pension as well as those still able to work. A full time minimum wage job yields the same before tax income as the best case retiree. Very few Licensees can afford to purchase the amount they are authorized to use for symptom relief and wind up short changed on a sufficient amount to relieve their suffering.

As a classic example I am one of the fortunate who has a License, a minimal 2 gram/day authorization and to this point the ability to afford my dosage. That ability is now in question and any future price increase is prohibitive. I am a Married Senior with combined OAS, CPP, US Social Security and a WCB Pensions for a total fixed family retirement income of about $38000. Until October of last year I was able to work as a Part time Security Guard for extra income that has now vanished. I was able to afford my Cannabis until now because I was one of the very fortunate few that found a Designated Grower who compassionately sold me at just over his cost at $100/oz., just over $3/gram.

As a comparison to the unfortunate many, let’s calculate the cost of an average 5 gram/day Rx and the ability of the average licensee (with the maximum Federal Pension Assistance) to pay for it. To buy at the lowest available price from Health Canada his medication will cost $25/day x 365 = $9125 per annum and represents nearly 50% of his annual income of $21,666 which was already below the poverty line set 6 years ago in a much healthier economy. A price increase to the $8 estimate of the Government will cost this poor guy an additional $5475 per year that has to be wrenched from the balance of his current survival money. He must now some how survive on the $7000 of his remaining income to pay for the essentials for survival. Impossible!

What if he is really in need of a 20g/day allowance? There is no way he can afford it. Now we are talking a minimum daily cost of $100 that is going to rise to $160 or nearly $60000 annually. To pay for medication that will cost more than three times his annual income is an impossibility.

So what do I want from my candidate and his approach to Cannabis.

1.     recognition that the rosy picture he is painting of his program actually has a dark side.

2.     An understanding that while the darkness only will affect a very small number of voters with no political influence; its impact will be catastrophic to their survival needs.

3.     Realization that to permit this to happen is not only inhuman, it is inhumane!

4.     If such action is not taken, I feel the Supreme Court will show consistency and decide that once again the patients’ rights to access will be violated. They will be blocked by a predicted prohibitive price for which there is no accommodation or exemption allowed and that is simply not Canadian.

5.     Above all: a pledge to foster the design and implementation of some sort of subsidy or assistance to ameliorate and minimize the impact of any price increase on the people who it will damage.

You do not have to believe anything I have said, all you have to do is use real numbers and do the math yourself. My predictions of doom are pretty safe. I have a B.A. in Statistics and 1+1 still equals 2.

I can’t understand Conservative thinking. Harpomath never did make sense to me but they all must be firm believers in his fiction. How else could they come up with all the weird financial bullshit they exude without provocation?

There I end. You know what I want. Where do you stand and how will you respond to the following;

Based on the recognition that major harm will result from any price increase no matters the size from the successful adoption of your proposals I would like you to attempt to create an end result simply

where a Qualified Medical Cannabis Licensee can 

legally purchase the quantity of Cannabis needed for his relief 

AT A PRICE THEY CAN AFFORD

My Question to you all?

What can I expect in return for my loyalty and vote or is that too much to ask?.

 Now it’s your turn.

Go for the Big Gold Ring- My vote.

Blaine Barrett

TheSmeeGoanGuy

An Appeal for Help to All Facebook Friends

I advocate for Dr. Rob Kamermans.

I believe him innocent but have no proof of it.

All media coverage has been prosecutorial

I need evidence of his innocence

It’s out there among you

Help me find it

Please!

S’mee again:

With the exception of this Blog there is a complete lack of knowledge or information about what Dr. Kamermans did to get persecuted by the Harpocrits. Everything is kept very low profile and what little national media exposure permitted is limited to a repetitious spewing of allegations, inferred moral deficiency and criminal motivations, capped off with regurgitation of the stupid biased criminal charges against him to complete the character assassination.

But:

1.    At no time has any actual evidence, or statement of verifiable fact, been provided by the prosecution.

2.    At no time has any condemnatory nor exculpatory evidence been discovered by any media, national or local. Investigative Journalists, if there are any left, either don’t know how to do the job or just don’t give a damn about justice via the truth.

3.    If they can’t find it why do I think I can? Because I know where to look.

There are only two people who know the truth about the validity of any commercial transaction: the buyer and the seller. We know the allegations against the Doctor but the only other people in this country who know what Dr. Kamermans actually did, and how he conducted these business affairs, are the 4000+ applicants he got licenses for.

Somewhere, out there, among all you friends, from coast to coast, these people are lining under the threat of disclosure and prosecution because their identities, addresses and all the personal private details in their pontificated Medical Records were illegally disclosed to a bunch of stupid ethically deficient morons who specialize in violating the privacy of others. The only privacy Canadian cops value is their own and their fellow officers when accused of crimes against the public. No body talks i.e. the G8/G20 assault and battery criminals who hid their badges.

I want to contact as many of Dr. Kamermans customers as I can to find out the truth of what happened. Is it a good truth or a bad one? Only they can answer.

Following is the list of questions that need their answers. I simply want every person who reads this to share it in order to contact them and inform them they are needed. This is being sent to every Facebook friend because you all are part of and well known within the Marijuana Tokers Team. I took a good look at what sharing can do and this can work with very little effort for any of you. I am asking all my readers and about 230 Facebook friends to help. If each of you simply shares this on your timeline after reading it my goal will largely be accomplished. Heavens, Several of you have friends and followers in the thousands! The cumulative weekly total visitors to those and 200 more fellow sites have to be astronomical!

The Questionnaire:

To all of the 4000+ (?) MMAR Licensees who obtained their License with the assistance of Dr. Rob Kamermans, you are now potentially vulnerable to the same illegal search, seizure, and persecution. I firmly believe that the confidential information contained in your Medical file regarding your identity, location, dosage, and most importantly if you are a Personal or Designated Grower has been extracted for follow-up. It is also my belief that this has been done as a sop to the Municipal Bylaw freaks and that the locations of all these grow ops will be, or possibly have already been, disseminated nationwide to every Municipal Bylaw enforcement officer and local cop shop.

The only way to find out what really happened and where it is going is to find out the information only you know. What is the truth of what happened between you and the Doctor from finding his identity to the receipt of the signed form and payment?

The following 18 questions are designed to get essential details only and no personal information beyond

1.    Your License to Possess Number- to verify the validity of the information and source if required, and

2.    The medical condition you needed Cannabis to relieve.

	Question
1	License to Possess Number:
2	Medical Condition:
3	Where were you residing when you found out about Dr. Kamermans? City or Riding name only.
4	How did you hear of him?
5	Why were you interested in him? No Doctors available locally? Please Expand on any problem finding treatment. How many turndowns?
6	How did you contact him & when? Method, month, year
7	What were you advised to do. Be as explicit as possible, Where to go, when to be there, docs to bring and funds to pay.
8	How long did you have to wait?
9	Where was the interview conducted? Hotel? Rented office? Meeting room?
10	Were you the sole attendee or were there others waiting, How many?
11	What happened between arrival, reception and your interview?
12	How was the interview conducted, desk? Table? Seating positions, etc
13	Describe the interview as best you can to assess both his procedure and the interview objective.
14	In your judgement was the interview: 1.    a professional medical assessment of your need with his advice or 2.    a commercial payment transaction with little medical assessment?
15	In your considered opinion was there any indication of criminal wrongdoing in the transaction? Any false information, evasion or deception noted?
16	How much did the Doctor charge? Was there any flexibility or negotiation involved?
17	Do you consider this a reasonable charge for the service rendered?
18	Were you happy with the result when you left?
	That is the end of the questions regarding your application process. Most importantly, in recent history has anything occurred to make you suspect that the personal information in your file may have been used to identify you as a Licensee and target for the enforcers? A surprise fire or building inspection: or an unjustified traffic stop with non traffic offence related questioning based on a “What do I smell?” excuse?  If you have please expand as much as possible. Theory is acceptable but facts to support it are needed.
	If you are going to reply and help please do so promptly, his trial date is less than six months away and that is not much time to collect and assess an overall picture from hopefully even only a 25% return. Please reply. Don’t assume others will do the job instead and your answers are not needed: they’re assuming you’ll answer as well. This really is worth your bother.
	Thank you for the time and effort spent. Your answer, combined with those your fellows will help create and then throw light on the dark spot in Harpo’s underwear.
	Please return your answer to me at TheSmeeGoanGuy@Gmail.com ASAP

Thanks to everyone who helps

Blaine Barrett

TheSmeeGoanGuy

A Criticism of the Marijuana for Medical Purpose Regulations

MARIHUANA FOR MEDICAL PURPOSES REGULATIONS

Nearly 150 Pages of Futile Salesmanship

You don’t realize just how much crap you are going to have to wade through when you open something like this because it’s so all encompassing. I split it into 2 parts:

1.      Rules and Regulations to criticise in this post, and

2.      The fantasy of the first 35 Pages titled Regulatory Impact Analysis Statement.

That is another pipedream of lies, evasions and distortion that attempt to justify what is presented here as a really good idea. Why would anyone trust the Harpocrits to ever have a really good idea? Everything they have proposed to date is simply job security for the Supreme Court? This is no different. I will deal with that at a future date.

 The Regulations started out as 100 Pages which I have distilled down to a simplified 17 pages. These extract the important points out of the 144 sections comprising the Regulation and reveal the complexity and overkill of unnecessary demands for details, reports, and requirements. A quick scan of the following three pages of the Table of Contents reveals the scope of control demanded by the Harper crew for compliance. It is these crushing overhead burdens plus the taxes demanded that inflate costs to the point where the product is priced out of the market and is simply not profitable nor competitive. Remember this is supposed to concern Medical Marijuana in a market comprised of buyers who are piss poor paupers watching every penny to survive.

What the Nabobs have issued is directed specifically directed toward LICENSED PRODUCERS. There is absolutely no consideration of what a Medical Marijuana customer needs, wants or their ability to pay. That is a topic to be dealt with separately when I tear into the manifest stupidity of the Regulatory Impact Analysis Statement with which they prefaced this farcical example of Administrative overkill.

Fortunately for most of you readers I’m smart enough to know that you are probably not a detail freak like me. One word of warning:, most readers will only need to SKIM the Table of Contents and not try to get as disgusted as I am. There really is no necessity to read the 144 Regulations themselves in detail to realize that there is little or no possibility of meeting them all and maintaining a profit.

If you are a detail freak, the pages following the Table of Contents condense the essentials of the Regulation to a readable 13 odd pages without all the irrelevant crap. Read them at the risk of uncontrollable nausea.

Blaine Barrett

TheSmeeGoanGuy

TABLE OF CONTENTS

MARIHUANA FOR MEDICAL PURPOSES REGULATIONS

INTERPRETATION

• 1. Definitions
• 2. Application of Narcotic Control Regulations

POSSESSION

• 3. Obtaining dried marihuana or cannabis
• 4. Possession limit — medical document

GENERAL PROVISIONS

• 5. Dried marihuana
• 6. Notice of refusal or revocation
• 7. Further information
• 8. Inspection of site
• 9. Police enforcement
• 10. Alteration of documents

PART 1

LICENSED PRODUCERS

DIVISION 1

PERMITTED ACTIVITIES AND GENERAL OBLIGATIONS

• 11. Activities
• 12. Dwelling-place
• 13. Indoor activities only
• 14. Indoor storage only
• 15. Identification of licensed producer
• 16. Alteration of medical document
• 17. Responsible person in charge present
• 18. Safekeeping during transportation
• 19. Report of loss or theft
• 20. Destruction

DIVISION 2

LICENSING

• 21. Eligible persons
• 22. Senior person in charge and responsible person in charge
• 23. Notice to local authorities
• 24. Application for licence
• 25. Security clearance required
• 26. Issuance of licence
• 27. Grounds for refusal
• 28. Period of validity
• 29. Application for renewal
• 30. Application for amendment
• 31. Notice to local authorities
• 32. Notice to Minister — change of personnel
• 33. Notice to Minister — various changes
• 34. Statement by signatory of notice
• 35. Revocation — lost or stolen licence
• 36. Revocation — notice of cessation of activities
• 37. Revocation — other grounds
• 38. Suspension

DIVISION 3

SECURITY MEASURES

General

• 39. Compliance with security measures
• 40. Unauthorized access

Restricted Areas

• 41. Restricted access
• 42. Visual monitoring
• 43. Intrusion detection system
• 44. Filtration of exhaust air

Site

• 45. Visual monitoring
• 46. Intrusion detection system

DIVISION 4

GOOD PRODUCTION PRACTICES

• 47. Prohibition — sale or provision
• 48. Microbial and chemical content
• 49. Premises
• 50. Equipment
• 51. Sanitation program
• 52. Standard operating procedures
• 53. Recall
• 54. Quality assurance
• 55. Lot or batch samples
• 56. Recall reporting
• 57. Adverse reactions

DIVISION 5

PACKAGING, LABELLING AND SHIPPING

• 58. Packaging
• 59. Weight of dried marihuana
• 60. Product label
• 61. Client label
• 62. Combined label
• 63. Department of Health document
• 64. Presentation of information — label
• 65. Expiry date
• 66. Reference to Acts or regulations
• 67. Shipping

DIVISION 6

IMPORT AND EXPORT

• 68. Application for import permit
• 69. Issuance of import permit
• 70. Refusal to issue import permit
• 71. Provision of copy of import permit
• 72. Declaration after release from customs
• 73. Revocation of import permit
• 74. Suspension of import permit
• 75. Application for export permit
• 76. Issuance of export permit
• 77. Refusal to issue export permit
• 78. Provision of copy of permit
• 79. Declaration after export
• 80. Revocation of export permit
• 81. Suspension of export permit

DIVISION 7

SECURITY CLEARANCES

• 82. Eligibility
• 83. Application for security clearance
• 84. Checks and verifications
• 85. Minister’s decisions
• 86. Outstanding criminal charge
• 87. Refusal to grant security clearance
• 88. Validity period
• 89. Security clearance no longer required
• 90. Suspension of security clearance
• 91. New applications
• 92. Sending of notices by Minister
• 93. False or misleading information

DIVISION 8

COMMUNICATION OF INFORMATION

• 94. Information concerning registered clients
• 95. Information concerning health care practitioners
• 96. Information concerning licensed producers
• 97. Information concerning import or export permit
• 98. Providing information to foreign organizations
• 99. Receiving of information by Minister
• 100. Security clearance — Minister
• 101. Security clearance — law enforcement agency

PART 2

REGISTRATION AND ORDERING

REGISTRATION

• 102. Eligibility
• 103. Registration application
• 104. Health care practitioner’s consent to receive dried marihuana
• 105. Verification of medical document
• 106. Registration of client
• 107. Expiry of registration
• 108. Refusal to register
• 109. Notice — refusal to register
• 110. Cancellation of registration
• 111. Application to amend registration
• 112. Amendment
• 113. Refusal to amend
• 114. Prohibition — transfer of medical document

NEW MEDICAL DOCUMENT

• 115. New application
• 116. Applicable provisions

PROCESSING AN ORDER

• 117. Order required
• 118. Shipping
• 119. Refusal
• 120. 30-day limit — registered client

PART 3

REGISTERED CLIENTS AND OTHER AUTHORIZED USERS

• 121. Proof of authority to possess
• 122. Prohibition — obtaining from more than one source
• 123. Return

PART 4

HEALTH CARE PRACTITIONERS

• 124. Authorized activities
• 125. Medical document
• 126. Labelling of dried marihuana
• 127. 30-day limit

PART 5

SALE OR PROVISION BY A LICENSED PRODUCER
TO A PERSON OTHER THAN A REGISTERED CLIENT

• 128. Order required — cannabis
• 129. Shipping
• 130. Refusal

PART 6

RECORD KEEPING BY LICENSED PRODUCERS

TRANSACTIONS

• 131. Cannabis received
• 132. Imported marihuana
• 133. Exported marihuana
• 134. Record of verbal order
• 135. Filling of order from registered client
• 136. Dried marihuana returned by registered client
• 137. Order from person other than registered client

CLIENT REGISTRATIONS

• 138. Information

PRODUCTION AND INVENTORY

• 139. Good production practices
• 140. Sown, harvested, dried, packaged and destroyed marihuana
• 141. Destroyed cannabis
• 142. Inventory

GENERAL OBLIGATIONS

• 143. Manner of keeping records
• 144. Information required by Minister

PART 7

CONSEQUENTIAL AMENDMENTS, TRANSITIONAL
PROVISIONS, REPEAL AND COMING INTO FORCE

CONSEQUENTIAL AMENDMENTS

• 145. Food and Drug Regulations
• 146.-169. Narcotic Control Regulations
• 170. Benzodiazepines and Other Targeted Substances Regulations
• 171.-191. Marihuana Medical Access Regulations
• 192.-193. New Classes of Practitioners Regulations

Following are the proposed Regulations, stripped of the needless sectioning; sub-sectioning, irrelevant references and excess verbiage the Mandarins love to  use to confuse all issues at stake.

LICENSED PRODUCERS

DIVISION 1

PERMITTED ACTIVITIES AND GENERAL OBLIGATIONS

Activities

11. (1) Subject to subsections (2) to (7) and to the other provisions of these Regulations, a licensed producer may

possess, produce, sell, provide, ship, deliver, transport and destroy marihuana;

possess and produce cannabis, other than marihuana, solely for the purpose of Divisions 4 and 5. conducting in vitro testing that is necessary to comply with the requirements of; and

sell, provide, ship, deliver, transport and destroy cannabis, other than marihuana, that was obtained or produced solely for the purpose of Divisions 4 and 5.

(2) A licensed producer may sell or provide a substance to another licensed

(3) The substances that may be sold or provided under subsection (2) are marihuana; and cannabis, other than marihuana, solely for the purpose of conducting in vitro testing that is necessary to comply with the requirements of Divisions 4 and 5.

(4) A licensed producer may sell or provide dried marihuana to a registered client of that producer or an individual who is responsible for the client; a pharmacist; a health care practitioner; a hospital employee, or granted MM Licensee..

(5) A licensed producer may conduct an activity is licensed to conduct the activity; and conducts the activity in accordance with the producer’s licence.

 (6) A licensed producer may import marihuana

 (7) A licensed producer may possess marihuana for export; and export marihuana

12. A licensed producer must not conduct any activity referred to in section 11 at a dwelling-place.

13. A licensed producer must produce, package or label marihuana only indoors.

14. (1) A licensed producer must store cannabis only indoors at the site specified in the producer’s licence.

 (2) A licensed producer must store dried marihuana in accordance with the Security Directive.

15. A licensed producer must include their name, as set out in their licence, on all documents including advertising, product labels, orders, shipping documents and invoices.

16. A licensed producer must not mark, alter or deface in any manner a medical document.

17. A licensed producer must not perform a transaction   unless the responsible person in charge or the alternate responsible person in charge is physically present at the site  

18. A licensed producer must, take any steps that are necessary to ensure its safekeeping during transportation.

19. If a licensed producer experiences a theft of cannabis or an unusual waste the licensed producer must

• (a) report the occurrence to a member of a police force within 24 hours and  provide a written report to the Minister within 10 Destruction

20. (1) A licensed producer must not destroy cannabis except in accordance with this

(2) A licensed producer may destroy cannabis if it is destroyed

• (a) in accordance with a method that
• (i) conforms with legislation applicable to the place of destruction, and
• (ii) does not result in any person being exposed to cannabis smoke; and
• (b) in the presence of at least two persons who are qualified to witness the destruction, one of whom must be a person referred to in paragraph (3)(a).

Witness to destruction

(3) The following persons are qualified to witness the destruction of cannabis:

• (a) the senior person in charge, the responsible person in charge and, if applicable, the alternate responsible person in charge; and
• (b) a person who works for or provides services to the licensed producer and acts in a senior position.

Transportation of cannabis

(4) If the cannabis is to be destroyed at a location other than the site specified in the producer’s licence, the senior, responsible person, in charge, or the alternate responsible person in charge must accompany the cannabis to the location at which it is to be destroyed.

DIVISION 2

LICENSING

Eligible persons

21. The following persons are eligible to be a licensed producer:

• (a) an adult who ordinarily resides in Canada; and
• (b) a corporation that has its head office in Canada or operates a branch office in Canada and whose officers and directors are all adults.

22. (1) A licensed producer must designate

• (a) a senior person in charge to have overall responsibility for management
• (b) a responsible person in charge to work at the site specified in the licence
• (3) The senior person in charge, the responsible person in charge and, if applicable, the alternate responsible person in charge

• must be adults; and
• (b) must be familiar with the provisions of the and the Food and Drugs Act.

23. (1) Before submitting an application the applicant must provide the following persons with a written notice

• (a) the local police force or Royal Canadian Mounted Police detachment (b) the local fire authority of that area; and c) the local government of that area.

 (2) The notice must contain the following information:

• (a) the name of the applicant; (b) the date of submission, (c) the activities referred to in subsection 11(1 and the address of the site and of each building within the site

 (3) The notice must be addressed to a senior official of the local authority.

24. (1) To apply for a producer’s licence, a person must submit to the Minister an application that contains the following information:

• (a) if the applicant is
• (i) an individual, the individual’s name, date of birth and gender and any other name registered with a province
• (ii) a corporation, its corporate name and any other name registered with a province, as well as the name, date of birth and gender of each of its officers and directors;
• (b) the address, telephone number and, if applicable, the facsimile number and email address for the site and each building within the site
• (c) the mailing address for the proposed site and for each building
• (d) the name, date of birth and gender of each of the following persons:
• (i) the proposed senior, responsible, and the proposed alternate responsible person in charge
•  (e) the name and gender of each of the persons authorized to place an order for cannabis on behalf of the applicant;
• (f) the proposed activities, the purposes for conducting those activities and the substances involved and the sites where activities are to be conducted
•  (h) a detailed description of the security measures at the proposed site
• (i) a detailed description of the method that the applicant proposes to use for keeping records;
• (j) if applicable, the maximum quantity (expressed as the net weight in kilograms) of dried marihuana to be produced by the applicant under the licence and the production period; and
• (k) if applicable, the maximum quantity (expressed as the net weight in kilograms) of dried marihuana to be sold or provided by the applicant under the licence to persons referred to in subsection 11(4) and the period in which that quantity is to be sold or provided.

DIVISION 4

GOOD PRODUCTION PRACTICES

47. (1) A licensed producer must not sell or provide dried marihuana in respect of which the requirements of this Division have not been met.

48. (1) The microbial and chemical content of dried marihuana must be within generally accepted tolerance limits

 (2) Dried marihuana must not contain any residue of a pest control product Control Products Act.

 (3) Analytical testing for microbial and chemical contaminants and for levels of delta-9-tetrahydrocannabinol and cannabidiol must be conducted using validated methods.

• 49. (1) Dried marihuana must be produced, packaged, labelled and stored in premises that permits the premises to be kept clean and orderly; permits the effective cleaning of all surfaces in the premises; permits the dried marihuana to be stored or processed appropriately; prevents the contamination of the dried marihuana; and prevents the addition of an extraneous substance to the dried marihuana.

 (2) Dried marihuana must be stored under conditions that will maintain its quality.

• 50. Dried marihuana must be produced, packaged, labelled and stored using equipment that is designed, constructed, maintained, operated and arranged in a manner that permits the effective cleaning of its surfaces; permits it to function in accordance with its intended use;  prevents it from contaminating the dried marihuana; and  prevents it from adding an extraneous substance to the dried marihuana.

• 51. Dried marihuana must be produced, packaged, labelled and stored in accordance with a sanitation program that sets outprocedures for effectively cleaning the premises in which those activities are conducted; procedures for effectively cleaning the equipment used in those activities; procedures for handling any substance used in those activities; all requirements, in respect of the health, the hygienic behaviour and the clothing of the personnel who are involved in those activities, that are necessary to ensure that those activities are conducted in sanitary conditions.

52. Dried marihuana must be produced, packaged, labelled and stored in accordance with standard operating procedures that are designed to ensure that those activities are conducted in accordance with the requirements of this Division.

53. A licensed producer must establish and maintain a system of control that permits the rapid and complete recall of every lot or batch of dried marihuana that has been made available for sale.

54. (1) A licensed producer must

• (a) have a quality assurance person who is responsible for assuring the quality of the dried marihuana; has the training, experience and technical knowledge relating to the activity conducted investigate every complaint received in respect of the quality of the dried marihuana.

 (2) Dried marihuana must be produced, packaged, labelled and stored using methods and procedures that, prior to their implementation, have been approved by a quality assurance person.

 (3) Every lot or batch of dried marihuana must be approved by a quality assurance person before it is made available for sale.

 (4) Dried marihuana that is sold to a person referred to in subsection 11(4) and subsequently returned to the licensed producer must not be resold.

Lot or batch samples

55. (1) Subject to subsection (3), if the Minister has reasonable grounds to believe that a lot or batch of dried marihuana made available for sale may — by reason of the manner in which it was produced, packaged, labelled or stored — pose a risk to the health of an individual who in accordance with these Regulations obtains the dried marihuana for their own medical purposes, the Minister may require the licensed producer who sold or provided the dried marihuana to provide the Minister with a sample of that lot or batch.

Quantity

(2) The sample must be of sufficient quantity to enable a determination of whether the lot or batch of dried marihuana meets the requirements of section 48.

Period

(3) The Minister must not require a sample to be provided if more than one year has elapsed after the date of the last sale or provision of any portion of the lot or batch of dried marihuana.

Recall reporting

56. A licensed producer who commences a recall of dried marihuana must provide the Minister with the following information in respect of the recalled dried marihuana within three days after the day on which the recall is commenced:

• (a) its brand name;
• (b) the number of each lot or batch recalled;
• (c) if known by the licensed producer, the name and address of each licensed producer who imported or produced any of it;
• (d) the reasons for commencing the recall;
• (e) the quantity produced or imported into Canada by the licensed producer;
• (f) the quantity that was sold or provided in Canada by the licensed producer;
• (g) the quantity remaining in the possession of the licensed producer;
• (h) the number of persons referred to in subsections 11(2) and (4) to whom it was sold or provided by the licensed producer; and
• (i) a description of any other action that the licensed producer is taking in respect of the recall.

Adverse reactions

57. (1) A licensed producer who sells or provides dried marihuana must provide the Minister with a case report for each serious adverse reaction to the dried marihuana, within 15 days after the day on which the producer becomes aware of the reaction.

Summary report

(2) A licensed producer who sells or provides dried marihuana must annually prepare and maintain a summary report that contains a concise and critical analysis of all adverse reactions to the dried marihuana that have occurred during the previous 12 months.

Provide Minister with report on request

(3) If, after reviewing a case report provided under subsection (1) or after reviewing any other safety data relating to the dried marihuana, the Minister has reasonable grounds to believe that the dried marihuana may — by reason of the manner in which it was produced, packaged, labelled or stored — pose a risk to the health of an individual who in accordance with these Regulations obtains the dried marihuana for their own medical purposes, the Minister may request that, within 30 days after the day on which the request is received, the licensed producer

• (a) provide the Minister with a copy of any summary report prepared under subsection (2); or
• (b) prepare and provide the Minister with an interim summary report containing a concise and critical analysis of all adverse reactions to the dried marihuana that have occurred since the date of the most recent summary report prepared under subsection (2).

DIVISION 5

PACKAGING, LABELLING AND SHIPPING

Packaging

58. A licensed producer who sells or provides dried marihuana to a person referred to in subsection 11(4) must ensure that

• (a) the dried marihuana is packaged in an immediate container
• (i) that keeps the marihuana free from contamination, that has a security feature that provides the container has not been opened prior to receipt, and is a child resistant package

59. A licensed producer who sells or provides dried marihuana to a person referred to in subsection 11(4) must ensure that the net weight of the dried marihuana in the immediate container is not less than 90% and not more than 101% of the net weight specified on the label in accordance with subparagraph 60(c)(v).

60. A licensed producer who sells or provides dried marihuana to a person referred to in subsection 11(4) must ensure that the immediate container carries a label that contains the following information:

• (a) the name of that licensed producer; and the words “Dried marihuana / Marihuana séchée”;
• (c) in respect of the dried marihuana in the container:
• (i) its brand name,
• (ii) its lot number, preceded by one of 4 designations:
• the percentage of delta-9-tetrahydrocannabinol w/w, followed by the word “delta-9-tetrahydrocannabinol”,
• (iv) the percentage of cannabidiol w/w, followed by the word “cannabidiol”,
• (v) its net weight, in grams,
• (vi) its recommended storage conditions,
• (vii) its packaging date, and
• (viii) either
• (A) its expiry date, if a stability period for the dried marihuana has been established in accordance with section 65, or
• (B) a statement to the effect that no expiry date based on stability data has been determined for the dried marihuana;
• (d) the symbol “N” set out in the upper left corner of the label in a colour contrasting with the rest of the label or in type not less than half the size of any other letters used on the label;
  
  (e) the warning “KEEP OUT OF REACH OF CHILDREN/TENIR HORS DE LA PORTÉE DES ENFANTS”; and
• (f) the statement “Important: Please read the Health Canada document provided with this package before using dried marihuana. / Important : Veuillez lire le document de Santé Canada qui accompagne ce colis avant d’utiliser la marihuana séchée”.

61. A licensed producer who sells or provides dried marihuana to a registered client or an individual who is responsible for the client must ensure that

• (a) the immediate container carries a label that contains the following information:
• (i) the given name and surname of the client,
• (ii) the given name, surname and profession of the health care practitioner who provided the client’s medical document,
• (iii) the name of the licensed producer,
• (iv) the daily quantity of dried marihuana indicated on the client’s medical document,
• (v) the expiry date of the client’s registration referred to in section 107,
• (vi) the shipping date, and
• (vii) the date referred to in subsection 120(2); and
• (b) a separate document containing the information referred to in paragraph (a) accompanies each shipment of the dried marihuana.

62. In the case of dried marihuana to be sold or provided to a registered client or an individual who is responsible for the client, the information may be set out on one label.

63. A licensed producer must ensure that each shipment of marihuana is accompanied by a copy of the current version of the document entitled Information on the Use of Marihuana for Medical Purposes,

• 64. (1) All information that is required must bein English and in French; clearly and prominently displayed on the label; and readily discernible under the customary conditions of purchase and use.

 (2) All information in a document that is required under paragraph 61(b) or section 63 must be in English and in French and readily discernible.

66. It is prohibited to include a reference, direct or indirect, to the Act, the Food and Drugs Act or any regulations made under those Acts on a label of or in an advertisement for dried marihuana unless the reference is a specific requirement of either of those Acts or those regulations.

Shipping

67. (1) A licensed producer who ships dried marihuana to a person referred to in subsection 11(2) or (4) mustship the marihuana in only one shipment per order; securely pack the marihuana in a package that will not open or permit the escape of its contents during handling and transportation, is sealed so that the package cannot be opened without the seal being broken, prevents the escape of odour associated with the marihuana, and prevents the contents from being identified without the package being opened;

• (c) A licensed producer must use a shipping method that involves a means of tracking the package during transit, andthe safekeeping of the package during transit;
• (d) ship it only to the following address:
• (i) in the case of a registered client or an individual who is responsible for that client, the shipping address specified in the client’s registration document, and
• (ii) in the case of any other person referred to in subsection 11(2) or (4), the shipping address indicated in the order referred to in section 128; and

• (e) in the case of a registered client or an individual who is responsible for that client, ship the marihuana in a quantity that does not exceed 150 g.

Shipping — cannabis other than dried marihuana

(2) A licensed producer who ships cannabis other than dried marihuana to a person referred to in subsection 11(2) must

• (a) use an approved shipping method to the shipping address indicated in the order referred to in section 128.

DIVISION 7

SECURITY CLEARANCES

Eligibility

82. Only the following persons may submit to the Minister an application for a security clearance: a person named in an application for a producer’s licence, the proposed senior, responsible , or proposed alternate responsible person in charge;

• If a producer’s licence is sought for an individual, that individual; but if a corporation, each officer and director of the corporation; and the holder of a security clearance.

83. (1) In this section, “common-law partner” means any person who is cohabiting with the applicant in a relationship of a conjugal nature and has done so for a period of at least one year.

 (2) An application for a security clearance must include the following (a) the applicant’s usual given name used, other given names, surname, all other names used and details of any name changes;

• date of birth, gender, height, weight, and eye and hair colour;
• (c) if Canadian , the number and province of issue of their birth certificate; but if the applicant was born outside Canada, their place of birth, the port and date of entry, and, in the case of a naturalized Canadian or permanent resident, the number of the applicable Documentation.
• (e) either of the following documents:
• (i) a copy of a valid piece of photo identification or a copy of the applicant’s passport .;
• (f) the addresses of all locations at which the applicant resided during the five years preceding the application including the names and street addresses of the applicant’s employers and any post-secondary educational institutions attended;
• (h) the dates, destination and purpose of any travel of more than 90 days outside Canada, during the five years preceding the application;
• (i) the information referred to in subsection (3) respecting the applicant’s spouse or common-law partner and any former spouses or common-law partners;
• (j) the applicant’s fingerprints, taken by a member of a Canadian police force;
• (k) a facial image of the applicant for identification purposes, certified by a member of a Canadian police force; and
• (l) a statement signed by the licensed producer or the applicant for a producer’s licence certifying that the applicant for the security clearance requires or will require a security clearance and specifying the reasons for that requirement.

Spouse or common-law partner

(3) The information required in respect of any of the persons referred to in paragraph (2)(i) is

(a) in the case of the applicant’s spouse or common-law partner, the following information: their gender, full given name, surname and, if applicable, maiden name, their date and place of birth and, if applicable, date of death, if born in Canada, the number and province of issue of their birth certificate, iv) if born outside Canada, their place of birth, their nationality and the port and date of entry into Canada, and) their present address, if known; and in the case of former spouses and common-law partners with whom the relationship ended within the preceding five years, the same information.

 (4) The application for a security clearance is valid only if signed by the applicant.

• 84. On receipt of a fully completed application for a security clearance, the Minister must conduct the following checks and verifications for the purpose of assessing whether an applicant poses a risk to the integrity of the control of the production and distribution of cannabis under the Act and its regulations, including the risk of cannabis being diverted to an illicit market or use: a criminal record check in respect of the applicant; and a check of the relevant files of law enforcement agencies, including intelligence gathered for law enforcement purposes.