The Cannabis Act governs medical and recreational cannabis in Canada. The Act provides a number of business license categories including: standard and micro cultivation, nursery, standard and micro processing, sale for medical purposes, analytical testing, and research.
The Cannabis Act also dictates a number of key individuals that must be designated by license holders. These positions include Head of Laboratory, Quality Assurance Person, Master Grower, Head of Security, and Responsible Person in Charge.
Head of Laboratory
An analytical testing license holder must designate an employee to serve as Head of Laboratory. This person is responsible for the testing that is carried out by the licence holder. A security clearance isn’t required for the Head of Laboratory under the Cannabis Act.
Responsibilities:
Planning, directing, organizing, and controlling the overall laboratory including: all analytical or microbial methods performed, regulatory compliance, data management, implementation of new technology, and related work as required
Overseeing lab staff who provide laboratory services to the medical and/or recreational licensed cannabis industry
Developing and maintain laboratory policy and procedure manuals, quality procedures, standard operating procedures (SOP’s), equipment specific requirements, and evaluating and implementing new procedures as necessary
Work at the licensed site and be responsible for the testing activities under section 91 of the Cannabis Regulations, including:
Testing for residues of solvents used in the production of cannabis oil
Testing for microbial or chemical contaminants as established in Schedule B of the Food & Drugs Act
Testing for dissolution or disintegration specific to formulation
Testing for the quantity or percentage of THC, THCA, CBD and CBDA
Developing analytical methods and microbiological assays
Preparing and/or reviewing regulatory, managerial, and operational reports
Preparing and delivering oral presentations at trade shows, industry events or government regulators events
Ensuring that employees are appropriately recruited, including hiring, training, daily management, discipline, and promotions
Overseeing facility improvements and maintenance to improve efficiency and safety
Formulating objectives and priorities, implement plans, and allocate resources to achieve long-term goals of the Laboratory
Qualifications:
Experience in Laboratory Management, proven knowledge and experience related to the duties of the position
Minimum of a science degree that was obtained in Canada or recognized by a Canadian university or professional association
Required to be familiar with the applicable provisions of the Act and associated regulations
Quality Assurance Person
Standard and micro processing license holders must designate a Quality Assurance Person (QAP). The QAP must have a security clearance.
This person is responsible for assuring the quality of cannabis before it is made available for sale, investigating complaints received about the quality of the cannabis, and taking corrective action.
Responsibilities:
Responsible for assuring the quality of the cannabis before it is made available for sale
Responsible for approval of methods and procedures related to GPP
Write, review and maintain standard operating procedures (SOP’s) for site facility
Ensure staff are trained on SOP’s and GPP, coordinate ongoing training to ensure compliance or re-training where needed
Oversee pest control program and ensure pest control procedures are authorized under the Pest Control Products Act or the Cannabis Act
Ensure cannabis is stored and distributed under conditions that maintain its quality
Oversee the sanitation of premises and equipment cleanliness, hygienic behaviour of personnel, and maintenance
Establish and maintain record keeping systems and ensure employee adherence to proper documentation practices
Review quality complaints and lead investigations including corrective action and preventive action
Ensure testing is conducted on each lot or batch of cannabis before it is released for sale
Ensure testing is conducted using validated methods, investigate deviations and out of spec results
Collaborate with other departments to ensure compliance with regulations
Manage and coordinate staff, create department efficiencies and provide leadership support
Communicate effectively to all levels of management
Perform internal audits and vendor evaluation audits on a regular basis to determine quality qualifications. Actively participate in external audits such as regulatory inspections.
Perform analysis of reports and production data to identify trends and recommend updates or changes to quality standards and procedures when necessary
Qualifications:
Experience in Quality Assurance Management in a similar production environment, proven knowledge and experience related to the duties of the position
Minimum of a science degree that was obtained in Canada or recognized by a Canadian University or professional association
Required to be familiar with the applicable provisions of the Act and associated regulations
Master Grower
Standard and micro cultivation license holders, as well as nurseries must designate a Master Grower. Master Growers are required to have a security clearance. This person is responsible for the care and growth life cycle of cannabis plants in a large-scale commercial facility.
Responsibilities:
Responsible for overall plant health and crop yield
Work towards achieving maximum yield, with lowest costs while maintaining high quality standards
Oversee all the tasks in the growing process including: seeding, cloning, transplanting, nutrient management, pest management, defoliation, topping, flushing, foliar, waste disposal, etc.
Develop and/or maintain facility protocol and nutrient regiment
Develop and/or maintain protocols for lighting, temperature and humidity manipulation
Apply knowledge on preventative maintenance of plant diseases, insects and fungi
Coordination of production schedules
Establish methods to meet work schedules and co-ordinate work activities, with production and quality assurance, setting clear expectations of the work to be done with the growers to ensure product quality
Provide a weekly crop status summary
Manage and account for all inventory and supplies
Follow all company standard operating procedures (SOP’s) to maintain compliance with regulations
Maintain concise daily records and ensure documentation is accessible and organized in a compliant manner
Lead, train and mentor junior staff
Maintain a clean and organized work environment
Qualifications:
A preference for a horticulture or science diploma or degree, or related field
Proven commercial growing experience in a management capacity
Knowledge of large scale commercial plant cultivation
Head of Security
Standard and micro cultivation, nursery, standard and micro processing, and license holders for sale for medical purposes are required to designate a Head of Security. The designated Head of Security is required to have a security clearance.
This person is responsible for the organizational security plan and for ensuring that the physical security measures comply with Part 4 of the Cannabis Regulations. The Head of Security is responsible for all video surveillance systems, monitoring all access control and intrusion detection systems, and monitoring and reporting violations of overall safety and security procedures throughout the facility.
Responsibilities:
Oversee risk mitigation procedures are in place to detect and respond to scenarios that could compromise an employee’s security clearance or the organization’s security
Implement and/or maintain proper protocols for staff, guest, vendor, and contractor arrival and entry to the facility, including procedures for breaches
Oversee proper access control and intrusion detection protocols for staff, guest, vendor, and contractors to areas where cannabis is present including vault/storage areas and deliveries/pick-up
Maintain appropriate records of entry and exit to restricted and storage areas
Implement and/or maintain response procedures for any access control or intrusion detection breaches to areas where cannabis is present, including vault/storage areas
Oversee security measures to ensure the safekeeping of cannabis when being shipped, delivered and/or transported
Maintain physical security through the monitoring, storage and retrieval of video monitoring footage
Ensure the specification, type and number of video surveillance devices meet requirements under the Act
Implement and/or maintain procedures for the secure handling of cannabis waste and destruction process
Oversee internal security training and awareness requirements for management and employees
Implement and/or maintain procedures for reporting security concerns, incidents or breaches by employees
Implement and/or maintain contingency plans for record keeping system failures
Oversee theft and loss detection procedures and awareness training
Implement and/or maintain procedures for validating that cannabis entering the facility is from a legal source
Oversee procedures for the protection of client information
Implement and/or maintain response procedures should cannabis be found to enter or leave the facility in an unauthorized manner, ensuring a testing protocol for the response procedure
Qualifications:
Proven experience in security leadership in a regulated environment
A diploma or degree in a related field
Security professional designation is considered an asset
Responsible Person in Charge
The Responsible Person In Charge (RPIC) is someone who has the overall responsibility for the activities in a cannabis facility and are the official point of contact with Health Canada and through the Cannabis Tracking & Licensing System (CTLS). As per Health Canada:
“Responsible person: This is an individual who has overall responsibility for the activities conducted under the licence and has the authority to bind the licence holder. The responsible person must have sufficient knowledge of the provisions of the Act and the regulations. Every licence holder, irrespective of the class or type of licence, will be required to have a responsible person.”
The RPIC title is technically a security clearance designation, which is unique to the cannabis industry. The person assigned as the RPIC would need to possess a security clearance and could also hold another position such as Master Grower.
The purpose of security clearances are to prevent those associated with organized crime or with past convictions for drug trafficking, corruption or other violent crimes from infiltrating the legal cannabis market.
As noted above in the job descriptions, in addition to RPICs, security clearances are required for the Head of Security, Master Grower and Quality Assurance Person - or their alternates for all license holders except analytical testing or research.
Cannabis At Work has extensive experience placing key personnel for license applicants and license holders. Please contact us for more information.
