Security Updates from the Health Canada for existing and potential Licenced Producers

On January 25, 2018, Health Canada updated the security requirements for Licenced Producers under the Access to Cannabis for Medical Purposes Regulations (ACMPR). This amendment to the regulations makes substantive changes to the storage area(s) for current licensed producers and applicants, including re-classification of which was previously the ‘vault’.  As per the Security Directive the vault is now generically defined to be a ‘secure rooms or areas’. There are also impacts on the requirement for cameras within controlled areas such as grow rooms.

For the “secure room” the minimum requirements are as follows:

  • The security that was previously required for the VAULT by way of intrusion system and sensors is to be maintained. This includes full and detailed video surveillance that works in all conditions, and access control for all entry/exit points that logs and records all person(s).
  • The secure room is no longer required to have ‘free and clear’ space on all sides and ceiling as per the regulations but needs to be physically built to prevent unauthorized entry through the entry/exit points and walls/ceiling/floor, as well as allow ‘good production practices’ for a clean zone.
  • The secure room must be constructed in a manner that allows for ‘good business practices’ for the cleanliness and ability to sterilize the area.
  • Either the RPIC or A/RPIC must be present when work is conducted in secure areas. Only person(s) required to be in the storage area(s) for their work are allowed.
  • The new regulations specifically removes the requirement for 24/7 visual monitoring/recording.

Although HC has reduced the requirement for security, there are additional considerations that must be reviewed at time of construction:

  • Insurance underwriters have strongly signalled that they will adopt the model used for the jewellery industry. This means the higher the value or risk area or history of the site/business, the higher the insurance premiums will be. Premium are, in part, linked to the sophistication of the security system and the ability of the business to protect itself against disruption or theft.

HC has yet to determine the “standard” physical requirements of the storage room(s), but it is clear that the materials used must prevent unauthorized entry through the doors, walls, ceiling or floor. This will require the room(s) to be constructed of a hardened material and the doors and door frames of commercial grade steel at a minimum.