Key changes to medical cannabis access with the ACMPR

Health Canada released their updated medical cannabis regulations today with the implementation of the Access to Cannabis for Medical Purposes Regulation and the repeal of the Marihuana for Medical Purposes Regulations (MMPR). While analysis is sure to unfold over the coming weeks, here are a...

Health Canada released their updated medical cannabis regulations today with the implementation of the Access to Cannabis for Medical Purposes Regulation and the repeal of the Marihuana for Medical Purposes Regulations (MMPR). While analysis is sure to unfold over the coming weeks, here are a few key stand-outs from the changes to the regulations:

Personal Production/Designated Growers

The biggest change in the new ACMPR allows those with authorization from Health Canada to produce cannabis for themselves, or through a designated grower. Those seeking to produce cannabis in this capacity can order starting materials (clones, seeds) from Licensed Producers.

Plant counts are based on the individual's gram-per-day recommendation from their health care provider. 1 gram a day = 5 plants indoors or 2 plants outdoors. Health Canada estimates one indoor plant can produce 30 grams of cannabis, with 3 crops in a year. They estimate one outdoor plant can produce 250 grams of cannabis, one time a year. When buying starting materials from an LP, 1 plant = 3 seeds. If the production of plants is part indoors/part outdoors, every 1 g per day of dried marihuana = 4 plants indoors and 1 plant outdoors.

Individuals can order only the amount of starting materials that their gram a day total allows, but may order that amount as many times as necessary to account for crop failure. Far more details apply, including background checks, location information, etc. Application.

Registration with multiple producers

While the MMPR didn't explicitly allow or dis-allow doctors to 'split' gram a day totals among various producers, the new ACMPR explicitly refers to doctors being able to do so with multiple documents.

Streamlined patient registration

Licensed Producers are no longer required to verify medical documents where the signature of the health care practitioner is known to the producer. This will allow producers to further streamline the registration process for patients. 

Streamlined Producer Licensing

The ACMPR will allow LP's a single application for production & sale of fresh & dried cannabis, cannabis oil, and cannabis seeds & plants. Under the MMPR, each required an individual license.

The ACMPR is expected to save money

Incremental costs of approximately $1.5 million in present value (PV) in the first fiscal year (2016–2017) and annualized average costs of approximately $3.4 million PV are expected for Health Canada in implementing the ACMPR. Health Canada’s administrative costs increased to almost $25 million annually by the time the MMAR were repealed. Health Canada costs to administer the MMPR in 2015–2016 were approximately $9.9 million.

Product Testing

Health Canada will now permit those allowed to produce their own cannabis under the ACMPR (as well as those currently covered under the MMAR Allard Injunction) to send their cannabis products to accredited testing labs. More info

Changes still coming

While Health Canada looked at pharmacy distribution in this initial rewrite, concerns with rapid implementation as well as this mode of distribution's ability to address the court's concerns regarding access and affordability were considered too limiting. However, pharmacy distribution is expected in future changes to the ACMPR.

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6 comments

  1. Robert Laurie Reply

    Good intro to the issues. My question. Are legal costs and court time plus government resources to enforce the mmpr factored into the costs savings analysis of the program?

  2. Moi! Reply

    Great article, sad that it has to cover this somewhat contentious issue still, though..

    Uhm.... why not disposable testing kits available at Canadian tire fro crying out loud... this is all great except the CDSA as a paramount 1st step renders ALL this moot right out of the starting gate.. really. sigh.

    1st things 1st, & can't believe the likes of me... average Canadian I be, having to remind the room of this yet again.

  3. Brad Reply

    At first, I was glad to hear that Canada would be embracing cannabis and legalizing it. It has been 30 years since I sat with friends on a basement couch somewhere and talked about how silly the laws around weed were. We knew this instinctively even as teenagers. As for affecting us at that young age...phht...all of us are doing quite well despite being potheads at young ages. Some of us are running businesses, some became professionals, some became artists, most have families. There is nothing wrong with weed at any age in my opinion. Baby not sleeping well? A little CBD oil should do the trick. Has the child some attention problems? Try a daytime Sativa tincture from early harvest plants and watch them concentrate better.
    I digress. Canada's government needs to get out of the cannabis business altogether. Collect taxes from the businesses that are in the weed game just like any other businesses. But forget all this licensing nonsense and restrictions and rules around how much you can or can't grow. NOBODY is going to follow any of these. They will continue to grow their own weed and grow some extra for sale. They will help their friends out when they need medicine too. For the government to let big corporate money take over is just a transference of cartel power to the Canadian government. They are essentially the new cartel. Just like Medien Columbia, where the cartels build the schools and the hospitals using profits from drugs, the Canadian government, by legalizing it, has effectively taken the business out of the cartel's hands and become the new drug czars. This is and will continue to be messy as long as the government thinks we cannot manage ourselves and that they need to govern us for our own safety, this won't work. The multi-billion dollar weed business was built by so called criminals and drug addicts. Yet at any given time in any given city, I can order weed right to my door in 15 minutes or less. The government's brilliant system? Order by mail and wait 2-4 days. Step back government. We can handle this better than you can. And far better than those who don't even use cannabis are going to do. How can any suit that's never had a reason to try weed, possibly run a company that is supposed to connect with the patients it serves? That's like hiring a roofing contractor that has never been on job sites. Doesn't makes sense. So what do they do? They hand it over to BIG PHARMACY, whom we all know don't want cannabis to disrupt their margins etc.. Good idea. They are the biggest crooks of them all. This is going to get really messy unless the government steps back and lets us do what we've been doing anyways for 70 years. Plus let anyone out of jail that is in there solely for weed charges. And say sorry to us all for being so blind and slow to fix this. Fewer rules are the answer. Not more.

  4. Dave Reply

    If growing outdoors, is crown land acceptable to grow on. Or does the government allocate a designated area.

  5. Jsmithers Reply

    This was a great read. One question I have is "if you are able to grow 15 plants at one time, can you have 15 (not quite mature) ladies and 15 seedlings at the same time? How do they answer this question?

    1. Profile photo of David Brown

      David Brown Reply

      Health Canada's rules don't appear to make a distinction between mature and immature.