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.
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.