Office of Medical Cannabis seeks to enhance how regulations enforced, interpreted

Canada's OMC is looking for input from producers and the public on how to better interpret and enforce existing medical cannabis regulations

Canada's Office of Medical Cannabis (OMC) is seeking to work with producers to help streamline their medical cannabis regulations, according to an announcement sent out to licensed producers under Health Canada's Access to Cannabis for Medical Purposes Regulations (ACMPR).

In keeping with Health Canada's Regulatory Transparency and Openness Framework (RTOF), introduced in 2014 with the goal of presenting information to the general public about the regulations behind the agency's health and safety rules, the OMC will be seeking to help refine and align the interpretation of the often confusing and cumbersome rules for licensed producers under the ACMPR.

Eric Costen, Health Canada

From an email sent to producers recently:

Health Canada’s RTOF planned activities included expanding and enhancing the inspection reporting for cannabis for medical purposes and providing the industry with more guidance to support compliance with current regulatory requirements. In support of these initiatives the OMC would like to publish the following documents on the Health Canada website:

· a guidance document on good production practices (Part 1, Division 1, Subdivision D) under the Access to Cannabis for Medical Purposes Regulations (ACMPR), and
· an industry guide on how to conduct a recall of cannabis for medical purposes.

The intent of both documents is to promote compliance and to enhance consistency in the application of both of these subjects by the licensed producers and Health Canada.

In line with the RTOF theme, Making Decision-Making Processes More Open, the OMC would like to engage you, the licensed producers, to contribute to our decision-making through consultation on the above documents.

The purpose of this email is to provide you with an opportunity to communicate valuable feedback on the usability (i.e. to make it user-friendly) and content (i.e. clarity, conciseness, feasibility) of the attached guidance document and industry guide. Your views and suggestions are essential to contributing to Health Canada’s decision-making process. We are seeking your input prior to these documents being published on the Health Canada website. As such, please include your feedback in the attached forms prior to the close of the consultation period (Tuesday, April 18, 2017). All comments received will be considered by Health Canada in making any revisions. If you do not have any feedback please respond to this email with a “nil” response.

Good Production Practices are the various rules for how cannabis and cannabis products grown and produced by Health Canada's licensed producers can be handled and processed. Canada's medical cannabis system is known for it's strict and often nebulous regulations, from security to quality assurance, which, according to input from numerous producers, often end up being interpreted differently depending on the inspector's own understanding of the rules.

These changes in this process, which will be made open and accessible to the public, will help address some of these issues of interpretation and attempt to create more of an even playing field for all producers. As the ACMPR grows and brings on more producers, this increased transparency and consistency will help ensure these new producers are not subject to a massive learning curve when it comes to this interpretive dance.

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