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Quality From Canada

The Devil is in the Detail – Changes to Canada’s Cannabis Regs to Encourage Patient Independence and Business Competition

By Tegan Adams, Elfi Daniel-Ivad MSc
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Canada’s new ACMPR was launched late last month on August 24th. The key change that most notice is that Canadians may now again grow their own cannabis at home for medical purposes. In addition, more strict guidelines for product testing and labeling requirements for Licensed Producers (LPs) were released.health-canada-logo

Short term pain for long term gain. While the combination of allowing patients to grow at home and more strict regulations for LPs may at first seem like a business disadvantage; overtime LPs will be thankful for the combination switch. Health Canada’s new requirements encourage a leveling of the playing field globally between LPs and large scale product manufacturers of pharmaceuticals, therapeutics and natural health products. The steps Health Canada is taking to regulate our producers, is exactly what they need to get ready for mass production that will be necessary for recreational markets, scheduled for release in Spring 2017.

Picture rows of Tylenol bottles on the shelf at your favorite pharmacy. Now picture rows of cannabis bottles on the shelf beside them. This is what medical cannabis will look like in Canada perhaps as early as 2018, if not sooner. With just under forty LPs on the map and a projected sales volume of modest billions, Canada’s LPs’ eyes are widening with dollar signs as they lube up their oil production and more to see what shelves in Canada will hold.

Curious to know more? Our regulatory department manager Elfi Daniel-Ivad is an expert in regulatory change. She has worked on close to 150 submissions for cannabis licensees in Canada and beyond. Here are a few key changes from her department’s overview to better understand.

MMPR ACMPR (Updated)
No personal production or designated production available to patients (aside from that grandfathered in by MMAR). Personal production and designated production available. Patients may grow 5 indoor plants OR 2 outdoor plants at any given time per gram prescribed to them.
Licensed Producers were not required to label THC or CBD amounts in dried cannabis, though most producers did for sales and educational purposes. Oils had to be labeled with THC and CBD amounts. Licensed Producers must label their percent THC and CBD for dried and fresh cannabis products.
For the labelling of oils, the total quantity of THC, CBD and oil in a container had to be shown. Restrictions on THC allowed no more than 10mg/mL THC per capsule and no more than 30mg/mL THC per mL oil to be distributed. In addition, oil labels must now include information on “carrier” oil and allergen information. Containers must be labelled with number of capsules, the net weight and volume of each capsule. .
No reference to validation of analytical testing methods. Analytical testing must be completed using validated testing methods; confirming reliability and consistency in results for   contaminants, disintegration, residues and THC, THC-A, CBD and CBD-A
Accredited labs can only test products as received from Licensed Producers. In addition to Licensed Producers, patients growing their own or having a designated grower growing for them may also test their products at an accredited lab.

In addition to these changes, it is important to note that if an individual or company has an MMPR proposal already submitted they can now revise it to include oil production (previously, it was first dried bud only). If a company submits a new ACMPR proposal, they can include oil production on their application right away. Interested in submitting your own application? Or need help with one in the USA? Our regulatory department would be happy to answer any questions you might have about the process.

Building or Converting to a Greenhouse? Four Considerations for Commercial Growers

By Taylor Engert
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Successful cannabis cultivation practices leverage commercial agricultural industry practices for the most efficient and cost-effective production of the crop. Since the 1990s, the cannabis industry has cultivated primarily in indoor warehouses and outdoor farms, however the industry is experiencing a significant shift toward greenhouses.

Shelly Peterson, vice president of light product solutions at urban-gro, joined a recent panel of industry experts including Shivawn Brady, chief executive officer and founder of Seva Crop Consulting, and Karl Keich, executive director at Canna Consulting Group, at the Marijuana Business Conference in Orlando, Florida, to discuss how to transition from an indoor or outdoor grow to a greenhouse facility.

What are the considerations when deciding between a warehouse and greenhouse? The panel shares four factors around the costs and operational challenges, and the benefits of a greenhouse.

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The panel at the Marijuana Business Conference.

Maximize Efficiency in Every Process

Why are cannabis cultivators looking toward greenhouses? Peterson says it is all about efficiency. “In a warehouse, electricity costs can run up to 50 percent of the total cost of goods sold, which is a tremendous amount that can be decreased by switching to a greenhouse,” says Peterson. “In a greenhouse, you can add supplemental lighting to augment what the plant is receiving from the sun.”

For cultivators, Peterson noted that it is critical to ensure growers have experienced vendors and advisors on the team to help maximize the efficiency of the greenhouse. “As the cost of this product comes down, the efficient growers will be the ones in it for the long haul,” added Peterson.

Construction vs. Operating Costs

A greenhouse facility that urban-gro helped bring to operation.
A greenhouse facility that urban-gro helped bring to operation.

The panel identified upfront cost as one of the biggest challenges faced when building out a greenhouse. “The cost of retrofitting a warehouse and building a greenhouse are similar, but where you will save is in the operational costs,” says Peterson. “Lighting can be up to one third of your total cost in indoor facilities, when you switch to a greenhouse that cost can be reduced by 50 to 70 percent.”

Brady acknowledged that some traditional greenhouses have challenges in controlling the environment, but automated greenhouses offer retractable roofs and siding. “If you have the resources to invest in your greenhouse system upfront, that is generally a better way to save money in the long run,” says Brady. “Managing pests in greenhouses can also become very challenging if you don’t have the proper climate regulations.”

Lighting for Your Greenhouse

One of the greatest benefits of growing in a greenhouse is the ability to source natural light. But what about the required light levels? Peterson pointed out that light levels change throughout the year and the plants have different light needs in different stage. Supplement with a lighting system that can read the natural light levels received over any given period of time and be adjusted accordingly. “Greenhouse facilities also need to be outfitted to meet the needs of the cannabis plant, which differ in some ways from other agricultural crops,” says Peterson.

Peterson explained that every light is designed with a different purpose in mind. “There are different lights for indoor warehouse facilities where the lighting system provides 100 percent of the available light for cannabis growth versus supplemental lighting for greenhouses,” Peterson adds. “The key is to measure how much light is actually delivered by the sun on a daily basis, which changes throughout the year; at urban-gro, we supplement the facility with light fixtures that will not create shadowing during hours of sunlight and adjust to reach the optimal collective light levels.”

With LED lighting a hot button topic, Peterson explained that the most important consideration for any light fixture, whether LED or HPS, is it’s efficiency capacity. “It all depends on the budget and payback period and a lot of numbers need to be crunched,” says Peterson. “Yield is directly correlated to light; planning properly, sealing your environment, making sure you have the right target DLI, and buying good light meters, are all key.”

Make a Positive Impact and Quality Product

Brady noted that industry leaders are conscious of positive impact towards human health and environmental stewardship when moving to a greenhouse. Cultivators may find the process challenging initially, however the facilities are quite easy to operate and manage, and allow stress-free cultivation of commercial-scale crops.

Keich added that the cannabis industry is becoming more like commercial agriculture. By utilizing the correct technologies and regulators, greenhouse cultivation makes the crop smell, taste and look that much better. “Let’s use natural sunlight to minimize costs and be environmentally friendly to produce a superior product,” says Keich.

Peterson wrapped up by stressing that cultivators should evaluate the greenhouse environment and lighting to improve their bottom line. “Look at the most efficient way to lower your cost of goods sold. Lighting is a very big component to that,” she continued. “Make sure you evaluate the efficiency of the fixture and ask the questions: Why are we targeting this light level? Is the color spectrum correct? Are you measuring in micromoles per watt? These are all different questions, however figure out how much light is coming out of the fixture and verify it for yourself, and you will be successful,” says Peterson.

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Biros' Blog

Sustainability of Cultivation in 2016, Part I

By Aaron G. Biros
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A few weeks ago, it was that time of the year when people set new year’s resolutions hoping to accomplish a set of goals or somehow better themselves. More often than not, those expectations never get met and those resolutions remain unfulfilled, lofty ambitions.

The cultivation of cannabis is a production process that is notoriously inefficient and energy-intensive. Indoor growing requires a very large carbon footprint. In 2015, we saw the country’s cannabis market grow to roughly $2.7 billion. Looking forward to 2016, we can expect more growth with multiple states voting on recreational sales including California and Nevada, leading to more growers and a higher volume of cannabis production across the nation.

I am suggesting a resolution for cultivators to adopt: Grow your cannabis more sustainably. This might seem unattainable, but the key to a good resolution is a force of habit, setting small goals to improve your production process and make your operation more efficient, ultimately saving you money and reducing your carbon footprint. This series will delve into some of the tools cultivators can use to grow cannabis more sustainably.

Environmental, social and economic sustainability are the three pillars of sustainability to keep in mind. Many describe it in terms of people, planet and profit in reference to the Triple Bottom Line of 21st Century Business. Essentially, cultivators should adjust their standard operating procedures and business model to include their responsibility to be environmentally, socially and economically sustainable.

The challenge of growing cannabis efficiently is understandably daunting. A research study published in the journal, Energy Policy, suggests, “One average kilogram of final product [dried flower marijuana] is associated with 4600 kg of carbon dioxide emissions to the atmosphere.” That translates to an enormous carbon footprint, the equivalent of roughly three million cars.

The use of pesticides is also a tangible social and environmental issue of sustainability because of the potentially harmful effects on the cultivation environment and the consumer. Just last week, Denver recalled almost 100,000 edibles due to concerns of dangerous pesticide residue. Growing pesticide-free marijuana is more sustainable across the board for obvious reasons; it is safe for the consumer, less harmful to the environment and more marketable as a clean and safe product.

There are a lot of tools in the cultivator’s arsenal they can use to work toward a more sustainable operation. Some of these include more energy efficient technology, like LED lighting and efficient HVAC systems. Some tools require more effort to implement like moving toward greenhouse growing, using post-consumer products, support fields, composting and others.

In this series, we will hear from growers offering advice on some of the steps you can take to grow your cannabis with sustainability at top of mind. Alex Cooley, vice president of Solstice, a cultivation and processing business in Washington, will share some insights on the sustainable technologies you can implement to improve efficiency in your grow operation. Stay tuned for Part II of Sustainability of Cultivation in 2016.

From Produce to Cannabis: The Future of Indoor Agriculture

By Aaron G. Biros
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Throughout the United States, a majority of cannabis for medical and adult use is grown indoors, which requires a tremendous amount of energy and is generally inefficient. State regulators and cultivators alike are beginning to notice the benefits of greenhouse and outdoor-grown cannabis, primarily for energy efficiency and environmental sustainability.

Basil plants ready for packaging and shipping at the Edible Garden facility in Belvidere, New jersey
Basil plants ready for packaging and shipping at the Edible Garden facility in Belvidere, New jersey

Terra Tech, a publicly traded company, cultivates environmentally sustainable produce through its subsidiary, Edible Garden, in Belvidere, New Jersey. Utilizing Dutch hydroponic cultivation methods, integrated pest management and computer-controlled automation, Edible Garden grows certified organic herbs such as thyme and basil in their greenhouses in New Jersey.

Poinsettias ready for distribution at Edible Garden facility in Belvidere, New Jersey
Poinsettias ready for distribution at Edible Garden facility in Belvidere, New Jersey

Edible Garden is certified by the Global Food Safety Initiative (GFSI), which provides internationally recognized benchmarks and guidance for managing food safety and meeting standards. According to Ken VandeVrede, chief operating officer of Terra Tech, the company plans to take these cutting-edge practices and standards from cultivating produce to the cannabis industry to grow quality, sustainable and safe cannabis in states where it is currently legal.

The company is actively making its operations more environmentally sustainable via greenhouse cultivation, Dutch style hydroponics, shipping locally, and integrated pest management. “We plan on implementing guidance from our two years of GFSI certification and our organic certification along with all of our practices from the food side and bring them to cannabis; for us, it is just another plant,” says VandeVrede. With the help of computer automation, he says they can cultivate cannabis at the commercial scale, creating more homogeneity by removing human elements and utilizing environmental controls. Through computer automated blackout curtains in their greenhouses, they plan to minimize energy usage by using natural sunlight when possible.

“The procedures are very similar across industries so we are creating our own internal standards for cannabis cultivation,” says VandeVrede. “We are trying to be at the forefront of the industry and set the standard for growing cannabis, because right now, there are no standards in place.”

Mint plants ready for harvest at the Edible Garden greenhouse
Mint plants ready for harvest at the Edible Garden greenhouse

Terra Tech has already started its move into the cannabis industry via its subsidiary, IVXX LLC, which makes medical cannabis extracts for dispensaries in California. The company has also broken ground on cultivation and production facilities in Nevada and dispensaries in California, and submitted an application for licenses in Maryland. “Terra Tech is doing everything with vertical integration in mind; we will control the cultivation, bringing experience from our agricultural background to cultivate high quality and high yield cannabis, making oil and extracts with it to sell in our dispensaries,” adds VandeVrede.

Looking to the future of cannabis cultivation, Terra Tech’s plan is to keep environmental sustainability at top of mind. “As a company we are growing indoor, but moving toward greenhouse cultivation across the board”, says VandeVrede. “Our focus on expansion will be [include] greenhouse-grown cannabis, which is a lot more efficient, saving us money but more importantly reducing our overall carbon footprint.” With more companies adopting these sustainable farming practices, the industry might soon usher in a new era of environmentally friendly cannabis cultivation.