Health Canada Update Summary on Physical Security Requirement for Cannabis for Medical Purposes
After 4 years of operation and nearly 1000 site inspections, Health Canada made an important announcement today regarding 2 targeted changes in the physical security requirement for cannabis for medical purpose.
- Licensed producers (LPs) will no longer be required to store cannabis in a highly secured physical vault.
- Instead of a vault, cannabis can now be stored in a secured area with physical barriers that includes an intrusion detection system, 24/7 visual monitoring and recording, recording of the identity of every individual that enters and exits the secured space and access restricted to those whose presence is required by their work responsibilities.
- Rooms where cannabis are grown no longer need 24/7 video monitoring and recording
- LPs are no longer required to maintain 24/7 video monitoring and recording of the space where cannabis is grown. However, it is still required to have 24/7 monitoring and recording of individuals accessing the secured area. In addition, seeds are no longer required to be stored in a vault and will now be permitted to be stored where cannabis is grown.
Health Canada concluded that these changes will not increase the risk of public health and safety. LPs are still required to respect all other security directives as outlined in the ACMPR including perimeter protection, intrusion detection, access control to prevent unauthorized access to the facility, visual monitoring and recording, access logs and strict control on inventory and shipment of cannabis product. The ultimate purpose of the regulatory control is to ensure that cannabis is not diverted to the illegal market.
From High to Low?
One comment that has repeatedly surfaced since the announcement is that Health Canada went from what many considered to be an excessive requirement for storage of cannabis goods and strict monitoring of plants growth, to something that may be labelled as “substandard”. Let us remember that the main goals of any security system are to protect its contents and personnel, deter potential attacks and maintain proper logistics for audit or incident review purposes. As a security consultant, I believe these targeted changes is a positive thing by making it much simpler for LPs to meet security compliance. That said, it is also our professional responsibility to open a dialogue with the LPs and to establish the right balance between minimum requirement, security effectiveness and of course, cost. While we often hear that it is important to educate our society on the benefits of medical cannabis, I think it is equally important for LPs to understand the importance of a proper security system to protect the future of their business investment.
A Look to the Future Together
As we move towards the legalization of cannabis for recreational use, I suspect these will not be the only security directives that will be updated. Many questions will be asked and certainly more confusing times are to come. Are you ready?
At CCI, we have the expertise and the know-how to help you navigate through this maze. Our team of consultants is composed of industry experts handpicked for their knowledge to help you reach your goal. Let us move together toward a future you envision. Contact us today.