Cannabis Prospect Magazine - February '20 - Issue #7

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Cannabis Licensing Challenges Critical Components to Consider When Submitting a Federal Licence Application By Michael Ciardullo Regulatory Affairs & Quality Manager - Cannabis Licensing Lead, dicentra Cannabis Consulting

The preparation and submission of a federal cannabis licence application can be extremely gruelling and challenging. At first glance, a licence application may seem straightforward and easy to compile however for the majority of applicants, this isn’t the case. Throughout the preparation process, there are a number of considerations and challenges that can arise. Even with multiple guidance documents and resources that are readily available from Health Canada₁, they do not account for every aspect that should be reviewed when preparing your application and when making decisions about your facility. Before you begin your cannabis licensing journey, the following should be thoughtfully evaluated.


Cannabis Prospect Magazine | February 2020


This is probably one of the most overlooked aspects of a federal licence application. Oftentimes individuals looking to apply aren’t aware of the challenges posed by the municipality where their proposed site is located. Some municipalities don’t and won’t allow for cannabis production or processing, while others are currently in the process of amending and overhauling their by-laws to allow for and permit activities involving cannabis to take place. Another thing to consider from a municipal standpoint is the zoning of the land on which you intend to operate on. If the land is not zoned appropriately, a supplemental submission such as a minor variance or zoning certificate of occupancy may be required.

New Build vs. Retrofit:

Another challenge is determining which route to take when it comes to your facility. Each option has pros and cons. For example, a pro for a new build is the ability to design and build your facility from the ground up taking into consideration all the mechanical systems that are required, allowing for an optimal layout for production. The con to this is that it is a time-consuming venture and can be costly. From a retrofit perspective, a pro would be not having to spend time and money building a facility; lease options also exist provided that your landlord agrees to allow for activities with cannabis to take place. However, a con for a retrofit is you are limited to the existing layout. Further to that, you must ensure that the building has the necessary systems (e.g. air filtration and ventilation, plumbing, electrical) that will meet Health Canada’s requirements and production demands. It is important to consider both options before undertaking any construction or renovation activities.