Often MMPR applicants don’t know what to expect from Health Canada when reporting on a monthly basis. We’ve had the pleasure of working with several licensed producers and developing an extensive record keeping and seed to sale traceability system, to make your monthly reporting a breeze. In fact, Grow One allows for “one click” Health Canada reporting, doing all the investigative work for you and your team.
In this article, we outline a monthly Health Canada report at a high level, and what information you will be expected to collect.
Cannabis Produced & Transferred
Total amount of marijuana produced and ready to be sold, and the amount of marijuana transferred from licensed producers.
Total Cannabis Sold
Total cannabis sold to clients and licensed producers.
Clients Registered
Total number of clients registered in total, and that particular reporting period.
Refusal of Registrations and Orders
Number of clients who were refused from registration, and refused from purchasing cannabis.
Production Inventory
Required to include, plants in every harvest phase, ready for sale, samples, inventory ready for destruction, and current plants in production.
Imports/Exports
Amount of marijuana imported and exported.
Lost, Stolen, and Destroyed
Total amount of marijuana and product that was lost, stolen, and/or destroyed.
Shipments
Must include total number of shipments to patients and wholesale clients. You’re also required to include the number of shipments per province.
Averages
Average amount of daily limit and shipment size.
Medians
Median amount of daily limit, and shipment size.
Highest/Lowest Totals
Ten highest and lowest of totals shipped to a client.
Physicians and Nurses
List of all physicians and nurses who have provided medical documents and prescriptions to patients.
Estimations and Forecasts
Three month production and inventory forecasting.
It’s a very deep level of reporting , but MMPR compliant seed to sale software like Grow One can provide one-click reporting at an ease, and actually make such reporting an extremely fun process.
When Licensed Producers under the Marihuana for Medical Purposes Regulations (MMPR) think of the long process of obtaining a medical document from a patient or physician, they often imagine it as a huge hurtle to overcome - a pain in the neck. Health Canada allows for e-prescribing or secure fax for obtaining the original medical document - a method not many MMPR applicants know of.
The traditional method for obtaining the medical document is receiving the prescription via snail mail, and phoning the physician endlessly until you are able to reach them, only to find out a patient attempted to add another “0″ to the end of the prescription making it “300″ grams rather than “30″ grams.
Thankfully, technology has brought us into a new age of automation, allowing us to transfer data quickly. Specific provinces allow for physicians to submit the original medical document electronically (which makes our lives A LOT easier)
To do this, the LP first needs to co-ordinate with the physician and verify that the province where the physician resides allows for electronic medical documents (refer to the provincial professional licensing authority). Without this, the physician is not allowed to submit an electronic version of the prescription.
It is indeed the responsibility of the LP to ensure that the electronic system used follows these guidelines:
All transactions are secure and protected
All data go through security checks before being processed
Persons submitting information are authenticated
Persons accessing information are authenticated and recorded
Full traceability
Retention of data, and ability to generate reports on demand
Follows PIPEDA guidelines and rules for how public sector organizations collect personal information
Of course, a verification is still required for each medical document. The ability to use e-prescribing speeds up the process significantly, making obtaining the medical document a smoother and more efficient process.
We recommend developing an SOP around obtaining medical documents and verifying them. Traceability and CRM software such as Grow One help record and document every aspect of your procedures.
We’re extremely pleased to announce that we’ve doubled our software team, introducing two new developers to the staff.
In addition to these new team members to our development, we’ve also introduced a new Sales and Account Manager to our company.
It seems like we’re running out of space on our website - so we will be introducing our new staff members over the course of the next few weeks on the Grow One blog (while we announce some other new exciting things happening)
Licensed Producers face a challenge when it comes to marketing and advertising within the MMPR in Canada. Health Canada continues to treat medical marijuana as both a “drug” and a “narcotic” - and thus they expect producers to take a traditional “big pharma” approach to advertising with physician outreach and education to patients.
As most licensed producers and applicants found out late last year, Health Canada monitors websites and other information published by applicants and LPs to ensure that everyone complies with the advertising prohibitions that they’ve outlined.
This is an on-going challenge that producers face as it’s a war of acquiring patients. We’ve heard some strategically ways that applicants (and some producers) are taking to acquiring patients, since the advertising prohibition makes it extremely hard to do so.
For a better understanding of prohibited advertising activities in the MMPR, we have listed a few examples:
Promotional images/pictures of cannabis processing and packaging
Explaining how the product tastes and makes patients feel
Promotional articles and videos
Therapeutic claims relating to the use of marijuana
Advertising materials that reference (or link) to other sources which claim this information
As you can see, Health Canada continues to make the advertising and marketing regulations a moving target and producers continue to face (new) challenges. It seems that Health Canada has made it obvious that they expect LPs to use the Health Canada List of Licensed Producers as a form of advertising - only providing the company name, and phone numbers for more information (removing the website links shortly after warning letters were issued).
For more information on the Health Canada’s advertising regulations for marijuana, please see the Advertising prohibitions pertaining to marijuana.
MMPR Guide - Which E-Commerce Platform is the best choice for your marijuana store
With so many options in the marketplace these days, choosing the best e-commerce platform for your marijuana store can be a difficult choice, especially for those who are not familiarized with web space. The number of e-commerce platforms your company can use as a channel to sell product to your patients is countless.
From a patient's point of view this choice may not seem all that important since virtually all e-commerce platforms allow you to customize the front facing end for your patients. However, the customization on the back-end of the platform, dealing with your processes and functionality with your seed to sale software, may be limited. Don't worry - Grow One plays nicely with everyone we list on this article!
In this article we provide non-biased reviews on 3 of the most popular e-commerce platforms that we suggest to our clients (and see licensed producers using) to distribute product to patients under the MMPR.
Shopify
Shopify seems to be a favourite with most Licensed Producers under the MMPR. The admin panel is sleek and easy to use. You can easily integrate this into most seed-to-sale software solutions (but you will need to use their proprietary platform to build an app to integrate in). They have pricing that best fits any size of company. They also integrate with most payment processors (including Moneris) - which is a major upside.
The downside to using Shopify is the limitations to customizing the check-out page, and the fact that it’s not an open source product and you’re required to use their proprietary apps (or build your own). We’ve seen most licensed producers build their own apps to integrate into Shopify, or use solutions such as Grow One to plug directly in. It’s also important to remember that your Shopify store will be hosted on their 3rd party servers, so you will not be able to host this information internally. However, if you use an MMPR compliant seed to sale ERP system like Grow One, your Shopify orders will be automatically synchronized to your Grow One server (whether you’re on the cloud or on-premise), and you can use our ordering and fulfillment system to handle your orders.
Pricing varies from a sales transaction fee model to a flat-fee model for larger transactions (Shopify Plus - which we see most licensed producers using).
Magento
Magento is what we refer to as the opposite of Shopify - rather than hosted on the cloud with a monthly subscription, it’s hosted either on-premise or on a dedicated server (so you can choose for it to be hosted in Canada). They offer the open source approach with a very large community, rather than Shopify where you need to use their proprietary apps (or build your own).
Additionally, rather then being forced to use proprietary apps (or build your own), Magento is completely open-source and allows for easy plugging in and integration without having to make your own app. Integration with payment processors is a breeze (like Shopify). Their platform is also extremely customizable.
Magento offers a (traditional) licensing fee of $18,000 per year, or you can choose to go with their free/light version which seems to fit most licensed producers.
WordPress
WordPress offers a very lean approach to e-Commerce. WordPress offers countless add-ons and themes to choose from. The major downside with WordPress is the simplicity of updating your online marijuana store (compared to Shopify). If you choose to work with WordPress it is suggested that you hire a web developer since they leave it up to you to deal with all the technicalities and securities associated with running your store.
WordPress E-Commerce can be be hosted either on your own server, or a server hosted with WordPress. Like Shopify, it integrates with most common payment processors (again, Moneris), but you will likely need to do the customization for your payment processor yourself, rather then it being turn-key.
A major upside with WordPress E-Commerce is that it’s completely free - yet you will likely have to absorb the cost of dealing with a web developer on a regular basis to help maintain your online store.
Although, each of these e-commerce solutions have plenty other options that are not listed in this article, these are high level features and benefits that can give you the step in the right direction when making your decision. For your convenience we’ve included a chart with a breakdown of the article.
MMPR Guide - Packaging and Labeling your Cannabis Flower
So you have a nice batch of freshly cured flower sitting in a sealed 1000 gram nitrogen pack bag, and you’d like to turn this product into packaged inventory so you can sell it to your patients.
There are a number of different workflows and procedures when Licensed Producers package their product, and in this article, we cover the most common approaches to packaging and labeling your product. The most common process at a licensed producer is a “Pick & Pack” approach; 1) orders are received, 2) the packaging and/or fulfillment clerk packages the cannabis flower on demand, 3) at the time of fulfillment, the product is labelled and placed into the customers order.
The second most common process to packaging and labeling, is to have a “Pre-Pack” process built-in where the licensed producer pre-packages high demand product to help keep shipments moving for your patients.
In other cases, advanced and larger scale facilities may have “Automated Packaging”; a labeling and filling machine to automate this process rather than using employees. We won’t cover this topic in this blog post, but will cover fill systems and machines in a later article.
Regardless of the scenario, this guide will serve all of the above.
Packaging
What Container/Package Sizes Should I get?
If you are in a Pick & Pack scenario, it’s likely that you may have only one standard size container that you ship for all marijuana orders. In a Pre-Pack scenario, you will likely have different containers that can hold different sizes of dried flower (typically in 5 g increments).
Pay close attention to your product and patient demand as to figure out what best suits your production facility. If you are still in the process of obtaining your MMPR license, it’s safe to suggest a Pick & Pack process and wait to see your patient and product demand. Otherwise, if you’re already a licensed producer and having problems keeping up with orders, it may be considerable to begin to Pre-Pack your high demand products and strains.
What are the Different Container/Package Types?
It’s important to consider your marijuana packaging as part of your company appearance as it will be one of the visuals your patient remembers you by. So be considerate and meaningful when selecting your packaging type.
Make sure the containers you purchase are large enough for your label to fit properly and legible for children to read. Your packaging must also be child-resistant. Packaging must also be sealed when shipped to a patient.
Pill/Jar Container
This is the most typical packaging we see for marijuana flower. Get a colour that matches your company. Again, purchase the container sizes based off your packaging workflow and approach. It’s also important to consider that if you’re buying one size of container, you may have to ship out multiple containers in one order for a patient, so you will want to consider being conservative on size. Odour control is sometimes difficult with containers. Containers distributed under the MMPR must be child-resistant and properly sealed when shipping to patients.
Bag Package
You can also use a paper-like bag for your packaging. The pricing for these is typically cheaper and they are known to keep the odour controlled. However, bags are not considered to be green because you cannot reuse or recycle them.
Labeling
Client & Product Label
Client and product labels are the least common type of labels (typically due to size constraints on most packaging). Remember to follow Health Canada's regulations, but ensure your label reflects your brand. Be sure to include all variables required by the MMPR.
It would be wise to use this approach to labels if you would like to label your product during the packaging process (remember, you are still required to attach the client label at the time of the sale).
Combined Label
A combined label is very similar to the client and product label, but rather than two separate labels, it’s combined into one label. This is convenient if you’re planning on labeling at the time of fulfilling an order. This is currently the most common approach to labeling. See the sample combined label below.
Implement a software system (such as Grow One) that allows you to upload your custom branded labels rather than having to go back to your software vendor each time to get your labels updated.
What About The Expiry Date?
A common question I receive from 3/4 of MMPR applicants I speak with is the requirement of putting an expiry date on their label.
It’s important to still include the “Expiry” text on your label, even if it’s not determined. The only way of determining an expiry date is if there has been stability studies on the specific product to ensure that the relevant criteria (like potency) has been maintained.
Things To Remember When Packaging & Labeling
A single packaged container cannot exceed 30 grams of marijuana.
The packaged container must keep contamination out of the flower.
Your container opening/lid must be able to be sealed (so the patient knows it wasn’t opened previously)
All containers/packaging must be child-resistant packaging.
Make sure labels are English and French.
Make sure your labels are compliant with the regulation, and at the same time represent your company brand.
Have a proper SOP written for the packaging and fulfillment process (if you write it correctly, you should be able to do a very easy recall with some investigative work). Be sure to have extra verification steps (to make Health Canada happy).Â
Eliminate human error: use MMPR approved seed-to-sale tracking software that manages inventory, packaging, and labeling like Grow One.
MMPR Guide - 8 Tips for Effective Record Keeping within the MMPR
With the MMPR (Marihuana for Medical Purposes Regulations), proper record keeping is absolutely crucial for any licensed producer's success. I decided to share our top 8 tips for effective Record Keeping and how to exceed Health Canada’s expectations.
1) Never Shred or Delete a Record
You read it right! Never delete or shred a record. Keep everything stored away, and any records that are no longer valid - mark them as void and date when it was voided and why.
2) Record Everything. Even if you didn’t do it - Record It
This is exactly what Health Canada wants to see. If you don't perform a procedure for any specific reason, record it.
3) Follow a Proper Documentation System
Use a proper Record Keeping and Seed-to-Sale system like Grow One and store physical records with a proper procedure in place to check-in and check-out files. Keep a proper tracking log (and make sure your Record Keeping software has proper document tracking) so your QAP can go back and see who checked out what record, and when the record was returned back to the proper location.
4) Store Physical Records in Fire Proof Cabinets
Go above Health Canada's expectations. Store physical records in a fire proof cabinet and keep backup disks and drives in a fire proof safe. Health Canada wants to see you go above and beyond!
5) Backup Everything. Physical and Electronic
Always backup. We advise clients to backup a minimum of 3 times a day (twice during the day and once at night). Even though you will always keep records of everything - back them up. This way if Health Canada needs proof that nothing was modified - you have backups :)
6) Retain Patient and Training Records Indefinitely
For liability purposes, never dispose of any patient or training records. You may never refer to them, but when you need them the most you will have them.
7) Physical Unique IDs should link to Electronic Unique IDs
Use an electronic Record Keeping (Seed-to-Sale) system that allows you to print multiple barcode labels for any record. This allows you to attach infinite barcode labels to physical records. If you have a physical record and you scan the barcode label, it will be linked to the electronic record.
8) Off-Site Records
For business continuity purposes, store electronic records off-site in a safe at a bank or an additional facility or office location. In case of disaster, you will have off-site records of backups allowing for recovery.
That’s it for now folks. And if you have any questions or concerns on the do and do not - reach out to the Record Keeping experts :)
Thanks
Peter Barbosa
(844) GROW ONE x701
peter [at] growone [dot] ca
Grow One team here. We just wanted to update you on some new and exciting events that will be held in Toronto, Canada concerning the #MMPR and Record Keeping. We’re excited to be attending all of them :-)
Firstly, we will be working with Experchem Laboratories to hold an MMPR Record Keeping event. This event is meant for companies seeking to obtain an MMPR license to produce medical marihuana in Canada. We’re very excited to sponsor the event, and Peter will also be doing a talk around the MMPR and Record Keeping regulations. If you want to find out more information, you can check out the flyer we have posted, or contact Sohil Mana from Experchem at (416) 665 2134 ext 298.
Canadian Medical Marijuana Conference - June 8 - 9 2015
We will be occupying booth space at the Canadian Medical Marijuana Conference event being held on June 8th and 9th 2015, at the Paramount Conference & Event Venue. Early bird pricing is in effect until April 10, 2015 so don’t hold off on getting your ticket.
2nd Annual Marihuana for Medical Purposes Regulations Conference
In addition, our friends at IPA Canada are holding their 2nd Annual Marihuana for Medical Purposes Regulations event on June 10th, and 11th 2015. We will also have our informative booth setup for this two-day conference.
That’s it for now everyone. We look forward to seeing everyone there.
It’s been an exciting few months since we first launched - and we’re happy to announce some new and exciting changes! Not only are we launching our first module for beta this February, but we’ve also launched our new website!
MMPR Customer (Patient) Relationship Management
The title says it best! We’re rolling out our Patient CRM system built for the MMPR.
No more excel sheets! Grow One CRM helps manage the workflow of patient on-boarding, verification, and relationship management. Assign notes, to-do’s, and tasks to patients (or employees), track physical records, daily and thirty-day limits, and integrate into your existing e-commerce system.
Best of all, our CRM will be ready for beta in February 2015 and we’re inviting all licensed producers to try it at no cost. Don’t hesitate to check it out.
New Staff
A warm welcome to Mackenzie Browne and Thomas Wilson as part of the Grow One team. Mackenzie and Thomas will be filling the positions of development and software support. They’re excited to come on-board and grow with us.
Upcoming Beta Releases
But there’s more - we’re scheduling the release of our Pre-Pack & Inventory System that will accompany our Ordering & Fulfillment System for March 2015. Shortly after, we will follow up with our Cultivation & Processing System, bundled with Quality Assurance and other goodies for licensed producers.
Our mission with Grow One continues to remain the same - enabling licensed producers to have a seamless vertically integrated solution to serve all their needs and Health Canada compliance.
We encourage you to check out our new website, and read into our software developed for the MMPR, Health Canada, and licensed producers.
We’re excited to continue to grow with licensed producers grow, and adapt in this fascinating booming industry.
Thanks,
The Grow One Team.
(844) GROW ONE
[email protected]
We'd like to welcome you to our website and blog. Grow One is currently in the process of developing leading edge software which will be complaint with the Marihuana for Medical Purposes Regulations (MMPR), in Canada.
Our turnkey software provides vertical integration for licensed producers, patients, physicians, and Health Canada. Grow One will manage virtually every aspect of your business: patient relationship management, cultivation, inventory, quality assurance, sales ordering, and your own branded store.
Not only will we help you track from seed-to-sale, but from plant-to-patient.
Our focus on the Canadian market, allows us to provide always compliant software for Health Canada.
We look forward to planting together. Stay tuned...
