Thinking outside the box
One of the most exciting changes that came with the introduction of the Cannabis Act was the opportunity for licence holders to cultivate cannabis outdoors. For years, knowledgeable growers have argued that outdoor cultivation is a viable way to produce high quality cannabis and it seems that regulators are finally onside.
Reduced production cost is a huge benefit, when compared to indoor cultivation, and the coming market for edibles means that the demand for “extraction grade” cannabis has never been higher.
Outdoor cultivation can take place at a dedicated, licensed site or be added to any existing standard licence. From an outdoor grow to an existing licence, the cultivation has to take place in the same facility address and within an area that meets the perimeter security requirements.
Licence holders who have suitable land around their facility would do well to consider taking advantage of this unique opportunity. I would also encourage prospective cultivators to consider the requirements for outdoor growing when selecting a site for their application.
Once the decision to engage in outdoor cultivation has been made, it is best to consult with someone who knows the security requirements and involve them in the design process from the beginning. I may be somewhat biased, but it really is critical to integrate security and compliance into your design at the early stages.
An outdoor growing operation requires much more than just an empty field with a fence around it. There’s a need for staging and support areas, equipment and supply storage areas, heavy machinery access, and many other considerations. All of these elements have unique security implications.
Another major consideration is the location of processing areas. Outdoor grown cannabis will still have to be dried, trimmed and potentially stored in compliance with the regulations. Will the outdoor growing facility have a dedicated processing area onsite or will the plants have to be transported? If cannabis is to be brought into an existing facility, how will the risk of cross contamination be controlled? Having knowledgeable and experienced people on your team is critical.
Outdoor growing operations tend to be located on farms and, as a result, there’s often a residence on the property. There was a time when that would have disqualified the site but thankfully, with the proper precautions, those days are over.
Today there are several licensed facilities with residences on the site. Health Canada will permit it under certain circumstances and it’s always reviewed on a case-by-case basis. The presence, location and proximity to operations should all be considered when determining a site’s suitability for outdoor growing.
Not surprisingly, outdoor growing facilities are subject to the same site perimeter security requirements as other standard licences. Those specific requirements can be found in the Cannabis Regulations and include surveillance and intrusion protection which fully encircles the site. For those who understand those requirements and have seen them applied to growing and processing facilities, that can seem a bit unreasonable when the site perimeter is potentially miles of fence.
As I’ve said before, the regulations are outcome-based and always open to interpretation. My approach to consulting in this industry has always been to encourage my clients to take calculated risks when interpreting the security requirements for their facilities. In some cases, Health Canada won’t agree with a certain interpretation and the approach has to be adjusted. When creative interpretations are accepted, my clients benefit from security solutions that are far more practical and cost-effective.
Outdoor cultivation is no different. Being new, there are lots of opportunities for creativity that is tempered by knowledge and experience. As always, I’m learning with every new application and passing those lessons on to my clients.
Practicality over complexity
Most importantly, be weary of rumors and misinformation. I’ve been in the cannabis consulting industry since 2013 and I’ve seen the regulatory framework change and evolve over that time. There have always been those who believe that the only way to gain Health Canada’s favour is through over-engineering and unnecessary complexity. Those people tend to waste a lot of money and end up changing their approach later to make things more practical.
Outdoor cultivation has been no different. I’ve heard rumors ranging from requirements for double fences, to flood lights, and security systems more commonly seen around missile silos.
Even this early in the process, there are already proven and practical solutions available that won’t blow your budget or alienate your neighbors. Health Canada is far more reasonable than some give them credit for. The federal agency has a mandate to create a sustainable, thriving cannabis industry that doesn’t compromise public safety. Those interests can be effectively balanced with the business interests of license holders.
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