Application requirements for cannabis analytical testing

Cannabis licensing application guide: Analytical testing

Application requirements and process to become a holder of a licence for analytical testing under the Cannabis Act and Cannabis Regulations

Table of contents

• Purpose
• Background
• Scope
• Getting started: the application process
• Step 1: Confirm the need for analytical testing licence
• Step 2: Create an account in the cannabis tracking and licensing system (CTLS)
  • Create an individual account in the CTLS
  • Associated individuals create accounts in the CTLS
• Step 3: Develop your application
  • I. Licence ownership (licence holder)
  • II. Mailing address
  • III. Site details (including activities)
  • IV. Site personnel
  • V. Destruction
  • VI. Physical security
  • VII. Record keeping
• Step 4 - Submit your application
  • Following submission
  • Service standards
  • Administrative procedures
• Contact us
• Feedback – help us improve
• Appendix A: Proposed head of laboratory or alternate head of laboratory for an analytical testing licence information form
• Appendix B: Physical security plan (suggested template)
• Appendix C: Record keeping attestation
• Appendix D: Submission checklist

Purpose

This document provides information on the application requirements to obtain a licence to conduct analytical testing on cannabis from Health Canada under the Cannabis Act and Cannabis Regulations.

Background

The Cannabis Act and Cannabis Regulations provide, among other things, the framework for legal access to cannabis and control and regulate its production, distribution and sale. Under this framework, a person is required to obtain a licence issued by Health Canada in order to conduct various activities with cannabis, among them analytical testing. Applicants and licence holders are responsible for compliance with the Cannabis Act and Cannabis Regulations as well as compliance with other applicable federal, provincial and territorial legislation and municipal by-laws.

The Cannabis Act establishes that an application for a licence must be submitted to Health Canada in the form and manner specified by the Minister ^{Footnote 1} and must include the information required by the Minister. This guide sets out the application process including the form and manner for submitting an application for an analytical testing licence and the information that is required.

Health Canada publishes other guidance documents and information on its website that may be used in conjunction with this document to assist you in preparing your application. In order to maintain consistency and transparency, this guide, as well as other guidance documents and information, will be updated, as required, to reflect changes to policies and/or operations.

Scope

This document provides guidance to anyone wishing to apply for a licence ("the applicant") under the Cannabis Act and Cannabis Regulations to conduct activities in relation to analytical testing involving cannabis.

For more information on requirements associated with the activities that are not addressed in this guide, applicants may refer to the Cannabis Act and Cannabis Regulations, additional guidance published on the Health Canada website, or contact Health Canada as outlined in at the end of this guide.

This guide does not include information on additional licensing requirements that may be required by the Canada Revenue Agency or provinces and territories.

Health Canada has established an online licence application system, referred to as the Cannabis Tracking and Licensing System (CTLS), to be used by applicants to apply to Health Canada for a cannabis licence. Licence holders can access the CTLS directly at Health Canada’s Secure Web Portal. Refer to the CTLS Getting Started Guide for more information.

Getting started: the application process

This guide is separated into four steps to help you navigate the application process. The process flow outlined in Figure 1 provides a general summary, with references to the relevant parts of this guide.

Text description

• Step 1: Confirm the need for an analytical testing licence
• Step 2: Create an account in the CTLS
• Step 3: Develop your application
• Step 4: Submit your application

Step 1: Confirm the need for analytical testing licence

Before applying for a licence, first determine whether an analytical testing licence is the appropriate class of licence needed.

Individuals and corporations may apply for an analytical testing licence (see below for definition of cannabis) if they wish:

• for the purposes of testing:
  • to possess; and,
  • obtain cannabis by altering its chemical or physical properties by any means.
• for the purposes of producing reference standards or manufacturing or assembling test kits:
  • to produce cannabis, other than obtaining it by cultivating, propagating or harvesting it
• for the purposes of selling and distributing reference standards.

Analytical testing activities may include, but are not limited to, any combination of the following testing processes: chemical contaminants, microbial contaminants, cannabinoid content, dissolution or disintegration, sterility, stability testing and/or pesticides, including ensuring requirements are met by licence holders bound by the Mandatory cannabis testing for pesticide active ingredients requirements.
If you or your organization hold(s) another licence under the Cannabis Act, you may already be authorized to conduct analytical testing activities under the terms of that licence (for example, in-house testing for THC or CBD). Contact Health Canada at sp-licensing-cannabis-licences-sp@hc-sc.gc.ca if you need to clarify your current authorizations.

Step 2: Create an account in the cannabis tracking and licensing system (CTLS)

Health Canada's CTLS, is a public facing web application that enables the submission of new license applications, requests for amendments, and licence renewals in addition to the submission of monthly tracking reports for those licence holders required to submit them.

Create an individual account in the CTLS

In order to submit a licence application in the CTLS, you must first request access. In order to do so, basic information is required including your full name and salutation, email, phone number, date of birth, language preference and security information. Health Canada will then provide an account ID that can be used to enter the CTLS. You can use the same account ID for each licence application with which you may be associated.

For more information on the steps to create an account please refer to the CTLS Getting Started Guide.

Associated individuals create accounts in the CTLS

User accounts are also required for additional individuals associated with an analytical testing licence application (see Table 1). These individuals must create their own accounts in the CTLS before an application can be completed and submitted to Health Canada.

Table 1: Individuals who require user accounts in the CTLS when applying for an analytical testing licence

Role	Account IDs required	Responsibilities and qualifications
Licence holder	Only if the applicant is an individual	Overall responsibility for the licence.
Responsible person	For all applicants	A licence holder must identify an individual, known as the responsible person, who has the authority to bind the licence holder. The responsible person will be the point of contact with Health Canada. They are responsible for submitting the application. They are responsible for submitting licence change requests. They are responsible for the activities conducted by the licence holder. Must have sufficient knowledge of provisions of the Act and Regulations that apply to the holder of a licence. You can designate one alternate responsible person who is qualified to replace the responsible person. The alternate responsible person must submit the same documents and attestations as the responsible person.
Head of laboratory	For all applicants	A holder of a licence for analytical testing must retain the services of one individual as the head of laboratory. The head of laboratory must work at the licensed site and be responsible for the testing activities under section 90-91.1 of the Cannabis Regulations (testing for each lot/batch for composition). This person must have sufficient knowledge of the provisions of the Cannabis Act and the Cannabis Regulations that apply to the holder of a licence for analytical testing and have knowledge and experience relevant to the duties of the position (further guidance can be found in table 4). This person must also hold: a diploma, certificate or credential awarded by a post-secondary educational institution in Canada in a field or occupation that is relevant to the duties of the position, such as chemistry, biology, pharmaceutical or scientific regulatory affairs, laboratory management, or laboratory technician; or, a diploma, certificate or credential awarded by a foreign educational institution in a field or occupation that is relevant to the duties of the position; and, an equivalency assessment as defined in subsection 73(1) of the Immigration and Refugee Protection Regulations, or an equivalency assessment issued by an organization or institution that is responsible for issuing equivalency assessments and is recognized by a province. You may designate one or more individuals as the alternate head(s) of laboratory who are qualified to replace the head of laboratory. These alternates must be identified and must meet the same requirements.
Directors	Only if the applicant is a corporation	N/A
Officers	Only if the applicant is a corporation	N/A

Creating a corporate profile

An application for an analytical testing licence can be created for an individual or a corporation. Applicants that are corporations (any incorporated organization) must ensure that a corporate profile for the organization has been created in the CTLS.

In order to create a corporate profile, individuals associated with the corporation (i.e., directors and officers) must create user accounts and those account IDs must be linked to the corporate profile. Once the corporate profile has been created, a new account ID is created for the corporation. This account ID can then be used to create the analytical testing licence application, where the corporation can be specified as the licence holder.

Creating a corporate profile has some additional requirements, as outlined in Table 2. Some requirements are needed to create a corporate profile in the CTLS, while others are required before an application is submitted.

Table 2: Corporate profile requirements

Requirement	Required details to include
The full legal name(s) of the organization	Any other name(s) registered federally or provincially under which the entity intends to do business, if applicable.
The incorporation number	As provided on the certificate of incorporation.
Business address and contact details	The business address and the contact details used for correspondence with the corporation, not the individual applicant (e.g., head office).
Controlling organizations (noted as "Parent Corporation" in the CTLS), if applicable	The corporation ID of each controlling organization. Note that any controlling organization will be required to create a corporate profile as per these requirements.
Certificate of incorporation	As part of an application, certificate of incorporation documents are required.
Corporate organizational chart	As part of submitting an application, a corporate organizational chart is required. The organizational chart: Must demonstrate the relationships between senior positions within the organization and the various controlling individuals or entities, if applicable. Must include all names and titles of senior management positions such as directors and officers of the organization and any controlling individual or entity, if applicable.
Organization personnel	As part of an application, specific organization personnel must be identified. These individuals must have individual CTLS accounts created so that their account IDs can be associated with the corporate profile. Directors or officers of corporations must be included as part of the corporate profile. Important: The CTLS requires at least one director or officer be named per corporate profile. In the case where there is no director or officer for the organization, the responsible person should be identified as an officer in this section of the CTLS.

Step 3: Develop your application

Once you have the appropriate account IDs to the CTLS, you are ready to start developing your application. There are seven main sections of an analytical testing licence application:

1. Licence ownership (licence holder)
2. Mailing address
3. Site details (including activities)
4. Site personnel
5. Destruction
6. Physical security
7. Record keeping

Each of these sections must be complete prior to submitting an application to Health Canada. If your application does not fulfill all of these requirements, Health Canada may refuse to consider your application.

I. Licence ownership (licence holder)

In this section of the application, you are required to identify the licence holder. An application can be created for an individual or a corporation. If you apply as a corporation, you must ensure that you have completed a corporate profile for the organization in the CTLS as outlined in Step 2.

A responsible person must be designated for all applications. The responsible person has the authority to bind the licence holder, has overall responsibility for the activities conducted, and is responsible for submitting the application. The responsible person is the official point of contact with Health Canada. You may designate one individual as an alternate responsible person who is qualified to replace the responsible person.

A copy of government-issued identification must be provided in order to verify the identities of the responsible person and alternate responsible person.

II. Mailing address

This section of the application allows you to enter a mailing address identifying a Canadian address where you would like to receive official mailed correspondence (e.g., a copy of the licence, if requested).

III. Site details (including activities)

This section of the application allows you to enter information about your site as well as information on the proposed activities to be conducted. Table 3 outlines the site detail requirements that must be provided.

Table 3: Site detail requirements for an analytical testing licence application

Requirement	Required details to include
Complete site address	Primary Canadian site at which the analytical testing is proposed to occur (cannot be a P.O. Box). Important: Licensed activities cannot be conducted in a dwelling house (i.e., a place of residence)
Analytical testing activities to be conducted	Identify the purposes of all analytical testing activities that the applicant is proposing to conduct. For example, testing for: Chemical contaminants (e.g., heavy metals, solvent residues) Microbial contaminantsTable 3 Footnote * (e.g., yeast, molds, bacteria, aflatoxins) Cannabinoid content (e.g., delta-9-tetrahydrocannabinol [THC], tetrahydrocannabinolic acid [THCA], cannabidiol [CBD], and cannabidiolic acid [CBDA]) Dissolution/Disintegration Pesticides Sterility Stability (e.g., if the licence holder proposes to include a product expiry date) Other (e.g., seed viability testing, reference standards, test kits)
Table 3 Footnote * Sterility appears as an independent item in the CTLS Table 3 Return to footnote * referrer

IV. Site personnel

As outlined in step 2, you will need to identify the individuals that must have CTLS accounts as part of your application. These individuals will differ based on the licence ownership (e.g., individual or a corporation). Identified individuals will need to create CTLS accounts and provide their account IDs to you. The majority of these individuals need to be identified if you are creating a corporate profile.

The only individual required to be identified within the "Site Personnel" section of the application is the head of laboratory and alternate head of laboratory. Table 4 includes information on what information should be provided to confirm the qualifications of this individual. This information should be provided via a document or documents, uploaded in this section of the application process.

Table 4: Site personnel requirements for an analytical testing licence

Requirement

Required details to include

Qualifications for the head of laboratory

Submit a copy of the proposed head of laboratory’s or alternate head of laboratory’s government-issued photo ID in this section. Submit details of the individual's qualifications, and any designated alternate head(s) of laboratory, as they relate specifically to the duties of the position using the Proposed head of laboratory or alternate head of laboratory for an analytical testing licence information form, included in Appendix A. Note that the head of laboratory must hold a diploma, certificate or credential awarded by a post-secondary educational institution in Canada in a field or occupation that is relevant to the duties of the position, such as chemistry, biology, pharmaceutical or scientific regulatory affairs, laboratory management, or laboratory technician. If awarded by a foreign institution, an equivalency assessment must be issued by an organization or intuition that is responsible for issuing equivalency assessments and is recognized by a province. Examples of the candidate's proof of qualifications should include, but is not limited to: Copy of a diploma, certificate or credential awarded by a post-secondary educational institution in Canada in a field or occupation that is relevant to the duties of the position, such as chemistry, biology, pharmaceutical or scientific regulatory affairs, laboratory management, or laboratory technician. If awarded by a foreign institution, a copy of an equivalency assessment issued by an organization or intuition that is responsible for issuing equivalency assessments and is recognized by a province. Resume/CV Below are examples of some details that may be included in the description of qualifications for the head of laboratory in the form. Do not copy-paste these examples into your completed form. The proposed head of laboratory holds a bachelor's degree in chemistry from University since 2010. During their studies, they developed and executed analytical testing methods including, but not limited to HPLC, GC-MS/MS, LC-MS/MS, ICP-MS. The proposed head of laboratory has worked 6 years as a quality control manager at Analytical Testing Co. They have prepared protocols, evaluated obtained data and interpreted it, prepared and approved certificate of analysis, and write reports for methods transfer and validation. The proposed head of laboratory has worked 2 years as a supervisor at Analytical Testing Co. They have supervised a team, delegated task to ensure proper workflow, evaluated laboratory procedures and policies and drafted standard operating procedures.

V. Destruction

Analytical testing licence holders must destroy the sample of a lot or batch of cannabis that has been distributed to them, and all cannabis obtained from that sample, within 90 days of the testing of the sample of the lot or batch being completed.

If testing of the sample of a lot or batch of cannabis distributed to the licence holder for analytical testing is not initiated within 120 days of its receipt, the licence holder must, by the end of that period, either destroy the sample or distribute it to another holder of a licence for analytical testing or to the individuals referred to in section 4 of the Cannabis Regulations ^{Footnote 2}. The destruction of cannabis samples of a lot or batch must be carried out in a manner that fulfills the requirements of section 43 of the Cannabis Regulations.

Table 5 provides a summary of the information that must be provided as part of an analytical testing licence application to demonstrate how the destruction requirements will be met.

Table 5: Destruction requirements for analytical testing licences

Requirement	Required details to include
Description of destruction method	A description of the destruction method to be used to that meets the requirements of the Cannabis Regulations, including: An attestation that at least two individuals who are qualified to witness the destruction (e.g., employees of the licence holder) will be present.

VI. Physical security

Site plan

The site plan must include the following details:

• The perimeter of the site must be clearly identified. Indicate whether the site perimeter is defined by a fence or the building envelope
• The footprint of any building(s) or units within a building must be clearly identified
• An indication if the building is a multi-unit building or a stand-alone site (i.e., single unit). If it is a multi-unit building, the site perimeter should be identified accordingly and all units must be labelled with information on their current use as well as company name, if possible.

If there are areas (including buildings) that will not be used exclusively by the licence holder, these areas must be outside of the proposed site perimeter.

The licence holder must also include a floor plan for each building including clear delineation of rooms where storage activities will take place.

Physical security plan

The physical security plan must demonstrate how the licence holder will meet subsection 75 of the Cannabis Regulations. It must describe how storage areas are surrounded by a physical barrier that prevents unauthorized access, and how access to storage areas is restricted to individuals whose presence in the area is required by their duties. You must include the following details:

• Brief description of the site
• Information regarding the physical barriers that prevent unauthorized access to storage areas
  • Examples may include, but are not limited to, a description of fences, walls, or any physical barriers that will secure the storage areas
• Information about the access control or restriction devices leading into storage areas
  • Examples may include, but are not limited to, proximity card readers, locks and keys, and keypads with electric door strikes, etc.
• If applicable, information regarding any other security measures present
  • Examples may include, but are not limited to, visual monitoring devices and intrusion detection systems, etc.
• A description of how access to the storage areas is restricted to individuals whose presence in the area is required by their duties
  • An example of how to meet this requirement may include, but is not limited to, a description of the internal processes (e.g., standard operating procedures) for determining which personnel will be given access (e.g., issued cards, keys, key fobs, personal identification numbers, etc.)

A template for the physical security plan can be found in Appendix B.

VII. Record keeping

The licence holder must include a signed and completed attestation form found in Appendix C: Record Keeping Attestation.

There are a number of regulatory requirements for record keeping that must be met by a licence holder. Table 6 provides a summary of the information that must be submitted as part of an analytical testing licence application.

Table 6: Record keeping requirements for analytical testing licences

Requirement	Required details to include
Attestation form	Include a signed and completed attestation form found in Appendix C: Record Keeping Attestation.

Step 4 - Submit your application

Once all required information has been entered/uploaded in the CTLS, the application is ready to be submitted.

Use the checklist in Appendix D to ensure that all required pieces have been completed and are included in your submission. Once an application is submitted, you can only make minor changes without having to withdraw your application.

Once the application is submitted, it will appear in the "Submitted Licence Applications" section of the CTLS. Each application will have a unique licence application ID. All correspondence with Health Canada in relation to the application should include this identifier in the subject title.

Following submission

Once an application is submitted in the CTLS, there are a series of steps Health Canada undertakes to review the licence and take a decision. Applicants are encouraged to check the status of their application using the CTLS at any time during the application process. Table 7 below provides an explanation of the four categories in the CTLS that denote the status of the application.

Table 7: Application status

Status	Explanation
Draft	The application has not yet been submitted. Health Canada does not receive, nor process, draft applications. The applicant must complete all sections of the application in order to submit an application for processing by Health Canada.
Submitted	Once the application is received by Health Canada, the application is considered "submitted" and remains at this stage until the screening of the application commences.
In progress	Health Canada has begun review of the application.
Pending information	A request for more information has been sent to you and Health Canada is waiting for a response.

Service standards

Health Canada commits to a non-binding 180 business days service standard to issue a decision for analytical testing licence applications.

Administrative procedures

Receiving and responding to a request for more information

Under subsection 62(5) of the Cannabis Act, Health Canada may request the submission of any additional information pertaining to an application.

It is the applicant's responsibility to meet all the licensing requirements. If information submitted as part of the application is unclear or requires further detail to show how it meets the requirements, Health Canada will ask the applicant for clarification through a Request for More Information (RMI). To avoid such a request, ensure your application is as detailed as possible and addresses all items in the checklist included in Appendix D.

When an RMI is sent, Health Canada strives to be clear about what information is needed from the applicant and a deadline to respond is provided. If the applicant is unclear about what is required to respond to the request for more information, they may contact Health Canada by email for further guidance (see Contact Us section). Note that it is not a requirement to retain the services of a third party (e.g., consultant) to prepare responses to Health Canada.

A request for more information will be emailed to the responsible person. The applicant must respond within the timeframe requested. Responses should be comprehensive and comment on each of the elements noted in the request for more information. A revised version of the original documents should not be resubmitted unless requested to do so.

Refusals and withdrawals

Health Canada may refuse to issue a licence under circumstances set out in the Cannabis Act and Cannabis Regulations. These include:

• Issuing the licence is likely to create a risk to public health or public safety, including the risk of cannabis being diverted to an illicit market or activity;
• There are reasonable grounds to believe that false or misleading information or false or falsified documents were submitted in, or in support of, the application;
• Within the last 10 years, the applicant has contravened a provision of the Cannabis Act, the Controlled Drugs and Substances Act or the Food and Drugs Act or of any regulation made under any of those Acts;
• There are reasonable grounds to believe that, within the last 10 years, the applicant has contravened an order made under the Cannabis Act, the Controlled Drugs and Substances Act or the Food and Drugs Act, or a condition of another licence or permit issued to the applicant any of those Acts;
• The applicant is a young person (as defined in the Cannabis Act), an individual who does not ordinarily reside in Canada, or is an organization that was incorporated, formed or otherwise organized outside Canada;
• The Minister is of the opinion that it is in the public interest to do so;
• Any prescribed grounds for refusal exist.

In the cases mentioned above, Health Canada may send a Notice of Intent to Refuse. This Notice will provide the applicant with a timeframe within which to respond, after which a Notice of Refusal will be issued.

The Notice of Refusal sets out the specific reasons or deficiencies that resulted in the decision to refuse to consider the application or issue a licence. All decisions to refuse an application are without prejudice to filing a new application for a licence. If an applicant wishes to submit a new application at a future time, it will be processed as such. Information and data submitted to support an application will not be returned to the applicant.

At any time during the review of an application, the applicant may withdraw the application through the CTLS. Withdrawal of an application is without prejudice to re-filing the application. If an applicant wishes to resubmit an application at a future time, the application will be processed as a new application.

Changes to an application/unsolicited information

Once an application is submitted, changes cannot be made to the application within the CTLS. If a change is required, the applicant must contact sp-licensing-cannabis-licences-sp@hc-sc.gc.ca. The email must clearly indicate the application file number, the applicant's name and the subject of the correspondence in the subject line of the email.

Contact us

For questions related to a specific licence application, an email may be sent to:sp-licensing-cannabis-licences-sp@hc-sc.gc.ca. The email must clearly indicate the application file number, the applicant's name and the subject of the correspondence in the subject line of the email. Meeting or teleconference requests are evaluated on a case-by-case basis.

For other general questions about the Cannabis Act and Cannabis Regulations outside of a specific application, including those related to the CTLS, email: cannabis@hc-sc.gc.ca.

Alternatively, the Controlled Substances and Cannabis Branch may be contacted by phone at 1-866-337-7705.

Feedback – help us improve

Health Canada is committed to providing all stakeholders with timely, accurate and reliable information. This includes providing applicants and licence holders with the information they require in order to be compliant with the Cannabis Act and Cannabis Regulations.

Health Canada appreciates receiving your feedback on whether this guide was useful and would welcome your suggestions for improvement. Please send us your feedback by email to: cannabis@hc-sc.gc.ca and indicate in the subject line: "Feedback on Analytical Testing Licence Application Guide".

Your feedback will help us improve this guide and better serve all applicants and licence holders.

Appendix A: Proposed head of laboratory or alternate head of laboratory for an analytical testing licence information form

Download PDF (3 pages, 905 KB)

Appendix B: Physical security plan

Download PDF (1 page, 595 KB)

• Appendix B - Text equivalent

  • Description of site
  • What are the physical barriers surrounding the storage areas?
  • How will the physical security of the storage areas prevent unauthorized access to the cannabis?
  • Who will have access to storage areas and how is their presence in the area is required by their duties?

Appendix C: Record keeping attestation

Download PDF (1 pages, 163 KB)

Appendix D: Submission checklist

Download PDF (2 pages, 594 KB)

• Appendix D - Text equivalent

  Analytical testing licence application checklist

  Licence ownership

  • Copy of the Licence Holder/Head of Laboratory/Responsible Person's Government-issued ID (e.g., driver's licence).
  • A copy of the Certificate of Corporation (if applying as a corporation).

  Site details

  • Complete address of your site including:
    • Unit number, if applicable
    • Street number
    • Street Name
    • City
    • Province
    • Postal code
  • Confirmation that the proposed site is not a dwelling house (i.e., residential) or an alternative address of your proposed site.

  Site personnel

  Qualifications of the proposed Head of Laboratory as well as those for any designated alternate Head(s) of Laboratory, as they relate specifically to the duties of the position. Note that the Head of Laboratory must hold a diploma, certificate or credential awarded by a post-secondary educational institution in Canada in a field or occupation that is relevant to the duties of the position, such as chemistry, biology, pharmaceutical or scientific regulatory affairs, laboratory management, or laboratory technician. If awarded by a foreign institution, an equivalency assessment must be issued by an organization or intuition that is responsible for issuing equivalency assessments and is recognized by a province.

  The candidate's proof of qualifications should include, but is not limited to:

  • Copy of a diploma, certificate or credential awarded by a post-secondary educational institution in Canada in a field or occupation that is relevant to the duties of the position, such as chemistry, biology, laboratory technician, pharmaceutical or scientific regulatory affairs, or laboratory management. If awarded by a foreign institution, an equivalency assessment must be issued by an organization or intuition that is responsible for issuing equivalency assessments and is recognized by a province.
  • Resume/CV.

  See Appendix A form.

  Destruction

  A description of the destruction method to be used to that meets the requirements of the Cannabis Regulations, including:

  • Attestation that at least two individuals who are qualified to witness the destruction (e.g. employees of the Licence Holder) will be present.

  Physical security

  • A physical security description for your site that includes:
    • how the physical security of the storage areas prevent unauthorized access to the cannabis.
    • who has access to storage areas and how their presence in the area is required by their duties.
    • the physical barriers surrounding the storage areas.
    See Appendix B for template.
  • A site plan with clearly identified perimeters and delineation of storage areas.

  Record keeping

  • Record Keeping attestation

  See Appendix C for attestation.