Cannabis Act: Job Descriptions for Key Personnel

The Cannabis Act governs medical and recreational cannabis in Canada. The Act provides a number of business license categories, including standard and micro cultivation, nursery, standard and micro processing, sale for medical purposes, analytical testing, and research.

The Cannabis Act also dictates a number of key individuals that must be designated by license holders. These positions include Head of Laboratory, Quality Assurance Person, Master Grower, Head of Security, and Responsible Person in Charge.

Head of Laboratory

An analytical testing license holder must designate an employee to serve as head of laboratory. This person is responsible for testing that is carried out by the licence holder. A security clearance isn’t required for the Head of Laboratory under the Cannabis Act.

Responsibilities:

  • Planning, directing, organizing, and controlling the overall laboratory, including all analytical or microbial methods performed, regulatory compliance, data management, implementation of new technology, and related work as required

  • Overseeing lab staff who provide laboratory services to the medical and/or recreational licensed cannabis industry

  • Developing and maintain Laboratory policy and procedure manuals, quality procedures, standard operating procedures (SOP’s), equipment specific requirements, and evaluating and implementing new procedures as necessary

  • Work at the licensed site and be responsible for the testing activities under section 91 of the Cannabis Regulations, including:

  • Testing for residues of solvents used in the production of cannabis oil

  • Testing for microbial or chemical contaminants as established in Schedule B of the Food & Drugs Act

  • Testing for dissolution or disintegration specific to formulation

  • Testing for the quantity or percentage of THC, THCA, CBD and CBDA

  • Developing analytical methods and microbiological assays

  • Preparing and/or reviewing regulatory, managerial, and operational reports

  • Preparing and delivering oral presentations at tradeshow, industry events or government regulators events

  • Ensuring that employees are appropriately recruited, including hiring, training, daily management, discipline, and promotions

  • Overseeing facility improvements and maintenance to improve efficiency and safety

  • Formulating objectives and priorities, implement plans, and allocate resources to achieve long-term goals of the Laboratory

Qualifications:

  • Experience in Laboratory Management, proven knowledge and experience related to the duties of the position

  • Minimum of a science degree that was obtained in Canada or recognized by a Canadian University or professional association

  • Required to be familiar with the applicable provisions of the Act and associated regulations

Quality Assurance Person

Standard and micro processing license holders must designate a Quality Assurance Person (QAP). The QAP must have a security clearance.

This person is responsible for assuring the quality of cannabis before it is made available for sale, investigating complaints received about the quality of the cannabis, and taking corrective action.

Responsibilities:

  • Responsible for assuring the quality of the cannabis before it is made available for sale

  • Responsible for approval of methods and procedures related to GPP

  • Write, review and maintain Standard Operating Procedures (SOPs) for site facility

  • Ensure staff are trained on SOPs and GPP, coordinate ongoing training to ensure compliance or re-training where needed

  • Oversee pest control program and ensure pest control procedures are authorized under the Pest Control Products Act or the Cannabis Act

  • Ensure cannabis is stored and distributed under conditions that maintain its quality

  • Oversee the sanitation of premises and equipment cleanliness, hygienic behavior of personnel, and maintenance

  • Establish and maintain record keeping systems and ensure employee adherence to proper documentation practices

  • Review quality complaints and lead investigations including corrective action and preventive action

  • Ensure testing is conducted on each lot or batch of cannabis before it is released for sale

  • Ensure testing is conducted using validated methods, investigate deviations and out of spec results

  • Collaborate with other departments to ensure compliance with regulations

  • Manage and coordinate staff, create department efficiencies and provide leadership support

  • Communicate effectively to all levels of management

  • Perform internal audits and vendor evaluation audits on a regular basis to determine quality qualifications. Actively participate in external audits such as regulatory inspections.

  • Perform analysis of reports and production data to identify trends and recommend updates or changes to quality standards and procedures when necessary

Qualifications:

  • Experience in Quality Assurance Management in a similar production environment, proven knowledge and experience related to the duties of the position

  • Minimum of a science degree that was obtained in Canada or recognized by a Canadian University or professional association

  • Required to be familiar with the applicable provisions of the Act and associated regulations

Master Grower

Standard and micro cultivation license holders, as well as nurseries must designate a Master Grower. Master Growers are required to have a security clearance. This person is responsible for the care and growth life cycle of cannabis plants in a large-scale commercial facility.

Responsibilities:

  • Responsible for overall plant health and crop yield

  • Work towards achieving maximum yield, with lowest costs while maintaining high quality standards

  • Oversee all the tasks in the growing process including: seeding, cloning, transplanting, nutrient management, pest management, defoliation, topping, flushing, foliar, waste disposal, etc.

  • Develop and/or maintain facility protocol and nutrient regiment

  • Develop and/or maintain protocols for lighting, temperature and humidity manipulation

  • Apply knowledge on preventative maintenance of plant diseases, insects and fung

  • Coordination of production schedules

  • Establish methods to meet work schedules and co-ordinate work activities, with production and quality assurance, setting clear expectations of the work to be done with the growers to ensure product quality

  • Provide a weekly crop status summary

  • Manage and account for all inventory and supplies

  • Follow all company Standard Operating Procedures (SOPs) to maintain compliance with regulations

  • Maintain concise daily records and ensure documentation is accessible and organized in a compliant manner

  • Lead, train and mentor junior staff

  • Maintain a clean and organized work environment

Qualifications:

  • A preference for a horticulture or science diploma or degree, or related field

  • Proven commercial growing experience in a management capacity

  • Knowledge of large scale commercial plant cultivation

Head of Security

Standard and micro cultivation, nursery, standard and micro processing, and license holders for sale for medical purposes are required to designate a head of security. The designated Head of Security is required to have a security clearance.

This person is responsible for the organizational security plan and for ensuring that the physical security measures comply with Part 4 of the Cannabis Regulations. The Head of Security is responsible for all video surveillance systems, monitoring all access control and intrusion detection systems, and monitoring and reporting violations of overall safety and security procedures throughout the facility.

Responsibilities:

  • Oversee risk mitigation procedures are in place to detect and respond to scenarios that could compromise an employee’s security clearance or the organization’s security

  • Implement and/or maintain proper protocols for staff, guest, vendor, and contractor arrival and entry to the facility, including procedures for breaches

  • Oversee proper access control and intrusion detection protocols for staff, guest, vendor, and contractors to areas where cannabis is present including vault/storage areas and deliveries/pick-up

  • Maintain appropriate records of entry and exit to restricted and storage areas

  • Implement and/or maintain response procedures for any access control or intrusion detection breaches to areas where cannabis is present, including vault/storage areas

  • Oversee security measures to ensure the safekeeping of cannabis when being shipped, delivered and/or transported

  • Maintain physical security through the monitoring, storage and retrieval of video monitoring footage

  • Ensure the specification, type and number of video surveillance devices meet requirements under the Act

  • Implement and/or maintain procedures for the secure handling of cannabis waste and destruction process

  • Oversee internal security training and awareness requirements for management and employees

  • Implement and/or maintain procedures for reporting security concerns, incidents or breaches by employees

  • Implement and/or maintain contingency plans for record keeping system failures

  • Oversee theft and loss detection procedures and awareness training

  • Implement and/or maintain procedures for validating that cannabis entering the facility is from a legal source

  • Oversee procedures for the protection of client information

  • Implement and/or maintain response procedures should cannabis be found to enter or leave the facility in an unauthorized manner, ensuring a testing protocol for the response procedure

Qualifications:

  • Proven experience in security leadership in a regulated environment

  • A diploma or degree in a related field

  • Security professional designation is considered an asset

Responsible Person in Charge

The Responsible Person In Charge (RPIC) is someone who has the overall responsibility for the activities in a cannabis facility and are the official point of contact with Health Canada and through the Cannabis Tracking & Licensing System (CTLS). As per Health Canada:

Responsible person: This is an individual who has overall responsibility for the activities conducted under the licence and has the authority to bind the licence holder. The responsible person must have sufficient knowledge of the provisions of the Act and the regulations. Every licence holder, irrespective of the class or type of licence, will be required to have a responsible person.”

The RPIC title is technically a security clearance designation, which is unique to the cannabis industry. The person assigned as the RPIC would need to possess a security clearance and could also hold another position such as Master Grower.

The purpose of security clearances are to prevent those associated with organized crime or with past convictions for drug trafficking, corruption or other violent crimes from infiltrating the legal cannabis market.

As noted above in the job descriptions above, in addition to RPICs, security clearances are required for head of security, master grower and quality assurance person - or their alternates for all license holders except analytical testing or research.

Cannabis At Work has extensive experience placing key personnel for license applicants and license holders. Please contact us for more information.