This came from HC regulatory impact. I don't really care whether or not you think this is helping LP's or not, I think it does make things easier for them
In addition, under section 66 of the MMPR, licensed producers are required to state their "site address" on the label on the immediate container for dried marihuana. Some licensed producers have pointed out that this requirement forces them to disclose the location of their operations to clients and members of the general public which, they believe, exposes their facilities to increased security risks. While the requirement to state the address of the licensed producer on the label is consistent with labelling practices for other controlled substances, such as morphine, these substances are typically dispensed from a pharmacy and show the address of the retailer (i.e. pharmacy) and not that of the manufacturer or wholesale distributor. Despite the fact that licensed producers have similar security requirements as those licensed to produce other narcotics, there is concern that the illegal widespread use of marihuana for recreational purposes may increase the risk that a licensed producer would be the target of crime if the production location is more generally disclosed. The Regulations Amending Certain Regulations Relating to Marihuana for Medical Purposes (the Amending Regulations) remove the obligation for the licensed producer to state their site address on the label and allow the licensed producer discretion in determining how their location information is disseminated.
Section 66: Paragraph 66(a) under the section is amended to remove the requirement to state the site address on the label of the immediate container for dried marihuana. Instead licensed producers are required to state a telephone number and email address with which they can be contacted. The amendment does not prohibit a licensed producer from stating their address on the product label for business or other reasons, if they see merit in doing so.
Section 1: A definition of pest control product has been added to this section of the MMPR to align with the definition for "pest control product" under the PCPA.
Section 6: Subsection 6(2) is amended to indicate that the prohibition against the sale or provision of marihuana with "additives" in subsection 6(1) of the MMPR excludes a residue of a pest control product unless a maximum residue limit is specified for the product and that limit is exceeded. This change replaces the previous provision on maximum residue limits and is better aligned with the relevant sections of the PCPA in respect of maximum residue limits
Section 54: This section is amended to indicate that pest control products that are not registered but otherwise authorized under the PCPA may be used on marihuana for medical purposes in addition to those which are registered. The change ensures that pest control products which are otherwise compliant with the PCPA are available for use.
Paragraphs 66(d) of the English version contained the phrase "upper left corner" and was inconsistent with the French version of the same paragraph. The word "corner" is replaced by "quarter" to correct the error and be consistent with the French version
Section 92: Subparagraph 92(b)(iv) of the French version contains a use of the masculine when the feminine should be used. The word "duquel" is replaced with "de laquelle" to correct the grammatical error.
In addition, section 54 of the MMPR restricts the use of pest control products on marihuana only to products that were 'registered' under the Pest Control Products Act (PCPA). Under the PCPA, products undergo a premarket approval process to minimize the associated risks. Pest control products must be either registered or otherwise authorized in accordance with the Act. The Amending Regulations harmonize the regulation of the use of pest control products on marihuana for medical purposes with the regulation of pest control products generally in the PCPA. All pest control products that are available for use on marihuana must be in compliance with the PCPA.
There are no incremental costs associated with the administrative changes to remove the obligation for licensed producers to state their site address on product labels or with the amendments to the use of pest control products. These changes are likely to have a zero net effect on licensed producer costs. On the contrary, access to approved pest control products may have potential benefits by reducing the chances of crop failure due to pests.
And this is the " consultation" that probably led to the latest threat, cause they sure didn't consult with patients now did they?
Consultation
The changes to the MMPR made by the Amending Regulations are mostly in response to feedback received from stakeholders representing law enforcement and municipalities after the MMPR came into force. As part of the transition to the MMPR, Health Canada has conducted a series of outreach activities with stakeholders including licensed producer applicants. The amendment to the information required on the product label was in response to feedback from both applicants to become licensed producers and recently licensed producers. As well, during the application process, many licensed producer applicants and licensed producers indicated to Health Canada that they need to be able to use pesticides to deal with pests in order to mitigate the significant risk of crop failure. The changes to the requirements for the use of pest control products on marihuana are in response to this request and inconsistencies with the PCPA noted after the MMPR came into force.
Finally, the amendment extending the notification requirement addresses feedback from other levels of government, including municipalities, as well as law enforcement agencies across Canada. In particular, during briefings with law enforcement on the transition from the MMAR to the MMPR, police forces told Health Canada that there should be transition measures to further enhance the elimination of personal production when the MMAR is repealed.
And of course there will be some costs to patients but too bad
Benefits and Costs Section
The Amending Regulations are an important measure towards a successful transition to the new MMPR and the end of personal production. These regulations, for the most part, affect Program participants and licensed producers and have a low overall impact on Canadians. Health Canada will incur incremental costs to implement the Amending Regulations. Program participants may also incur costs. Licensed producers will not incur any incremental costs when the Amending Regulations are implemented but may benefit from some of the changes. The greatest benefit, however, would accrue in terms of health and safety effects from the destruction and removal of unauthorized marihuana from the homes of those individuals who are no longer permitted to possess or licensed to grow under the repealed MMAR.
Health Canada's incremental implementation costs will be up to approximately $400,000. This includes contract costs involved in mailing approximately 42,000 letters to Program participants. It also includes salary and operational costs associated with the retention of staff who would be primarily responsible for data entry and processing of returned notices. This staff will also be responsible for tracking, follow-up, compliance monitoring and reporting information for enforcement activities that may be undertaken.
Program participants are required to send a notice to Health Canada after the amending regulations are promulgated. These notices may be sent in a variety of ways including mail. The costs incurred by the Program participants would be dependent on the method of notification chosen. For example registered mail would incur a cost; however, email would not. The cost of destruction of marihuana, if any, exists under the 'status quo' and is not incremental to the Amending Regulations.
There are no incremental costs associated with the administrative changes to remove the obligation for licensed producers to state their site address on product labels or with the amendments to the use of pest control products. These changes are likely to have a zero net effect on licensed producer costs. On the contrary, access to approved pest control products may have potential benefits by reducing the chances of crop failure due to pests.
In summary, the total cost of implementation is not expected to exceed $500,000.