Health Canada GPP requirements, explained

What GPP is, in one paragraph

Sections 78.1 through 88.94 of the Cannabis Regulations set out Good Production Practices: the conditions under which cannabis must be produced, packaged, labelled, distributed, stored, sampled, and tested. Unlike pharmaceutical GMP, GPP does not prescribe how to meet each requirement — it makes you responsible for demonstrating that your methods work and are followed. That is why the recurring inspection theme is not equipment or facilities; it is evidence.

The obligations that matter daily

Standard operating procedures (s.80)

Everything quality-relevant must be done under an SOP that is current, approved, and actually matches what the floor does. The classic finding is not a missing SOP — it is an SOP at Rev.02 in the binder while the approved system copy is Rev.04.

Premises and sanitation (ss.81-87)

A written sanitation program, with completed records proving it ran. Gaps in cleaning logs on days the site produced are one of the fastest observations an inspector can write.

Equipment (s.86)

Equipment must be designed, maintained, and calibrated for its use. In practice: an equipment register, in-date calibrations, and daily balance verification with acceptance criteria. The scale that weighs your net contents is the first instrument an inspector checks.

The Quality Assurance Person (s.88)

Every lot must be approved by the QAP before it is made available for sale, and every complaint investigated. The QAP must be named on the licence and genuinely competent for the product classes you run. See our companion guide on QAP responsibilities.

Testing (ss.90-92)

Final testing per product class, on the lot actually released, with COAs retained. The traceability chain — input lot on the batch record → COA lot number → label potency — must hold exactly. A broken link there is a critical finding.

Records and retention (ss.231-232)

Part 11 requires records to be kept for at least two years and producible on request. Inspectors increasingly apply ALCOA thinking: records must be attributable (who), contemporaneous (when it happened, not later), original, and accurate. Back-dated entries and unsigned steps are data-integrity findings, not paperwork nitpicks.

What inspectors ask for first

1. Your master list of current SOPs and forms (they will spot-check the floor against it).
2. A recent lot: full batch record, COA, label, and the QAP release approval.
3. Sanitation and balance-check records for the last 30 days.
4. Your complaints log and the investigations behind it.
5. Your recall procedure and evidence of a mock recall.
6. Distribution records for at least the last six months, queryable by lot.
7. Your current inventory list, reconciled to the records.

If you can produce those seven in under an hour, most inspections go smoothly. If any of them takes a day of digging, that is the gap to close first.