QAP responsibilities in cannabis: what the signature actually carries

The legal basis

The Cannabis Regulations require a processing licence holder to retain a Quality Assurance Person, and s.88 (Quality assurance) assigns their duties. The QAP must be named on the licence — meaning Health Canada has reviewed the appointment — and changing the QAP is a licence amendment, with security clearance implications, not an HR decision.

What the QAP must personally do

• Approve every lot before sale (s.88). No product may be made available until the QAP has approved it against the specifications and the batch evidence. This is the signature the whole system exists to support.
• Investigate every complaint (s.88). Each complaint needs an investigation and, where warranted, corrective action — documented to a standard an inspector will accept.
• Approve quality-relevant methods and procedures. SOPs that touch product quality carry the QAP's approval, and revisions go back through them.
• Assure returned or recalled product is handled correctly, including re-testing or destruction decisions.

What inspectors expect the QAP to evidence

The duty is personal, so the evidence must be attributable: releases signed and dated by the QAP (or the designated alternate), complaint dispositions in the QAP's name, and no gaps where product shipped without a recorded approval. The most damaging pattern an inspector can find is a lot with a distribution date earlier than its QAP release date — that single timeline check is run at almost every inspection.

The alternate QAP

One person cannot be available 365 days a year. Following Health Canada's streamlining amendments to the Cannabis Regulations, the former two-alternate cap no longer applies — a licence holder may designate additional alternate QAPs, and defined tasks may be delegated to qualified individuals under the QAP's oversight. The practical requirements have not changed: each alternate's and delegate's scope is documented, their training record matches the duties, and hand-offs are clear enough that any release can be attributed to exactly one accountable person.

Qualifications

The QAP must have the training, experience, and technical knowledge for the product classes on the licence (s.88.1, competencies and qualifications). For edibles and extracts, Health Canada expects demonstrable competence in those processes — a dried-flower-only background may not carry a licence into Class 2 products.

Outsourcing and fractional QAPs

Small licence holders often retain a fractional or external QAP. That is legitimate — but the appointment still goes through the licence amendment, the QAP still needs real oversight of the site (not a signature-for-hire), and the systems must give them genuine visibility: batch records, labels, complaints, and deviations they can review from wherever they are. If your QAP cannot see the floor's records remotely, the model does not work.