Security Requirement Consultant services: Narcotics & Controlled Substances, including Cannabis / Marijuana – under the:
- Controlled Drugs and Substances Act (CDSA) and it’s Regulations
- Narcotic Control Regulations (NCR)
- Benzodiazepines and Other Targeted Substances Regulations
- Industrial Hemp Regulations
- Access to Cannabis for Medical Purposes Regulations
- Precursor Control Regulations
- Application for a Dealer’s Licence under Part G of the Food and Drug Regulations (FDR)
Whether you want to set up separate storage facilities for your small pharmacy chain, QC testing lab, or as a cannabis / medical marijuana producer / distributor / dispensary, we have the hands-on experience, including being present for Producers License or Drug Establishment Licence application & renewal compliance inspections with Health Canada’s HPFBI.
As a Security Requirement Consultant since 1999, we have been intimately knowledgeable of Health Canada’s security Regulations, Policies, Directives & Guidance Documents as they apply to various different products and situations. We know that “one size doesn’t fill all“. Health Canada also recognizes that as well. For example, which city / region your facility is located at, can impact what Level of security is required.
And not only does this apply to your product, but also to the data relating it storage & distribution (electronic & hard copies).
We approach these requirements from a practical Risk Management perspective. In addition, for cannabis (medical marijuana), through the Access to Information (ATI) process, we were able to obtain Health Canada’s internal checklists along with their Standard Lines for requesting further information relating to security requirements, as well as Health Canada’s Draft “Compliance and Enforcement Policy” CS-POL-001, under the Controlled Drugs and Substances Act (CDSA).
We have worked with various security companies over the past and keep up to date on the latest technologies – not only for the physical detection equipment, but the software for monitoring, and data collection, relaying & storage. We also understand what would be the minimum technical specifications, but also look at their expandabilty vs. what equipment might be “over-kill” (i.e.: why buy a Cadillac when a Prelude is more than adequate?)
Because we are an independent third party, we are often asked to be the technical liaison between the client and the proposed security installation & monitoring firm(s), to ensure that not only the Health Canada regulations are being met, but to also ensure the system is most appropriate for those taking care of it in-house, and that it is not-overkill. (i.e.: is the security firm recommend that many cameras because of the situation, or because they make more money on the sales? (See our Sourcing services web page for more details).
We also have the technical abilities to converse with the IT people relating to the computer hardware & software side of the equation.
We have developed the SOPs and their associated forms / checklists such as: security equipment installation & maintenance;
We have also created a lengthy Protocol for the Security / Threat Risk Assessment which addresses, but not necessarily limited to:
- Risk Analysis:
- Consequences to Society if product is stolen (incl. pilferage by staff);
- Consequence to the company;
- probability of the event occurring;
- Each of the above is then broken down into 5-10 further subcategories
- Concepts to be Applied:
- Rings of Protection;
- Split Target concept;
- Assessing the security requirement for each individual room / area.
- Physical Security Issues:
- Barriers, such as fences, doors
- Proper type & location of cages, vault
- Electronic Monitoring & Data Storage Techniques:
- Intrusion detection systems such as: motion sensors; infra-red cameras; glass & glazing panel break sensors; door access (PINs, FOBs, card readers); etc.
- sensors to ensure the equipment isn’t being tampered with;
- perimeter systems vs interior;
- Use of Linux server
- Off-site secure data storage
- back-up of power supply, use of Wi-Fi, signal interference issues.
By the time we’re done our Assessment & audit checklists, our report can be anywhere from 8-30 pages, depending on the product(s) and type & size of operation operations. In addition, a third-party Security Audit Report to Health Canada may throw more weight with them, as it was performed by someone external who would be viewing the security program from a similar outside perspective.
Why use a consultant?
Weighing the numerous pros & cons of bringing in a consultant vs. tackling it all in-house? Please see our web page “Why Use a Consultant” as part of that critical thinking process. Based in British Columbia, but covering all of Canada.