For large Medicinal Cannabis greenhouses, you typically need a large flat area with a fall of less than 1 in 400 (making all airports prime Medicinal Cannabis cultivation sites). Recently, there was an article about a medicinal cannabis “farm” which had been approved to be built in Brisbane, but had provoked a degree of “public outrage” as a result. It’s yet another reminder of the importance of site selection and the moral complexities involved; not only do you need to consider the numerous business, technical and legislative requirements, but also the potential impact to local communities.
One of the main concerns springs from an access and security perspective, i.e., schoolkids potentially coming into contact with the crop. However, given the strict security requirements for companies setting up medicinal cannabis manufacturing facilities, the likelihood that somehow school children will be able to jump over a several meter-high fence to access a restricted crop is highly improbable.
The other concern circles around the odour that is released by the flowering medicinal cannabis plants. Whilst in my opinion, this odour alone will do no harm to nearby schools or residents, I also have not seen any scientific studies about the potential long-term exposure of this odour on children, so I can’t make any definitive comments. But, having worked in pharmaceutical industries for some time, I can only assume, as per the EPA requirements, that the air will be carbon treated to remove objectionable odours and aromatics prior to its exhaustion.
For manufacturers trying to select sites, the situation is further complicated when taking into account the differences between each city council – for example, the City of Greater Dandenong restricts the operation of Pharmaceutical plants to a distance of greater than 1 km to the nearest residence. Other council restrictions could also be in place that don’t just involve general proximity to local populations. In more rural settings, council rules might permit only production activities or only manufacturing activities. This would allow for the packing of strawberries, but not for the production of strawberry jam. Translated into a Medicinal Cannabis context: the growing, harvesting and drying of the Medicinal Cannabis plants might be permitted but the extraction of the therapeutic cannabinoids might be restricted (and vice versa).
When thinking of site selection, it is worthwhile to bear in mind that the TGA and other regulators require Medicinal Cannabis products to comply with acceptable levels of pesticide residues (as per TGO 93) and explicitly require the use of USP Purified Water (water used in pharmaceutical preparations). Thus, water run-off from a neighbouring farm to a prospective plot of land could contain residues of pesticides and other unwanted toxins. Large quantities of Fire Fighting Foam, especially PFOS, have also been shown to be persistent and bioaccumulative pollutants. Before formally acquiring any piece of land, it is advisable to test local water sources for toxic residues so that any problematic discoveries are made well in advance of the first batch of product samples returning out of specification results during QC testing!
In Canada, as recreational Cannabis will become fully legalised on the 17 October 2018, they have published specific additional regulations which prohibit the cultivation and selling of Cannabis products in close proximity to schools and other sensitive areas. While the Office of Drug Control (ODC) does not explicitly mandate this, it is perhaps something they should provide guidance on in the future. Due to the nature of Medicinal Cannabis businesses and their associated sites, the need for confidentiality and discretion is paramount. However, given the potential impact to communities (the provision of new jobs notwithstanding), the ODC may want to relax their regulations on explicitly preventing community consultation so that acceptable middle grounds may be reached between all potential parties involved or affected.
If you are interested in reading other articles about the indoor vs outdoor debate, or if you are looking for an ideal site and would like advice on the site selection and factors to consider, please contact us at one of our offices around the world.