For federally licensed cannabis cultivation and processing, start the training file with the person’s role and the procedures they perform. This article addresses ordinary cannabis production, excluding cannabis drugs, reference standards and test kits.
Section 80 of the Cannabis Regulations requires cannabis and ingredients to be produced, packaged, labelled, distributed, stored, sampled and tested under standard operating procedures designed to meet the applicable requirements of Parts 5 and 6. Cannabis Regulations, section 80.
- Match personnel requirements to the licence and activity: sections 12, 19 and 88.1 address different roles and activities.
- Health Canada's GPP guide includes training before new or revised SOPs take effect among its examples of practices that may demonstrate compliance.
- Processing licence holders must retain a document describing the qualifications of their quality assurance person and any alternate.
- Distinguish qualification records from the SOP and sanitation documents covered by section 232.
The binding requirements below come from the Cannabis Regulations; the separately identified training examples come from Health Canada’s GPP guide.
Match the evidence to the person’s work
Cultivation and processing have different personnel rules
Under section 12, micro-cultivation and standard cultivation licence holders must retain a master grower who is responsible for cultivation, propagation and harvesting and has sufficient knowledge of the Act and Regulations concerning those activities.
Under section 19(1), a processing licence holder must retain a quality assurance person with training, experience and technical knowledge of the Parts 5 and 6 requirements applicable to the cannabis class involved. If that person lacks the required edible-cannabis expertise, section 19(1.1) requires a processor conducting edible-cannabis activities to retain another individual with that expertise. Sections 12 and 19.
Edible cannabis and sanitation
Section 88.1 requires a processing licence holder to ensure that individuals conducting activities involving edible cannabis or its ingredients have the competencies and qualifications necessary for those activities at the licensed site. Separately, the sanitation program must address the personnel health and hygiene requirements necessary for sanitary operations under 87(1)(d). Sections 87 and 88.1.
For each role, choose evidence that addresses its actual work. Avoid assigning the quality assurance person’s qualification standard to the whole workforce by default.
Connect training to the procedure version
Health Canada’s guide identifies documented training before the implementation of new or revised SOPs as an example of a practice that may demonstrate compliance with section 80. The guide also carries a notice that updates reflecting the 2025 amendments are pending. Treat its examples as guidance and check binding duties against the regulation. GPP guide, notice and section 5.1.1.
As a practical record format, capture the employee, work activity, SOP identifier and version, training date, trainer and any observed demonstration. Keep a revised procedure’s training evidence identifiable instead of overwriting the earlier evidence. These are suggested filing fields, not a prescribed federal training-certificate template.
Use how to build a training matrix to organize the proposed role-to-procedure mapping.
Separate required records from supporting evidence
| Record or evidence | Regulatory basis or guidance | Suggested supporting material |
|---|---|---|
| Quality assurance qualification document | Processing licence holders must retain it for the QAP and any alternate under 231(1)(e)(i). | Describe relevant training, experience and technical knowledge. |
| SOP and sanitation documentation | Section 232 requires documentation describing the procedures and sanitation program in use, except for cannabis drug licence holders. | Keep each version identifiable. |
| SOP training evidence | The guide gives training before revised SOP implementation as a compliance example. | Link the person, procedure version and training date. |
| Edible-cannabis competency evidence | Section 88.1 requires the competencies and qualifications needed for the relevant activities. | Consider an assessment tied to the work performed. |
Regulations, sections 88.1, 231 and 232, and GPP guide, section 5.1.1.
Apply retention to the correct record
Sections 231(1)(e)(i) and 231(2)(d) require the holder of a licence for processing to retain the quality assurance person's and alternate's qualification documents while each person serves in that capacity and for at least two years afterward. Section 232(2) requires each SOP and sanitation-documentation version to be retained for at least two years after replacement or, if not replaced, at least two years after licence expiry or revocation. Sections 231 and 232.
Do not apply either period to every employee record without first identifying the applicable record category.
Keeping the records in TrainGrid
TrainGrid supports recording completions and attaching a certificate or other file, subject to the user’s permissions. Consider attaching the relevant training evidence to its completion record. See the assignments and completions guide and audit-ready training records.