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You Won’t Believe Australia’s Security Rules for Medical Cannabis

Published on November 2, 2016 · Last updated July 28, 2020
High tech overhead security camera at a government owned building.

Want a license to grow medical cannabis in Australia? You’d better have a custom-built, high-security facility. And get ready for the government to vet your business associates and family members.

That’s what you can expect based on documents released by the country’s Office of Drug Control (ODC) this week. The ODC published a number of example forms which will be the basis of online applications for licenses to cultivate, produce, and manufacture medical marijuana in Australia. Along with the forms, the ODC published several guidance documents for security, “fit and proper person” requirements, and fees.

Permits, which prescribe the types and quantities of cannabis that can be cultivated, are not yet available, and there’s yet no word on when they’re expected. But the licenses make clear that growing any amount of cannabis for medical or research purposes in Australia is going mean a lot of red tape.

Shipments must be made by unmarked vans traveling on regularly varied schedules and routes.

The ODC takes the Single Convention on Narcotics Drugs very seriously—concerns about stockpiling cannabis mean that licenses will only allow enough production to meet the domestic demand for medicine. In practical terms, this is a bureaucratic Catch-22; production can’t exceed patient demand, but the ODC can’t be certain what those requirements are going to be until the market exists. Officials estimate that “only a small number of cultivators will be necessary to meet domestic demand.”

High-security measures

In its 23-page guideline document regarding security, the ODC ticks off detailed requirements for how to keep stringent controls on medicine. The mandates are onerous. Along with the standard closed-circuit TV monitoring and alarm system, these include “climb-proof perimeter fencing” free of shrubbery, outsourced security staff making perimeter sweeps, and even measures to monitor the security staff, requiring that licensees effectively watch the watchers.

It doesn’t stop there. A safe, vault, or strong room will be necessary for storage, the guidelines say, but those can’t be housed in a room that shares an exterior wall. Presumably that’s to shield the non-stockpile of medical cannabis from explosive heists or attacks by wreaking ball.

And to protect cannabis in transit, GPS tracking chips will accompany shipments—shipments, by the way, that must be made by unmarked vans traveling on regularly varied schedules and routes.

The ODC even suggests “pocket-less clothing” for employees in a novel defense against workers walking off with small quantities of product.

On top of all that, cultivators are required to prevent cross-pollination or spread of their crop as the cannabis is grown. That means outdoor growing will be, in the ODC’s words, “difficult.”

Application fees and charges

Estimates of the ODC’s non-refundable fees were also made available this week (all amounts in AU$):

  • Application for a cultivation/production license: $5,290
  • Application for a cultivation/production permit: $1,830
  • Inspection in relation to an application: $7,050

Annual charges have yet to be revealed. But compare the cost of a license (including inspection) to the charge for a low-level medicine manufacturing license from the Therapetic Goods Administration, which regulates medicines, ($6,160) or an Australian Taxation Office license to manufacture alcohol—which has no application or renewal fee. Then consider that the ODC defines cultivation as all steps up to, but not including, harvest. Production is “harvest and placing in a container.” So unless your business is based on putting someone else’s cannabis in a container, you’ll likely need two licenses.

Add the substantial cost of complying with the ODC’s security measures and you are looking at a high regulatory bar to entering a market which is estimated (at least by the ODC) to be relatively small. It isn’t yet clear how many potential applicants will be willing to clear that bar.

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