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There are quite a few common misconceptions around adhering to GACP. In another edition of our acronym-series we translate the bureaucratese, point out some issues and show you how to solve them... and as an extra bonus we tell you how an audit happens.
These four letters, GACP, fully written out Good Agricultural and Cultivation Practices, might sound complicated at first. But although one might think it is just another bureaucratic hurdle that needs to be overcome, it goes beyond that. In fact, it will help you cultivate your cannabis in way that it will provide the highest possible benefits to the patients, and ultimately put your process in order, so that you can achieve your goal. Conquering it stands between you and your crop’s acceptance in a bigger, wider and more moneyed market. By understanding exactly what is at play here, things start becoming clearer. With the help of our Head of Compliance & Regulatory Affairs, Luis Soares, we have made a list of common misconceptions people have with following the GACP and how to solve them. At the end of the article, we also give you a breakdown of how an audit works and what to look out for.
Can't wait until the end of the article?
Before we go into the details, Luis summarises the importance of GACP as follows: “The GACP has two major objectives: Making sure that contamination of the cultivation is kept to a minimum and secondly make sure that your operations and actions are done consistently. To accomplish this, you have to record every critical step along the way to make sure that everything you do in is documented, It’s not just about how you do it, but about how you show you do it. Some flaws will happen and are common to anybody who works under a regulated area and some are unique to cannabis. Make an effort to have a good understanding of the GACP standard and you will succeed”.
The list of misconceptions and solutions
First taking a look at SOPs
SOPs should showcase the author's knowledge; the purpose of an SOP is to demonstrate expertise.
Writing down a SOP is not a time to show your knowledge. The purpose of a SOP is for you to give a clear-cut instruction. It should assist the person to perform a clear-cut task.
SOPs serve the general purpose of passing an inspection and can be applied broadly; specificity and task relevance are not essential considerations.
An SOP should serve a specific purpose or be applicable to a given task one does in the field.
SOPs should be lengthy and complex;
SOPs should be practical and straight to the point, using objective definitions & words, and in an imperative style.
Communicating that a new SOP is in place is sufficient, and there is no obligation to provide the reasons behind said procedures.
Effectively communicate SOPs and detailed work instructions, ensuring comprehensive understanding. Train and engage individuals on the reason behind performing tasks in specific ways.
Only significant events need to be documented; lack of documentation is only needed when the auditors find issues during inspections.
If it’s not written down, it never happened. Every single task should be documented, or as the auditors say, there needs to be “objective documented evidence”
How to go through an Audit
Auditors and inspectors are solely responsible for identifying discrepancies and ensuring regulations are applied. It is the inspector's or auditor's role to identify non- compliance and make sure that rules are followed.
The main body responsible for making sure regulations are applied is the company, not the auditors or inspectors. It is the responsibility of the company to pick up and point out discrepancies. Inspectors and auditors are not looking for mistakes. They assume in general that you comply and it is your role as a company to show that you are complying and to explain that you are following the rules.
Human errors are the primary cause of deviations.
While most errors are commonly linked to system failures rather than human error, these mistakes often arise from inaccuracies in SOPs (more about that later) or other internal processes that are not streamlined and should be corrected or optimised.
Risk assessment needs to be addressed after an incident or deviation occurs.
Risks have to be addressed and mitigated before they become issues. Sometimes, people incorrectly look at risks only after mistakes have occurred. Risk needs regular evaluation, and each time you do this, it begins a new round of risk assessment.
Communication during an audit is a one-way street; the company is only required to answer questions, and there's no need to understand the reasoning behind the inquiries.
Passing on information is a form of communication. Any message, such as an SOP, given to workers should be as clear as possible. During an audit interview, the company is not only required to respond to the question but also to make an effort to comprehend the underlying reason behind the question.
Following inspectors' instructions without questioning is acceptable; understanding the reasoning behind the questions may seem unnecessary, as you'll have to address them regardless.
Do not just do something because the inspector told you so. Understand why something is being asked or expected of you. Don’t follow instructions blindly, understand why you are being asked to do something in a specific way and remember: auditors and inspectors ask questions based on an existing regulation or guideline. Make sure you know your regulations.
