Cannabis Enforcement Hazards and Task Analysis


The federal Cannabis Act came into effect on the 17th of October 2018. It made Canada the second country in the world, after Uruguay, to formally legalize the cultivation, possession, acquisition and consumption of cannabis and its by-products. Canada is the first G7 and G20 nation to do so.

Cannabis in Canada is legal for both recreational and medicinal purposes.

Medicinal use of cannabis was legalized nationwide under conditions outlined in the Marihuana for Medical Purposes Regulations,
later superseded by the Access to Cannabis for Medical Purposes Regulations, issued by Health Canada and seed, grain, and fibre production was permitted under licence by Health Canada.

Health Canada hired ONPAR to investigate the roles and responsibilities–including Occupational Health, Safety and Security– of Health Canada inspectors and enforcement personnel pertaining to inspections conducted on License Holders permitted by the Government to produce and/or sell cannabis and vaping products.


ONPAR assembled a team of experts and visited all primary Health Canada enforcement and inspection locations (Vancouver, Winnipeg, Toronto, Ottawa, Montreal and Halifax). The ONPAR team documented all inspector activity and met with occupational health and safety committees and security personnel within each region.
This effort allowed ONPAR to document the organization’s current state of readiness, distilling information at the operations level into common inspection and enforcement duties. These documents created a map of the organization’s documentation, giving headquarters a better understanding of the work being done in the field. Once all information was logged and analyzed, ONPAR was able to benchmark against best practices– identifying gaps, opportunities and threats to the organization and its personnel. This led to an easier transition to the provincial leads, along with a framework for governance.


ONPAR’s efforts resulted in two task analysis of vaping and cannabis inspectors, two risk and hazard reviews of inspector roles from an Occupational Health & Safety point of view, a gap analysis of current practices, two separate standard operating procedures for inspectors in the cannabis and vaping sections, program recommendations, and a roadmap to develop the inspection regime framework within Health Canada’s decentralized enforcement model.


Broader concerns relating to the international supply chain and small subsections of the Cannabis Act that enable micro-producers were uncovered and addressed.

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