Health Canada recently implemented their system for authorizing non-therapeutic research on cannabis (NTRC).

AND… if you have an existing sensory research licence, you probably just got an email from Health Canada saying you need to apply for and be APPROVED under the NTRC framework by December 2024.

Before this, only sensory research was permitted, but now NTRC applications allow for measurement of physiological and psychological effects — albeit with more stringent requirements.

The previous system was much easier to obtain licences under. There was less documentation required to be submitted, with a tiered system based on how much cannabis was expected to be stored on site.

Under that regime we’ve seen at least one facility operate as an indoor “vapour lounge” doing sensory testing under a research licence, and they sough cover under the exemption for “scientific research and testing facilities” to the Smoke-Free Ontario Act’s indoor smoking/vaping prohibition.

But with the new framework they’re going to face requirements they didn’t already need to meet, and may face roadblocks to continuing to operate a progressive vapour lounge style research establishment.

There are three categories of NTRC research based on risk factors present in the proposed licenceholder’s research protocols – Categories 1, 2 or 3 – each with increasing requirements.

Category 1, the least onerous class to apply for, is limited to organoleptic testing and chemesthetic/sensory-emotive responses. However, participants need to be between 18 and 65 without significant health problems, and are limited to the types of cannabis and modes of consumption they report “typically” using. Only individuals who use cannabis at least 3 times a week are eligible to be participants. There are limits to how much can be consumed; For smoking that is “three or four inhalations of cannabis smoke, vapour or aerosol per cannabis item.”

Category 2 can study psychological/physiological effects, however most of the other requirements remain.

Category 3 is the highest category, and is the most permissive, with many of these restrictions reduced.

But Category 3 studies have the most onerous application requirement: You’ll need to prepare and submit: An Application form, Cannabis information form, Full protocol, and a Cannabis research and evidence dossier. Oh, and you may even be required to obtain Research Ethics Board approval.

It’s difficult, but it’s not impossible.

Just know that Health Canada’s mandate isn’t to allow vapour lounges to pop up across the country under the cover of a research licence.

But if it’s valid research, you can demonstrate that to Health Canada, and you’re ready to meet the requirements of the Category you fall under, it can be done.