Loading...
HomeMy WebLinkAboutLEG 010-001 Marijuana Grow Operations ProcedureChi 00 PICKERING CITY PROCEDURE Procedure Title: MARIJUANA GROW OPERATIONS PROCEDURE Procedure Number: LEG 010-001 Reference: Law Enforcement and Forfeited Property Management Statute Law Amendment Act, 2005 Date Originated: April 16, 2007 Date Revised: January 2009 Approval: Chief Ad nistrati - officer i Point of Contact: Chief Building Official Procedure Objective The Corporation of the City of Pickering is required to co • •I with the Law Enforcement and Forfeited Property Management Statute La A • endment Act, 2005, in respect of the inspection and remediation of marijuana gro - ations, when a marijuana grow operation has been identified by the Durham Regional Police. The objective of this procedure is to: 1. Establish procedures for City staff once notification has been received from Durham Regional Police that a marijuana grow operation has been identified. 2. Ensure that no member of the public is placed at any significant increased risk as a result of occupying a building formerly used as a marijuana grow operation. 3. Ensure the safety of City staff by adhering to the Occupational Health and Safety Act. 4. Ensure that appropriate inspections are undertaken which identify unsafe conditions as defined by the Building Code Act. 5. Ensure that appropriate action is taken to rectify any unsafe condition. Index 01 Definitions 02 Responsibilities 03 Governing Legislation 04 Procedures 05 Inspection 06 Notification from Pickering Fire Services 07 General - Notification from a Third Party Appendix 1 Formal Notice from Durham Regional Police advising that a marijuana grow operation has been identified in Pickering. Appendix 2 Marijuana Grow Operation Inspection Report Appendix 3 List of Qualified Private Inspection Companies 01 Definitions 01.01 City — means The Corporation of the City of Pickering. 01.02 Chief Building Official — means the Chief Building Official and the Deputy Chief Building Official as appointed by the Council of The Corporation of the City of Pickering. 01.03 Consultant — means a consultant with special expertise in the inspection and remediation of buildings that have been used as marijuana grow operations. 01.04 Council — means the Council of The Corporation of the City of Pickering. 01.05 Inspector — means an officer, employee or agent of the City or of any local board of any municipality whose responsibilities include the enforcement of a by-law, an Act or a regulation under an Act. 01.06 Inspection — mean an inspection that includes entering the property to determine whether or not the property is unsafe, as prescribed by the Building Code Act. 01.07 Marijuana Grow Operation - means a property that has been used or altered significantly for the purposes of growing marijuana. 01.08 Notice — means a formal announcement, in writing, indicating that a marijuana grow operation exists. Procedure Title: Grow Operations Procedure Page 2 of 20 Procedure Number: LEG 010-001 01.09 Order - means an Order issued under the Building Code Act. 01.10 Owner - means the registered owner of a property. 01.11 Police Force — means a municipal police force, the Ontario Provincial Police or the Royal Canadian Mounted Police. 01.12 Property — means a house, an apartment, a dwelling, or any other building. 01.13 Unsafe — means unsafe according to section 15.9 (2) of the Building Code Act. 02 Responsibilities 02.01 City Clerk to: a) receive Notice on behalf of the City from Durham Regional Police indicating that a marijuana grow operation has been identified; b) forward Notice from Durham Regional Police to appropriate City departments for action and/or information purposes; c) forward Notice from Durham Regional Police to Regional Clerk at the Region of Durham; and d) ensure that Notice is entered into City's property records (AMANDA). 02.02 Fire Chief to: If marijuana grow operation discovered by Pickering Fire Services as a result of a Fire: a) ensure Pickering Fire Services remain at the scene to provide continuity of evidence until the Durham Regional Police arrive; and b) inform Enbridge and Veridian of the marijuana grow operation and request that the hydro and natural gas services to the property be disabled. If City is made aware of marijuana grow operation by Durham Regional Police: Procedure Title: Grow Operations Procedure Page 3 of 20 Procedure Number: LEG 010-001 c) ensure that Fire Prevention Officer or designate attends the property with the Inspector to: (i) inspect the building; and (ii) provide an inspection report identifying any unsafe conditions to the Chief Building Official. 02.03 Chief Building Official to: a) administer the municipal inspection responsibilities set out by the Law Enforcement and Forfeited Property Management Statute Law Amendment Act, 2005; b) coordinate appropriate inspection and enforcement actions as required by the Municipal Act, as amended, and in accordance with sections 15(9) and 16 of the Building Code Act; c) undertake measures necessary to correct any unsafe conditions resulting from the operation of a marijuana grow operation; and d) create and maintain records of inspection and of any enforcement measures taken. 03 Governing Legislation Law Enforcement and Forfeited Property Management Statute Law Amendment Act. 2005 On December 15, 2005, the Law Enforcement and Forfeited Property Management Statute Law Amendment Act, 2005 came into effect, which in part, supports a province -wide strategy to combat the increase in marijuana grow operations. The Act requires municipalities to inspect a property upon written notification from police within a reasonable timeframe and requires the municipality to take whatever actions are necessary to ensure the property is not unsafe to the public. Municipal Act, 2001 The Municipal Act, 2001 has been amended by the Law Enforcement and Forfeited Property Management Statute Law Amendment Act, 2005 by adding sections 431.1 and 431.2, as follows: Section 431.1 Inspection of buildings containing marijuana grow operations Procedure Title: Grow Operations Procedure Page 4 of 20 Procedure Number: LEG 010-001 (1) If the clerk of a local municipality is notified in writing by a police force that a building located on land in the local municipality contained a marijuana grow operation, the local municipality shall ensure that an inspection of the building is conducted within a reasonable time after the clerk has been notified. Persons who may conduct inspection (2) An inspection referred to in subsection (1) may be conducted by, (a) a by-law enforcement officer of any municipality or of any local board of any municipality; or (b) an officer, employee or agent of any municipality or of any local board of any municipality whose responsibilities include the enforcement of a by- law, an Act or a regulation under an Act. Nature of inspection (3) The requirement in subsection (1) for an inspection is for an inspection that includes entering upon the land and into the building. Powers to conduct inspection (4) The inspection shall be conducted pursuant to the powers of entry and inspection that the person conducting the inspection otherwise has under law, but only to the extent that the person conducting the inspection is able to do so. Action to be taken (5) Upon conclusion of the inspection, the person who conducted the inspection shall take whatever actions he or she is authorized by law to take in Order to make the building safe and otherwise protect the public. Section 431.2 Where marijuana grow operation is in a lower -tier municipality (1) If the clerk of a local municipality that is a lower -tier municipality is notified under subsection 431.1(1) that a building located on land in the lower -tier municipality contained a marijuana grow operation, the lower -tier municipality shall, if in its opinion it is appropriate to do so, forward a copy of the notice referred to in subsection 431.1(1) to the clerk of the upper -tier municipality of which the lower -tier municipality forms a part. Procedure Title: Grow Operations Procedure Page 5 of 20 Procedure Number: LEG 010-001 Same (2) Upon the clerk of the upper -tier municipality being notified under subsection (1), the obligation under subsection 431.1(1) to ensure that an inspection of the building is conducted becomes the obligation of both the lower -tier municipality and the upper -tier municipality. Building Code Act - Section 15.9 Inspection of Unsafe Buildings (1) An inspector may enter upon land and into buildings at any reasonable time without a warrant for the purpose of inspecting a building to determine, (a) whether the building is unsafe; or (b) whether an Order made under subsection (4) has been complied with. 2002, c.9, s.26 Interpretation (2) A building is unsafe if the building is, (a) structurally inadequate or faulty for the purpose for which it is used; or (b) in a condition that could be hazardous to the health or safety of persons in the normal use of the building, persons outside the building or persons whose access to the building has not been reasonably prevented. 2002, c.9, s.26 Sewage Systems (3) Order In addition to the criteria set out in subsection (2), a sewage system is unsafe if it is not maintained or operated in accordance with this Act and the building code. 2002, c.9, s.26 (4) An inspector who finds that a building is unsafe may make an Order setting out the reasons why the building is unsafe and the remedial steps necessary to render the building safe and may require the Order to be carried out within the time specified in the Order. 2002, c.9, s.26 Service (5) The Order shall be served on the owner and each person apparently in possession of the building and such other persons affected thereby as the Procedure Title: Grow Operations Procedure Page 6 of 20 Procedure Number: LEG 010-001 Chief Building Official determines and a copy of the Order may be posted on the site of the building. 2002, c.9, s.26. Order Respecting Occupancy (6) If an Order of an inspector under subsection (4) is not complied with within the time specified in it, or where no time is specified, within a reasonable time, the Chief Building Official, (a) may by Order prohibit the use or occupancy of the building; and (b) may cause the building to be renovated, repaired or demolished to remove the unsafe condition or take such other action as considered necessary for the protection of the public. 2002, c.9, s.26 Power of Entry (7) Service For the purpose of clause (6)(b), the Chief Building Official, an inspector and their agents may enter upon land and into buildings at any reasonable time without a warrant. 2002, c.9, s.26 (8) The Order under clause (6)(a) shall be served on the owner and each person apparently in possession of the building and such other persons affected thereby as the Chief Building Official determines and a copy of the Order shall be posted on the site of the building. 2002, c.9, s.26 Timing (9) The Order under clause (6)(a) is effective from the time it is posted. 2002, c.9, s.26 Lien (10) If the building is in a municipality, the municipality shall have a lien on the land for the amount spent on the renovation, repair, demolition or other action under clause (6)(b) and the amount shall have priority lien status as described in section 1 of the Municipal Act, 2001. 2002, c.17, Sched. C, S.4(1) Deemed Taxes (11) If the building is in a territory without municipal organization, the amount spent on the renovation, repair, demolition or other action under clause (6)(b) shall be deemed to be taxes imposed under section 3 of the Provincial Land Tax Act for the purposes of sections 26 and 27 of that Act. 2002, c.9, s.26 Procedure Title: Grow Operations Procedure Page 7 of 20 Procedure Number: LEG 010-001 Section 16 Entry to Dwellings (1) Despite sections 8, 12, 15, 15.2, 15.4 and 15.9, an inspector or officer shall not enter or remain in any room or place actually being used as a dwelling unless, (a) the consent of the occupier is obtained, the occupier first having been informed that the right of entry may be refused and entry made only under the authority of a warrant issued under this Act; (a.1) a warrant issued under this Act is obtained; (b) the delay necessary to obtain a warrant or the consent of the occupier would result in an immediate danger to the health or safety of any person; (c) the entry is necessary to terminate a danger under subsection 15.7(3) or 15.10(3); or (d) the requirements of subsection (2) are met and the entry is necessary to remove a building or restore a site under subsection 8(6), to remove an unsafe condition under clause 15.9(6)(b) or to repair or demolish under subsection 15.4(1) Notice (2) Within a reasonable time before entering the room or place for a purpose described in clause (1)(d), the inspector or officer shall serve the occupier with notice of his or her intention to enter it. Section 18 Powers of Inspector (1) For the purposes of an inspection under this Act, an inspector may, (a) require the production for inspection of documents or things, including drawings or specifications that may be relevant to the building or any part thereof; (b) inspect and remove documents or things relevant to the building or part thereof for the purpose of making copies or extracts; Procedure Title: Grow Operations Procedure Page 8 of 20 Procedure Number: LEG 010-001 (c) require information from any person concerning a matter related to a building or part thereof; (d) be accompanied by a person who has special or expert knowledge in relation to a building or part thereof; (e) alone or in conjunction with a person possessing special or expert knowledge, make examinations or take tests, samples or photographs necessary for the purposes of the inspection; and (f) order any person to take and supply at that person's expense such tests and samples as are specified in the Order. 1992, c.23, s.18(1); 1997, c.30, Sched. B, s.11. Samples (2) The inspector shall divide the sample taken under clause (1)(e) into two parts and deliver one part to the person from whom the sample is taken, if the person so requests at the time the sample is taken and provides the necessary facilities. 1992, c.23, s.18(2). Idem (3) If an inspector takes a sample under clause (1)(e) and has not divided the sample into two parts, a copy of any report on the sample shall be given to the person from whom the sample was taken. 1992, c.23, s.18(3). Occupational Health and Safety Act - Sections 25(2)(d) and (h) An employer shall, (d) acquaint a worker or a person in authority over a worker with any hazard in the work and in the handling, storage, use, disposal and transport of any article, device, equipment or a biological, chemical or physical agent; and (h) take every precaution reasonable in the circumstances for the protection of a worker. Section 26(1)(g) An employer shall, (g) comply with a standard limiting the exposure of a worker to biological, chemical or physical agents as prescribed. Procedure Title: Grow Operations Procedure Page 9 of 20 Procedure Number: LEG 010-001 Section 43(3)(b) A worker may refuse to work or do particular work where he or she has reason to believe that, (b) the physical condition of the workplace or the part thereof in which he or she works or is to work is likely to endanger himself or herself. 04 Procedures Responsibilities of Police Service The following was provided by the Durham Regional Police Service to municipalities in Durham — March 26, 2007. When an illicit marijuana grow operation has been discovered to be operating in a premise, building or structure on property within the jurisdiction of the municipality, the police service shall ensure that: 04.01 An investigation is conducted into the illicit marijuana grow operation in accordance with the adequacy requirements in police operations as they pertain to drug investigations, the police service's Criminal Investigation Management Plan, if appropriate, and the police service's policies and procedures. 04.02 A notice is placed on the principal entrance to the premises. 04.03 The Clerk of the municipality is notified, in writing, by courier (signature required) or registered mail, consistent with the On - Site Report upon the completion of the on-site phase of the police investigation. 04.04 Appropriate agencies/personnel necessary to the police investigation at the premises are contacted, this may include: Hydro suppliers Fire services Children's Aid Society Immigration 04.05 A site is deemed suitable for inspection by persons other than police when: a) the police investigation of the premises and removal of the marijuana plants is complete; Procedure Title: Grow Operations Procedure Page 10 of 20 Procedure Number: LEG 010-001 b) all hazards of which police are aware of, have been contained, dismantled and/or are listed on the Site Report and sent to the municipality; and c) the notice has been affixed to the principal entrance of the premises indicating that a marijuana grow operation was dismantled and the premises may not be suitable for habitation/use until inspected by the municipality. Responsibilities of the Municipality 04.06 Once the City Clerk has received a Notice from the Durham Regional Police indicating that a marijuana grow operation has been identified, the City Clerk shall, a) forward Notice to: Chief Building Official; Fire Chief; and Manager, By-law Enforcement Services. Copy Notice (for information purposes) to: Chief Administrative Officer; Director, Corporate Services & Treasurer; Director, Office of Sustainability; Director, Operations & Emergency Services; and Director, Planning & Development. b) forward Notice to the Regional Clerk, Regional Municipality of Durham via email (Appendix 1); and c) update AMANDA (municipal property records) to include information outlined in Notice from Durham Regional Police. 05 Inspection 05.01 Upon receipt of Notice, Chief Building Official shall: a) obtain a title search of the property to determine ownership; b) obtain a search warrant; c) retain an Environmental Consultant; and d) assign the matter to the appropriate area Inspector. Procedure Title: Grow Operations Procedure Page 11 of 20 Procedure Number: LEG 010-001 05.02 Prior to attending the site, the Inspector shall: a) review hazards identified in Police Notice; and*** b) verify that electrical supply has been disabled. 05.03 In the event the electrical supply has not been disabled, Inspector shall confirm that an Electrical Safety Authority inspection has been conducted prior to entering the property. 05.04 Inspector shall coordinate inspection of the property with the Environmental Consultant and Fire Prevention Officer, or designate, in accordance with the timeline set out in the search warrant. ***In the event the Police Notice confirms that chemical or mould contamination is present, Inspection shall be conducted solely by the Environmental Consultant — Inspector will not be required to enter property. In this case, the Inspector shall prepare issue and enforce the required "unsafe Orders" in accordance with section 05.08 herein, on the basis of information provided by the Durham Regional Police and the Environmental Consultant. ***Once remediation of chemical or substantial mould contamination has been completed, or the Consultant has confirmed that the building is free from contamination, the Inspector shall undertake inspection of building to determine if any other unsafe condition exists. 05.05 Prior to the Inspector entering the property: a) a visual inspection of the exterior of the property shall be conducted; and b) the following protective equipment must be worn, unless confirmation is received from the Environmental Consultant that the building is free from chemical and mould contamination: (i) disposable TYVEK® coverall with attached hood and boots (ii) Nitrile® gloves (iii) N95 Respirator (iv) CSA approved eye protection (v) CSA approved work boots with steel toes and shank ("Green Tag") Procedure Title: Grow Operations Procedure Page 12 of 20 Procedure Number: LEG 010-001 (vi) CSA approved hard hat, and; c) the following equipment may be required: (i) flashlight (ii) camera 05.06 Upon completion of the inspection and receipt of Environmental Consultant and Fire Prevention reports, the Inspector, in consultation with the Chief Building Official shall make a determination if any unsafe condition exists according to section 15.9(2) of the Building Code Act. 05.07 A copy of the Environmental Consultant's Report shall be issued to the Owner. Building Not Unsafe 05.08 If it is determined that building is not 'UNSAFE', Chief Building Official shall notify: City Clerk; Fire Chief; and Manager, By-law Enforcement Services. Copy same (for information purposes) to: Chief Administrative Officer; Director, Corporate Services & Treasurer; Director, Office of Sustainability; Director, Operations & Emergency Services; and Director, Planning & Development, advising of inspection findings; and a) update AMANDA to reflect inspection information and, complete Inspection Report (Appendix 2); and b) close file. Procedure Title: Grow Operations Procedure Page 13 of 20 Procedure Number: LEG 010-001 Building Unsafe 05.09 If `UNSAFE' condition exists, Inspector shall prepare, issue and enforce an "Order to Remedy an Unsafe Condition" and an "Order Respecting Occupancy" pursuant to sections 15.9(4), 15.9(6) and 16 of the Building Code Act, to the Owner and Mortgagee, and any other affected person, in accordance with established departmental procedure BLD -017 "Issuance of Compliance Orders". The Owner shall be issued a copy of the Consultant's Report which forms the basis of the Order. 05.10 Once Orders have been issued, Chief Building Official shall update: City Clerk; Fire Chief; and Manager, By-law Enforcement Services. Copy same (for information purposes) to: Chief Administrative Officer; Director, Corporate Services & Treasurer; Director, Office of Sustainability; Director, Operations & Emergency Services; Director, Planning & Development; and City Solicitor, advising of inspection findings. 05.11 In the event the "UNSAFE" condition is not rectified in the time specified in the Order, the Chief Building Official shall forward final Notice, by registered mail to all affected persons, setting out the date that the Chief Building Official shall cause the building to be renovated, repaired or demolished. 05.12 In the event the "UNSAFE" condition is not rectified in the time specified, the Chief Building Official shall cause the building to be renovated, repaired or demolished to remove the unsafe condition in accordance with the Building Code Act. 05.13 Contractors retained to undertake any renovation, repair or demolition shall be obtained in accordance with the Purchasing Policy, PUR 010.001, item 4 — Authorities and Dollar Limits, or PUR 010.001, item 6 — Emergencies, as applicable. Procedure Title: Grow Operations Procedure Page 14 of 20 Procedure Number: LEG 010-001 05.14 Upon completion of renovation, repairs or demolition by the City, Chief Building Official shall notify: City Clerk; Fire Chief; and Manager, By-law Enforcement Services. Copy same (for information purposes) to: Chief Administrative Officer; Director, Corporate Services & Treasurer; Director, Office of Sustainability; Director, Operations & Emergency Services; and Director, Planning & Development, advising of the completion of remediation activity, and a) update AMANDA to reflect inspection information and, complete Inspection Report (Appendix 2); b) advise Director, Corporate Services & Treasurer of the applicable Lien amounts authorized under section 15(9-10) of the Building Code Act; and c) close file. 06 Notification from Pickering Fire Services 06.01 If a marijuana grow operation has been discovered by the Pickering Fire Services as a result of responding to a fire call, Pickering Fire Services shall remain on scene to provide continuity of evidence until the Durham Regional Police Service arrives at the location. 06.02 Pickering Fire Services will inform Enbridge and Veridian of the marijuana grow operation and request that hydro and natural gas services to the location be disabled. 06.03 Pickering Fire Services will not deal with chemicals or insecticides on site or participate in the removal of them. 07 General - Notification from a Third Party City staff shall not conduct any type of inspection should information of a grow operation be received from a third party — (i.e. real estate agent, resident). City Procedure Title: Grow Operations Procedure Page 15 of 20 Procedure Number: LEG 010-001 staff may, if requested, provide information to third party of qualified private inspection companies (Appendix 3). Appendix 1 Formal Notice from Durham Regional Police advising that a marijuana grow operation has been identified in Pickering. Appendix 2 Marijuana Grow Operation Inspection Report. Appendix 3 List of Qualified Private Inspection Companies. Procedure Title: Grow Operations Procedure Page 16 of 20 Procedure Number: LEG 010-001 APPENDIX 1 POLICE NOTIFICATION of ILLICIT MARIJUANA GROW OPERATION Please be advised that the Durham Regional Police Service has investigated and dismantled an Illicit Marijuana Grow Operation at the under -mentioned location. DATE TIME POLICE INCIDENT # Postal Code ❑ Structural alteration/damage Officer in Charge of Investigation Phone Number/Email Address Registered Owner Mortgagee SITE DETAILS Lot No./Street City/Town/Village Postal Code ❑ Structural alteration/damage ADDITIONAL INFORMATION IF AVAILABLE: Registered Owner Mortgagee Length of Ownership/ Own/Lease/Rent ❑ Mould/Water Damage Realtor/ Property Management Insurer Name on Rental/ Lease Agreement ❑ COMMENTS / HAZARDS IDENTIFIED* Hazard Location Comments ❑ Structural alteration/damage ❑ Chemicals or fuels ❑ Mould/Water Damage ❑ Electrical Wiring/Fire Damage ❑ Other: Procedure Title: Grow Operations Procedure Procedure Number: LEG 010-001 Page 17 of 20 * Disclaimer: Police Services are not experts at identifying all hazards. This list is not exhaustive and hazards not identified here may exist. Signed: Officer in Charge — Drug Enforcement Unit Date: Procedure Title: Grow Operations Procedure Page 18 of 20 Procedure Number: LEG 010-001 Address APPENDIX 2 Inspection Report Marijuana Grow Buildings X = No visible building damage R = Building damage requires repair Building Envelope integrity, damage Foundation Wall integrity, damage HVAC Systems alterations, ventilation, operating condition Electrical System alterations Visible Mould finishes, building materials ❑ Approx. 1 s.f. ❑ 10 s.f. ❑ > 10 s.f. Egress Doors operating condition Smoke and CO Detectors installed and operational Inspection by Inspectors Comments ri Windows and Doors integrity, damage, operating condition Perimeter Wall Insulation moisture damage, mildew ri Plumbing System alterations n Structural Integrity damage to walls, floors, roof n Fire Separation integrity, damage nStairs, Handrails, Guards safe condition Date ❑ No conditions observed which are unsafe according to s. 15.9 of the Building Code Act ❑ Unsafe condition exists Environmental Consultant ❑ See attached report ❑ No conditions observed which are unsafe according to s. 15.9 of the Building Code Act ❑ Unsafe condition exists LIMITATION The purpose of this inspection is to determine if the former use of this building to grow marijuana has created an unsafe condition according to s. 15.9 of the Building Code Act. This is not a comprehensive building condition assessment. Date PD0701-10/10 Procedure Title: Grow Operations Procedure Procedure Number: LEG 010-001 Page 19 of 20 APPENDIX 3 Environmental Laboratories and Consultants Please be advised this list does not represent all consultants and laboratories available, nor is this list a recommendation for any consultant or laboratory by the City of Pickering. AMEC 3190 Steeles Avenue East, Suite 305 Unionville, ON L3R 1G9 905.415.2632 Cunningham Lindsey Environmental Solutions 50 Burnhamthorpe Road West, Suite 1102 Sussex Centre Mississauga, ON L5B 3C2 905.896.8181 www.esrs.ca Decommissioning and Consulting Services Ltd. 121 Granton Drive Richmond Hill, ON L4B 3N4 905.882.5984 Fisher Environmental 40 Esna Park, Unit 15 Markham, ON L3L 3K2 905.475.7755 Guelph Chemical Laboratories Ltd. 246 Silvercreek Parkway N Guelph, ON N1 H 1E7 519.836.2313 Jacques Whitford 7271 Warden Avenue Markham, ON 905.474.7700 Maxxam Analytics Inc. 6740 Campobello Road Mississauga, ON L5N 2L8 1.800.563.6266 905.817.5700 Pinchin Environmental 5749 Coopers Avenue Mississauga, ON L4Z 1R9 905.507.4855 T. Harris Environmental Management Inc. 93 Skyway Avenue, Suite 101 Etobicoke, ON M9W 6N6 416.679.8914 Trow Consultants 1595 Clark Blvd. Brampton, ON L6T 4V1 905.793.9800 Procedure Title: Grow Operations Procedure Page 20 of 20 Procedure Number: LEG 010-001