Top 5 Marijuana Cultivation Center Infractions
Originally Shared By: Steve Owens, Adherence Compliance
After conducting more than 600 cannabis compliance inspections with our automated compliance software platform built on Amazon AWS and Apple, Adherence Compliance is sitting on a treasure trove of operational compliance data by operational license type (e.g. Cultivation Centers) and jurisdiction (State, County & City). Adherence knows how marijuana businesses fail. Moreover, Adherence utilizes our compliance data to help marijuana stakeholders succeed at every level of financial and regulatory compliance.
Here are the Top 5 Medical Marijuana Cultivation Center Infractions:
- The licensee does not reconcile all on-premises marijuana inventories at the close of business each day.
- The facility does not document material changes required for standard operating procedures and regulated processes.
- The facility does not have a complete inventory of material safety data sheets where the product is used or stored.
- The facility does not maintain an adequate Chemical and Pesticide Application Log (document and record).
- The cultivation facility has not properly documented all waste and waste removal.
For cultivation centers, owners/operators must manage the physical state of plant inventory – e.g. immature, clones, vegetative, flowering, harvested, etc. Regulators are reviewing “Aging Lists” to determine if license owners are current on inventory. Marijuana plants either move to the next phase or die off. If a plant is in an immature state for more than a 2 month period, the tracking tag is listed on an aging report. The more “aging” infractions a cultivation center has, the more likely it is that regulators will plan an unannounced inspection.
Standard Operating Procedures (SOPs)
Are SOPs materially complete – i.e. are there handwritten notes, missing page numbers or lack of a revision control process? If so, the SOPs may be incomplete and any related employee training on SOPs may be insufficient as well. Issues with SOPs often lead to further violations in multiple areas.
Each cultivation facility must have an accurate, up-to-date listing of all Material Safety Data Sheets for all chemicals and pesticides on-site. Any containers of liquids that are unidentified (unmarked) may lead to a complete inspection of all chemicals and pesticides, as well as additional marijuana testing scrutiny. State regulators may request involvement from the Department of Agriculture if issues with chemicals or pesticides exist.
Logs, Logs, Logs…
Complete, updated and accurate logs are imperative to avoiding a deeper investigation in all areas of Business Records Required. Common logs include application, waste, visitors and security & surveillance logs. It is fairly easy to see lacking compliance in this area, as a quick visual review can spot potential issues and omissions.
Does the facility document all associated plant waste, including floor waste (prior to harvest) and harvest waste (wet to dry weights, evaporation, etc.)? Does the facility utilize a 3rd party for waste removal and are their processes compliant? For California, water waste for cultivation licenses will be imperative to monitor and track as well.
Fortunately, all of these concerns are easily addressed using the BioTrackTHC seed-to-sale cannabis software. No matter what your license type (cultivation, processing/manufacturing, dispensary and full vertical), we provide one of the most complete and comprehensive seed-to-sale cannabis tracking solutions for every jurisdiction and license type.
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