Of all the cannabis-related compliance issues, cultivation is the least understood. There are three main concerns for licensed cannabis growers.
Regulators have a number of critical issues that they review primarily to ensure that the licensee complies. They include:
Employee safety and health
OSHA, together with its relevant state agency, is responsible for securing the job security, and although cannabis is illegal at the federal level, it is still subject to federal workplace regulation.
OSHA offers a free on-site consultation program to review safety hazards. There are four key state and OSHA occupational safety issues:
• Adequate danger signs, fire exits, chemical storage, warning signs
• Adequate and proven fire safety plans that include exit markings, firefighters to ensure the safe exit of everyone, contact information and protocols for fire emergencies.
• Inadequate hazard communication plan. Who is responsible for: calling the police during an emergency, shutting down the facility and making sure everyone is out, alerting everyone of a chemical leak or spill?
• Inadequate or lack of personal protective equipment. Do all employees who need it have the proper personal protective equipment? Is it easily accessible?
Security issues
Is the crop facility part of the global security plan? Are there locking systems suitable and periodically tested for access?
Does the alarm system have adequate storage and backup and do all the cameras and systems work? Does camera coverage cover the entire area?
To preserve your investment, the security system should be tested quarterly to ensure that it can respond successfully to any issues.
Cleaning, pollution and sanitation
Cannabis cultivation, processing, storage and packaging require a very clean installation, with proper operating protocols and procedures.
Are all work surfaces cleaned and sterilized properly, and then documented by the person doing the work? Is all processing equipment disassembled and sterilized according to the manufacturer’s requirements?
Soil, water and chemicals are stored safely to prevent spillage and pollution? What about actual ventilation system filters?
Inventory records
Does your plant count match what you have at METRC or any other state-required inventory system? How often is the plant, seed, or clone collected? How often is commercially packaged inventory audited and accounted for?
Learning to control inventory through the mandatory state system is critical. One of the first tasks that regulators will perform is to make sure that no product is counted, tested or sold in the illicit market.
If there is an inventory error, find it. Are there any count discrepancies? Track it to the source. Is the product disappearing? Keep a close eye on the camera system.
How can I avoid compliance issues with cannabis cultivation?
Perform your own compliance audit to identify your weaknesses. List all state regulations for cannabis, and then honestly assess your compliance with it. Repeat the procedure with state employee safety regulations, fire regulations, worker safety regulations, and so on. From there, create a worksheet that can be filled out daily and train your employees on your compliance documentation.
In fulfillment, strict consistency is your best friend.
