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Questions To Ask When Checking Compliancy


Eek is a distributor in the legal cannabis products. As a distributor we see how all the other licensees we are ultimately responsible for enforcing the chain of custody between cultivators, manufacturers, and retail. We’ve compiled our observations on some of the scariest compliance issues- to help you avoid getting fined- or worse.
Physical premises.
For the most part, the rules are set up to make sure that marijuana products are tracked and traced between facilities. A facility is a location that has been approved to be running under the local jurisdictions rules. After you have been approved, it is still important to keep on several parts of the physical premises.
There are rules that govern how and what type of video surveillance is required. Once it is set up, it is important to check to make sure it is working. It is the licensees job to verify that the cameras are all working and the proper on-site and off-premises storage retention is being met.
Changes to the facility.
Once a facility is approved by the governing body, changes to the facility must be approved before being made. It’s really easy to move that shelf, or add another wall to a business as it grows. But, when it’s a licensed cannabis facility, approval is needed first, or there may be a fine if the facility goes out of compliance.
For all licensees inventory is a critical component to compliance. The rules in many states are that inventory is to be reconciled every single day. It’s really easy to rely on the registry or POS system and cross your fingers that it all totals out. The reality, however, is that this job needs to be added as a standard operating procedure that the entire team working at the facility learn, adapt, and adjust. There are so many scenarios for cultivators, wholesalers, manufacturers, and retailers that it’s impossible to list here – but the key is that any time cannabis is changing its quantity – for any reason – it needs to be tracked in the system.
One area where it can be tricker to stay in compliance is transfers. This is where a package is moving from one facility to another. In the simplest case, it’s easy to do and works smoothly. Everything that is transferred is accepted, papers are signed, and it’s all done. However, the other scenarios, such as rejected projects, transfers not being accepted, or partially accepted is where things can get tricky. A good idea for licensees is to regularly make sure incoming, outgoing, and rejected transfers are completed at the end of every day.
Changing rules.
Be on the lookout for rules changes in your jurisdiction. These can be anything from how the transfer forms are signed (and where they sare signed), to removal of entire product categories (e.g. CBD products). The rules are evolving frequently, so having a regular review will help you avoid becoming out of compliance without even knowing it. Here are a couple of additional tips for retailers:
End of the jar.
Don’t forget to adjust and finish jars when they reach the bottom. It’s almost impossible for it all to add up correctly, but don’t let that stop you in reconciling the quantity that is actually there.
Negative inventory.
Some POS systems can let a package go into negative inventory. Although probably not a fineable offense, it’s a good idea to check the registry and clear these out.
Trade Samples.
It’s really easy to accept awesome trade samples. Retailers, make sure you take the extra moment to adjust and finish those so they aren’t phantom inventory.
Test Your Team on Selling to Minors.
It’s not only critical to know the policy in your area, but also to execute it in a reliable and repeatable way. In states that have been doing compliance verification, there have been failures where dispensaries that are trying to follow the rules get fined. Making sure everyone is on the same page and that the leadership for the facility are all running the same process to check identification for all purchases. Ask for help. When in doubt, call the governing body. They are here to help, and asking goes a long way towards compliance. There are some things that only they can answer, fix, or explain.


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