If you're a licensed cannabis operator and can't deal with state and local inspectors visiting your facility with clipboards and tablets in hand, you're in for a long and difficult road. All kinds of authorities want to inspect cannabis operations and facilities. Inspections will be led by state regulatory inspections, insurance and banking partners, local regulatory agencies, OSHA, and the EPA. On average, cannabis businesses are visited once or twice a year for state inspections, once for insurance purposes, and once for banking purposes. Depending on the reason for the visit, cannabis businesses can expect inspectors to be on-site for varying amounts of time. 1 hour if the inspection involves insurance, banking, or local regulations (electrical, mechanical, plumbing, fire extinguishers, alarm systems); 1 hour if the inspection involves insurance, banking, or local regulations. Depending on the type of license, the pre-use inspection takes him two to four hours, and once he gets the call from OSHA, it takes him four hours. If an inspector shows up unannounced in response to a complaint or potential violation, be prepared to stay for 4 to 8 hours.
This article focuses on how to prepare for three types of national regulatory inspections: pre-operational, unannounced, and renewal. However, the basics of preparing for a state-regulated inspection apply to all inspections. First, let's define the reasoning behind each type of state-regulated inspection and focus on the most common items that need to be provided/presented to the inspector.
Before operation
All licensed businesses must pass a state pre-business inspection before opening for business. In most states, the regulatory authority assigned to the licensee will provide instructions on what to expect and the requirements for passing the inspection. Preparing in advance and showing the inspector that you and your staff take compliance and safety seriously will go a long way in making the inspection faster and smoother. This naturally means that you can start making money sooner.
At a minimum, you should have a binder or software program with all the necessary documents organized to pass the pre-operation inspection. Depending on your state, you may need:
- floor plan
- training plan
- Standard Operating Procedures (SOPs) are intended to:
- Track inventory to prevent diversion and diversion
- Storage and display of inventory
- Control access to areas where cannabis is displayed or stored
- Please check your ID to prevent minors from purchasing
- Maintain a safe and sanitary facility
- Responsible for overall facility management
- Dealing with adverse events
- security system
- Alarms, surveillance cameras
- Save video recordings safely and timely
- Equipment maintenance procedures
- If applicable, MSDS sheets for chemicals used during the work.
- Administrative requirements such as insurance contracts, security deposits, corporate documents, administrative and other legal agreements
In addition to reviewing the required documentation, inspectors will tour the facility to ensure that submitted floor plans are accurate and that the building, security equipment and controls, signage, lighting, and access controls are all compliant. , make sure the license is displayed in an easily visible place. .
Unannounced inspection/unannounced inspection
If an inspector shows up unannounced at a cannabis facility, it is likely in response to a tip or complaint of non-compliance from a customer or neighboring business.
The best way to prepare for the unexpected is to stay organized. Set up compliant systems and manage operations before problems occur. Be proactive and have an organized binder or software program with all the necessary documents to prove your operations are compliant.
Set up your system to track:
- Sales and inventory records
- Employee onboarding.training documents
- Security equipment and system maintenance
- Opening/closing procedure
- Health and safety of people and products
- Environmental impact, odor reduction
- advertising, marketing campaigns
- Packaging and labeling procedures and protocols
- Mandatory test results, Certificate of Analysis (COA)
- Documentation of storage process
- Control access for employees, visitors, and prevent minors from purchasing cannabis or cannabis products
- Administrative requirements
Ask your regulatory representative if there is a checklist you can use to ensure your operations are compliant. That way, you'll always be prepared, even for unannounced inspections.
Update check
The renewal inspection has three purposes. They are designed to ensure that:
- You are doing what you said you would do in your original license application.
- Procedures are followed and records are kept properly.
- We have not made any changes to our facilities or operations without first obtaining state approval.
Applying for license renewal can often be time-consuming and difficult, especially if you don't have a compliance system set up with an organizational binder or software portal where information is readily available. To prepare for a renewal inspection, you will need all the information provided in the pre-operational inspection and unannounced inspection, as well as any required annual reports such as the company's diversity, community and environmental impact .
How to prepare for all state inspections
There are some best practices that can help you impress state inspectors and ultimately avoid notices of deficiency and fines. With a little preparation, you can confidently greet the marijuana inspector with a smile and a welcoming attitude, setting the tone for a pain-free inspection.
The first thing to do is set up an easily accessible and accurate record-keeping system as early as possible in your business lifecycle. Make sure your facility manager or shift leader knows where to find and share state-required documents.
Ed Windvigler, director of internal operations for Fawn River Cultivation Company in Michigan, said: State Inspector. ”
The second is to maintain a clean and safe facility. Walk around the facility regularly to ensure that the facility and all of its equipment is clean and that products are properly displayed and stored. Make sure your license is prominently displayed.
Third, talk to your staff and let them know that compliance is a priority and testing is not a reason to panic. She will designate one person (or, if the facility is large, one person for each area of the facility) to guide inspectors and respond to questions and requests for information. Please let the staff know of your upcoming plans. Be sure you know what regulations apply to your position, where your department's standard operating procedures are, how to alert management if you witness violations or parts of your facility, and how to respond to threats such as theft (collaborative) Let's understand. – employees or customers), altercations or aggressive behavior, fire, or natural disasters. Consider role-playing so employees can become familiar with the types of questions the inspector might ask.
Windvigler, who has a regular internal audit system in place, was asked how he prepares his employees for inspections. Our internal audit typically detects problems early. ”
Fourth, walk around the facility using safety precautions. Andy Shelley, a former Oregon cannabis inspector and founder and CEO of cannabis compliance consulting firm CannXperts, recommends having an employee walk the site and have another person oversee the surveillance. is proposed. Adjust your camera or install additional cameras to cover blind spots. Ensure surveillance records are stored in a manner that complies with state requirements. Ensure that areas of your facility containing cannabis or cannabis products have appropriate access controls. Ensure your facility's visitor logs are complete and compliant with regulations.
“One thing I can say consistently is that state inspectors will be paying more attention to oversight and security above all else. We want to make sure these systems are rock-solid. We train one or two field employees to check the systems daily and weekly, and conduct a full compliance inspection of those systems during the audit,” Shelley said.
“JARS is a company that is committed to providing the best possible service to our customers,” said Jacob Lawson, JARS Compliance Specialist and Sarah Stoker, Director of Compliance, at JARS Arizona. We expect states to constantly monitor all aspects of compliance. ”
And fifth, regularly audit your facilities, staff, and operations to identify areas of weakness or noncompliance. Some states publish checklists for inspectors to use when visiting a facility. If you have yours, use it! Consultants and operational platforms often have their own checklists based on state rules and regulations. If you have an existing relationship, see if there are resources available to prepare for the test.
Shelley advises: “Check everything, double-check everything, and then check everything again. There's no better way to test your compliance system than to have it inspected by fresh eyes a few times a year. We rotate our inspectors so they never visit the same facility twice, so we look at our client's work with a fresh eye each time. It could destroy the company.”
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