KNOW THE REGS: HANDY CHECKLISTS AND REQUIREMENTS
First of all, we want to acknowledge the hardworking people at the Cannabis Control Commission. We had such a positive response to our first two Know the Regs columns, and especially the last one outlining the equity provisions written into the Mass recreational law to help certain populations get a leg up on the application process, that we wanted to make sure people realized that, in the task of writing these installments, we are essentially middlemen. The information we’re providing can mostly be found right in the regulations and tangential documents compiled by the CCC; we suggest that people check them out in full, whether you are going for a license or not, but in the meantime we are here to parse and dice the regs like strains among so many jars, and to occasionally add context where it’s needed.
Speaking of the dutiful commission, anyone who’s even thinking about applying for a license should print out the extremely handy “Application Checklist,” available at mass-cannabis-control.com, as well as the guidance for licensure as a marijuana establishment. In broad terms, the latter breaks down the three packets you will need to submit in order to obtain any of the licenses—cultivator, microbusiness, craft cooperative, independent testing lab, research facility, retailer, product manufacturer, transporter:
- Packet 1: Application of Intent. Asks things like “Who is the marijuana-establishment applicant?” “How is the business organized?” “How will the Marijuana Establishment be funded?”
- Packet 2: Background Check. Which includes but is not limited to “a description of any criminal action, whether felony or misdemeanor, that resulted in a conviction, guilty plea, plea of nolo contendere or admission of sufficient facts, in any jurisdiction, Massachusetts or otherwise.”
- Packet 3: Management and Operations Profile. Which “is intended to provide the Commission with a snapshot of the applicants’ approach to operating the Marijuana Establishment.”
Sound excruciating? Perhaps, but don’t even bother applying if you’re afraid of compliance. We will comb through the innumerable rules of cannabis biz upkeep in the coming weeks, but at this point just consider a few of the state’s “General Operational Requirements for Marijuana Establishments”:
- Be prepared to have extensive “Written Operating Procedures [including] but not limited to … Security measures … Employee security policies, including personal safety and crime prevention techniques … A description of the Marijuana Establishment’s hours of operation and after-hours … Description of the various strains of marijuana to be cultivated, processed or sold … A staffing plan … Emergency procedures …
- You will also need “alcohol, smoke, and drug-free workplace policies … ”
- As well as “policies and procedures to prevent the diversion of marijuana to individuals younger than 21 years old.”
And the fun is just beginning…
As of Tuesday, 619 user accounts have been created in the CCC’s online application system, with 448 applications started. If you want to see the commission in action, whether to commend commissioners, state grievances, or get your questions answered, its next open meeting is Tuesday, April 17, at 10:30 am in the Mass Gaming Commission Public Meeting Room at 101 Federal St in Boston.
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