What a whirlwind this year has been for us all!
First, Missouri became the 21st state to make cannabis legal recreationally. Now, the State has not only rolled out the “Item Approval Process” but also requires the license holders to implement a QMS for their facilities. With so many questions and concerns in our market currently regarding regulation I wanted to take a few moments to touch on these topics.
That recreational vote brought so much excitement to our industry, however, it also brought a lot of lax with regard to regulation.
STL Cannabis Services visits roughly four dispensaries per week, and since rec, we have seen a serious increase in violations.
Somewhere the dollar signs became more important than continuing to fight the stigma around cannabis as a legitimate business.
One of the most common violations we see in the retail space is patient/caregiver cards not being scanned at the check-in station. Keep in mind the regulation requires all “department issued” cards to be scanned, not “government issued,” i.e., driver’s licenses. When conducting mock internal audits for clients, we always see the driver’s license being scanned but 100% of the audits revealed that patient cards were not being scanned.
Another common violation seen is that when accessories are displayed on the sales floor there must be signage present that states “These products are not regulated by the department.” I know to most license holders these are very minor violations, but DCR is similar to the FDA in this regard. If the DCR finds a few small things, it will just encourage them to start turning over bigger rocks to see what else isn’t being followed.
With regard to cultivation and manufacturing, the top violations we have seen here are; of course, the infamous visitor logs with blanks (usually the time-out column) and the Missouri Food Code is the other common violation. License holders need to keep in mind this is an additional 113 pages of regulation that must be followed when producing consumables. The biggest offenders with food safety have been PPE, product 6 inches off the ground and one inch from the wall, and sanitation practices.
Now let’s talk about this oh-so-wonderful “Item Creation Process,” as we heard at MoCann this quarter, this process has not been easy on any license holder and the State is still not consistent with feedback on rejection. STL Cannabis Services has seen so many different denial reasons we have begun creating a “Denial Library.”
A few pointers without giving away the whole library, be mindful that your THC diamond mockup shows the size of the diamond in the UOM of inches. When it comes to your Compliance Label submissions, make sure your “servings/doses” line item reads “Servings/Doses per package.” There are so many small nuances with this process so attention to detail is going to be key. Even verbiage such as “Keep Refrigerated After Opening” can be considered an additional logo/text on the packaging. Having a very organized resource for these submittals is going to be key to the success of item approvals for each and every license holder!
Last but certainly not least, the robust QMS requirements.
When I consult with clients regarding DCR Cannabis Regulation, I like to remind them that meeting DCR’s regulations is just the first layer of law requirements.
If we as license holders are missing very minor citations as mentioned above, what makes DCR confident that the facility is now following even more stringent standards like those of a QMS?
We know the expectation of DCR was for every licensed facility to have a QMS implemented by no later than 12/1/23.
I am not sure how many of you have dove into these standards, but they are no joke!
STL Cannabis has a long history in the Food Safety space and let me tell you, QMS even tops those standards when it comes to the detail required in each expectation. Things such as, the lubrication utilized for preventative maintenance on your trim machine, now requires a food-safe certification.
STL Cannabis Services chose to receive all their consultants’ training and education on QMS from CSQ, Cannabis Safety and Quality. CSQ is also one of the companies recognized in DCR’s final regulation published, as a reputable resource for obtaining certification of this implementation requirement. Their certification standards were built around ISO/IEC 17067 and their mission is to not only provide the industry with reliable standards but also to help support license holders with learning the standards and expectations of a true Quality Management System. DCR is cracking down, and not having a good handle on this expectation could leave you months behind and create a potential reason for DCR to suspend a license.
We all are in agreement that there is a fine line we are hovering over with regard to operating compliantly and being profitable. As a compliance industry expert, I encourage you all to consider my closing statement:
How profitable can you be with a suspended or revoked license due to Initial Notices of Violation? We embraced the department’s lax in the medical market, however, times have changed and the State is ramping up its investigative unit as we speak. I highly encourage you to have a resource who can make compliance a part of your brand’s everyday operations as opposed to a separate entity within the organization.
Suzanne Morrison is a Committee Chair at JAINE, a cannabis industry training expert, and the founder of STL Cannabis Services. With over 20 years experience in the hospitality industry, and a track record of success and innovative training, Morrison brings a unique perspective and skillset to the cannabis industry. Morrison’s work is a result of her passion and commitment to educate on the medicinal benefits of cannabis and destigmatizing the plant.
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