OLCC Executive Director Issues Cannabis Industry Winter Holiday Checklist

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Oregon’s legal recreational marijuana system recently passed a one year milestone. It was Oct. 1, 2016 when the first OLCC marijuana license retailers opened for business. A year later, there are more than 500 licensed retailers among the 1,600 licensed marijuana businesses operating in Oregon. Looking forward, there is still more work to do. The OLCC team is working to get through the backlog of applications and to finish marijuana rules that reflect the work of the past legislative session. The legislature recently authorized the OLCC to add more staff to help with the workload and the team is in the hiring process right now, according to an email letter from OLCC Executive Director Steve Marks.
Now the expectations the OLCC has for themselves and the industry reflect the year of experience. During the fall 2016 outdoor harvest season, producers were challenged in learning how to account for product in the Cannabis Tracking System (CTS). The CTS is a vital point of accountability in Oregon’s regulated market. This year, OLCC expects its licensees to be proficient in understanding the OLCC rules, obligations under the rules and operational requirements of CTS.
Below is a list of violations the OLCC is seeing on a regular basis. It’s important for licensees to identify if they’re at risk for any of these compliance issues.
Outdoor Producers & Metrc Compliance
The OLCC reminds outdoor producers that as they get near the end of the 45-day harvest packaging window that they repackage their marijuana flower and record the weight in CTS so the OLCC won’t have to take compliance action. The OLCC will be analyzing CTS data to capture those harvests that aren’t repackaged and recorded within 45 days, and licensees can expect the OLCC to be issuing violations.
Video Security Compliance
The OLCC compliance team will soon begin spot compliance checks on licensees. Checking that the licensees are complying with security requirements will be a key focus, especially ensuring that there’s backup video from video surveillance systems. Failure to produce backup video is a Category I violation under which a licensee could conceivably lose their license and investment by not producing the backup video for OLCC; this is regardless of whether or not any other violation have been proven. Rather than finding out how the system works when an inspector shows up, licensees should establish best practices and have procedures in place to ensure cameras are providing coverage where they’re supposed to, and that the video system is working properly.
Retailers and Minors on Premises Compliance
With the holiday season upon us, retailers will be preparing for shoppers looking for gifts. Another preparation step is to re-double efforts to make sure no one under 21 (or under 18 with a medical card) is entering a licensed retail premises. Failure to identify the age of a minor is a serious violation. In December, the OLCC will begin Minor Decoy Operations at licensed marijuana retailers around the state. Now would be a good time to make sure there are good age verification procedures in place. Education on minor decoy detection is available from the OLCC, including ID checking classes. Also, please remember that a licensee’s own minor children are not permitted to be on the licensed premises for any reason.
Retailers and Daily Purchase Limits
The OLCC will also be checking to make sure that retailers aren’t selling to individual customers more than the allowable daily limit under OLCC Rules 845-025-2800. Licensees can also download this poster listing the daily limits from the OLCC website.
Marijuana Worker Permit Compliance
In August 2017, the OLCC allowed growers to hire employees who had an application for a worker permit in process with the OLCC. That exception comes to an end on Dec. 15, 2017. After that date, all employees must have a worker permit if they are handling marijuana.
• The good news is that the OLCC has approved a workforce of 19,000 people who have been issued their worker permits.
• The OLCC has also approved permits for about 9,000 applicants, but those applicants have not been issued their work permits because they have not paid the permit fee of $100. If these workers pay for their permits, the regulated industry will have an approved workforce of nearly 30,000 people.
• An additional 9,000 applicants are under review and have not been issued their permits. 
• After Dec. 15, 2017, approved, but not paid, applicants and applicants awaiting approval can no longer work in the licensed premises of an OLCC licensee until they have a Marijuana Worker Permit. Now is the time to ensure the workforce will be compliant to avoid violations after Dec. 15.
The OLCC brings these reminders to the attention of the licensees because they’re important to the integrity of properly operating Oregon’s regulated marijuana industry. With each passing day, the OLCC licensees are seeing and hearing about increased OLCC enforcement activity. During recent actions, the OLCC immediately suspended two licenses, are now routinely issuing and settling violations, and now have several priority investigations under way and are routinely issuing and settling violations. Compliance is critically important in building this industry so licensees need to take action to prepare for the increasing likelihood that they may be inspected in the field and that their CTS data will be scrutinized.
The recent out-of-state arrest of one of the OLCC licensees was certainly a setback for the integrity of the Oregon marketplace the state has worked to create. The OLCC will do all it can to ensure the integrity of the Oregon marketplace and its competitive fairness for licensees who follow the rules.
As this year closes, the OLCC remains committed to the success of its licensees in Oregon’s system and working with them and state leaders to improve it.
The OLCC has put together this check list to help licensees make sure they’re in good standing this holiday season:
45 Day Harvest Packaging Reminder:  
Outdoor producers who’ve completed their 2017 fall harvest need to make sure they’ve segregated their harvest lots of dried flower to ensure compliance with OLCC Division 25 Rules 845-025-2080.  Each harvest lot needs to be packaged separately with a CTS (Metrc) User Identification Tag linked to each plant and recorded in CTS within 45 days of harvest.
30 Day Video Backup Reminder:
All OLCC marijuana licensees are required to have off site (away from the licensed premises) back up recordings from their video surveillance system for a minimum of 30 days. Licensees can do this by uploading to the cloud or to a physical location away from the licensed premises, per OLCC Division 25 Rules 845-025-1450.
No Minors on the Licensed Premises Reminder: 
No one under the age of 21 is allowed on a licensed premises. That means if someone’s under 21(or under 18 if they have a medical card) they can’t be in a licensed retail operation, per OLCC Division 25 Rules 845-025-1230.
Daily Purchase Limit Reminder:  
There’s a daily limit to the amount of recreational marijuana that a retailer can sell to an individual customer, per  OLCC Rules 845-025-2800.
Avoid Marijuana Worker Permit violation Reminder:  
After Dec. 15, 2017, all workers are required to have an issued marijuana Worker permits or licensees will be subject to violations of the rules. Refer to Compliance Education Bulletin CE2017-11. The exception allowing OLCC applicants for worker permits to work on a license facility expires Dec. 15, 2017.

Source: Cannabis Business Times

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