Creating Gatekeepers of Compliance
With it being a New Year, there is no better time to tighten up on compliance and to make sure your house is in order. January is the perfect time to start fresh, with a clean slate on compliance. We’re anticipating coming down the pipeline in 2024 more enforcement actions in multiple States, as the newer markets begin to hit their 2 to 3 years anniversary in regulated cannabis. In the 3rd quarter of 2023 violations began to increase due to the educational phase being over in newer regulated States.
How can a Cannabis Operation benefit from this fresh start? One big benefit is the impact of having a healthy culture of compliance on employees, and how it inherently is creating them to become gatekeepers of compliance.
In some States, for example like Colorado, a new set of rules went into effect on January 8th, that will impact cannabis operations. Having a gauge through an assessment, as a way to measure where you’re at is important. Whether you’re utilizing a third-party auditor or performing your own internal audits of the day-to-day operations. We find most companies wait until there is an issue or a threat of a violation before wanting to perform the due diligence of having a third-party audit. Why not be proactive throughout 2024, and ensure your operations are buttoned up and prepared for annual inspections. Think of a third-party audit like an oil change you get every 5000 miles or any other mileage maintenance you get for your car. It’s about taking the steps to keep the business running smoothly and efficiently.
Employees are the gatekeepers because they are the day-to-day implementers and administrators of a Cannabis operation, especially in the more mature markets, or larger scale companies. If you take care of your employees, you actually are taking care of your customers at the same time.
Here are some important areas to review:
Records: File records for 2023 and start new 2024 files/and or binders for anything that is non-static. For example, transportation manifests, employee training logs, vendor invoices, testing records, employee lists, visitor logs, waste logs, trim, and manicure logs. All these can be filled and kept separate from 2024 records. Be sure to still follow all recordkeeping retention requirements in your State.
Checklists: Internal checklists and reviews are a must in managing a business that is under the regulatory microscope. Provide the proper compliance checklists for Staff to ensure there is compliance efficiency. Third-party audits provide an outside eye view of the operation and can be very beneficial and a value add to any compliance plan.
Employee Quarterly Training: Provide employees with ample training covering their job role and overall compliance for each facility type. The industry is always changing and adapting to rules and regulations, employees should be well equipped to handle the changes. Additionally ensure that all State mandated training like responsible vendor, food safety, security & safety, and OSHA is tracked properly.
Safety Program: It’s vital to promote a safe work environment for employees. Creating a safety program and implementing standards is the key to keeping employees safe. Standards like OSHA, QMS, and Worker Safety are important tools to include in a Cannabis safety program.
Compliance Program: What is your plan for compliance? The beginning of the year is a good time to either update your current compliance program or create one for your cannabis operation. A compliance program is basically creating a system to organize all things compliance, ensuring you have specific cannabis standards and requirements included, and how that system gets implemented. Getting your plan for compliance organized into little boxes and knowing what job each box does.
SOP Reviews: Document reviews are recommended on a quarterly basis to ensure that the cannabis operation’s SOPS and employee training attestations are up to date. SOPs should be updated anytime a material change has taken place in the day-to-day operations. This also includes new equipment, new production recipes, or any plant application changes are just a few examples of a material change.
All these areas not only contribute to creating a culture of compliance in a Cannabis operation, but it also naturally prepares employees in their roles of being the gatekeepers of compliance. No matter what, employees need to implement their job functions in a compliant manner. The overall compliance health is important and feeding it lowers the compliance risks.
ICS Consulting specializes in Compliance based services, such as Third-Party State Regulatory Audits, State and Local License Application Support, Technical Writing, Standard Operating Procedures Development, Worker Safety, QMS, OSHA Compliance, Metrc Seed-to-Sale Support, Compliance Operations Training, Employee Retention Solutions, and Employee Onboarding. For more information on how ICS Consulting Service can help your Cannabis Business, book a free 30-minute consult and we'll help you map out your next steps to be successful in the Regulated Cannabis Industry