Back in January of 2019, we published a blog post detailing how a licensed retailer or licensed distributor in the state of California can best use Simplifya’s standard operating procedures (SOPs) to help in completing forms issued by California’s Bureau of Cannabis Control (BCC). Since then, we have updated our SOPs to even better aid licensees in filling out these forms.
Remember those Pesky BCC Forms?
To refresh your memory, back in December 2018, the BCC announced the release of the proposed cannabis regulations that went under review by the California Office of Administrative Law (OAL). The Bureau’s rulemaking action regarding these regulations, initially noticed on July 13, 2018, was submitted to OAL for review on December 3, 2018. OAL approved the rulemaking and filed with the Secretary of State on January 16, 2019, thus codifying these regulations and declaring them effective January 16, 2019
One major change to these regulations was the requirement that all applicants submit multiple forms to the BCC as a step toward obtaining a license. These forms ask the applicant to provide detailed descriptions of the organization’s operating procedures. Even if an applicant submitted full SOPs earlier in the process, these forms must be submitted and are meant to satisfy the entire requirement for operating procedures.
Still as Relevant as Ever
Although these forms were published almost TWO years ago (wow time really flies during a global pandemic), they are still required by the BCC and are still presenting challenges to both new applicants and licensees seeking to renew a license. The forms include numerous topics such as quality control, inventory, security, transportation, and delivery and ask around 15 questions per form. The questions require in-depth answers regarding the applicants’ current and future operational activities. Applicants have been left scratching their heads over how best to complete these forms and which regulations need to be addressed when filling them out. At Simplifya, we designed our SOPs to provide our clients with the information needed to best complete these forms.
Why Simplifya SOPs?
Simplifya’s SOPs integrate both regulatory requirements and operational best practices in order to create easy-to-follow documents that outline policies, procedures, and resources. The topics required by the BCC forms (quality control, inventory, security, delivery, and transportation) make up the bulk of our SOP content. Our SOPs also go beyond these topics to include waste management, customer relations, employee training, sanitation practices, advertising, recordkeeping, and reporting requirements. All Simplifya SOPs reference the most up-to-date version of the BCC’s regulations. In our most recent California Retailer and Distribution SOP template release, we condensed several SOPs into a single, more detailed SOP. In other circumstances, we deleted SOPs that were no longer relevant to the BCC’s regulatory requirements or current California cannabis operations as a whole. Furthermore, in each SOP template, we identify which SOPs help answer which SOP form, and provide links to the correlating BCC form.
Here’s a breakdown of our California Retailer and Distribution SOP templates by category:
Books and Records (2)
Patients/Customers (1)
Deliveries (7)
Employees (5)
Facilities (2)
Inventory Management (14)
Inventory Tracking (2)
Quality (1)
Reporting Requirements (2)
Retail (1)
Sanitation (6)
Security (17)
Testing (2)
Transportation (4)
Visitors (2)
Waste (4)
Packaging and Labeling (1)
Emergency (12)
An Illustration
An example of a Simplifya California SOP that has been created specifically to address the questions asked in the BCC forms is the Sharing Security Personnel With Other Licensees SOP. In the Security Procedures Form, the BCC asks that the applicant describe how they will “share security personnel with other licensees (when sharing services at the same location), if applicable.” Simplifya’s Sharing Security Personnel With Other Licensees SOP takes the BCC rules regarding sharing security personnel with other licensees, security personnel in general, and security requirements and standards, and converts them into easy-to-follow tasks. Using the information found in this SOP (tasks, citations, policies, resources, definitions), an applicant can efficiently and thoroughly respond to this question. This is just one of many examples demonstrating how Simplifya’s SOP content can effectively assist applicants and licensees in completing the BCC forms.
It’s worth pointing out that the aforementioned SOPs don’t do all of the work for every user. While they provide information the user will need to complete the form, a user still needs to take the information provided in the SOPs and edit it to fit their particular business operations. For example, In the Security Procedures Form, an applicant is asked to provide a list of employees who have access to the premises, including their roles and responsibilities. This question is very specific to an individual company’s organizational structure and therefore not possible for Simplifya to answer for an applicant. Although our SOPs can’t fill out those forms for you, they can make the task a lot easier! Check out our “cheat sheet” that tells you which Simplifya SOP to use for which BCC form and question.
Other Perks of Simplifya’s California SOPs
There are more new perks to using Simplifya’s California SOPs beyond BCC forms assistance. In our latest California SOP update, we also implemented clickable citations and defined terms in order to provide users with direct access to specific laws and regulations cited in an SOP without ever leaving the Simplifya app. Clickable citations allow users to access the exact regulatory text on which an SOP task was based, while defined terms allow users to hover over specific terms from the regulations in order to quickly see their regulatory definition. Furthermore, we have updated our California SOP content to reflect federal and state rules regarding COVID-19 prevention. We have also created comprehensive, Good Manufacturing Practices (GMP) compliant Manufacturing SOP templates that our clients can use when implementing GMP procedures and/or certifying that their facilities are GMP compliant. Although the BCC does not oversee cannabis manufacturers in California, GMP compliance is still very prevalent in the state’s regulated cannabis market, as GMP compliance is required by the California Department of Public Health.
We’re Here to Help
As anyone who has experience in this industry knows, the license application and renewal process is a tedious, yet critically important (if not THE most important) part of operating a licensed cannabis company. One definitely does not want to come up short when applying or renewing a license. Since a prominent component of the application process is adequately drafting detailed answers to the questions asked in BCC forms, applicants will need all the help they can get in order to efficiently and successfully fulfill this license requirement. And, using Simplifya’s updated standard operating procedures to draft these answers is a great way to do that.