California’s Bureau of Cannabis Control (BCC) recently announced the release of the proposed cannabis regulations that are right now 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. The proposed regulations have not yet been approved and are not currently in effect. While the regulations are under review, the readopted emergency regulations remain in effect. The OAL has 30 working days — until January 16, 2019 — to review the regulations. Not to mention that, in October, the BCC made changes to the proposed rules that were issued in July.
One major change to the readopted emergency regulations is the requirement that all applicants submit multiple forms to the BCC. These forms ask the applicant to provide detailed descriptions of the organization’s operating procedures. That doesn’t sound too tedious until you get ahold of the forms and realize how in-depth they are. California cannabis companies are left scratching their heads over how best to complete these forms and which regulations need to be addressed when filling out them out.
Using SOPs to solve for BCC forms
The solution for these BCC forms is standard operating procedures (SOPs). We drafted and edited numerous SOPs that provide thorough responses to the questions asked in the BCC’s forms. We also changed 68 SOP templates as a direct result of the updated rules. Key additions to the templates include:
- Sharing security systems;
- Facility pest control;
- Tracking and monitoring delivery vehicles;
- Auditing delivery activities;
- Handling returns;
- Employee inventory training;
- Transporting cannabis goods by foot;
- Environmental controls;
- Inventory storage;
- Facility maintenance and cleaning; and
- Updating employee credentials.
All Simplifya SOPs reference the final version of BCC’s regulations. Our California retail and distribution SOPs have also been given a more general makeover. This “makeover” includes:
- increased detail to policies and procedures,
- more in-depth explanations of applicable definitions and resources needed for each SOP
- additional procedures that are specific to California’s unique market, and
- improvements in readability.
Here’s a breakdown of our California Retailer and Distribution SOP templates by category:
- Books and Records (10)
- Customers (1)
- Deliveries (13)
- Employees (17)
- Facilities (2)
- Inventory Management (24)
- Inventory Tracking (11)
- Quality (8)
- Reporting Requirements (16)
- Retail (4)
- Sanitation (20)
- Security (76)
- Testing (2)
- Transportation (6)
- Visitors (4)
- Waste (8)
- Packaging and Labeling (4)
An example of a Simplifya California SOP that has been created specifically to address the questions asked in the BCC forms is the Delivery Employee Training SOP. In the Delivery Procedures Form, the BCC asks that the applicant describe “the training provided to delivery employees.” Simplifya’s Delivery Employee Training SOP takes the BCC rules regarding delivery employees, cannabis goods carried during delivery, and the delivery route as well as general employee training standards and converts them into easy-to-follow tasks. Statewide delivery has been one of the most contested subjects within the proposed rules, so I would imagine the BCC will be very stringent when considering applicants wanting to participate in delivery. Therefore, comprehensive delivery SOPs are key.
As California works out the kinks of its legal cannabis market, it’s a good time for companies seeking retailer and distributor licenses to get their ducks in a row. One step in doing this is drafting detailed answers to the questions asked in BCC forms. Using Simplifya’s updated standard operating procedures to draft these answers is a great way to efficiently fulfill the license application requirement.