$6,500 Fine: A Maryland Dispensary Not Following Regulations
The Maryland Medical Cannabis Commission (MMCC) released a consent order against GreenMart of Maryland dba Health For Life Baltimore related to the company not following required regulations properly. There were two seperate fines one of $5,000 and the other for $1,500.
Areas of concern in the investigation:
Product Tracking System– The Commission shall establish requirements for security and product handling procedures that a dispensary must meet to obtain a license under this section, including a requirement for a product–tracking system. In this case, there were no checks and balances between the Point of Sale (POS) and the state seed to sale tracking system (METRC), so that inventory was not being reconciled properly. They had a single employee that had responsibility for the systems.
Termination of Employees– per the regulations the MMCC must be notified within 1 business day of an agent’s departure and have the agent’s badge returned within 30 days. This should be covered in a Standard Operating Procedure, here is an example of one we have created a section of the SOP to cover this issue:
Recording Keeping- per 10.62.28.05 Equipment Sanitation, Accuracy, and Maintenace Log the regulations a shall maintain the sanitation of equipment that comes in contact with medical cannabis to prevent contamination in accordance with the approved standard operating procedure.
How are you keeping track of these types of items? If you do have logs what is your process for storing the records so that if an inspector arrived on site you could show them the records. In Maryland, records have to be kept between 2 and 5 years depending on the type of records for a Cannabis licensee. This is why we recommend that clients use a document management system to store these types of items. All of our clients use PowerDMS which is a compliance platform that has 20 years of experience in managing compliance-related content and much more in Law Enforcement, Healthcare, Financial Services, Fire Safety, Corrections, and Hemp and Cannabis, and many other markets.
Understanding regulations is one thing, making systems and building a compliance architecture to support the entire operation. As always learn from others to strengthen your program.
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To see the full consent order, click here