A few months ago, our team stumbled upon a little known section of the MED website: Compliance Tips. The MED website can be a bit difficult to navigate, but if you visit the “Licensees” page, you’ll notice three Compliance Tips about two thirds of the way down the page. After chatting with some of our users, we realized most folks are not familiar with these hidden gems, so we wanted to bring them to your attention. After all, if these are important enough for the MED to put up on their website, it’s fair to assume these are items your investigator might be looking for!
This tip specifically addresses how exactly a business should go about determining what constitutes the “front” of packaging as it pertains to the placement of the Universal Symbol. This is especially applicable to operators who package products in cylindrical vessels, such as child resistant plastic vials. What exactly constitutes the “front”? The MED explains:
“The inclusion of the word ‘front’ in the packaging and labeling rules is intended to affirm that the symbol should be clearly visible and conspicuous, in order to place the consumer or other party on notice of the contents of the product. It should be construed according to the plain meaning of the word, by a reasonable person.”
Keep this tip in mind when designing your packaging!
As many of our readers might already know, all licensees are required to maintain the current employee list in METRC, even for those employees that are not METRC users. However, our team was surprised by the following requirement:
“All employees who work at a licensed premises, including those working on a short term basis (e.g. trim crew), must be added to the Metrc employee list for that license.”
It seems somewhat excessive to add a temporary trimmer to your METRC list, especially if that trimmer might only be around for a single shift, but the MED has spoken so be sure to keep your list current! Be sure to track these temporary workers in your visitor log as well.
This tip clarifies that labs are required to report data for “R&D” tests:
“If the Testing Facility is testing for Research & Development purposes or for a state mandated test, the results of the tests must be accurately recorded in Metrc.”
In other words, if you send a sample off to the lab, expect to see that data in METRC regardless of the purpose of the test!
As always, our team vigilantly monitors Compliance Tips, Industry Bulletins, and Statements of Position and we urge our readers to do the same. We’ll continue to write about developments on these fronts. Please reach out with any questions, and perhaps your question will show up here on our marijuana compliance blog!
Yours in Cannabis Compliance,