The Alaska Alcohol and Marijuana Control Office announced nineteen (19) new enforcement actions against growers, product manufacturers and retail stores. The largest number of enforcement actions were related to METRC and the failure to enter inventory into the tracking system. Other violations involved advertising (public consumption and failure to include risk warnings), odor compliance, failure to transport marijuana in accordance with the regulations and operating procedures, transporting edibles prior to testing, video surveillance failures and waste disposal lapses. Below are some lessons learned from this month’s enforcement actions.
Do not allow your family, including children, to enter the premises and restricted areas. Regulations prohibit visitors under the age of 21, and other visitors must be logged and escorted in restricted areas. Regulators can bring additional charges if the visitors log is not signed and the family members failed to wear ID badges.
Advertisements should always include risk statements. When in doubt as to whether a published item constitutes an advertisement - include risk and disclosure statements. Place yourself in their shoes of there regulator and determine whether your advertisement would cause the regulator to take a second look.
Learn how to use METRC and ensure that employees are trained. Develop operating procedures that require daily reconciliation and review of the inventory tracking system. Repeated violations may cause the regulators to question whether you are engaged in diversionary activities.
Review video cameras and surveillance recordings frequently. Regulators routinely bring enforcement actions for surveillance camera / recording violations. This is low hanging fruit. Your operating procedures should require a frequent review of coverage areas, functionality and ensuring that entire recording areas are visible and retrievable.
Training, training, training. Employees should be trained when hired and periodically thereafter. Do not entrust a new employee with entering items into METRC or transporting marijuana product until you are sure they understand your operating procedures. Provide employees with a copy of the operating procedures and obtain an attestation that they have read and understand.