From non-functional cameras to expired products and prohibited advertising
Even its biggest cheerleaders would say the Massachusetts Cannabis Control Commission is navigating a period of significant transition and operational strain. From shifts in leadership, to a severe hiring freeze due to budget shortfalls, the CCC has several senior and frontline positions unfilled, which has directly impacted the agency’s ability to provide timely oversight and support to licensees.
At the same time, a lot of the regulations it is tasked with enforcing are complete nonsense. Bullshit, to put in mildly. To combat these challenges and streamline the oversight process, the commission has established a Red Tape Removal Committee. The group is tasked with identifying and sunsetting outdated regulations that no longer serve a clear purpose for public health or safety.
In that vein, leadership has expressed a desire to leap over regulatory hurdles, allowing staff to focus on critical safety concerns rather than administrative minutiae. As the interim chief of investigations and enforcement noted at a recent meeting, the goal is for the agency and its licensees to be able to focus on the “really important issues” of maintaining a safe and viable market.
“This is one of the reasons that we created this position,” he said, “because there is some confusion. … I want to make sure we are clear in our direction, but also what are the corrections we can make so our staff can focus on the really important issues.”
In the meantime, they’re analyzing what the CCC has focused on up to this point. Here’s a breakdown from their notes …
Common Violations: All License Types
These issues are universal and affect every category of licensure, from retail to cultivation.
- Responsible Vendor Training: Failure to conduct required annual and ongoing training in a timely manner, or failing to have those records available for inspection.
- Metrc Training: Lack of timely ongoing training for the seed-to-sale tracking system or missing documentation of such training.
- General Record Keeping: Records are often non-compliant or missing entirely. This frequently includes background checks/CORIs, inventory logs, and waste records.
- Limited Access Areas (LAA): Failure to keep these areas properly secured or locked. Common issues include not limiting access to necessary personnel and improper signage.
Operational Violations
Applicable to all licenses except Courier and Third-Party Transporters.
- Video Surveillance: Cameras are often non-functional, have obscured views, or fail to sufficiently capture areas where marijuana is handled and stored.
- Inventory Tagging: Failure to physically attach Metrc tags to all marijuana plants, clones, and packages.
- Waste Documentation: While updated regulations now only require one agent to witness the process, many facilities still struggle with properly recording and processing waste.
Transportation & Logistics Violations
Applicable to all licenses except Research and Standards Labs.
- Emergency Stop Logs: A frequent lack of adherence to logging requirements when a transport vehicle makes an emergency stop.
- Manifest Accuracy: Transport manifests are often not maintained or kept current during the delivery process.
- Vehicle Security: Transportation vehicles are sometimes found without operational alarm systems.
Inventory & Product Management Violations
Applicable to Cultivators, Manufacturers, Retailers, Cooperatives, Microbusinesses, and Delivery Operators.
- Real-Time Inventory Discrepancies: Discrepancies between physical inventory and the virtual Metrc system, including reported vs. actual locations or quantities.
- Expired Products: Failure to properly separate products with test results older than one year (expired) in either virtual or physical inventory.
- Prohibited Advertising: Violations related to adult-use advertising regulations (specifically for adult-use only licenses).
- Waste Processing: Failure to properly grind and mix waste to ensure it is rendered unusable for its original purpose.
