Lesson 1, Topic 1
In Progress

Other Cannabis Businesses

Cannabis Registrants

Let’s talk about what “Registrant” means in the context of our industry. When we refer to a “Registrant,” we’re talking about a business that’s officially registered by the Administration to operate within the cannabis industry.

Now, the term “Registrant” covers a few different types of businesses. Here’s a quick rundown:

  1. Independent Testing Laboratory – These are the folks who ensure everything meets quality and safety standards. We’ll dive deeper into what they do on the next page.
  2. Transporter Business – They’re responsible for moving cannabis products safely from point A to point B. We’ll go into more detail about their role later in this section.
  3. Security Guard Company – As you might guess, they handle the security aspects.
  4. Waste Disposal Company – They deal with the disposal of cannabis waste, ensuring compliance with environmental and safety standards.
  5. Cannabis Nursery – These are the businesses that cultivate the beginnings of what will eventually be part of your product line.
  6. Other Cannabis Businesses – This includes any other type of business authorized by the Administration to handle cannabis plants or products directly.

All these businesses must register with the Administration to provide services to cannabis licensees. We’ll review the registration process in detail later in this section.

Independent Testing Laboratory

Let’s unpack what an “Independent Testing Laboratory” really means within our industry framework.

What is an Independent Testing Laboratory?

An independent testing laboratory is a specialized facility or entity that:

  1. Registration: Must be registered with the Administration to conduct tests on cannabis and cannabis products.
  2. Independence: Should be independent of any other entities that are licensed under specific sections of the Maryland code to grow, process, or dispense cannabis.
  3. Accreditation: Needs to be accredited to the International Organization for Standardization (ISO) standard 17025 by an accreditation body that:
    • Operates according to ISO standard ISO/IEC 17011.
    • Is a signatory to the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA).

Registration Process

Here’s how an independent testing laboratory gets registered:

  • Initial Steps: The lab submits a completed registration form and pays the specified registration fee.
  • Documentation: They need to provide a copy of their certificate of accreditation and the scope of accreditation.
  • Employee Details: The lab must submit the name, address, date of birth, and Social Security or Taxpayer ID number for each employee, along with a completed application form for each.

If a lab hasn’t yet received their certificate of accreditation, they can still obtain provisional registration by:

  • Submitting a contract and proposed accreditation scope with the accrediting body.
  • Showing proof of accreditation from another jurisdiction.
  • Providing all other required details as listed in the guidelines.

Once Accredited

After receiving their certificate of accreditation, a provisionally registered lab must apply for registration, which:

  • Lasts no longer than the original provisional term.
  • Does not require an additional registration fee for that period.

Standards of Care

The lab must:

  • Adhere to the methodologies and parameters of their accreditation scope.
  • Establish and maintain standard operating procedures and method validations.
  • Register any new employees with the Administration before they start.
  • Handle termination of employees by securing all lab access and notifying the Administration within one business day.

Security and Record Keeping

  • Maintain 24/7 high-quality video surveillance.
  • Store video recordings for at least 90 days and provide access to these recordings to the Administration upon request within 48 hours.
  • Keep a detailed log of all visitors for two years.

Violations

Failing to provide video recordings to the Administration within 48 hours is a violation, and each day delayed constitutes a separate offense.

Renewal Process

Every two years, the lab must renew its registration by:

  • Submitting the registration form and fee.
  • Providing the latest assessment from the accreditation body and proficiency testing results.

Other Responsibilities

  • Use statistically valid methods for sample collection.
  • Ensure all testing and analysis follow the Administration’s guidelines.
  • Issue detailed certificates of analysis for each batch tested.
  • Properly dispose of all green waste according to standard procedures.

Transportation and Beyond

The lab is also responsible for the secure transportation of cannabis samples and must adhere to specific vehicle standards. We’ll review these standards on the next page.

State Cannabis Testing Laboratory

The Administration operates a State Cannabis Testing Laboratory to conduct and oversee proficiency testing, develop testing methodologies, and ensure compliance among registered labs. They may also initiate pilot programs to adapt or improve public health and safety standards.

Transport Operations

Let’s dive into the specifics of how cannabis and cannabis products are transported under these regulations, making sure we cover all the bases from licensees to security measures.

Basics of Cannabis Transportation

Let’s review the transportation of cannabis by licensed growers, processors, dispensaries, or registered transport businesses. The journey includes moving between licensee premises, independent testing labs, the State Cannabis Testing Laboratory, and disposal sites for green waste.

Responsibilities of Licensees and Registrants

  1. Agent Identification: Every agent must carry a valid driver’s license and proof of their registration with the Administration.
  2. Dress Code: Agents should avoid wearing anything that might reveal their connection to cannabis during transit.
  3. Vehicle Requirements:
    • Operated by a registered agent.
    • Fitted with locked, secure storage containers that aren’t accessible while on the move.
    • Containers must be concealed and the vehicle should not display signs indicating it’s carrying cannabis.

Specifics for Vehicles

  • Vehicles need current registration and must be insured.
  • For green waste transporters, some rules like vehicle insurance and secure containers don’t apply.

Electronic Manifest

An electronic manifest tracks every cannabis shipment’s journey:

  • It includes detailed information like the shipper’s details, shipment ID, and specifics about each package.
  • Entries are required at each stage of the shipment’s handling, documenting everything from preparation to delivery.

Protocol for Delivering and Receiving Shipments

  • Upon delivery, the shipping agent alerts the receiving agent to maintain the chain of custody.
  • The receiving agent logs the shipment details into the seed-to-sale system, checks the shipment against the manifest, and ensures everything is in order before accepting it into inventory.
  • Both the delivery and reception of the shipment must be logged in the electronic manifest, which is then kept on record for two years.

Handling Discrepancies

  • Any differences between the manifest and the actual shipment must be reported and, if possible, rectified immediately.
  • Serious discrepancies require formal reporting to the Administration and an investigative process by the shipping licensee.

Additional Rules

  • There are special guidelines for transporting and receiving edible cannabis products.
  • Registered transport businesses are explicitly prohibited from delivering cannabis directly to patients, caregivers, or adult-use consumers.

Registration

Now that we’ve discussed various cannabis businesses and registrants, let’s delve into how these businesses actually get registered to operate in Maryland, focusing on those providing transportation, disposal, or security services to cannabis licensees.

Registration Requirements

Before any cannabis business can start operations, they need to be officially registered with the Administration. Here’s what they need to do to register:

  1. Registration Form: Submit a completed registration form.
  2. Agent Information: Provide the name, address, date of birth, and Social Security number for each agent employed by the business.
  3. Security Plan: Include a security plan that covers emergency protocols.
  4. Business Documentation: Submit copies of the articles of incorporation and authorization to do business in Maryland.
  5. Registration Fee: Pay the fee as specified.
  6. Vehicle Inspection: Present any secure transport vehicles for inspection by the Administration.
  7. Background Checks: Provide proof that fingerprints of all cannabis agents have been submitted to CJIS and the FBI.

Approval Criteria

The Administration will approve a cannabis registration if the business:

  • Submits all required and accurate documents.
  • Is legally authorized to operate in Maryland.
  • Pays the necessary registration fee.

Possible Denial of Registration

The Administration may deny registration for any reason deemed sufficient, often related to ensuring compliance and integrity within the industry.

Collection of Information

During registration, the Administration might collect demographic information from applicants to better understand the landscape of cannabis businesses in the state.

Grounds for Denial or Revocation

A registration can be denied or revoked if any agent or individual with an ownership interest in the business has a conviction or has pleaded nolo contendere to a crime involving moral turpitude, regardless of any ongoing appeals.

Registration Validity and Renewal

  • The registration is valid for two years.
  • To renew, businesses must resubmit the registration form and proof of up-to-date fingerprint submissions for all agents.

Working with Licensed Businesses

Licensees are only allowed to contract services with cannabis businesses that are registered by the Administration, ensuring all parties adhere to the same stringent standards.