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Lesson 1, Topic 1
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Requirements for Employees

Registration

If you’re running a cannabis business and looking to register your agents, it’s essential to understand the registration process with the Administration. Here’s a comprehensive guide to help you navigate through the requirements:

  1. Registration Basics:
    • Agents must be registered with the Administration before they can start working or volunteering at your business.
    • Each registration is valid for two years.
  2. Requirements to Register:
    • Agents must be at least 21 years old.
    • They must undergo a State and national criminal history records check, if available.
  3. Who Can’t Register:
    • Individuals who do not meet the age and background check requirements cannot be registered.
    • The Administration can disqualify anyone convicted of, or who has pleaded no contest to, a crime involving moral turpitude, regardless of any ongoing appeals or proceedings.
  4. Cannabis Offenses:
    • Any cannabis-related offenses prior to July 1, 2023, will not prevent an individual from registering.
  5. Training Requirements:
    • All registered agents must complete an annual Responsible Vendor Training program. This is crucial to ensure compliance and safety in your operations.
  6. Grandfathering Clause:
    • Cannabis agent registrations issued by the Natalie M. LaPrade Medical Cannabis Commission before July 1, 2023, remain valid under the new regulations.
  7. Applying to Register an Agent:
    • You’ll need to submit the agent’s name, address, date of birth, and Social Security Number or Individual Tax Identification Number.
    • Documentation of the agent’s fingerprints must be submitted to the Criminal Justice Information System’s Central Repository along with a request for a criminal history record.
  8. Reporting Requirements:
    • If a registered agent is convicted of, or pleads no contest to, a crime involving moral turpitude, this must be reported to the Administration within 14 days.
  9. Disqualification and Revocation:
    • The Administration can disqualify or revoke an agent’s registration if they are convicted of, or plead no contest to, a crime involving moral turpitude, with or without pending appeals.
  10. Temporary Registrations:
    • In certain cases, the Administration may issue a temporary cannabis agent registration for up to 60 days if alternative methods for criminal records checks are used.

Registered Agent Identification Cards

Let’s go over how to manage Registered Agent Identification Cards in your cannabis business to ensure compliance and security:

  1. Issuance of ID Cards:
    • The Administration will issue an ID card to each of your registered agents. This card will feature a recent photograph taken no more than six months prior to the application.
  2. Wearing the ID Card:
    • t’s crucial for your agents to wear their ID cards visibly at all times while on any licensed or registered premises. This helps in maintaining security and compliance.
  3. Renewal of ID Cards:
    • ID cards need to be renewed every two years. Keep track of the expiration dates to ensure all your agents’ cards are current.
  4. If an ID Card is Lost or Stolen:
    • Should an ID card be lost, destroyed, or stolen, action must be taken within 24 hours. Agents must:
      • Report the incident to the Administration immediately.
      • Apply for a replacement card.
      • Pay any applicable replacement fee.
  5. Ownership of the ID Card:
    • Remember that the ID cards are property of the Administration. If an agent’s registration is revoked or expires, you may be required to return the card or the Administration might seize it.
  6. Temporary Proof of Registration:
    • If an ID card is lost and the loss has been reported, ensure you keep a copy of the notification. This will act as temporary proof of registration until a new card is issued.

Termination

Let’s go through the steps to take when a registered agent’s employment is terminated, ensuring everything is handled smoothly and securely:

  1. Immediate Post-Termination Actions (Within 30 Days):
    • Custody of ID Card: Once an agent’s employment ends, the licensee need to collect their identification card.
    • Retrieval of Keys/Entry Devices: Make sure to collect any keys or other devices that grant access to the premises.
    • Access Revocation: It’s crucial to ensure the terminated agent can no longer access the licensed premises.
  2. Notification Requirements (Within 1 Business Day):
    • Notify the Administration:
      • Inform the Administration of the agent’s termination and the circumstances surrounding it.
      • Confirm whether the terminated agent has returned their ID card.
    • Initiate ID Card Delivery: Start the process of sending the terminated agent’s ID card back to the Administration.
  3. Administration’s Response:
    • Upon notification, the Administration will revoke the registration of the agent who is no longer employed with the licensee.
  4. Handling Unreturned ID Cards:
    • If the agent does not return their ID card within 30 days of termination, the Administration will notify the local law enforcement agency.

Training

Let’s dive into what training entails for registered agents at a licensed cannabis operation:

  1. Comprehensive Training for Agents:
    • Legal and Regulatory Knowledge: Agents need to be educated on federal and state cannabis laws and regulations, along with any other laws relevant to their roles.
    • Standard Operating Procedures: Training must cover the specific operational procedures of the facility. Bright Buds Training can integrate your Standard Operating Procedures into our platform, creating tailored online courses for your employees. For more information on how to streamline your training process, please contact Molly Dupont at molly@brightbudstraining.com.
    • Drug-Free Workplace Policy: Agents must learn about state policies on maintaining a drug and alcohol-free workplace as outlined in the Code of Maryland Regulations.
    • Diversion Prevention: Techniques on how to detect and prevent the diversion of cannabis. At Bright Buds Training, we offer a comprehensive one-hour course on Diversion Prevention. Enhance your employee training program by incorporating this course alongside this RVT training. For more details or to add this course to your curriculum, please contact Molly Dupont at molly@brightbudstraining.com
    • Security Measures: Comprehensive security training to safeguard the premises. 
    • Safety Protocols: Training includes how to respond to various emergencies such as medical situations, fires, chemical spills, and criminal threats like armed robbery or burglary. Bright Buds Training offers an extensive selection of over 100 safety training courses to ensure your employees meet all training requirements. For further details or to enroll your team, please contact Molly Dupont at molly@brightbudstraining.com.
  2. Documentation and Compliance:
    • Record-Keeping: The licensee must keep all training materials and attendance records, which should be available for inspection by the Administration. Bright Buds Training LMS offers advanced reporting and tracking features that can assist you in managing these records efficiently across all types of training. To explore how our platform can streamline your compliance process, please contact Molly Dupont at molly@brightbudstraining.com.
  3. Responsible Vendor Training:
    • Program Requirements: All registered agents are required to complete a Responsible Vendor Training program certified by the Maryland Cannabis Administration. By participating in this course, you are fulfilling this requirement.