Truth be told, I'm somewhat of an old school weed head. I'm in this industry to serve the plant, and the people it helps. I too often railed against weed going "corporate" and being taken over by "the man", and truth be told, sometimes I still do.
That said, I take compliance seriously, and so should you. Not because "the man" has a moral right to tell the industry what to do, but because people's investments (money, time, energy) and jobs are on the line, and frankly one missing document can threaten everyone's ability to provide for their families, patients and customers (and yes investors too).
Yes compliance is costly, labor intensive and time consuming. But it's less costly than a fine (in Colorado, Violations Affecting Public Safety carry fines up to $100,000, and can be the result of simply not having up- to-date Employee Training Materials/Records), or as brain damaging as dealing with regulators and/or the Attorney General that oversees license sanctions for months (such as when product is put on hold, while they figure it out).
Unfortunately, not all Operators have the same perspective. This is understandable to some degree as often as their perspectives are limited to their individual operations. They only know their grow, lab or store (or any combination of the three if vertically integrated), but any compliance consultant that has seen the internal workings of a couple dozen operations or more has some pretty eye brow raising war stories of relatively innocent mistakes costing an operation dearly in money, time and bandwidth. Most of these mistakes being gaps in required record keeping and document maintenance.
Compliance is more than just reconciling METRC. It's not enough to have SOPs and Employee Training Documents. These documents all have to be up-to-date and reflect reality. If a new nutrient/pesticide is integrated into the cultivation process, that SDS (Safety Data Sheet) not only needs to be accessible and on site but any PPE (Personal Protection Equipment) called out for on the SDS needs to be on site and accessible as well, and it might even require documented training for each person that might have to use it.
On top of that we are now expected to have defined conformities for our products and many of our processes and will soon be expected to have plans (CAPA or Corrective Action Preventative Action) on how to address product/process nonconformities when they arise. If operators don't have these in place, they will need to relatively soon (January 1, 2021), or otherwise they might be facing fines and license sanctions.
Now, it's not all Doom and Gloom. The silver lining to this is that cannabis and hemp operations are being compelled to consider traditional business standards, such as ISO (International Organization of Standards) and GMP (Good Manufacturing Practices), that facilitate not only compliance but consistency, quality replicability and scalability as well.
The word "corporation" is etymologically related to "corporeal" and "corpse" and essentially means the forming of a body. Being compliant, or having a QMS (Quality Management System), might sound "corporate" to some. But in reality, it's what said body needs to immunize itself from harm, and to ensure that metaphorical breaths and heartbeats that the corporate body takes don't lead to operational versions of strokes and/or heart attacks.
It's not hard to understand that as operations grow in size and complexity their potential exposure to the dangers of non-compliance and system inefficiencies, grows proportionately (if not exponentially) as well. Each new hire and each new task is a new potential failure point both in compliance and quality. Simply put, to quote the late Biggie Smalls "Mo Money, Mo Problems".
Therefore, Operators should not take their compliance, or quality output, for granted. 3rd Party audits from experienced consultants go far inn helping insulate the facility from pain. Document development (or updates) should not perpetually sit on a back burner, only to be gotten to when bandwidth allows. I've seen many a well-intended operator get burned by not being able to produce a document when requested, even though it might have legitimately been on their to-do list. In compliance and quality management there is no cigar for coming close, unfortunately.
So consider this the next time an Operator says “compliance, we’ve got it covered…”, “Quality Management System? That sounds complicated…”. Frankly, we’re no longer in the Wild West like we once were. We used to risk getting guns shoved in our face over a few pounds in a sketchy parking lot back in the day. Now, the modern-day version of “getting caught slipping” is not having your paperwork in order, your staff making a mistake and not managing your processes properly.
So don’t be that guy, or gal. Don’t take it for granted that everyone on your staff is doing the right thing, all the time. Don’t be dismissive about compliance. And don’t take opportunities to improve your processes for granted. This is a hard-enough business as it is. Life’s too short and the stakes are too high.
Ponder on this. You might just agree.