Final month, together with streamlined licensing, the Oregon Liquor Management Fee (OLCC) introduced a major (and welcome) change to its compliance perform by instituting a brand new Verification of Compliance program (VOC) that may give attention to training reasonably than penalties for sure sorts of marijuana rule violations. The VOC launched in early October and arose from conferences with the trade this previous summer time. The OLCC is within the means of formal everlasting rulemaking for the VOC program, which I count on will take a number of months.
The VOC program permits OLCC inspectors to concern VOC paperwork (the “ticket”) to licensees for a choose variety of violations. The place the licensee is ready to repair the issue throughout the required timeframe, the OLCC is not going to start additional proceedings towards the licensee. That is nice information! However beware– the OLCC reserves discretion to pursue “ticket” violations if a licensee reveals a basic disregard for guidelines and legal guidelines. So licensees mustn’t deal with cavalierly rule violations which can qualify for a “fix-it ticket.”
What sorts rule violations might qualify for the VOC? The OLCC recognized 4 standards related to this willpower.
- The violation have to be probably fixable, i.e. the licensee has the aptitude of fixing or correcting the issue. (Not an instance: promoting marijuana to a minor.)
- The corrective motion have to be measurable by the OLCC. This implies licensees and regulatory specialists should be capable to level to tangible/concrete motion to show compliance. (Instance: fixing digital camera protection).
- The violations eligible for VOC ought to be teachable, learnable, and executable. (Instance: points with METRC). This narrows the record of eligible violations significantly and displays that the VOC is designed to deal with comparatively widespread violations with a low likelihood of recurrence.
- The VOC ought to present a optimistic influence for each licensees by educating licensees and for OLCC workers by decreasing the workload quantity of enforcement instances presently routed by the executive listening to division.
Has the OLCC recognized violations that qualify for VOC? Sure, the OLCC’s compliance training bulletin identifies 5 violations that meet the above standards. These are video recording, Seed-to-Sale monitoring with METRC, stock reconciliation with METRC, safety necessities, and UID tags. However be aware this record might change because the OLCC implements this system and develops everlasting guidelines.
That is wonderful work by the OLCC, which continues to show its want to work with, reasonably than towards, Oregon’s marijuana trade. The VOC program displays the maturation of the trade on the West Coast—final 12 months Washington State took steps to shift from adversarial enforcement to compliance for its marijuana licensees— and aligns with statements by the OLCC that it seeks “willing partners” within the hashish trade.
You will discover the OLCC’s information launch on the VOC here and its Compliance Schooling Bulletin here. And for extra data regarding the OLCC’s enforcement of the marijuana guidelines and rules and what to do in case your marijuana enterprise discover itself in bother with the OLCC, see: