Final month, together with streamlined licensing, the Oregon Liquor Management Fee (OLCC) introduced a major (and welcome) change to its compliance operate by instituting a brand new Verification of Compliance program (VOC) that may deal with schooling relatively 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 season. 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 challenge VOC paperwork (the “ticket”) to licensees for a choose variety of violations. The place the licensee is ready to repair the issue inside the required timeframe, the OLCC won’t begin additional proceedings in opposition to the licensee. That is nice information! However beware– the OLCC reserves discretion to pursue “ticket” violations if a licensee exhibits a common disregard for guidelines and legal guidelines. So licensees shouldn’t deal with cavalierly rule violations which can qualify for a “fix-it ticket.”
What varieties rule violations could qualify for the VOC? The OLCC recognized 4 standards related to this dedication.
- The violation have to be probably fixable, i.e. the licensee has the potential 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 have the ability to level to tangible/concrete motion to exhibit compliance. (Instance: fixing digital camera protection).
- The violations eligible for VOC needs 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 frequent violations with a low likelihood of recurrence.
- The VOC ought to present a optimistic influence for each licensees by educating licensees and for OLCC employees 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 schooling 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 notice this record could change because the OLCC implements this system and develops everlasting guidelines.
That is wonderful work by the OLCC, which continues to exhibit its want to work with, relatively than in opposition to, Oregon’s marijuana trade. The VOC program displays the maturation of the trade on the West Coast—final yr 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’ll find 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 hassle with the OLCC, see: