What to do AFTER you get your Commercial Cultivation license

Congratulations! After a lot of hard work getting your application together and approved, you deserve a break!
But now what?
This checklist will set you up for success as you learn to navigate the constantly changing minefield of the cannabis industry.

First a quick overview:

Additional Licenses and Registrations:

Get Department of Agriculture Licensing

Collect frequently requested documents

Do Monthly Reports:

Set up Inventory Management System (Seed-to-sale)

Create Cannabis Waste Documentation

Create a filing system

Testing, Transport & Security:

Choose a licensed laboratory for testing

Decide if you need a transporter agent license

Create a manifest template

Security System and biometric locks

Take a deep breath:

First a quick overview:

1

Register with OBNDD
2

Get licensed Nursery Grower Card from the Department of Agriculture
3

Create a folder for frequently used business documents.
4

Do the monthly report
5

Implement an Inventory Management System
6

Prepare Cannabis Waste affidavits
7

Decide how you’ll handle transport
8

Create a Manifest template
9

Decide on a testing laboratory
10

Set up a Security System with biometric locks

Additional Licenses and Registrations:

Put down the weed!

Or at least hide it. You’re not legal until you register with the OBNDD.

And you can’t sell anything until you get a Nursery Growers license from the Department of Agriculture.

Let’s take a look.

Register with OBNDD

OBNDD Registration.

Any dispensary, grower, processor, or researcher issued a license authorized by this Chapter, is required to obtain an Oklahoma State Bureau of Narcotics and Dangerous Drugs Control (“OBNDD”) registration prior to possessing or handling any marijuana or marijuana product

Fee: $500 for one year.

Link to OBNDD registration

Get Department of Agriculture Licensing

In order to grow and sell plants in Oklahoma you must obtain a nursery growers license from the Department of Agriculture.

Link to Oklahoma Department of Agriculture

Fee: $25 plus $1/1000 sq ft

Collect frequently requested documents

Everyone wants to see these documents.

Make a folder on Google Drive, or something like it, so you an easily share them

When it’s time to open a bank account
When you apply for insurance
If you’re using an accountant
Anytime a representative of OMMA pays a visit.

It’s always the same and always all of these:

1

Cannabis business licenses
2

EIN letter
3

Certificate of Compliance or Zoning Compliance letter
4

Certificate of Good Standing from the Secretary of State
5

LLC Operating Bylaws, Minutes of Organizational Meeting
6

Any and all agreements with lenders, investors, or landlords
7

Standard Operating Procedures

Do Monthly Reports:

You will have to enter exact quantities of cannabis harvested, bought, sold, destroyed or otherwise transferred–as well as the number of plants and seeds in your possession.

You will have to provide details about where they came from, where they went to and how they got there.

Then provide dollar amounts for all of the above.

Link to OMMA Monthly Report portal

and a sneak peak:

Set up Inventory Management System (Seed-to-sale)

An electronic inventory management system, or seed-to-sale tracking, is mandatory. The chain of custody of all cannabis and cannabis products must be maintained at all times.

1

It must note when cannabis is planted, harvested, sold or destroyed
2

It must make any theft or diversion obvious.
3

It will document all aspects of transportation.
4

It will insure that the cannabis can be traced back to its source.
5

It will use an identifying batch number and barcode.

Create Cannabis Waste Documentation

In an effort to keep medical marijuana off of the street

1

all waste material from the plants must be accounted for by weight or number.
2

Waste must be destroyed by burning, burying, mulching, composting or incineration.
3

This must be recorded in an affidavit signed by a witness
4

and the records kept for 5 years.

Create a filing system

Everything is documented

As you can see by now everything is documented and everything that’s documented must be kept for 7 years ( I know, I know I said 5 years earlier but like I said I don’t write the laws).

1

All transactions involving money or the transfer of ownership of cannabis
2

all cannabis related documents including manifests and test results.
3

Documentation must include the name and license number of all involved parties.
4

The strain, quantity, and batch number of the cannabis.
5

The date and amount of each transaction.

Testing, Transport & Security:

The final section deals with some topics that are, how should I put it?–

vague?
poorly communicated?
ill conceived?
sketchy?

Whatever you think is best.

I’ll say what I think is happening. I’ve asked my attorney and I’ve exhausted the internet looking for answers. So, I feel confident that I understand what there is to understand. Feel free to let us all know if you’ve got some inside information. For now, this is what I’m doing.

Choose a licensed laboratory for testing

Before cannabis can be sold or processed it must be tested by a laboratory that is licensed by OMMA

Here’s a link to OMMA’s list of licensed laboratories:

OMMA Licensed Laboratory List

These are the tests that need to happen:

microbial analysis
mycotoxins,
residual solvent analysis
pesticide analysis
THC and cannabinoid potency,
terpene profiling
heavy metals, and
foreign materials

Decide if you need a transporter agent license

This bit of the law is super confusing. You already have a transporter license, right?

Please, don’t kill the messenger. I don’t write the laws, I just share them.

But if you plan on driving around with the goods, you need another license–the transporter agent license. Don’t ask me to explain it, but it’s true.

According to the OMMA website

“every person who transports medical marijuana will be required to have a transporter agent license. You may fill out the Transporter Agent Employment Verification Form for yourself if needed”

Fee: $100 for one year

Create a manifest template

All traveling cannabis must be accompanied by a manifest which includes all of the following:

1

The license number, business name, address, and contact information for the receiving licensee;
2

The license number, business name, address, and contact information of the originating licensee;
3

The license number, business name, address, and contact information of the commercial transporter, grower, processor, or dispensary transporting the medical marijuana if such licensee is not the originating licensee;
4

A complete inventory of the medical marijuana and medical marijuana products delivered to the receiving licensee, including the quantities by weight or unit of each type of medical marijuana and medical marijuana products and the batch number(s);
5

The date and estimated time of arrival;
6

The printed names, signatures, and transporter agent license numbers of the personnel accompanying the transport; and
7

The printed names, titles, and signatures of any personnel accepting delivery on behalf of the receiving licensee.

Security System and biometric locks

And, last but not least, the security system requirements. Now, OMMA is pretty vague on the topic. The OBNDD, however, is not.

Link to OBNDD security requirements: general

Link to OBNDD security requirements: manufacturing

If you read the boring details, you may have noticed that it doesn’t say “biometric locks” anywhere. However, the requirements of #3 in the Manufacturing document are stated so that biometric locks are the simplest way to fulfill the “limited to a minimum number of employees and can be changed upon termination” requirement.

Keep in mind that these are the minimum requirements. Your insurance provider will have a more extensive list of demands.

Take a deep breath:

My intention is to flesh this out over time with templates and other useful things. But, please keep in mind I’m in this boat with you.

So for now, I’ve got work to do and so do you.

Oh, I came across a quote from the Bhagavad Gita:

“You are only entitled to the action, never to its fruits.”

Put that in your pipe and smoke it.

Until next time!

Keith

Take control of your workflows today.

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