While many sectors of the economy were forced to cease their day-to-day operations, the essential businesses of cannabis industry in Michigan are able to conduct business with the implementation of new safety practices and procedures.

On May 20th, 2020, Michigan’s Marijuana Regulatory Agency (MRA) first issued an advisory bulletin aimed at ensuring the creation and enforcement of infection-control practices. The bulletin contains several new requirements for maintaining a compliant facility. On June 10th, 2020, the MRA updated the bulletin to reflect changes from the new executive orders (2020-114 and 2020-115).

Licensed Marijuana Operations Under COVID-19 Executive Orders June 10th, 2020

Licensed Marijuana Operations Under COVID-19 Executive Orders June 10th, 2020

As outlined in the Executive Orders, all marijuana licensees are required to allow employees with a confirmed or suspected case of COVID-19 to return to the workplace ONLY after they are no longer infectious, according to the latest guidelines from the Centers for Disease Control and Prevention (CDC).

Additionally, provisioning centers/retailers located in regions 1, 2, 3, 4, 5 and 7 (above) can engage in in-store retail activities by appointment only; with a limit of 10 customers inside the provisioning centers/retailers at a time; and with prescribed social distancing/facial covering restrictions.

The most substantial changes for cannabis licensees include:

  • The development of a COVID-19 preparedness and response plan. This facility must prepare and make the plan available no later than June 1st, 2020, or within two weeks after resuming in-person activities, whichever is later;
  • One or more worksite supervisors must be designated to implement, monitor and report on the COVID-19 control strategies;
  • Development of COVID-19 training for employees;
  • Must conduct daily self-screening protocol for all employees or contractors upon entrance;
  • Adherance to social distancing practices including providing non-medical grade face coverings to employees, increase facility cleaning and disinfection especially on high-touch surfaces, and protocols for cleaning and disinfections in the event of a postitive COVID-19 case in the facility.

The bulletin also includes guidance for different license types, which are elaborated on as follows:

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Cannabis Growers

  • Stop all non-essential in-person visits (including tours)
  • Reduce congestion in common spaces (when possible) and the number of employees in the facility at one time
  • Stagger meal and break times, vary employee start times at each entrance
  • Develop and implement practices to reduce personal contact during work
  • Develop and implement procedures to limit the sharing of tools and equipment, establish frequent cleaning and disinfection of tools, equipment and frequently touched surfaces

Cannabis Processors

  • Stop all non-essential in-person visits (including tours)
  • Reduce congestion in common spaces (when possible) and the number of employees in the facility at one time
  • Stagger meal and break times, vary employee start times at each entrance
  • Develop and implement practices to reduce personal contact during work

Cannabis Retailers/Provisioning Centers

  • Create signs, pamphlets, etc. to inform patients and customers of changes to practices and explain precautions
  • Stores under 50,000 square feet of customer floor space MUST limit capacity
  • Signs MUST be posted at the entrance(s) instructing customers of their obligation to wear a face covering inside the storefront, and not to enter if they were recently sick
  • Train staff on how to manage symptomatic customers upon entry
  • Limit staff to minimum number necessary to operate

Secure Transporter

  • Avoid recirculated air option for the vehicle’s ventilation during transport, and use the vehicle’s vents to bring in fresh air

Safety Compliance Facility

  • Stop all non-essential in-person visits (including tours)
  • Close open areas
  • Conduct office and dry lab work remotely
  • Minimize the use of shared equipment, and create protocol for disinfecting equipment and tools
  • Restrict all non-essential work travel

In additional to these requirements, Safety Compliance Facility Field Samplers must:   

  • Avoid using the recirculated air option for the vehicle’s ventilation during travel
  • Use Personal Protective Equipment (PPE) when on-site at a facility
  • Limit total number of daily sampling events by a given field sampling team, consider staggering scheduling
  • Field samplers MUST wash hands between facilities, or use alcohol-based hand-sanitizer
  • Field samplers MUST familiarize themselves with the COVID-19 precautionary measures implemented at each facility type where samples take place
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Designated Consumption Establishments

  • Limit capacity to 50% of normal seating
  • Six (6) feet of separation between individuals
  • Create signs, pamphlets or other resources to tell customers of changes to practices and precautions taken to prevent infection
  • Provide physical guides for social distancing (example: tape on floor or sidewalks)
  • Post signs at the entrance(s) instructing customers of their obligation to wear a face covering inside the stores and not to enter if they have been recently sick
  • Train employees on management of symtomatic customers upon entrance
  • Close IMMEDIATELY if an employee shows multiple symptoms of COVID-19, and perform a deep clean

Temporary Events

Currently, licenses for temporary events are not being approved. Additional guidance will be provided at at later date.

Any violation of the workplace health-and-safety standards may result in disciplinary action. These new requirements are not only a matter of regulatory compliance, but also public health.

Questions?

If you have any questions regarding this Advisory Bulletin or would like help with any of the narratives or requirements, please do not hesitate to reach out to us, and we would be happy to assist.

We are committed to working for you during this crisis via Skype, Zoom or phone. Read our COVID-19 Policy for more information. 

Kali Rose (19 Posts)

Kali is one of Cannabis Legal Group’s Paralegals. She began legal career at the Law Offices of Barton Morris and Cannabis Legal Group in 2017 as an Administrative Assistant. In July 2018, she was promoted to Paralegal at Cannabis Legal Group. She earned an Associate of Applied Science from Terra State Community College in Fremont, OH and holds background in communications and marketing. Kali is responsible for client relations, managing attorney calendars, and works to ensure research and document support are carried out effectively and efficiently for our cannabis clients.


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