On Monday, July 20th, 2020, the Marijuana Regulatory Agency (MRA) updated the advisory bulletin for Licensed Marijuana Operations Under COVID-19 Executive Orders. This advisory bulletin updates the MRA’s initial advisory bulletin from June 10th, 2020 that put various infection-control practices in place.
Below are the following modifications and newly announced requirements for Michigan cannabis businesses to follow:
All Marijuana Licensees
- Conduct a daily entry self-screening protocol for all employees, contractors, suppliers, and any other individuals entering the facility, including a questionnaire covering symptoms and suspected or confirmed exposure to people with possible COVID-19, together with a temperature screening.
- Adopt protocols to clean and disinfect the facility in the event of a positive COVID-19 case in the workplace.
- When an employee is identified with a confirmed case of COVID-19:
(1) Immediately notify, the local public health department, and
(2) Within 24 hours, notify any co-workers, contractors, or suppliers who may have come into contact with the person with a confirmed case of COVID-19.
- *As of July 29th, suppliers and customers are no longer required to be screened and temperature screening is no longer required.
- Provide any communication and training on COVID-19 infection control practices in the primary languages common in the employee population.
- Place posters in the languages common in the employee population that encourage staying home when sick, cough and sneeze etiquette, and proper hand hygiene practices
- Require face coverings in shared spaces, including during in-person meetings and in restrooms and hallways.
Additional Requirements for All Cannabis Businesses
- Any individual able to medically tolerate a face covering must wear a covering over his or her mouth – such as a homemade mask, scarf, bandana, or handkerchief – when in any enclosed public space or in an outdoor space when they are unable to consistently maintain six feet of distance or more from individuals who are not members of their household.
- A business may not assume that someone who enters the business without a face covering falls in one of the exceptions specified in EO 2020-53, including the exception for individuals who cannot medically tolerate a face covering. A business may, however, accept a customer’s verbal representation that they are not wearing a face covering because they fall within a specified exception.
- All businesses that are open to the public are prohibited from providing service to a customer or from allowing a customer to enter its premises, unless the customer is wearing a face covering.
- Post signs at entrance(s) instructing customers of their legal obligation to wear a face covering while inside.
New Requirements for Processors/Marijuana Processors
- Ensure there are sufficient hand-washing or hand-sanitizing stations at the worksite to enable easy access by employees, and discontinue use of hand dryers.
- Notify processor/marihuana processor supervisors and potentially exposed individuals upon identification of a positive case of COVID-19 in the facility/establishment, as well as maintain a central log for symptomatic employees or employees who received a positive test for COVID-19.
- Send potentially exposed individuals home upon identification of a positive case of COVID-19 in the facility/establishment.
- Require employees to self-report to processor/marihuana processor supervisors as soon as possible after developing symptoms of COVID-19.
- Shut areas of the processing facility/establishment for cleaning and disinfection, as necessary, if an employee goes home because he or she is displaying symptoms of COVID-19.
New Requirements for Provisioning Centers/Retailers
- Establish an enhanced cleaning and sanitizing protocol for high-touch areas like restrooms, credit-card machines, keypads, counters, shopping carts, and other surfaces.
- Notify employees if the employer learns that an individual (including a customer or supplier) with a confirmed case of COVID-19 has visited the store.
- Design spaces and store activities in a manner that encourages employees and customers to maintain six feet of distance from one another.
New Requirements for Safety Compliance Facilities/Marihuana Safety Compliance Facilities
- Avoid using the recirculated air option for the vehicle’s ventilation during transport; use the vehicle’s vents to bring in fresh outside air and/or lower the vehicle windows.
- Employ the use of personal protective equipment such as masks and gloves and Tyvek suits where applicable when on site at a facility. Samplers should also use sanitary technique when removing, storing, and disposing of these items.
- Limit the total number of daily sampling events by a given field sampling team.
- Consider staggering sampling teams or having teams dedicated to certain facilities to avoid potential cross-contamination.
- All field samplers should wash their hands thoroughly between facilities OR have alcohol-based hand-sanitizer readily available for use in the vehicle designated for sampling purposes.
- All vehicles designated for travel to and from sampling events should be thoroughly cleaned and disinfected at the end of each day or prior to next use.
- Be familiar with the COVID-19 precautionary measures implemented at each of the facility-types where sampling will take place.
Enforcing COVID-19 Orders for Cannabis Businesses
Additionally, Executive Order 2020-147 requires the use of face coverings indoors and in crowded outdoor spaces. The order requires businesses to post notices and does not allow a business to permit a customer to enter its premises unless the customer is wearing a face covering. Compliance with the mask order could not be more important to try and avoid the more sweeping restrictions employed in the past.
If you have any questions regarding this Advisory Bulletin or would like help with any of the requirements, please do not hesitate to reach out to us. We would be happy to clear anything up for you to best serve your business.
We are committed to working for you via Skype, Zoom or phone. Read our COVID-19 Policy for more information to see our policy on in-person consultations, disinfection practices, and more.