November 1st, 2019 is the first day that the Marijuana Regulatory Agency (MRA) starts accepting applications for adult-use establishment licenses. The MRA just released a tip bulletin for licensees, which highlights the requirements or important changes that those companies who have medical facilities licenses must follow. This is in order to pass pre-licensure inspections and compliantly possess adult-use licenses.
Here are some of the main takeaways from this bulletin:
People under the age of 21 cannot volunteer or work for the marijuana establishment
According to Adult-Use Emergency Rule 56(2)(a), all licensed medical marijuana facilities must either be completely partitioned from a proposed adult-use establishment or not employ a person under the age of 21 if the facilities are not partitioned.
Fire safety inspections are required for all marijuana establishments
Adult-Use Emergency Rule 34(4) requires a marijuana establishment to obtain pre licensure approval from the Bureau of Fire Services (BFS). The following marijuana facilities will also require a fire safety plan review:
- Designated Consumption Establishment (DCE).
BFS has information on how to submit plans on their website after the MRA notifies the licensee when they can submit for a BFS Plan Review.
Following the Natural Resources and Environmental Protection Act
Adult-Use Emergency Rule 30(3)(a) requires marijuana establishments to comply with the natural resources and environmental protection act, 1994 PA 451, MCL 324.101 to 324.90106. Additional environmental guidance is available here.
Social equity plans must be provided for adult-use establishment licenses
Applicants are required to provide a social equity plan that promotes and encourages participation in the marijuana industry by people from communities that have been disproportionately impacted by marijuana prohibition and enforcement and to positively impact those communities.
Visitors are barred from hazardous areas in the marijuana facility
Adult-Use Emergency Rule 56(7) elaborates that visitors that are not employees or providing trade services are prohibited where hazardous materials are used, handled, or stored in the marihuana establishment.
For the notable Safety Compliance facilities and secure transporters, read the full MRA tip bulletin here.
Contact an experienced cannabis attorney
These requirements may seem overwhelming to manage in an already heavily regulated industry. However, compliance is one of the most important aspects to keeping your business afloat. Our team of experienced cannabis attorneys can ensure success in maintaining regulatory compliance.