Missouri has extensive requirements for standard operating procedures (SOPs) for microbusiness dispensaries.
These can be found under the current rules, Title 19 (Department of Health and Senior Services), Division 100 (Division of Cannabis Regulation), Chapter 1 (Marijuana) (19 CSR 100) of Missouri Code Regulations.
Section 3A1B of Rule 19 CSR 100-1.030 Complaints, Inspections, and Investigations requires all marijuana facility license holders in Missouri, including microbusiness dispensaries, to include “[a]ll SOPs necessary for the facility licensee to show compliance with regulations applicable to it” in their requisite, formal request to commence operations.
This is taken to mean that marijuana facility license holders must have written SOPs showing how they will comply with ALL Missouri regulations, not just where Missouri rules explicitly require them to provide SOPs.
We will therefore not list all the SOPs Missouri microbusiness dispensaries need here; the list would be too extensive and would simply be a reiteration of everything in the Missouri marijuana regulations. Instead we will focus on the SOPs that are explicitly required for Missouri microbusiness dispensaries under current rules.
Missouri Marijuana Training Requirements
Section 1 of 19 CSR 100-1.080 (Facility Employee Training) lists the SOPs that are required for employee training. These include security, recordkeeping, emergency, and consumer/patient education SOPs.
(1) Facility licensees must ensure all facility employees, including contract employees, are trained in at least the following and must maintain records of employee training for at least five (5) years:
(A) The use of security measures and controls that have been adopted by the licensee for the prevention of diversion, inversion, theft, or loss of marijuana product, as applicable to the employee’s duties;
(B) Proper use of the statewide track and trace system, as applicable to the employee’s duties;
(C) Procedures for responding to an emergency, including severe weather, fire, natural disasters, and unauthorized intrusions;
(D) The safety and sanitation procedures of the facility, as applicable;
(E) Department rules and guidance as applicable to the employee’s duties;
(F) All processes and procedures used by the facility that are applicable to that employee’s duties;
(G) Transportation and dispensary licensees must ensure employees responsible for assisting customers or handling customer purchase records are trained in standards for maintaining the confidentiality of information related to the use of marijuana product and in procedures for verifying the identity and age of consumers, qualifying patients, and primary caregivers; and
(H) Dispensary licensees must ensure that employees responsible for assisting customers are trained in the following:
- Procedures for verifying purchase limitations of consumers, qualifying patients, and primary caregivers;
- The differences in the purported effects and effectiveness of the strains of marijuana available for purchase at their dispensary and the methods of their use; and
- The expected timeframes for individuals to feel the effects of marijuana product based on their chosen method of use”
Missouri Marijuana Facility Security SOPs
Section 2 of 19 CSR 100-1.090 (Facility Security) requires all marijuana facility licensees to establish and follow policies and procedures:
(A) For restricting access to the areas of the facility that contain marijuana product to only facility agents who are employees, contractors, owners having access to a medical or marijuana facility, and volunteers of the facility. Individuals without an agent identification card may be present when necessary for legitimate business purposes, if they sign in and sign out of a visitor log and are escorted at all times by facility agents in a ratio of no less than one (1) facility agent per five (5) visitors;
(B) For identifying persons authorized to be in the areas of the facility that contain marijuana product;
(C) For identifying facility agents responsible for inventory control activities;
(D) For monitoring the security for the facility;
(E) For the use of the automatic or electronic notification and manual, silent alarms to alert local law enforcement agencies of an unauthorized breach of security at the facility, including designation of on-call facility personnel to respond to, and to be available to law enforcement personnel responding to any alarms; and
(F) For keeping local law enforcement and the department updated on whether the facility employs armed security personnel and how those personnel can be identified on sight.
Missouri Marijuana Facility Operations SOPs
Items G-H of Section 4 (General Operations) of 19 CSR 100-1.100 (Facilities Generally) requires:
(G) All licensees shall establish and follow SOPs in the event the facility is suspended or ordered to cease operations.
(H) All licensees shall establish and follow detailed SOPs for marijuana product remediation.
(I) All licensees shall establish and follow SOPs to ensure marijuana remains free from contaminants. The systems, equipment, and documentation necessary to follow procedures must address, at a minimum:
- The flow through a facility of any equipment or supplies that will come in contact with marijuana including receipt and storage;
- Employee health and sanitation; and
- Environmental factors, such as:
A. Floors, walls, and ceilings made of smooth, hard surfaces that are easily cleaned;
B. Temperature and humidity controls;
C. A system for monitoring environmental conditions;
D. A system for cleaning and sanitizing rooms and equipment;
E. A system for maintaining any equipment used to control sanitary conditions;
For assistance with developing your SOPs for your Missouri microbusiness dispensary, please reach out to Forte SOPs