Avoid Infractions: Top 5 Metrc Cultivation Compliance Violations
New METRC users are shocked to find that the regulations' expectations do not easily align with METRC functionality.
Whether utilizing a third-party technology solution or entering data directly into METRC's User Interface, cannabis businesses must continuously monitor all aspects of the operation to maintain comprehensive compliance. If you want to get ahead of the METRC learning curve while decreasing violation risks, seek proper education from experienced instructors.
How do you stay METRC compliant?
Whether you are a brand new METRC user or a veteran who has been using the platform for 6+ years, the best first step to a compliant business is your Standard Operating Procedures (SOP's). Begin analyzing your standard operating procedures, compliance playbooks, and operational infrastructure to ensure you can educate and validate your cannabis business's workflows.
To help you prepare for inspections and identify data irregularities, listed below are the top five most common METRC cultivation violations in California that RMCC has seen over the past year.
1. The lack of compliantly recorded green waste
Infraction Amount: $501 - $1,000 per Occurrence*
In Violation of BPC 26031 3 CCR 8308(j): Failure to use the track-and-trace system and documentation required pursuant to sections 8405 and 8406 of this chapter to ensure the cannabis waste materials are identified, weighed, and tracked while on the licensed premises and when disposed of pursuant to subsections (f), (g), (h), and (i) of section 8308.
RMCC’s Operational Solution: No matter the plant growth phase, if any weight is removed from the plant(s) in any way, waste is to be recorded in METRC. This includes, but is not limited to; destroying non-thriving immature plants, pruning mothers, de-fanning flowering plants, and recording waste during harvest.
2. the failure to attach a metrc plant uid at the base of each flowering plant
Infraction Amount: $501 - $1,000 per Occurrence*
In Violation of BPC 26031 3 CCR 8403(b)(4): Licensee failed to properly place and maintain the required UID on each mature plant.
RMCC’s Operational Solution: To compliantly maintain thirty (30) day reconciliation requirements and accurately input METRC data, every mature flowering plant should have a METRC Plant UID tag attached at its base. Failure to complete this physical workflow can lead to compounding infractions for each occurrence. All flowering plants must be tagged within three (3) days of reaching the flowering phase or upon entering the licensed canopy area.
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3. failure to label each immature plant within an immature batch with the corresponding batch uid plant tag
Infraction Amount: $501 - $1,000 per Occurrence*
In Violation of BPC 26031 3 CCR 8403(b)(1): Failure to label each plant in an immature lot with a label containing the UID number assigned to the immature lot by the licensee.
RMCC’s Operational Solution: All individual immature plants are to be labeled with the entire 24-character alphanumeric METRC Plant UID associated with the Immature Batch. If immature plants are not properly labeled, this will create confusion for the inspector, cause reconciliation discrepancies, and will be a violation of record retention requirements. Use plant labels to place in the soil next to the base of each plant to record the entire Plant UID that corresponds to the full Immature Batch.
4. non-compliance of thirty (30) day on-premise reconciliation of plants and inventory with metrc
Infraction Amount: $501 - $1,000 per Occurrence*
In Violation of BPC 26031 3 CCR 8406(a): Failure to reconcile all on-premises and in-transit cannabis or non-manufactured cannabis product inventories at least once every thirty (30) calendar days.
RMCC’s Operational Solution: METRC does not provide a reconciliation tool within the user interface; however, cultivators are required to maintain records for seven years of each month’s reconciliation of METRC to physical plants within every growth phase and on-site inventory location.
5. compounding entry errors and improper metrc training is causing the failure of licensees to compliantly correct discrepancies within three (3) calendar days
Infraction Amount: $501 - $1,000 per Occurrence*
In Violation of BPC 26031 3 CCR 8402(c)(5): Failure to correct data entered into the track-and-trace system in error within three (3) calendar days of discovery of the error.
RMCC’s Operational Solution: New METRC users are unaware that METRC has no built-in safeguards against non-compliant data entry. METRC and state agencies expect the operator to record all data - even if that data is derived from an error or oversight that results in noncompliance. Examples of this would be: pulling too much weight out of a source tag creating a negative quantity package, harvesting multiple strains within a single harvest batch, or creating immature plant batches containing more than 100 plants per batch.
