Rocky Mountain Cannabis Consulting

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From Regulations to a Training Plan

Debbi Spranza

I READ THE EMERGENCY REGULATIONS, NOW WHAT?

RMCC works with licensed cannabis operators in all legal states who are looking to remain in compliance with their state regulations, implement new regulations, or adapt to emergency regulations. Ultimately, saving every operator we work with time, money, and effort. Many of them have successful businesses already, some are just getting started. But each of them is looking to answer one question, "What do I do to ensure my operation remains compliant when new state cannabis regulations drop?"

Last month, the California Department of Cannabis Control consolidated and revised their regulations from the three previous agencies (California Department of Food and Agriculture, California Department of Public Health, and the Bureau of Cannabis Control) overseeing the cannabis industry to streamline the regulatory framework. If you are a California cannabis business, we aren’t sure where you're at on your journey, but to provide one piece of universal advice it would be this: look at your training plan and compliance infrastructure now. 

It might feel scary knowing that when state regulations change they potentially make your workflows out of date and noncompliant, risking everything you’ve worked so hard to build. It can feel like the rug is being pulled out from under you; everything was already dialed in! You already worked hard implementing procedures. It was difficult enough understanding how regulations impacted your workflows. When regulations are adjusted or new regulations are published, and then implemented in an operation, changes can impact current procedures, workflows, and tasks by tightening the flexibility of tasks, eliminating tasks, or creating new tasks.

after you read all updates or new regulations, ask yourself these important questions:

  • How will you analyze and update your SOPs? 

  • How are you going to analyze what rules impact your workflows?

  • How are you going to know if everyone is on the same page once these changes come out? 

  • How are you going to tell impacted workers what to do and what not to do as a result of these rules and know you were heard?

The answer is your training plan. Regardless of whether you deliver the training yourself or work with partners like RMCC, without training plan infrastructure, you are risking:

  1. Increasing employee turnover

  2. Employees executing old workflows that can lead to penalties, fines, and regulatory violations

  3. Outdated SOPs

  4. No accountability if/when changes are implemented

ensure your training plan is executable, repeatable, and measurable.

Employees can’t just read the regulations and be expected to analyze the implications to your bottom line and then adapt their behavior accordingly. Entry-level and inventory employees are not experts in interpreting and digesting the regulations. They need support from the compliance team and leadership. RMCC has seen some operators rely on old-fashioned ineffective communication methods like self-reporting reading updates and memos. This antiquated method does not teach an employee what the regulations mean to them and their everyday job duties. Instead, it causes more confusion and pressure. Expecting every employee to become a compliance expert is unrealistic. As a cannabis business owner, you’re responsible for providing an employee with the training they need in order to continue performing their job correctly when changes occur.

whether you have your own internal training team or outsource your training to partners like RMCC, adaptability with infrastructure is key.

Take a look at your compliance update training plan for these 3 key elements:

1) Communication Plan: How will you ensure key employees receive new relevant information and changes to procedures in a way that is immediately actionable? Lindsey Kincade, RMCC’s Chief Compliance Officer leads the team with a weekly compliance update which we make available to our clients here.

Reading and acknowledging emails or SOPs is not a plan.  A communication plan determines who will be receiving the communication, how those people will receive it, when they'll receive it, and how often they should expect to receive that information. An integral part of communication compliance updates is being on the same page right when changes occur.  

2) SOPs and Playbook Development: When regulatory changes occur, your compliance officer, compliance managers, and/or technical writers should immediately jump into action to ensure your SOPs and playbooks are up to date. 

SOPs should include regulatory references. Not only does this keep your employees aware of the regulatory framework that dictates workflows but also makes updating the SOPs in response to specific regulatory changes easier.

You should have a corresponding playbook for each SOP. These playbooks should contain click-level and step-by-step details and capture those best practices that allow your operation to complete processes that surpass the minimum requirements set out by your local and state regulators. 

3) If your operation already incorporates processes and procedures that exceed minimum regulatory requirements, you may not need to make any changes as your state and local regulators tighten their rules over time. 

4) Evaluation Methods: All training plans, SOPs, and playbooks should be evaluated for effectiveness and revised with improvements. Be sure to track who received what training and when. Do those who finish the training perform as expected or are employees still confused about how to complete a compliant workflow? Your plans should be measured using the data metrics you have available in your HR learning systems or track manually.

If you don’t have an internal training team, it may seem overwhelming to adapt to emergency regulations when they come out. 

Right now RMCC’s students and clients are benefiting from our stringent interpretations of state regulations and recommended workflows. 

Emergency regulations in California were announced on September 8, 2021, causing a flurry of activity as the community processed the regulations and their implications. Our team reviewed the regulations, analyzed their impacts on our clients, and recommended workflows with best practices. RMCC was able to deliver the assurance and news that the best practices we taught in fact, saved them the time, cost, and hassle of updating their SOPs and workflows. When we tell our clients we have their backs, we mean it. 

Invest in training with RMCC to receive support in sustaining your operation and leave the training to us.