First, when is your current expiration date? You should begin planning your renewal 90 days ahead and submit no later than 30 days before expiration. Most licensees find that they need to change something in their license or get an updated fire inspection or local business license before renewing their state license. If you aren’t sure, just ask. We’ve helped to license more than 100 facilities around the state for every type of activity imaginable. Let our team help you build a plan to keep track of your state and local requirements.
Is this the time to make changes to your license? Renewal is just that: renewing the existing license as-is.
The renewal process does not allow for the addition of new locations or modifying your license from your initial license. If you need to make those changes, we can help you do so through the amendment process now before you renew with inaccurate license details.
If you have done any of these, or expect to in the next year, let’s discuss a strategy to amend or update your license before you renew:
- Adding, removing or changing a controlling person (owner, investor, executive decision-maker). (18.104.22.168.A.6)
- Increasing or decreasing plant counts. (22.214.171.124)
- Changing the class of a manufacturing license to allow for new product lines or activities.(126.96.36.199.A.K)
- Adding a new location.(188.8.131.52.Z.)
- Adding another activity (adding a manufacturing license to production, for example, so you can package and make your own products on site).(184.108.40.206.AA.)
- A change in water source use for producers, or an increase of 10% or more in water use above the estimates in your first year Energy & Water plan.(220.127.116.11.D)
- Changes to security systems, including adding new cameras.(18.104.22.168.D)
- Changing the size of your facility. (22.214.171.124.D)
Multiple locations or licenses? It might be time to upgrade to an integrated license instead of renewing. If you have multiple licenses with different renewal dates it may be smarter (and cheaper) to roll them all together into a new integrated license to streamline compliance and renewals in the future. It also makes adding additional activities or locations quicker and cheaper in the future. If you have multiple licenses or think you will add activities or locations next year, an integrated license may be smarter than renewing standalone licenses.
What about local permits? In addition to your CCD license, most operators have local business registrations, fire inspections, and health permits that must be in place, current or renewed as well. Remember that licensees are required to have all local permits up to date and post them in your facility in order to maintain your CCD license or avoid violations during inspection.
Is your training up to date? Each licensee is required to have a training program in place and complete retraining for all employees annually. Since your renewal requires you to attest that you have all the training complete and available for inspection, now is a great time to check.
Depending on your license type, your training program will include health and safety, emergency procedures, OSHA compliance, alcohol and drug-free workplaces (yes, you must be a drug-free workplace and have policies in place to enforce it), HIPAA health privacy, security procedures, record keeping and more. Food handling certificates must also be updated annually for managers and staff. If you never got around to building that training program, or if you need help getting through retraining, our compliance team can help.
What records or policies need to be updated? Everything. State and local rules have changed countless times since the first licenses were issued last year. If you developed policies based on the first rules, you need to update them to reflect today’s requirements. Additionally, many cities and counties have added local ordinances and restrictions you must incorporate to receive a renewed business license.
Do I need that new health permit? If you are manufacturing or handling cannabis products, probably.. The NMED health permit (non-City of Albuquerque) is about 30 pages long and requires you to share sanitation policies, product recipes and site diagrams.
Albuquerque’s health permit is a little easier but it also applies to most retailers, even if you do not have a manufacturing operation on site. We’ve developed a suite of policies to meet state and local rules. Reach out if you need help.
What other records do I need to check? Accident forms (OSHA 300), security incident logs, CCTV logs, visitor logs, cannabis waste and disposal logs (you’ve been submitting those to CCD every time as required, right?!), and about a dozen other recordkeeping logs should all be up to date.
Producers (growers) also need records detailing purchase of all growing media or required soil and water tests if grown in ground or using local soil (you did do those before you started, right?!)
Manufacturers should use this opportunity to review the latest rules on packaging (including childproofing standards) and ensure your labels meet current requirements.
Retailers, ensure all of your products have current test results and that you have records of your required monthly inventory reconciliations.
Again, if you never got around to setting up those systems, Weeds can help.
How do I know if I’m ready for a CCD, health or local fire inspection? We recommend completing a mock inspection with one of our compliance specialists. We schedule a visit with you to inspect your facility using the same forms and standards your regulators use so you know what is expected and identify any deficiencies that should be addressed to stay compliant.