Article: Security, Chain of Custody, and The Transportation Manifest

Cannatech report

Cannabis compliance for licensees is finally emerging from the shadows into the forefront as regulators move from the application phase to the operational phase.

In performing Freedom of Information Act (FOIA) requests and reviewing online compliance audit reports and letters to licensees, there are a number of specific issues regulators are required to review, but the majority of warning letters and flagged inspection reports show only a handful of cited issues for the vast majority.

First, let’s look at the issues still dogging both new and experienced licensees that we have culled from our files, but are easily corrected with a new standard operating procedure (SOP), employee training, and rebooting the corporate culture.

Below are the most frequent issues encountered.


For many licensees in the cannabis industry, security is the most often cited issue.  

Security should be homogenous – applied uniformly and followed in a specific formula that has been vetted by your security vendor or director.

Despite constant upgrades to technology and upgrading security employees’ skillsets, security is far and away the greatest cannabis compliance risk and the most frequently cited issue by regulators.

After review of over 1,000 citations from different states, we have created the following list of critical elements that regulators have consistently focused on when conducting cannabis licensee audits.  

They include:

False ID, Expired ID, Lack of ID

The first barrier to entry at any licensed cannabis facility is providing government issued identification verifying the individual’s age and residence.

Unfortunately, underage users have utilized any number of providers of fake ID both here and abroad to obtain credentials that have almost impossible to duplicate holograms and embedded chips.

Employee Theft

The largest issue with inhouse security is not with customers and patients – it is with the staff.

Many citations show improper reconciliation and storage of cannabis has resulted in theft and displacement by staff.  

Improper Chain of Custody, Documentation

The employee theft issue will run parallel to citations issued for improper chain of custody and creating an audit trail and documentation sufficient to satisfy regulators. 

If you can’t provide regulators with proper paperwork demonstrating the complete handoff of all products from receipt to sale, then there is potential for further issues.

Product Safety/Labeling and Packaging

This is a catch all category in which regulators generally have no trouble finding infractions.

Are all the proper warnings on the label?

Medical cannabis is the largest concern for improper labeling and packaging. 

Does your label have the toll free number for Poison Control?

If you’re selling products for ingesting cannabis such as vaporizers and other rigs, do they contain adequate instructions for use, servicing instructions, warning statements or other information for the protection of users?

Avoid this issue – go straight to the state regulations’ and the FDA regulations’ website for easy to utilize guidance.  

Improper testing is another area for concern.

Not happy with the results from the lab where your samples are analyzed? Start shopping!

Many growers will shop lab results to find a vendor who provides the highest THC and other cannabinoid profiles.

There is little if any risk to licensees – there is no centralized database for lab results, so licensees are free to shop their product’s results with impunity. 


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