Deadline looms for medical marijuana businesses to comply with seed-to-sale tracking system

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On September 18, 2020, the Oklahoma Medical Marijuana Authority (OMMA) officially partnered with Metrc, becoming the 14th state, along with the District of Columbia, to utilize the seed-to-sale track-and-trace regulatory cannabis system. With more than 10,000 active business licenses in the state, the Metrc system will assist OMMA with its regulatory and compliance efforts in the budding medical marijuana industry in Oklahoma.

Metrc system overview

All Oklahoma business licensees are required to participate in the Metrc system, which uses a combination of online software and physical tags to provide real-time tracking and tracing for medical marijuana and medical marijuana products that are grown, processed, transported, tested, and sold in Oklahoma. The Metrc software is available for $40 per month per license, with all tags provided by Metrc at a price of $0.45 per plant tag and $0.25 per package tag. These non-reusable, serialized tags are attached to individual plants or packages, each containing text, barcodes, and scannable RFID chips, which allow the tags to be uniquely identified, both visually and digitally. This data is inputted into the Metrc system and is available to both the licensee and OMMA. The information is kept private from other licensees, the exception being that when licensees do business together, the purchaser can access the data on the specific package to ensure the accuracy of the shipment before accepting it into its inventory.

Licensees have options regarding how to employ the new system. Relevant data may be entered directly into the Metrc system, but licensees may instead utilize the Metrc Application Programming Interface (API) and use a third-party inventory management vendor, such as a Point of Sale (POS) provider. Any third-party vendor used by a licensee must be validated by Metrc. A list of such providers will be distributed by Metrc.

More information on Metrc, its system, and its partnership with OMMA is available on www.metrc.com/oklahoma.

Implementation process

The deadline for licensees to comply with the Metrc system is April 30, 2021. In order to facilitate this rollout, OMMA and Metrc are offering free daily training and credentialing sessions from March 1 until March 26. Attendance at a training session is mandatory for licensees to become credentialed and gain access to the Metrc system.

A licensee’s Metrc system must be handled by an administrator within the licensed facility, which can either be an owner or a designated manager. Each administrator is obligated to take the new business training course. In addition to the facility’s administrator, it should be common practice for all employees that contribute to the facility’s Metrc system to complete the training course. Such training creates a safeguard by ensuring that relevant employees properly utilize the system. The initial training sessions cover general Metrc system use, and advanced training courses focused on specific license types will be available at a later date.

Once the training course is completed by the facility’s administrator, the business owner must email support@metrc.com to obtain log-in credentials. There are strict guidelines for this email: the subject must read “Requesting OK Credentials”; and the body of the email must include the (1) business owner’s name, (2) licensee’s OK Medical Marijuana License Number, (3) name of the business and the DBA, if applicable, (4) licensee’s phone number, and (5) email address designated to receive the Metrc credential email. Once the credential email is received (normally within 48 hours), the administrator must log in to the business’ Metrc account within 24 hours.

Beginning March 27, trained and credentialed licensees will gain access to the Metrc system. Over the following five weeks, licensees are expected to learn the system, order necessary tags, and input a beginning inventory. It is essential that this initial information be a true and accurate reflection of the facility’s inventory, as it will serve as a baseline for its Metrc system recordkeeping. As of April 30, licensees must have the beginning inventory entered into the system and begin reporting all transactions. Because it tracks facility operation and inventory, the Metrc system will replace the monthly reports that are submitted to OMMA. Thus, the final report required to be submitted to OMMA will be the March report, which is filed in April. Subsequently, proper upkeep of the Metrc system will satisfy OMMA’s monthly report requirement.

Further instruction will be given in the new business training course and can be found on Metrc’s website. Additionally, Metrc’s training materials are available for download upon the receipt of a licensee’s credentials.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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