California Cannabis Business Preparedness Resources for Wildfires, Power Outages and Remote Audits

By Genevieve Meehan, Christina Sava

Aug 28, 2020

In recent weeks, our Vicente Sederberg's California office has heard reports of operational concerns due to wildfires, power outages, and remote agency audits from our clients and contacts. As a result, we've gathered some helpful resources:

Wildfires

As devastating wildfires tear through California, many businesses are experiencing delays in order fulfillment, evacuations that implicate the ability to conduct operations, and serious damage to outdoor cultivation operations. Businesses and residents in Lake, Napa, San Mateo, Santa Cruz, Solano, Sonoma, and Yolo Counties are part of a Presidential Major Disaster Declaration and may apply for recovery resources at www.disasterassistance.gov. If you are having difficulty complying with any cannabis regulatory requirements as a result of the wildfires, we can assist with determining appropriate disclosures and requests for relief, including requests to move cannabis goods to prevent destruction. Now is a good time to review emergency response procedures with your staff and run fire drills if you have not done so recently.

Power Outages

Due to the California Independent System Operator (CallSO) Flex Alert, the state is asking businesses and residents to reduce energy usage in order to prevent service interruptions, and in some areas has shut down power temporarily. We know that your businesses rely on technology for smooth operations and that sudden outages may implicate your security and surveillance equipment, quality control procedures, and your access to inventory tracking systems. In preparation for possible outages, we recommend that you review manual recordkeeping procedures with your employees, and have a draft BCC Notification and Request Form reporting the loss of connectivity ready to be sent. If power outages due to fire or heat conditions are implicating your day-to-day operations, we can aid in outlining best practices for modified procedures.

Remote Audits

In the wake of COVID-19, regulatory agencies are conducting off-site audits with licensees via email. These compliance spot checks request quick turn-around times for providing required documentation such as training logs, testing records, production or harvest batch records, and standard operating procedures. We suggest preparing for a remote audit by taking the time to review and update your internal records to meet state and local requirements. Our compliance specialists can provide tips for on-site recordkeeping best practices, and more details on what to expect in the event of a remote audit. Some documents to be sure you have prepared include:

• Quality SOPs addressing handwashing, personal hygiene, and disease control
• Facility cleanliness procedures, including PPE overview as well as maintenance and equipment logs
• Clear evidence of employee training procedures including training completion logs
• Regulatory compliance test results or production batch records

We hope that you and your employees are safe and healthy. We know this has been a challenging year, and VS is here to support you as needed. Don't hesitate to contact us if you need assistance.