How to Write a Winning Application in Pennsylvania

Pennsylvania came out with their Medical Marijuana Grower/Processor Permit Application, and it is well thought out, with a few potential headaches for those who haven't done this before. The Pennsylvania Medical Cannabis Society provided me with some insight beyond the application, so first a hat's off to them. Anyway, here are just a few of the subtle issues that most people are going to lose points on. The diversity plan should be applauded - but be careful how you answer. Don' try to accumulate employees based solely on their diversity in order to capture points. Put together the best team, based on qualifications, not sexual preference, ethnic origin or disability. You'll find in the cannabis work force there is sufficient diversity to hire skilled people from any of the different groups of people outlined in Section 615 of the Act (35 P.S. Section 10231.615). Make sure you highlight the fact that you will maintain contracting set asides for women, veterans, individuals with disabilities, etc. Go to https://www.worksforme-pa.org for a fantastic source of individuals with disabilities who are eager to work, and will show the state regulators that your work force is not only diverse, but committed to your enterprise.

The plan of operation is the bulk of the points on the application - 550 out of a possible 1,000. The items that must be covered look straightforward, but don't be fooled. Security and surveillance goes beyond cameras and security guards, so think outside of the box. What are the steps if the facility is robbed or on fire? What are the appropriate steps and in what order? Where will the first aid kits be located in the event of an accident? It's these little things that people overlook and lose points for. Labeling is one of my favorite catch alls for losing points. Anywhere on the web you can find plenty of labeling recommendations, but are your labels tamper proof? Are they resistant to heat? And the one biggest one most people forget - did you put the 800 number for poison control on the label in the event a child gets hold of any products?

What is the facility's return and recall procedures? Can you trace the product to a batch and lot number? What happens if a patient has an adverse effect to the finished product - do you test just what they bring in, or are there samples in storage of each lot and batch in the event you need to retest? Quality control, especially cleaning is a hot button. Will your staff first clean up the big pieces, then dissemble the equipment, clean it, disinfect it, reassemble it, and keep a log of when and who cleaned it, the chemicals used, and data sheets for the products used? Did you remember to mention with nutrients that you will have employees wear disposable HEAVY duty gloves in the event the pH needs to be lowered with some acidic mixture?

Diversion is going to get a lot of people in trouble. When the trash goes out, has it been rendered unusable by mixing it with an inert compound? Are the trash bags clear so the manager can see what's inside of them? Is the dumpster locked by the manager? Is there a surveillance camera there? Is the surveillance camera IP based so management, regulators or law enforcement can view the facility in the event of an emergency? Are the cameras pixel dense and work in low light situations? Is the alarm system on a separate circuit in the event there is a power issue?

I'm not even going to touch the operational timetable, because it's too complicated, and there are a number of overlapping tasks that need to be accomplished in order to meet the timeframe. Think this out carefully, and make sure you can keep the schedule you set. You have a six month window to become operational. Let's touch on transportation. Obviously you are going to want an unmarked car, driving a random route to avoid observable patterns. Does the driver have a binder with the car's registration, proof of insurance, the appropriate transportation licenses, and does the driver have a commercial license? Think this through carefully. The transport manifest section doesn't mention chain of custody from the facility to the driver to the recipient. If you leave those words out, you'll lose serious points.

Winning a license will be based on the highest number of points and other qualifying factors. It's always easy to think about the procedures that should be followed, but make sure you explain what steps will be taken if there is a breakdown in the standard operating procedures. Explain how quality control will be carefully monitored. Speak about random safety drills, and individuals responsible for specific tasks if there is an "adverse event". This is a very through application, so read through it carefully, and make sure you run through every scenario from planting to harvest, and how you will create standard operating procedures for each.