5 most common types of violations:
  1. Failing underage compliance checks (16 individual citations, 7 business citations).
  2. Recordkeeping/METRC compliance issues (22 citations).
  3. Inadequate camera coverage or inadequate security for recording devices (18 citations).
  4. Failing to disclose all owners or financial interests (5 citations).
  5. Failing to ensure employees wore badges (5 citations).

Other categories of violations with about 5 citations each include: Not using RFID tags, making product transfers to marijuana businesses that were not commonly owned, improper waste disposal and recording, and not maintaining transport manifests.

Most severe types of violations:

  1. Undisclosed ownership interests (almost always results in revocation of all licenses and restrictions on future ownership or licensing).
  2. Operating without a license (small or no fine, usually results in license revocation and restrictions on future ownership or licensing).
  3. Butane processing without proper equipment or permits (two incidents, one resulted in license revocation, the other resulted in a $100,000 fine).
  4. Diversion of product (wide range in severity of consequences, deliberate diversion results in license revocation and/or fines up to $150,000).
  5. Deliberately lying to the MED (There were two instance, both of which involved numerous other violations. Both resulted in a fine and license revocation. One was $50,000, one was $21,000).

Listen to commentary on the Marijuana Podcast for more!