The Pennsylvania Department of Health issued a series of draft regulations for comment regarding grower/processors.   Unfortunately, they were not available on the Department’s website for any significant length of time.    Nevertheless, even a quick review of these regulations can provide significant insight for those individuals and businesses interested in cannabis cultivation and processing in Pennsylvania.  While future blogs will include far more detailed insight into these and other proposed regulations, the proposed regulations provide grower/processors with some important information to consider while developing your business plans.

The Department’s draft regulations add several considerations to the basic business plan.   Each of these considerations are extremely important and will need to be presented to the Department along with the grower/processor permit application.   Primarily, these numerous considerations fit into three plans:  Initial Operational Plan; Business Plan of Operation and Diversity Plan.

The Initial Operational Plan can best be considered as the timetable for the grower/processor from start-up to fully operational.    In other words, the Department wants to know that IF a permit is issued, and the onsite investigation is satisfactory, will the grower/processor be able to conduct operations and provide medical marijuana as necessary within the territory and to the dispensaries therein.

The second and most comprehensive plan is the Business Plan of Operations.  Here, the Department delves into the actual day-to-day operations of the grower/processor.    This plan will cover issues such as security, transportation of product, employee policies and procedures, inventory tracking systems, cultivation and processing plans, safety considerations, quality control, sanitation and maintenance, diversion and recall plans and various other considerations.   The regulations detail many of the requirements for each of these areas.  Grower/processors are strongly encouraged to begin planning for each of these considerations during the preparation of their business plans.

The final major plan is the Diversity Plan.   Here, the Department wants to know exactly how the grower/processor will encourage ownership, employment and operations by minorities, women and veterans both in its own operations as well as its contractors.

Grower/processors need to thoroughly evaluate and consider many issues aside from the basic business plan considerations when preparing documentation in support of their applications for permits.   Although this article only provides some of the details of these issues, the time to begin preparing is now.   Start by gathering your team and drafting your proposals.   CILG is happy to work with you in your venture.


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