Show me your Corrective and Preventive Action Plan!
By Rebecca Ray, Paralegal and Cannabis Compliance Expert
Starting January 1, 2021, Marijuana Enforcement Division (MED) regulation requires all Medical and Retail Marijuana Stores, Cultivations and Infused Product Manufacturers to have a Corrective and Preventive Action Plan in place. The plan consists of written procedures outlining various elements required by code. Licensees must retain all records and documents as business records required by the MED. Failure to comply with this new rule could constitute a violation affecting public safety. There are eight main elements, listed below, required by Licensees to include in their Corrective and Preventive Action Plans to remain compliant:
What constitutes a Nonconformance in the Licensee’s business operation;
Analyzing processes, work operations, reports, records, service records, complaints, returned product, and/or other sources of data to identify existing and potential root causes of nonconformances or other quality problems;
Investigating the root cause of nonconformances relating to product, processes, and the quality system;
Identifying the action(s) needed to correct and prevent recurrence of Nonconformance and other quality problems;
Verifying the Corrective Action or Preventive Action to ensure that such action is effective and does not adversely affect finished products;
Implementing and recording changes in methods and procedures needed to correct and prevent identified quality problems;
Ensuring the information related to quality problems or nonconformances is disseminated to those directly responsible for assuring the quality of products or the prevention of such problems; and
Submitting relevant information on identified quality problems and Corrective Action and Preventive Action documentation, and confirming the result of the evaluation, for management review.
Did your eyes glaze over half way through that list? Half way through #1?! If so, RZA Legal can prepare a Corrective and Preventive Action Plan and further develop your SOPs after consulting with you on some details of your operations to keep you compliant and focused on your business.
Don't wait until December to make sure that you are prepared to implement a compliant Corrective and Preventive Action Plan. Contact RZA Legal before that January 1, 2021 deadline rolls around!