Maui Medical Dispensary Application Redacted Sec3
Maui Medical Dispensary Application Redacted Sec3
Maui Medical Dispensary Application Redacted Sec3
County
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Table of Contents
STAFF SCHEDULE ...................................................................................................... 13
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NUTRIENT STORAGE AREA .............................................................................................................. 25
PROPAGATION AREA ........................................................................................................................ 25
VEGETATIVE AREAS .......................................................................................................................... 25
FLOWERING AREAS ........................................................................................................................... 25
TRIM AREA .......................................................................................................................................... 26
DRYING ................................................................................................................................................ 26
CURING AREA ..................................................................................................................................... 26
CANNABIS PACKAGING/LABELING AREA ....................................................................................... 26
KITCHEN AREA ................................................................................................................................... 26
EXTRACTION LABORATORY ............................................................................................................. 26
SECURED AREAS ............................................................................................................................... 27
EMPLOYEE BREAK ROOM ................................................................................................................ 27
SECURED PRODUCT STORAGE AREA ............................................................................................ 27
QUARANTINED PRODUCT STORAGE AREA ................................................................................... 27
CHEMICAL STORAGE AREA .............................................................................................................. 27
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EMPLOYEE CONSERVATION ............................................................................................................ 33
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Caryophyllene ............................................................................................................................................. 49
Myrcene ...................................................................................................................................................... 49
Limonene .................................................................................................................................................... 50
Humulene ................................................................................................................................................... 50
Pinene ........................................................................................................................................................ 50
Delta3Carene ............................................................................................................................................. 50
Cineole/Eucalyptol ...................................................................................................................................... 50
CANNABINOIDS .................................................................................................................................. 50
THC ............................................................................................................................................................ 51
THC-A......................................................................................................................................................... 51
CBN ............................................................................................................................................................ 51
CGB ............................................................................................................................................................ 51
CBC ............................................................................................................................................................ 52
CBD ............................................................................................................................................................ 52
CBD-A ........................................................................................................................................................ 52
VARIETIES OF CANNABIS ................................................................................................................. 52
Cannabis Sativa ......................................................................................................................................... 52
Cannabis Indica .......................................................................................................................................... 52
Cannabis Ruderalis .................................................................................................................................... 53
CBD Varieties ............................................................................................................................................. 53
Quantum Cannabis ..................................................................................................................................... 53
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UV Filtration ................................................................................................................................................ 61
ENVIRONMENTAL ZONE SPECIFICATIONS BY ROOM .................................................................. 62
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Magnesium (Mg) ......................................................................................................................................... 73
Sulfur (S) .................................................................................................................................................... 74
MICRONUTRIENTS (TRACE ELEMENTS) ......................................................................................... 74
Micronutrient list ......................................................................................................................................... 74
NUTRIENT SOURCES AND PREPARATIONS ................................................................................... 75
Inorganic and Synthetic Nutrients ............................................................................................................... 75
Organic Nutrients ........................................................................................................................................ 76
Organic Compost Teas ............................................................................................................................... 76
Top Packs................................................................................................................................................... 77
Spikes ......................................................................................................................................................... 77
Organic Bottled Nutrients............................................................................................................................ 77
Hybrid organic/synthetic formulas ............................................................................................................... 77
NUTRIENT DEFICIENCIES COMMON FOR CANNABIS ................................................................... 78
Calcium Deficiency ..................................................................................................................................... 78
Copper Deficiency ...................................................................................................................................... 78
Iron Deficiency ............................................................................................................................................ 80
Nitrogen Deficiency..................................................................................................................................... 80
Phosphorus Deficiency ............................................................................................................................... 81
Potassium Deficiency ................................................................................................................................. 81
Magnesium Deficiency................................................................................................................................ 83
Sulfur Deficiency ......................................................................................................................................... 83
Zinc Deficiency ........................................................................................................................................... 84
Manganese Deficiency ............................................................................................................................... 84
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SEXING A CANNABIS PLANT............................................................................................................. 91
SEED STORAGE ................................................................................................................................. 92
CLONING CANNABIS PLANTS ........................................................................................................... 92
Cloning Process ......................................................................................................................................... 93
Watering Clones ......................................................................................................................................... 93
Cloning Hot House ..................................................................................................................................... 94
Transplanting Clones .................................................................................................................................. 94
Watering Transplants.................................................................................................................................. 94
VEGETATIVE PHASE: SETTING UP FOR SUCCESS ....................................................................... 95
Early Vegetative (V2) .................................................................................................................................. 95
Late Vegetative/Pre-flowering (V3) ............................................................................................................. 95
Transplanting Vegetative Plants ................................................................................................................. 96
Pre-Flowering (V3)...................................................................................................................................... 97
Flowering F1-F20 ....................................................................................................................................... 97
Late Flowering ............................................................................................................................................ 97
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Streptomyces griseovirdis strain k61 ........................................................................................................ 105
Streptomyces lydicus WYEC 108 ............................................................................................................. 105
Trichoderma asperellum ICC 012 ............................................................................................................. 105
Trichoderma gamsii ICC 080 .................................................................................................................... 105
Trichoderma harzianum Rifai KRL-AG2 ................................................................................................... 106
Trichoderma virens G-41 .......................................................................................................................... 106
Reynoutria sachalinensis .......................................................................................................................... 106
COMMON PEST VARIETIES AND SYMPTOMS .............................................................................. 106
White Flies ................................................................................................................................................ 106
Thrips........................................................................................................................................................ 106
Spider Mites.............................................................................................................................................. 106
Aphids....................................................................................................................................................... 107
Fungus Gnats ........................................................................................................................................... 107
COMMON PLANT DISEASES ........................................................................................................... 108
Powdery Mildew ....................................................................................................................................... 108
Root Rot/Pythium ..................................................................................................................................... 108
Mold/Botrytis ............................................................................................................................................. 108
Fusarium Wilt ............................................................................................................................................ 108
ENVIRONMENTAL STRESSES ........................................................................................................ 108
Over-feeding (nutrients) ............................................................................................................................ 109
Root Bound............................................................................................................................................... 109
Light burn.................................................................................................................................................. 109
Over-watering ........................................................................................................................................... 110
Under-watering ......................................................................................................................................... 110
Heat burn .................................................................................................................................................. 110
CO2 burn .................................................................................................................................................. 110
pH Imbalance ........................................................................................................................................... 111
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CURING .............................................................................................................................................. 119
SECURED STORAGE ....................................................................................................................... 119
SEALING PRODUCT ......................................................................................................................... 119
TESTING ............................................................................................................................................ 120
PACKAGING ...................................................................................................................................... 120
Post-Testing ............................................................................................................................................. 121
Packing ..................................................................................................................................................... 121
Final Weight.............................................................................................................................................. 121
Packaging container specifications ........................................................................................................... 121
Labeling specifications.............................................................................................................................. 122
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EMERGENCY PROCEDURES ................................................................................... 135
FIRE EMERGENCY ........................................................................................................................... 135
CHEMICAL SPILL .............................................................................................................................. 135
OTHER EMERGENCIES ................................................................................................................... 135
RECORD KEEPING/DOCUMENTATION .......................................................................................... 135
Documentation/Records Needed .............................................................................................................. 135
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PROCESS FOR RENDERING CANNABIS UNUSABLE ................................................................... 152
DISPOSAL OF CANNABIS WASTE RENDERED UNUSABLE ........................................................ 152
Liquid Waste ............................................................................................................................................. 152
Hazardous Waste ..................................................................................................................................... 152
STATE REGULATIONS ..................................................................................................................... 152
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Job Descriptions
Director of Production
The Director Production will drive the long-range strategic planning process for
operations by overseeing and managing all production operations, including production
itself, and inventory control. The Director of Production will be responsible for the
products life cycle management, maintaining quality, safety, and regulatory compliance
relating to the production facilities. Additionally, the Director Production will be involved
in the development of operations-related plans, capacity, budgets, infrastructure,
policies and procedures.
Director of Manufacturing
The Director of Manufacturing will be responsible and accountable for leading the
scientific group of the organization through the development and execution of the
business plan that achieves the Consumables market by delivering innovative products
to customers. Additionally, the Director of Manufacturing will have close oversight over
analytics, formulations, and extractions. Specifically, in accordance with Act 241, the
Director of Manufacturing will oversee the preparation, propagation, compounding,
conversion, or processing of a substance containing cannabis or its principal
psychoactive constituent tetrahydrocannabinol.
Cultivation Manager
The Cultivation Manager is responsible for executing protocols and standard operating
procedures for all phases of cultivation, including: propagation, vegetative, flowering
and harvest. Must maintain cleanliness standards and oversee daily inspections and
inventory management. Must be able to maintain safe working practices and report
occurrences of diversion and loss or workplace hazards immediately.
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needs to be able to oversee a team of individuals to ensure all plants are ready and
harvesting on schedule.
Vegetation Agent
Vegetation Agents ensures that the vegetative area is always clean, and all production
goals are on schedule. Vegetative assistants shall care for all plants in the vegetative
growth phase, following precise nutrient regimens and pest-prevention procedures in
order to maximize plant health and prepare crops for the flowering phase.
Required experience, qualifications and education: The Vegetation Agent should have a
high school diploma at minimum or an equivalent. The individual should have an
interest in understanding the vegetative stage of the cultivation of cannabis. They need
to be able to collaborate with team members to ensure success of their area.
Clone Agent
The Clone Agent ensures that the demand for new clones of the appropriate strains is
propagated in a manner consistent with the CCO’s schedule for production.
Required experience, qualifications and education: The Clone Agent should have a high
school diploma at minimum or an equivalent. The individual should have an interest in
understanding the clone stage of the cultivation of cannabis. He or she needs to be able
to collaborate with team members to ensure success of their area.
Processing Manager
The Processing Manager oversees all phases of processing beginning at plant harvest.
Phases include curing, trimming, marijuana-infused-products (MIP) production,
processing and packaging. Additional responsibilities include quality control and
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damaged product/waste disposal. Must be proficient with tracking and monitoring
systems. Post-production is the highest risk phase for diversion and loss, and this
position will work closely with the Director of Security to maintain regulatory compliance
and prevent loss. The Processing Manager is responsible for manifesting all finished
products from cultivation facility inventory into the dispensary inventory. Must ensure the
production outputs are in line with the workflow.
Processing Agents
The Processing Agent is responsible for curing, trimming, processing into MIP and
packaging of all cannabinoid products. Experience and qualifications include the ability
to perform repetitive tasks for a continuous period.
Required experience, qualifications and education: The Processing Agent should have
a high school diploma at minimum or an equivalent. Basic labor skill set required, with
experience working within a manufacturing or agricultural setting preferred.
Required experience, qualifications and education: The Packaging Team Lead should
have a bachelor or associate degree from a college/university. The individual’s
background should be within management, preferably in the agriculture field or
packaging industry. He or she needs to be able to oversee a team of individuals to
ensure all packaging is ready and on schedule for delivery to dispensaries.
Packaging Agent
Packaging Agents are responsible for packaging all products produced by the facility.
Cannabis Packaging Agents will also ensure that the cannabis-infused-products portion
of the facility is always clean and sanitary and all production goals are on schedule.
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The Cannabis-Infused Products Manager ensures that the demand for medication of the
appropriate strains and varieties are available for patient purchase that is in a manner
consistent with the CCO’s schedule for production. Lead agents are responsible for
ensuring smooth and efficient daily operations. Managers will also be in charge of direct
supervision of cannabis-infused-products agents.
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PayChex Services
Payroll Services
In addition to processing the organizations regular payroll for both exempt, and non-
exempt employees, Paychex will ensure compliance with federal and state regulations
in regards to payroll taxes by managing withholdings for federal, social security,
Medicare, state & local taxes, and also provide end of year W-4 processing.
Employee Handbook
Paychex offers a service that will assist in writing the employee handbook that
implements company specific policies, and matches company culture, while still
maintaining regulatory compliance with local, state, and federal law.
In addition, the EAP program offers a wellness program. The wellness program includes
a comprehensive health risk assessment, up to three sessions with a personal wellness
coordinator hot help navigate wellness services, 24/7 access to a virtual fitness trainer,
and wellness tools, trackers, and articles.
Recruiting and applicant tracking will be streamlined through the use of the Paychex
applicant tracking system to assist in creating a positive candidate & new hire
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Safety Plan
Training
Maui Medical Marijuana Dispensary LLC, will provide training upon hire as well as
annually to each employee including but not limited to:
Record keeping
Maui Medical Marijuana Dispensary, LLC, will retain all records, both physical and
electronic for a minimum of six years. Electronic data will be encrypted and stored on
secure servers in secure storage areas under 24-hour video surveillance. Physical
records will also be stored in a secure storage room under 24-hour surveillance. The
secure storage room will have limited access. The Dispensary may utilize biometric
security measures as well as pin number protection. Access Logs will be analyzed daily
to ensure no unauthorized entry has occurred. Access Logs, as well as all other
records required by the department in HAR §11-850-41, will be stored for a minimum of
six years including but not limited to:
Inventory Tracking
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Sales records will be retained for each individual qualifying patient and primary
caregiver to reflect compliance with dispensing limitations as required by HAR
§11-850-42.
Financial Records
Logs recording every individuals entrance and exit from the Dispensary.
Employee Records
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Team Meetings
Team meetings will be implemented organization-wide and will provide opportunities for
team members to receive updated training as required by 11-850-34(d) and chapter
329D, HRS, and to discuss current trends and ideas on how to make processes more
effective or efficient. Team meetings will, at the very least, be held once a week for each
facility as well as a weekly meeting between all facility managers.
Shift Meetings
Shift meeting will be held on a daily basis between team members and the facility
manager or department leads. A shift meeting will be held prior to the start of business
each day to discuss workflow and goals for the shift. A meeting will also be held at the
closure of business to discuss the day’s operations and to determine if shift goals were
achieved.
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Receiving Areas
In accordance with §11-850-61 subsection (a), after medical cannabis products are
transferred from the dispensary or are received from a wholesale distributor, they must
be inventoried and checked in. These products are then assigned an attribute number
or ID for inventory tracking and POS identification. These products can then be
transferred to the cannabis-infused products production area for processing and
manufacturing. The facility manager is responsible for this area.
Propagation Area
All clones are stored in the propagation area until they are ready to be transplanted and
transferred to a vegetative area. The propagation must be maintained at 80°F/26.7°C
and 80% relative humidity. The vegetative manager is responsible for maintaining this
area.
Vegetative Areas
The vegetative area is where plants are grown to the appropriate size before being
transferred to the flowering area. The vegetative area consists of 3 zones: mother plant
quarantine (V1), early- veg area (V2), and the pre-flowering area (V3). Lighting
remains on for a minimum of 18 hours a day within all vegetative zones. The vegetative
manager is responsible for maintaining this area.
Flowering Areas
The flowering area of the dispensary is where full size plants produce flowers. The
flowering area is divided into many zones. Plants grow in each zone for 9 weeks before
being harvested. All flowering areas must receive 12 hours of uninterrupted darkness in
order for plants to produce flowers. Light interruptions will cause plant stress that could
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Robbery or Theft
If being robbed at gunpoint or you feel your life is in danger, comply with all
requests from perpetrator. Give them whatever they ask for.
Try to signal for help through security panic buttons provided or through the panic
button or police services button located on the alarm panel.
Contact police as soon as possible
Notify any required state or local authorities
Fire Emergency
If fire is small and isolated, try to exhaust the fire with one of the fire
extinguishers.
In case of a fire emergency, dial 911 for Fire Department or push the symbol on
the alarm panel for fire emergency.
Chemical Spill
Try to use chemical spill kit for smaller incidents of chemical spill.
If chemical spill is large or you do not know how to handle the situation, get the
facility manager to handle the situation.
Other Emergencies
Contact 911 for break-ins or burglaries.
Contact any required state or local authority in cases of theft, break-ins or
burglaries.
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The intent is one of mutual respect between neighbors; to avoid adversarial positions, to
treat others as one would like to be treated; to keep an open mind; and be willing to
cooperate with neighbors with a goal of creating a safe and healthy neighborhood
environment.
MMMD, LLC has worked hard to build positive relationships with the residents and
businesses and will continue to build relationships with the community through:
In order to neutralize the odors associated with growing healthy plants, MMMD, LLC will
utilize a three-phase odor reduction system to eliminate odor within and around our
production facility. Highlights of this plan are as follows
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Environmental Plan
Conservation and the reduction of our carbon footprint within the communities we
operate in is a primary objective of the organization. This will be implemented
throughout the entire organization and at every facility. We will look for new and
innovative ways to reduce our carbon footprint within the dispensary and/or the
dispensing organization facility. ‘Reduce, Reuse, and Recycle’ will be implemented on
an organization-wide scale.
The dispensary management will also create and implement an employee conservation
plan. The employee conservation plan will detail specific actions employees can take for
conservation efforts to try and reduce their carbon footprint. A possible reward program
may be created and implemented to reward facility employees for conservation efforts.
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Climate Plan
Additional carbon offsetting shall be utilized to ensure that our carbon footprint is fully
eliminated.
Wind energy credits shall be purchased in the direct amount needed to offset
the total energy consumption of the dispensary.
Solar technologies continue to advance in the ability to produce more energy
and are becoming more affordable. Solar shall be utilized in addition to wind
energy to offset and eliminate carbon emissions.
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New high frequency ballast with double-ended HPS bulbs have surpassed all
current lighting in production per watt and per square foot. What this means is
overall electrical consumption is reduced by 20-30% over traditional HPS
technology when utilized within the flowering areas of the dispensary.
LED
LED lights allow you to provide the optimal lighting spectrum for photosynthesis.
They are perfect to utilize in vegetative growth and can replace lights such as
metal halides, easily reducing vegetative electrical consumption for lighting by
20-30%. LEDs also produce substantially less heat therefore reducing cooling
cost by around 50%.
Florescent
Florescent lighting technologies are perfect for early vegetative growth and
mother plants. They use far less electricity and produce very little heat, making
them perfect for reducing overall electrical consumption.
Water Plan
Facility procedures utilizing water will be created with conservation in mind.
Smart Filtration
Re-capturing
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Our gardening requires minimal run-off from the watering of plants and little to no
additional nutrient needs to be added to the water. All water that does run off
from daily watering practices can be captured and filtered along with any water
used for cleaning within the facility.
Employee Conservation
Team members within the cannabis-infused products facility will recycle all paper and
plastic waste products. Energy efficient lights and equipment will also be utilized within
the facility. We will also create programs within the organization that will encourage and
reward employees for their personal conservation efforts, such as carpooling and riding
a bike to work. Waste products from the facility will be composted on-site or mixed with
biodegradable products for disposal.
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Inventory/Tracking Requirements
Inventory management is a critical factor in every area of the dispensary. Pursuant to
§11-850-61, subsections (a) (c) and (d), The tracking of all medical cannabis from seed-
to-sale will be done through an advanced electronic inventory control system with
multiple checks and balances in place to allow our staff to have a complete awareness
of all inventory through each stage of processing from propagation to point of sale,
disposal, or destruction including: seedlings and clones, vegetative plants, flowering
plants, harvested plants and batches, curing batches, pre-tested dry flower, pre-tested
trim, post-tested approved dry flower, post-tested approved trim, all unapproved
(quarantined) flower and trim, extractions, infusions, and waste. The electronic inventory
control system will allow the department to monitor in real-time, the dispensary’s
tracking system and inventory records. All data collected shall be recorded through the
use of template log sheets, computer systems, Secured Information Systems (SIS) and
Point-of-Sale systems (POS). In accordance with §11-850-61 subsection (a), the
dispensary will maintain a record of clear and unbroken chain of custody at all stages.
Physical inventory counts will be done on a daily, weekly, and monthly basis at the
cannabis-infused products facility in addition to scheduled inventory checks random
audits will be performed. Inventory control procedures shall be utilized as the primary
way of determining whether there has been any product diversion and ensuring that all
medical cannabis and cannabis-infused products are only being distributed to licensed
dispensing organization facilities and licensed, valid state medical cannabis patients.
Physical inventory template log sheets will be filled out each morning before the start of
business and again at the closure of business. All weekly inventory/tracking requirement
procedures shall be conducted in full compliance with §11-850-61 (a) (c) and (d). Data
collected during daily, weekly, annual and random inventory procedures shall be logged
and input into computer, SIS, and POS systems. Inventory figures will be cross-
referenced with the POS system inventories and data to determine that there are no
quantity discrepancies and the chain of custody is maintained in a clear and unbroken
manner. In the case of a discrepancy within inventory, we will investigate the root cause
of the discrepancy to determine the cause. If the discrepancy is due to employee theft
or diversion, we will act quickly to terminate the employment of the perpetrator and
contact all necessary authorities for further action. All inventories, procedures, and other
documents required by the department shall be maintained on the premises and made
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Inventory Control
Our organization shall designate in writing a medical cannabis establishment agent who
has oversight of the inventory/tracking control system of the medical cannabis
establishment. The compliance manager will be responsible for oversight of the
inventory control system. The following information outlines how the dispensary staff will
maintain inventory control within the dispensary.
The compliance manager is the designated agent who shall oversee the dispensary
inventory control system at all times in order to ensure that daily inventory
documentation, batch specific documentation, product transfers, inventory
discrepancies, and record keeping are always maintained and up to the minute. The
appropriate dispensary staff member shall document the following items as they occur:
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For each batch of cannabis cultivated, the processing manager shall document
the following into the inventory control system:
o The batch number;
o Whether the batch originated from cannabis seeds or cannabis cuttings;
o The strain of the cannabis seeds or cannabis cuttings planted;
o The number of cannabis seeds or cannabis cuttings planted;
o The date on which the cannabis seeds or cuttings were planted;
o A list of all chemical additives used in the cultivation, including, without
limitation: nonorganic pesticides, herbicides, and fertilizers;
o The number of cannabis plants grown to maturity;
o Harvest information, including, without limitation: the date of harvest, the
final yield weight of processed usable cannabis, and the name and
medical cannabis establishment agent registration card number of the
medical cannabis establishment agent responsible for the harvest; and
o The disposal of cannabis that is not usable cannabis, including a
description of and reason for the cannabis being disposed of, including, if
applicable: the number of failed or other unusable cannabis plants, the
date of disposal, confirmation that the cannabis was rendered unusable
before disposal, the method of disposal, and the name and medical
cannabis establishment agent registration card number of the medical
cannabis establishment agent responsible for the disposal.
All data pertaining to the disposal of all cannabis that is not usable shall be
tracked in the inventory control system including:
o A description of and reason for the cannabis being disposed of, including,
if applicable, the number of failed or other unusable cannabis plants;
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Product Information
For each batch of cannabis produced in the dispensary, the following information
shall be recorded for internal use and to be made available to the purchasing
dispensary upon or prior to delivery:
o The batch number
o Whether the batch originated from cannabis seeds or cannabis cuttings
o The strain of the cannabis seeds or cannabis cuttings planted
o The number of cannabis seeds or cannabis cuttings planted
o The date on which the cannabis seeds or cuttings were planted
o A list of all chemical additives used in the cultivation, including, without
limitation, nonorganic pesticides, herbicides and fertilizers
o The number of cannabis plants grown to maturity
o Harvest information, including, without limitation:
The date of harvest
The final yield weight of processed usable cannabis
The name and medical cannabis establishment agent registration
card number of the dispensary agent responsible for the harvest
Loss or Theft
o In the event that any loss or theft of cannabis from the dispensary occurs,
the compliance manager shall document and report the incident to the
appropriate law enforcement agency and to the department. All records
and documentation required shall be maintained for a minimum of six
years after the date recorded of the documentation. Copies of the
documentation shall be made available to the department for review upon
request.
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All cannabis in the process of production, distribution, transfer or analysis shall only be
accessible only to the minimum number of specifically authorized personnel essential
for efficient operation, and shall be returned to its secure location immediately after
completion of the process or at the end of the scheduled business day. If a production
process cannot be completed at the end of a working day, the processing area or tanks,
vessels, bins or bulk containers containing cannabis shall be securely locked inside an
adequately secured area. All cannabis and manufactured cannabis products will be
tracked electronically to maintain clear and unbroken chain of custody at all stages.
Chain of custody
The chain of custody of all cannabis and cannabis-infused product shall be
documented, through scanning and logging, at all times as it moves through each
process within the dispensary. Chain of custody documentation shall be maintained for
six years and shall be made available to the department and SP upon request. All
plants within a plant group shall be given a unique batch number during the initial
transplant. Batch numbers shall remain with each plant and plant group through final
packaging and sale. Transplanting shall occur prior to a plant reaching 18 inches in
height. At the time of transplant form clone to the second vegetative phase, all plants
shall be assigned a specific number and tagged with an individual tag containing the
batch number and plant number. Information pertaining to each plant, and batch of
plants, including the strain and location, shall be recorded electronically (RFID) or kept
in an electronic file until harvest or destruction. All plants shall be physically inventoried
on a weekly basis by the cultivation team and records of the inventory shall be kept at
the facility for a minimum of six years. All batch movements shall be tracked and
recorded so their physical location is known at all times during the cultivation and
production processes. Any plants removed from a batch shall be recorded on a
permanent record and maintained on-site for a minimum of six years. All batch numbers
shall be included on approved labels for all products designated for distribution to a
dispensary. See plant inventory for detailed tracking processes.
Independent laboratory staff may enter the dispensary for the sole purpose of
identifying and collecting cannabis samples for purposes of conducting laboratory
tests.
Emergency personnel may enter the dispensary when necessary to perform their
duties.
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All persons who are not dispensary agents, but who are permitted on the premises of
the dispensary pursuant to subsection HB 321 §-16, shall obtain a visitor identification
badge from dispensary security personnel prior to entering the dispensary, and shall be
escorted and monitored at all times by licensed agents of the dispensary. Visitor
identification badges shall be visibly displayed at all times while the visitor is within the
dispensary. All visitors must present a valid government issued identification card with a
picture in order to be permitted within the premises. All visitors shall be logged in and
out, and that log shall include the date, time and purpose of the visit and shall be
maintained and made available to the department, at any time, for a minimum of six
years. All visitor identification badges shall be returned to dispensary security personnel
upon the visitor exiting the dispensary.
Not produce or maintain cannabis in excess of the quantity required for normal,
efficient operation;
Store all cannabis and cannabis-infused products in a safe, vault or secured
room and in such a manner as to prevent diversion, theft or loss;
Maintain all cannabis that is not part of a finished product in a secure area or
location within the dispensary accessible only to specifically authorized
personnel, which shall include only the minimum number of employees essential
for efficient operation;
Keep all approved safes, vaults, or other equipment or areas used for the
production or storage of cannabis securely locked or protected from entry, except
for the actual time required to remove or replace cannabis;
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If a loss, theft or diversion of cannabis has occurred from the dispensary, the dispensary
agent in charge shall notify the department and the nearest SP district immediately. The
department and SP shall determine the appropriate storage and security requirements
for all cannabis in the dispensary and may require additional safeguards to ensure the
security of the cannabis. If a reduction in the amount of medical cannabis in the
dispensary’s inventory is due to suspected criminal activity, the dispensary agent in
charge shall immediately report the reduction to the department and SP.
All areas of the dispensary containing cannabis, including any rooms with approved
safe or approved vaults, shall have a sign posted at all entryways, which shall be a
minimum of 12 inches in height and 12 inches in length and shall state: "Do Not Enter −
Limited Access Area – Access Limited to Authorized Personnel Only" in lettering no
smaller than one inch in height.
No dispensary agents and/or security policies shall prohibit members of the department,
local law enforcement or other federal, state, local government officials, or persons
authorized by the department from entering any area of the dispensary to perform their
governmental duties, in accordance with § 11-850-37 subsections (b) (c) and (d).
Pursuant to §11-850-32(a), the dispensary will provide the department with the address,
tax map key number, and a copy of the premises title or lease of the proposed location
of the production center and allow the department to inspect the premises in compliance
with this law and 329D HRS, at least 30 days prior to producing cannabis or
manufacturing cannabis products at the dispensary.
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All inventories, procedures and other documents required by HB321 §-6 and § 11-850-
61(a)(c) and (d) shall be maintained on the premises and made available to the
department at all times.
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The dispensary will submit quarterly reports on the 15th of each quarter, thus, on
January 15, April 15, July 15, and October 15. (Reports will be considered on time if
submitted the next day if the 15th is a Saturday, Sunday or a State holiday.) Reports
shall include, but are not limited to pursuant to HAR §11-850-38:
Records of entry and exit for all individuals who entered the facility
Amounts by category of cannabis products manufactured and offered for sale by
the dispensary
Amounts by category of cannabis and manufactured cannabis products sold by
the dispensary
A list of all cannabis, manufactured cannabis products, or unusable cannabis
materials that have been destroyed or will be destroyed by the dispensary
A summary of the financial statement
Laboratory results of all tests that were conducted
Description of any breach or halt in the dispensary’s security system and tracking
system
Any additional/other information requested by the department
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Visitor Log
Cleaning Log
The dispensary manager is responsible for overseeing the use of a daily cleaning
log to track cleaning within all zones of the dispensary.
Maintenance Log
A facility maintenance log will be utilized to track maintenance and upkeep on all
equipment within the dispensary.
To ensure all grow lighting is maximized, the light produced by each lamp must
be checked on a monthly basis by the dispensary staff. The dispensary
cultivation manager shall work with each zone manager to measure lighting
throughout each growing zone in the dispensary.
Plant growth zone managers will be responsible for tracking and logging all pest
and disease control measures within the dispensary.
Plant growth zone managers will be responsible for tracking feeding schedules in
all growth zones for which they are responsible. Any change or variance in the
respective plant-zone feed schedule must be noted and brought to the attention
of the dispensary manager.
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The transfer log tracks all plant movement throughout the dispensary. The
vegetative manager is responsible for tracking plant movements before flowering
begins.
Harvest Log
All flowering zone harvest schedules are tracked on the dispensary harvest log.
The flowering zone management team is responsible for updating this log and
noting any variances to the CFM.
All zone managers are responsible for performing daily inspections and
communicating all variances to the dispensary manager. All zones must comply
with the information designated in the growing environment and quality control
section. The daily inspection log includes:
o Room temperature: zone manager
o Humidity: zone manager
o CO2: zone manager
o Electrical and lighting: zone manager
o Pest and disease: zone manager
o Photoperiod: zone manager
Curing Log
A curing log shall be maintained by the processing manager to track the time
specific strains and batches are in the curing area. In addition to time,
environmental conditions such as temperature and humidity are also recorded.
Testing Log
A testing log shall be maintained by the processing manager to keep track of all
batches, their respective test dates and results.
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Each plant shall be tracked by its physical grid location in the premises at all times. All
significant dates and observations will be recorded as key data points in the SIS for
referencing needs throughout the plant's life cycle. This information can be used to
recall any contaminated medium, nutrient, or issue that may occur during the stages
listed above and allows for easy removal from production or inventory of any product
that does not meet the requirements of the state.
An inventory of cannabis in the cultivation stage shall be conducted each week. During
the cultivation process, physical location will be broken up into a grid system and each
square will have a designated number of plants per grid area.
Auditing the inventory of all plants shall be effectively and efficiently accomplished with
spot checks done daily to mitigate any diversion during cultivation, processing and/or
packaging, as well as detecting any human error that may have occurred while entering
information during the plant’s life cycle.
After the flowering cycle has been completed and the plant is harvested, inventory shall
be transitioned from the flowering zone to the processing department, and prepared for
trimming. During this transfer, all product will be scanned, tracked and logged. At this
point, a pre-trimming weight will be determined and logged.
After being weighed and logged, all flowers will be cleaned, trimmed, and prepared for
drying in the secured vault. Each batch is transferred through each state with the
entirety of the batch. All green waste from the trimming process shall be weighed,
logged and disposed of according to our policy for managing waste from cannabis
plants (see transportation protocol).
After drying and curing, each batch shall be tested for efficacy. Once a batch has
passed all regulated testing protocol and our standards set forth by business
management, it shall be released for packaging and labeling. Before being transferred
to packaging, the entire batch will be weighed again, scanned and logged into the SIS
via RFID.
As each package is wrapped and processed, each individual package will be weighed
again and reconciled against the total batch weight. Once packaged, all product shall be
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Terpenes
Terpenes are compounds that constitute what is arguably the largest and most diverse
class of natural products. The majority of these compounds are found in plants. They
provide the flavor and the smell to cannabis, but also provide an array of medicinal
benefits. The dispensary cultivation manager shall plan production of a wide range of
strain varieties in order to produce multiple terpene profiles and combinations in order to
treat the varying conditions within multiple patients. The following are examples of
terpenes commonly found in cannabis and their medicinal benefits:
Linalool
Caryophyllene
Rich spicy, sweet, woody, clove, camphor, pepper. Anti-septic, anti- tumor, anti-
inflammatory, anti-fungal, anti-bacterial.
Myrcene
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Humulene
Pinene
Delta3Carene
Pungent, sweet, pine, woodsy, cedar. Can help dry excess fluids such as runny
nose and perspiration.
Cineole/Eucalyptol
Cannabinoids
There are over 480 natural components found within the cannabis plant, of which at
least 85 have been determined to be cannabinoids. Cannabinoids are chemicals found
in animals and other plants as well, but nowhere are they more abundant and effective
than in the cannabis plant. The most well-known and researched of these is THC or
delta-9-tetrahydrocannabinol. THC is the substance primarily responsible for the
psychoactive effects of cannabis.
Like opiates and opiate derived pharmaceuticals, cannabinoids affect the user by
binding with receptors within the cells of the body and different parts of the central
nervous system. There are at least two kinds of cannabinoid receptors found to date,
termed CB1 and CB2. Anandamide is a cannabinoid-like substance found within the
brain commonly referred to as the “Bliss Molecule.” Naturally occurring anadamide
binds to CB1 receptors. Other naturally occurring substances that bind to CB1 have
recently been discovered, and these, together with the receptors, have been termed the
endogenous cannabinoid system or endocannabinoid system.
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The dispensary cultivation manager shall review test results for every batch in order to
ensure that multiple strains are produced with varying cannabinoid profiles in order to
properly and accurately provide medicines to treat multiple patients with different needs.
By combining different cannabinoids and different terpene profiles, the possibilities for
medicinal healing are vast. The dispensary cultivation manager shall utilize cannabinoid
profiles when planning for strain production at all times. The following cannabinoids are
all known to provide different effects and medicinal benefits:
THC
THC-A
CBN
(Cannabinol) As THC oxidizes from exposure to heat and light, it turns into CBN.
CBN is only mildly psychoactive and highly sedative.
CGB
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Cannabichromene has been shown to be 10 times more effective than CBD for
treating anxiety. CBC also stimulates bone growth. It is non-psychoactive.
CBD
CBD-A
CBD-A is more commonly found in the ruderalis varieties, which are often bred
with sativa and indica varieties for their auto flowering abilities. CBDA has been
linked to anti-tumor and anti-inflammatory effects.
Varieties of Cannabis
Cannabis Sativa
Cannabis sativa is the tallest variety of cannabis. All other varieties most likely
evolved from the sativa plant. Most hemp is actually sativa. Sativa varieties are
thin and wispy, most likely from evolving in hotter regions of the world where
adequate airflow between branches was necessary to remain disease free. 100%
sativa strains take up to six months to flower and can grow extremely tall making
true sativa unsuitable for indoor and commercial production. The sativa strains
commonly grown for medicine are actually hybrids that have been bred with
indica varieties to shorten both their height and flowering time. Sativa produces a
cerebral effect that can be energizing, followed by an increase in appetite. Sativa
hybrids are very helpful for anyone experiencing loss of appetite such as those
undergoing chemotherapy or patients with HIV/AIDS.
Cannabis Indica
Cannabis indica is short and bushy with thick stems. Most likely evolving in the
cooler regions of Asia and Afghanistan, cannabis indica has a short flowering
time, most likely to complete its reproductive cycle prior to freezing conditions.
Most medicinal varieties of cannabis are a derived form of indica, and its
cannabinoid profiles are well-balanced producing significant levels of THC, CBD,
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Cannabis Ruderalis
Cannabis reuderalis is of very poor quality and is only grown in hybrid form with
sativa or indica due to its auto flowering capabilities. For the most part, ruderalis
hybrids should be avoided in indoor cultivation. Ruderalis is the shortest
cannabis variety, and it has minimal branching. Avoid all seeds and strains that
state they are auto flowering.
CBD Varieties
CBD varieties are now being bred as they offer many of the medicinal benefits of
cannabis with little to no psychological effects making them suitable for children
and adults who wish to remain clear headed. CBD effects on THC can be noticed
with as little as 1% CBD, however, the ratio of THC to CBD can be widely
influenced and tailored to create the desired effect for a particular ailment or
specific patient. One-to-one ratio strains often have the best of both worlds where
the psycho effects of THC are diminished by CBDs, however, all the medicinal
effects from THC remain intact.
Quantum Cannabis
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Key findings:
Accumulation of CBG, CDB, CBC and THC is under genetic control
Genetic variation, needed for classic breeding to succeed, has been
demonstrated to exist.
Studies demonstrate clear and repeatable segregation for accumulation of
cannabinoids, emphasizes need for genetic diversity in genetic library/collection
Demonstrated that breeding efforts can be utilized to stabilize chemotype
Published genetic model below:
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The rare plants can be found through repeated chemotype analysis; requires
close collaboration with analytical lab to regularly test young plants.
Challenges:
Low amounts found: 0-4% w/w (15-100% CBC by weight of total
cannabinoids) %CBC increases with decreased light. To maximize yield,
research needs to balance plant growth and CBC accumulation.
Requires repeated chemotype analysis with first true leaves and then
confirmation of % accumulation of mature floral structure.
Pure CBD lines may be difficult to achieve due to shared genetic pathway with
THC. Highest CBD lines may accumulate a minor percentage of CBC, CBG,
and/or THC. Similarly, high THC lines may accumulate a minor percentage of
CBD, CBC, and/or CBG. Challenge is to improve accumulation and purity with
breeding.
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Methods described in great detail in Lata et al., 2009; specific method optimized
for Cannabis. Proven genetic and chemotype stability over several generations.
Protocols/Methods demonstrated commonly online; sterile technique required
utilizing clean air hood.
Breeding 101
There are three main steps to breeding:
Evaluate
Select
Recombine
Mate only high performers based on improved chemotype and phenotype. Sow
seeds and Evaluate progeny to begin the breeding cycle again.
Result
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Repeat sowing 100 seeds, evaluation, and selection until plants closely resemble each
other in desired chemotype and phenotype.
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It is the goal of the dispensary team to deliver the highest quality, purest cannabis with
consistency of dosage. To achieve these high standards, the dispensary is engineered
for year-round production. Our growing rooms are all capable of maintaining constant
environmental conditions including temperature, humidity, and CO2. In addition, we
introduce fresh air through an advanced smell-eliminating air flow system that works in
conjunction with other controls such as UV light to avoid all mold, bacteria, mildew and
fungal outbreaks. Our closed loop ventilation system will lessen the potential of pest
contamination and reduce the need for any organic pesticides.
The microclimate within each section of the dispensary must be constantly maintained
in order to prevent pest and disease and achieve the highest and purest quality. In
order to maintain an optimal environment, the dispensary cultivation manager shall
ensure that the following conditions are constantly maintained:
Temperature Control
Humidity
Air Circulation
Circulation fans are used to improve air quality, strengthen plants, and prevent
pest and disease. Circulation fans will be placed every four to six feet throughout
all growing and drying areas of the dispensary. We will keep fans running 24
hours a day.
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Air and humidity will leave each growing space through an activated carbon filter
via a main trunk line.
Odor Reduction
After air leaves each working area, it is filtered through carbon a second time and
then treated with ozone before leaving the building through a roof top stack.
Detailed description of air treatment systems that will reduce off-site odors:
The dispensary will contain a three-phase odor reduction system to eliminate
odor within and around our production facility. Cannabis production is organized
into a series of separately sealed zones including but not limited to: vegetative,
flowering, trimming, curing, storage, processing, infused products, and hallways
connecting rooms. Within each zone, a predetermine number of activated carbon
filters will circulate and scrub the air at a flow rate calculated to filter all the air in
the room every 15 minutes. Each zone will maintain neutral air pressure created
by exhausting the air through one point at the same rate fresh air enters the
zone. The exhaust from each zone is filtered a second time through an activated
carbon filter before entering a sealed ducting system to be transferred to a
common air bank. Before exiting the building through a filter system, all exhaust
is filtered a third time through a series of activated carbon filtration screens
thoroughly reducing odor emission rates.
Carbon Dioxide
CO2 levels shall be maintained at 1,000 ppm in all vegetative areas and 1450
ppm in all flowering areas. CO2 levels shall be monitored daily by the dispensary
staff.
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Vegetative lighting will consist of florescent lighting for mother plants, clones, and
early vegetation. Larger vegetative plants will be placed under LED or 600-1,000
watt Blue Metal halide lamps to achieve appropriate size to be transferred into
the flowering area. Flowering plants will be grown using 1,000 watt E-Papillion
with high-frequency adjustable strength ballasts or equivalent lighting. Lighting
shall be monitored daily by the dispensary staff and intensity verified and logged
monthly.
Drainage
All plants not in auto-pot or hydroponic systems will need appropriate drainage.
Drainage shall be achieved through the plumbing of each growing surface and
will be brought to a central floor drain located in each section of the dispensary.
Drainage shall be monitored daily by the dispensary staff.
UV Filtration
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Short Life
Relative to humans, the cannabis plant lives for a very short period of time. Plants within the
dispensary will live an average of 3.5-4.5 months. This short life span means you can see the
direct effects associated with the “energy” surrounding them during their life cycle.
Positive Attitude
It is important for the growing facility staff to leave negative energy at the door and come to
work positive and happy. Plants can pick up on human energy and are affected by it.
Sun Energy
While it would be great to utilize the sun alone, cannabis gardening must be done indoors for
security and discretionary purposes. Innovation in lighting plays a key role in quantum
cannabis gardening. The QC gardener is always watching the latest technology with a patient
eye. In QC gardening, the best light to replace the sun is the light that produces the most
grams per watt per sq. ft. and produces excellent quality finished product.
Components of photosynthesis
Hydrogen, carbon, and oxygen are essential non-mineral elements necessary for plant growth
as all play major roles in photosynthesis. Photosynthesis is a process used by plants and other
organisms to convert light energy, traditionally from the sun, into chemical energy that later can
be utilized to fuel the organisms' activities. Light energy is used to form glucose from CO2
taken in by leaves and water taken in through the root system. Oxygen, which humans
breathe, is a bi-product of plant respiration.
Stomata
As part of the photosynthesis process, plants take in CO2 and other nutrients through
tiny holes in the leaf surface called stomata. Be aware that spray pesticides can clog up
stomata. Each zone manager is responsible for utilizing ethical pest management
(EPM) practices.
Temperature
Plants uptake more CO2 in warmer environments, however, cannabis quality also
diminishes at higher temperatures; therefore, we utilize a comfortable mid- range
temperature no higher than 78° F/ 25.5° C. Each zone manager is responsible for
keeping temperature at the above-mentioned temperatures. All variances shall be
reported to the dispensary manager.
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Plants thrive in humid conditions. To avoid fungal issues, humidity must be kept in the
mid-range. Each zone manager is responsible for keeping humidity at or lower than
55% in vegetative zones, and 45% in flowering zones. Zone managers will report any
humidity variances to the dispensary manager.
CO2
CO2 level should be maintained at or below 1500 in all flowering rooms and 1,000 in all
vegetative rooms unless otherwise dictated by the dispensary manager. Each zone
manager is responsible for monitoring CO2 levels within their respective zone and
reporting any variances to the dispensary manager.
The dispensary manager will determine the initial water quality in order to implement an
adequate filtration process. Reverse osmosis is only recommended as a last resort as it
removes all micronutrients from water. In the event reverse osmosis must be used, the
dispensary cultivation manager shall ensure an adequate replacement formula to meet
all plant requirements.
Under-watering
If plants wilt prior to watering, and the soil is dry, plants are severely under-watered. If
plants wilt immediately after watering, it is also likely they are being under-watered.
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Over-watering
Over-watered plants will also wilt, however, the medium will be very soggy vs. dry.
Over-watering plants, in effect, drowns them and stunts overall growth by hindering
proper root development. If it is determined a root zone is over-watered, it is imperative
to allow the medium to fully dry and then begin to re-moisturize slowly just as if the plant
were recently transplanted. The addition of mycorrhizae and nutrient teas can help re-
invigorate a plant's root zone and decrease the recovery time after over- watering has
occurred. The dispensary manager shall work with each zone manager to avoid and
correct over-watering scenarios.
o Water prep: Each zone manager is responsible for preparing the water to be
used for plant cultivation within his or her respective zone. Preparing water is a
two-part process:
o Filtration: All water should be filtered through, at a minimum, a two-stage
filtration process. Water should be filtered a minimum of 24 hours in advance to
prepare for aeration.
o Living Water: All water should be brought to “life” by properly aeration. Air-
stones shall be placed at the bottom of all water reservoirs after water has been
properly filtered. Aeration time is a minimum of 24 hours.
Vortex: When mixing nutrients, water shall be stirred in an alternating
clock- wise and counter clockwise motion. When water is stirred in a
vortex motion, it becomes electrically charged and allows for better
nutrient absorption. All zone managers shall utilize a vortex motion while
mixing solutions to be applied to crops.
Vortex mixing instructions: Stir 20 seconds until a vortex occurs in one-
direction and then reverse the direction
Optimal pH
Cannabis absorbs available nutrients best in the pH range of 5.8-6.5. The plants' pH shall be
checked before and after mixing nutrients and adjusted accordingly by the zone manager for
each respective zone. Cannabis absorbs nutrients better in slightly more alkaline conditions
when in soil rather than in hydroponic gardens.
Lighting
Light provides the energy to turn water and CO2 into usable plant food (glucose) and oxygen
during photosynthesis. When the optimal lighting spectrum and strength combine with CO2,
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HID lighting
High Intensity Discharge (HID) lighting is currently the best replacement for the natural
sun, which is by far the best light for production, taste, terpene profile, and root
formation. Producers of agricultural lighting products have created HID lighting to
attempt to mimic the sun for indoor growing purposes.
HPS
High Pressure Sodium (HPS) lighting has been the go to light for vigorous growth
indoors for years. Traditional HPS produces the most intense light and helps plants
reach a large size and produce large amounts of resinous flowers. Recently LED
lighting has proven itself to be a slightly better choice than traditional HPS, however,
new HPS technologies have surpassed current LED lights in production capacity.
Traditional HID lighting is no longer an effective option for the emerging cannabis
market where the environment and cost must be taken into account for large cannabis
dispensary.
HF HPS lighting with newer double-ended lamps are currently the most efficient light
available for cannabis production. The light produced from lamps such as Gavita and E-
Papillion actually registers a slightly higher PAR value than the natural sun. The
dispensary shall utilize HF HPS throughout all flowering zones in order to optimize
energy consumption and produce the highest quality cannabis with consistent dosage.
Metal Halide
Metal halides have always been an excellent light source for vegetative growth. Metal
halides with blue spectrum create dense growth, large green fan leaves, and short
internode length. Plants that vegetate under blue spectrum metal halide can easily
achieve MGP. 1,000 watt blue spectrum metal halides shall be used for late vegetative
growth in the V3 zone in order to prepare plants to go under 1,000 watt HF HPS lighting
in their designated flowering zone.
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T5 florescent lighting is perfect for areas where heat and ceiling height may be an issue
and where small plants, clones, or mother plants are being grown. T5 fluorescents save
energy and produce healthy plants. T5s shall be utilized in the hot house for cloning and
in mother plant zones of the dispensary.
LED lighting
LED lighting has passed the traditional HPS lighting for flowering cannabis plants,
however, it is not quite on par with HF HPS. LED shall be utilized in the V2 section of
the dispensary for the second phase of vegetative growth. Additionally, one flowering
room will act as a research and development center to continue to test new LED
products as they hit the market to determine their efficiency. Once they are proved, the
entire facility shall eventually utilize LED lighting.
Induction Lighting
Induction lighting has been developed specifically for plant cultivation and currently is
very useful in the vegetative phase. However, due to the high cost associated with it, it
is still in the R & D phase and shall be tested in the V2 zone along with LEDS.
Photosynthetic Spectrum
An efficient lamp will turn as much energy as possible into photosynthetic energy. The
only light plants use for photosynthesis appears within the PAR (photosynthetic active
radiation) region. The PAR region occurs from 400 to 700 nm within the light spectrum.
As you can see on the chart below, the main spectrums of usable light for the cannabis
plant are blue and red. The light spectrum (color blend) strongly influences the
development of the plant.
Blue spectrum lighting promotes dense growth and short internode length. Metal
halide lights with high quality blue bulbs are recommended for vegetative growth.
High intensity fluorescent lights are recommended in the smaller/early stages of
vegetative growth and mother quarantine sections to save energy and reduce
heat. Newer lights such as LED have a more balanced light spectrum and will
soon surpass traditional metal halides for vegetative growth.
Red spectrum lighting promotes large plants with big beautiful blooms. Red
spectrum lights provide more intensity for the later stages of plant growth and are
currently recommended for flowering. Traditionally, HPS lights have been used. If
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Hybrid lighting Plants grow best in a mix of red and blue light. Currently, LED
lighting appears to have the best spectrum potential, however, the intensity is still
not quite on par with newer high frequency HPS technology. Newer double-
ended bulbs designed for lights like the Gavita and e-Papillion have a more
balanced spectrum and should be used in all flowering spaces where heat is not
an issue.
The dispensary facility manager shall ensure lighting intensity is maintained throughout
the plant growing cycle. The dispensary manager shall ensure all lamps within each
flowering area of the dispensary are providing 1500 umols within the propagation range.
The dispensary facility manager shall utilize a light meter that measures light in
micromoles such as the apogee to measure lighting intensity.
A lighting strength inspection shall be done monthly by the respective manager with in
each zone.
Photoperiod
The photoperiod is the length of the day that plants are exposed to photons. Cannabis
flowering is influenced by the photoperiod so it must be constantly maintained to avoid
plant stress. The dispensary manager shall work with each zone manager to ensure all
flowering zones receive 12 hours of un-interrupted darkness and that each vegetative
zone receives a minimum of 18 hours of light throughout each day.
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Primary Macronutrients
Nitrogen, Phosphorous, and Potassium (NPK) are the three macronutrients required to
cultivate healthy cannabis plants. It is the dispensary manager’s responsibility to ensure all
cannabis plants receive sufficient NPK. NPK can be found in all high quality base nutrients and
multiple organic additives such as guano.
Nitrogen (N)
Cannabis uses more nitrogen than any other nutrient. Nitrogen is most important in the
vegetative and early flowering phases of the cannabis life cycle. Nitrogen helps plants
produce chlorophyll, which gives plants their green color and is essential for
photosynthesis. When a plant is deficient in nitrogen, its lower leaves will start to turn
yellow and die. The dispensary cultivation manager shall work with each zone manager
to monitor for nitrogen deficiency.
Phosphorous (P)
Cannabis plants use phosphorous to create necessary chemicals during all stages of
plant growth; however, cannabis requires higher phosphorous levels during floral
development in the flowering stage. When plants are deficient in phosphorous, the
stems will turn purple and growth vigor will decline. The dispensary cultivation manager
shall work with each zone manager to monitor for phosphorous deficiency.
Potassium (K)
Potassium plays a major role in chemical synthesis and metabolism within the cannabis
plant. Having the correct amount of potassium in your plants gives them sturdy and
thick stems, makes them disease resistance, and aids in water respiration as well in
photosynthesis. Potassium is necessary for water transportation throughout the entire
plant, and is utilized during all stages of growth, especially in flower formation. Lack of
potassium can make plants vulnerable to diseases such as mold, fungus and mildew.
Red stems, declined plant vigor, along with the previously mentioned diseases are all
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Understanding nutrient labeling: Nutrient containers display nutrient levels in NPK ratios,
such as 10-10-10, located on the front label. Nitrogen is always the first number followed by
phosphorous and then potassium. A numerical display of 10-10-10 means the solution
contains equal parts of all three nutrients and each nutrient is at a concentration equal to 10%
of the solution's weight.
Secondary Macronutrients
Calcium, Magnesium, and Sulfur (CaMgS) are necessary in sufficient levels to reach MGP.
The secondary nutrients promote plant growth and overall health. CaMgS are generally found
in high quality soil, however, soil often lacks sufficient amounts to keep rapidly growing
cannabis plants healthy throughout the entire life cycle so supplements and or soil additions
are recommended. The dispensary cultivation manager shall plan the nutrient feeding
schedule and soil mixture accordingly to avoid problems associated with calcium, magnesium,
or sulfur deficiencies.
Calcium (Ca)
Calcium is a part of the cell wall development in the cannabis plant. It strengthens the
stems and branches of cannabis and helps in the formation of the root and its tip’s
growth. A calcium deficiency causes rust spotting on leaves and impedes root system
development. A high quality calcium supplement is a must to avoid problems before
they can adversely affect plant health and overall yields. The dispensary cultivation
manager shall work with each zone manager to monitor and avoid calcium deficiencies.
Magnesium (Mg)
Magnesium influences the formation of chlorophyll, which gives plants their green color
and acts as a light absorber during photosynthesis. Magnesium also affects most
enzymatic reactions within plants. The structures within cannabis plants (leaves and the
veins) are healthy due to this element. Yellowing combined with leaf curl (especially
upward) are signs the plant needs more magnesium. We will include a good
magnesium supplement in the feeding schedule to keep plants happy and healthy. The
dispensary cultivation manager shall work with each zone manager to monitor and
avoid magnesium deficiency.
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Sulfur participates in the formation of chlorophyll and the growth of the plant. The
deficiency is presented by slower rates of growth along with pale green or yellow color
on the top of the plant where new growth appears. The leaves on cannabis plants
lacking sufficient sulfur will develop a mutation that causes them to round and roll
upwards. The dispensary cultivation manager shall work with each zone manager to
monitor and avoid sulfur deficiency.
Micronutrient list
Iron
Manganese
Boron
Essential mineral elements
Zinc
Copper
Molybdenum
Silicon
Sodium
Beneficial mineral elements
Cobalt
Selenium
Hydrogen
Essential non-mineral elements Carbon
Oxygen
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Dispensary cultivation operations must follow the manufacturer’s application, storage, and
disposal recommendations for the nutrient product. Dispensary operations must not return
unused rooting hormone to the source container.
Nitrate-based and other oxidizing fertilizers must be stored away from solvents, fuels and
pesticides.
Inorganic and synthetic nutrients meet the plant nutrient requirements through
immediate absorption through the plant's root system. These instantly bio-available
nutrients have advantages in an indoor growing environment as they can be adjusted to
meet a plant's nutrient requirements quickly to avoid and correct nutrient deficiencies,
and aid in reaching MGP.
Always mix nutrients into water one at a time. The appropriate zone manager shall mix
all nutrients. The manager will use a reservoir with the appropriate amount of living
water, measuring devices, and a stirring rod and will follow these steps:
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Organic Nutrients
Traditional organic nutrients are mixed into soil and must break down over time
providing the full spectrum of nutrients required for plant growth. Microbial life plays an
essential role in breaking down organic matter in soils and making fresh humus that
contains all elements for healthy root systems and plants. Teas are highly
recommended to supply fresh microbes and nutrients needed throughout the plant's life
cycle. Top packs and spikes can also be utilized to provide nutritional component for
plant growth later in the life cycle. Traditional organic gardening is consistent with TLO
or true living organic gardening.
Newer bottled organic nutrients are often further processed and provide readily bio-
available nutrients along with soil enhancers. These nutrients can be used alone in an
inert substrate or used in combination with traditional organic methods to improve
growing time and correct deficiencies.
Compost teas should be used bi-weekly to ensure there is a healthy microbial level
within the growing medium. Each zone manager shall utilize the appropriate tea recipe
for each phase of the cannabis life cycle. Teas shall be applied on a two- week
schedule. Teas feed the microbial life in the soil and create healthy plants that resist
disease, yield more, and produce consistent cannabis with an excellent terpene profile.
Basic tea requirements: Five-gallon bucket, living water, air pump, worm castings,
humic acid, sea kelp, earth worm castings
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Mitigating plant deficiencies and increasing production capacity can be done organically
through the use of top packs. Super soils with organic nutrients built in will only maintain
maximum plant growth until the plant has used up the nutrients. Top packs can be
applied half way through the flowering cycle to ensure the plant has all nutrient needs
met and produces the highest quality end product.
o Determine appropriate amount for container size (¼ cup per gallon of substrate)
o Mix three bat guanos together to equal appropriate measurement
o Apply to the top of the soil mixture
o Water with living water
Spikes
Spikes are small compact nutrient zones into which roots can grow and use additional
nutrients as needed by the plant. Flavor bombs are pre-made spikes and are a good
way to prevent deficiencies and provide maximum growth, quality, and consistency.
o Add spikes when transplanting into final container for flowering phase.
o Determine the appropriate amount for container size (1 spike (flavor bomb) per
gallon)
o Place spikes evenly throughout the planting medium
o Water in as plant needs
Organic bottled nutrients can be used to maintain nutrient needs as the plant grows
larger and nutrient requirements increase. In 100% organic growing, all nutrients shall
be OMRI listed organic nutrients.
Hybrid growing formulas combine aspects from both organic and synthetic growing
styles. Hybrid methods are superior to either method separately in producing high
yielding cannabis plants that still have great flavor and terpene profiles. Hybrid growing
would utilize a light organic potting medium.
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Calcium Deficiency
Calcium helps provide structure to the cannabis plant and helps it withstand stress. A calcium
deficiency can sometimes be difficult to diagnose since it is often accompanied by magnesium,
iron, and/or other deficiencies. Calcium moves relatively slowly through the plant, so calcium
deficiencies tend to show up in newer growth (upper leaves) and middle vegetative growth.
Calcium deficiencies are more likely to appear with filtered or reverse osmosis water, because
tap water has enough calcium to prevent deficiencies. Supplementing soil-less grow mediums
with lime will prevent calcium deficiencies. Because a calcium deficiency can occur at any
stage of growth, the entire Cultivation Team is responsible for identifying and treating calcium
deficiencies.
Treatment Plan:
1. Check pH. Calcium is best absorbed by the roots in the 6.2-7 pH range.
2. Flush the plants with clean, properly pH adjusted water with a regular dose of nutrients
that includes calcium. This will remove any nutrient salts that may be affecting the
uptake of calcium and help restore pH.
3. Check plant to make sure new growth does not contain calcium deficiencies. Old,
damaged growth will not recover.
4. If deficiencies continue, feed the plant with Cal-Meg, a calcium and magnesium
supplement.
Copper Deficiency
Copper deficiency in cannabis plants is rare and manifests itself as leaves curling back, lack of
growth, and unusual dark coloring of the leaves. Copper doesn't move easily through the plant
and is considered low mobile. Leaves will appear dark, with purple or blue undertones and a
metallic sheen.
It is very unlikely that there is no copper available in the water or soil, so usually a copper
deficiency in cannabis is caused by a pH problem at the roots that is restricting access to
nutrients. Copper deficiency is often a problem with another nutrient or with the pH that causes
the plant to appear deficient.
Copper toxicity (too much copper) in cannabis plants is rare, though a severe case of too much
copper can cause cannabis plants to suffer die. Because a calcium deficiency can occur at any
stage of growth, the entire Cultivation Team is responsible for identifying and treating calcium
deficiencies.
Treatment Plan:
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Iron deficiency in cannabis is relatively rare, and the symptoms of a cannabis iron deficiency
appear most often alongside other nutrient problems or deficiencies. The main symptoms of an
iron deficiency are yellowing of upper fan leaves and yellowing of smaller inner leaves while
the veins of leaves stay green. Sometimes affected leaves will even appear white. Often the
symptoms appear near the top of the plant on newer leaves. This nutrient deficiency can look
similar to a magnesium deficiency, but an iron deficiency will affect younger/upper/inner leaves
(where a magnesium deficiency affects older/lower leaves). Because an iron deficiency can
occur at any stage of growth, the entire Cultivation Team is responsible for identifying and
treating iron deficiencies.
Treatment Plan:
1. Check pH. Iron is best absorbed by the roots in the 6-7 pH range. Iron tends to get
locked out at higher pH levels. Keep pH levels under 6.5 to help flush the plant.
2. Flush the plant with clean, properly pH adjusted water with a regular dose of nutrients
that includes Iron. This will remove any nutrient salts that may be affecting the uptake of
iron and help restore pH.
3. Check plant to make sure new growth does not contain iron deficiencies. Old, damaged
growth will not recover.
Nitrogen Deficiency
Nitrogen deficiency will cause the older, lower leaves on the plant to turn yellow, wilt away and
eventually die. The yellow leaves of a nitrogen deficiency may show signs of brown, and they
will usually become soft before turning crispy and falling off on their own. Nitrogen is a mobile
nutrient, which means it can move throughout the plant as needed. Cannabis needs nitrogen
to keep leaves green and make energy from light. All new leaves get plenty of nitrogen to
make them green and help with photosynthesis. If new leaves aren't getting enough nitrogen,
the plant will start to "steal" nitrogen from the older, lower leaves, so that it can give it to newer
leaves. This is what causes the yellowing and wilting of a nitrogen deficiency. Because
nitrogen deficiencies are expected during the late flowering stage, the vegetation Cultivation
Team is most responsible for identifying and treating nitrogen deficiencies.
Treatment Plan:
1. Check pH. The roots in the 6-7 pH range best absorb nitrogen.
2. Flush the plants with clean, properly pH adjusted water with a regular dose of nutrients
that includes nitrogen.
3. Check plant to make sure new growth does not contain nitrogen deficiencies. Old,
damaged growth will not recover.
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Phosphorus deficiencies in the vegetative stage usually appear at the bottom of the plant on
some of the oldest leaves, and will progressively climb up the plant if left unchecked. New
leaves may be smaller than average or look twisted or stunted. When there is a phosphorus
deficiency, the lower (oldest) leaves will sometimes turn dark green, occasionally with a bluish
or bronze tinge, and may thicken or curl downward before exhibiting dark gray, bronze or
purplish splotches. A common symptom of a cannabis phosphorus deficiency is red or purple
stems. It's important to remember that some cannabis strains naturally grow with red or purple
stems even when all their nutrient needs are being fulfilled, so red or purple stems is not a
symptom to worry about on its own.
In the flowering stage, a cannabis phosphorus deficiency usually manifests near the buds that
are being hit with strong, direct light. Cannabis plants use phosphorus heavily in the flowering
phase to produce flowers, and are a crucial component of photosynthesis (turning light into
energy for the plant). A phosphorus deficiency is most common in the flowering stage when
plants are under very bright light, and cannabis is constantly using up phosphorus in the
process of building buds and making energy from light. In the case of a cannabis phosphorus
deficiency in the flowering stage, the leaves, which are not getting hit by direct light, will usually
remain green. The leaves directly under the light and nearest to the buds are the first to turn
reddish or yellow as they display the signs of a phosphorus deficiency. Because a phosphorus
deficiency can occur at any stage of growth, the entire Cultivation Team is responsible for
identifying and treating phosphorus deficiencies.
Treatment Plan:
1. Check pH. Phosphorus is best absorbed by the roots in the 6.2-7 pH range.
2. Overwatering and wet, compact soil can trigger a phosphorus deficiency. Check the soil
for too much moisture.
3. Flush the plant with clean, properly pH adjusted water with a regular dose of nutrients
that includes phosphorus. This will remove any nutrient salts that may be affecting the
uptake of phosphorus and help restore pH.
4. Check temperatures in the grow room. Cooler temperatures and large temperature
swings can make it difficult for the plant to absorb phosphorus.
5. Check plant to make sure new growth does not contain phosphorus deficiencies. Old,
damaged growth will not recover.
Potassium Deficiency
Potassium deficiency causes older leaves turn yellow then start getting dark, with scorched
lesions around the edges of the leaves. Plants may stretch and stems may become weak. The
symptoms are very similar to an iron deficiency except the tips of the leaves curl as the edges
burn and die.
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Treatment Plan:
1. Check pH. Potassium is best absorbed by the roots in the 6-7 pH range.
2. Flush the plant with clean, properly pH adjusted water with a half dose of nutrients that
includes potassium. This will remove any nutrient salts that may be affecting the uptake
of potassium and help restore pH. Potassium isn’t absorbed properly where there is too
much calcium or nitrogen in the plant, so the half dose will flush out extra nutrients that
cause lock out.
3. Check plant to make sure new growth does not contain potassium deficiencies. Old,
damaged growth will not recover.
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A light green or yellow coloring will begin to show on the veins and edges of the lower and
older leaves. Magnesium is a mobile nutrient, which means that the plant can move it from old
leaves to new leaves.
The plant will pull magnesium out of older leaves and bring them to the newer leaves. That's
why a magnesium deficiency usually appears towards the bottom of the plant and on older,
less important leaves.
The edges of the leaves may become yellow or bright green and may start feeling crispy to the
touch. This crispiness around the edges is different from nutrient burn, which does not lighten
the margins inside the leaves.
Because a magnesium deficiency can occur at any stage of growth, the entire Dispensary
Cultivation Team is responsible for identifying and treating magnesium deficiencies.
Treatment Plan:
1. Check pH. Magnesium is best absorbed by the roots in the 6-7 pH range.
2. Flush the plant with clean, properly pH adjusted water with a regular dose of nutrients
that includes magnesium. This will remove any nutrient salts that may be affecting the
uptake of magnesium and help restore pH.
3. Check plant to make sure new growth does not contain magnesium deficiencies. Old,
damaged growth will not recover.
Sulfur Deficiency
Sulfur deficiency will manifest itself as all-over chlorosis (yellowing of leaves), usually starting
with the newer leaves and at first may look like a nitrogen deficiency. The parts underneath the
leaves may take on a pinkish red or orange color. The buds on a flowering plant may start
dying off. Unlike most other deficiencies that cause chlorosis, a sulfur deficiency will start at the
back of the leaf and move its way forward as opposed to starting at the tips.
Because a sulfur deficiency can occur at any stage of growth, the entire Cultivation Team is
responsible for identifying and treating sulfur deficiencies.
Treatment Plan
1. Check pH. Sulfur is best absorbed by the roots in the 6-7 pH range.
2. Flush the plant with clean, properly pH adjusted water with a regular dose of nutrients
that includes sulfur. This will remove any nutrient salts that may be affecting the uptake
of sulfur and help restore pH.
3. Check plant to make sure new growth does not contain sulfur deficiencies. Old,
damaged growth will not recover.
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Plants with zinc deficiency, younger leaves start yellowing in between the veins. Leaf tips get
discolored and start dying. Cannabis plant leaves will take a unique banded appearance and
the plant will stop growing vertically. There will be much less space between new nodes which
will cause all the new leaves to start bunching together. If the plant is budding, its flowers may
start dying. Because a zinc deficiency can occur at any stage of growth, the entire Cultivation
Team is responsible for identifying and treating zinc deficiencies.
Treatment Plan:
1. Check pH. Zinc is best absorbed by the roots in the 6-7 pH range.
2. Flush the plant with clean, properly pH adjusted water with a half dose of nutrients that
includes zinc. This will remove any nutrient salts that may be affecting the uptake of zinc
and help restore pH.
3. Check plant to make sure new growth does not contain zinc deficiencies. Old, damaged
growth will not recover.
Manganese Deficiency
Cannabis Plant leaves may become yellow in between the veins, with mottled brown spots on
the affected leaves. These brown dead patches may spread and eventually kill the leaf.
Leaves may also shred and fall apart. Overall growth of the cannabis plant may be stunted.
With a manganese deficiency, the yellowing will begin at the base of the leave and move
outwards towards the tips. Because a manganese deficiency can occur at any stage of
growth, the entire Dispensary Cultivation Team is responsible for identifying and treating
manganese deficiencies.
Treatment Plan:
1. Check pH. Manganese is best absorbed by the roots in the 6-7 pH range. Higher pH
ranges are where manganese deficiencies are more likely to occur.
2. Flush each plant with clean, properly pH adjusted water with a regular dose of nutrients
that includes manganese. This will remove any nutrient salts that may be affecting the
uptake of manganese and help restore pH.
3. Check plant to make sure new growth does not contain manganese deficiencies. Old,
damaged growth will not recover.
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Earth (living) characteristics of a perfect growing medium: Naturally occurring soils are truly a
living microenvironment. All mediums except for hydroponic should possess the following
physical, chemical, and biological properties in order to grow the healthiest plants and reach
MGP soil.
Aeration/porosity
Naturally occurring soils contain textured materials such as rocks and shells that
provide adequate drainage, pockets of oxygen, and chelate into usable nutrients.
Microbes thrive in tiny porous holes that are provided by substrate additions such as
perlite and lava rocks. We will use an array of different size textured materials to create
humid air pockets for roots and numerous porous surfaces to hold oxygen and grow
microbes.
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The following components of growing media will provide aeration and porosity thus
allowing drainage, oxygenation, and microbial growth resulting in a healthy root zone
and robust plant:
o Perlite
o Lava rocks
o Hydroton
o Worm castings
A good growing medium will have ample water holding capacity and still be porous
enough to allow excess water to drain away. In cannabis gardening, coconut coir is a
perfect inert substrate that will hold water. We will work diligently to provide the perfect
balance between water holding capacity and drainage by utilizing a mix of absorbent
substrates and porous substrates.
The following components will provide water-holding capacity and should be used in
balance with porous additions to maintain the proper moisture/oxygen/nutrient balance
within the root zone:
o Coco coir
o Potting soil
o Peat moss
o Humus soil
pH
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CEC refers to the capacity to which a growing medium can hold positively charged ions
thus resulting in the nutrient storage capacity within a given medium. Because most
artificial growing media are inert, CEC capacity must be considered. Within the growing
medium, plants absorb nutrients through roots via a process in which excess charged
ions are exchanged for charged nutrient ions. Once cation exchange has occurred,
nutrients are transported to the foliage where they are used for growth and development
by the plant. Because the CEC of a growing medium reflects its ability to hold nutrients
for plant uptake, substrates with a relatively high CEC are recommended for cultivating
cannabis. The dispensary cultivation manager shall adopt a medium with the
appropriate CEC for optimal plant growth.
Microbes
Bacteria and fungus feed on each other and excrete pure humus into the soil. It is
imperative to use at a minimum of 15-20% soil in planting mediums in order to provide a
solid foundation for beneficial bacteria and fungal growth. These beneficial organisms
provide all the quantum aspects needed within the growing substrate to ensure plants
reach MGP. The dispensary manager and each respective zone manager shall manage
the application of organic soil composts and teas.
Humus
Humus is nature's perfect plant food and has all necessary macro and micronutrients to
support vigorous root growth and a healthy plant life cycle. The soil component of all
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Worm Compost
Made up from the excretions of the earthworm, worm castings are a great amendment
for both the porosity of the media and the microbial life within the media. Each zone
manager shall utilize worm castings in all transplant media and in the creation of
compost teas to be fed throughout the plant's life cycle.
Tools: Mixing tub (large kiddie pool, thick tarp, wheelbarrow, or soil mixer), flat nosed
mixing shovel
Ingredients: Fox Farm Ocean Forrest Soil, Fox Farm Big and Chunky Perlite, Plagron
Coco Coir, humus soil, worm castings. (All brands can be exchanged for other high
quality brands that meet the above listed requirements for cannabis growing media).
Ratios: 25% soil, 25% coco coir, 7.5% humus soil, 7.5% worm castings, 35% chunky
perlite
Directions: Starting with perlite, measure and place in mixing area. Measure and add
coco coir. Measure and add humus and worm castings. Measure and add soil. Mix all
ingredients with shovel or soil mixer until evenly mixed.
Coco coir: Coco coir with a top drip-feeding system is the recommended replacement
for hydroponic gardening as it solves every problem associated with hydroponics and
can achieve similar results. Quantum semi-soil with a hybrid system utilizes coco coir as
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TLO: True Living Organics produces the highest quality cannabis with the best terpene
and flavor profiles. TLO consists of building a super soil and feeding beneficial
microbes. Plants take the nutrients they need directly from the soil as time and microbial
feeding and excretion release make micro and macronutrients bio-available.
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Planting seedlings
Once a seed has germinated, the vegetative manager will plant the seed in a prepared
medium. Seeds should always be planted in small containers to establish a basic root system
before being transplanted into larger containers.
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Male plants will grow distinct ball-like sacs. Once they open, a fine powder is released (pollen)
that is dispersed throughout the room on the slightest breeze. The zone manager will take the
most care to eliminate contamination risk when removing and destroying male plants.
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Feminized vs. Regular: Feminized seeds are seeds that have been bred by forcing a female
plant to become hermaphroditic and fertilize itself in order to produce an all-female crop. These
seeds have a greater propensity to be hermaphrodite and must be monitored closely when
flowering.
A mother plant is a female plant reserved in a continuous vegetative state for the purpose of
taking cuttings. The cuttings from the mother plant are grown and flowered to produce the final
product. The vegetative manager shall ensure that healthy mother plants are maintained at all
times to ensure healthy clones through the following procedures:
Mother plants shall be watered with a well-balanced nutrient formula that is high
nitrogen.
The mother plant shall be sufficient in size prior to cloning.
Super cropping and topping techniques shall be followed to increase the number of
cloning sites on each mother plant.
Avoid taking too many cuttings from a mother plant; leave at least 2/3 for future cloning,
and allow at least 1 week between cloning sessions for the mother to recover from
stress.
Materials needed for cloning: Rubbing alcohol, cutting board, scissors, new razor blades,
cloning gel (for organic use honey), small container, distilled or reverse osmosis (RO) water,
vinyl work gloves, and cloning medium
Cloning mediums: Rockwool cubes, rapid rooter cubes, coco coir cups, aeraponic systems
Procedure for taking clones: The vegetative manager will train a dedicated zone manager
for the propagation of all clones.
The vegetative manager will identify and approve a mother plant to be cloned.
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The cloning manager will prepare all tools and surfaces by wiping them clean with 90%
rubbing alcohol and will then follow this protocol:
Watering Clones
10-14 days after cuttings have been taken, the root system should be established
enough to allow the uptake of nutrients. From this time until transplanted into
containers, the cloning manager shall ensure proper care is taken to ensure healthy
plants for transplanting.
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A minimum of one room within the vegetative area of the dispensary shall be
maintained as a hot house. The hot house shall meet all environmental standards and
be fully enabled to maintain a room temperature of 80° Fahrenheit and a humidity level
of 80%.
Transplanting Clones
Once a clone is fully rooted, it is ready to be transplanted and moved into the V2 zone
of the dispensary. The vegetative manager will ensure all clones are transplanted,
labeled, tagged with RFID and that each transfer is logged and tracked in the SIS.
He/she will prepare all materials needed for transplanting and perform transplanting
procedures. The following procedures shall be followed whenever transplanting:
Watering Transplants
Post transplanting, plants require special attention in watering to ensure proper root
development. The vegetative manager shall ensure all new transplants are given water
and nutrients by the following process:
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Timeliness and consistency throughout the vegetative process will allow for accurate planning
throughout the dispensary and enable patient needs to be met. The vegetative manager is
responsible for preparing the plants for all future flowering zones. Each plant should reach its
pre- determined full size prior to being transferred into its designated flowering zone. The
vegetative manager must have full awareness of the timeliness and demands set forth by the
flowering schedule and plan accordingly.
During the early vegetative phase, the main focus is establishing an inner root ball
within a smaller container and pruning the plant to achieve a robust branching system.
All plants in V2 will be in one-gallon containers for a three to four week period. Lighting
in the V2 stage will consist of t5s, 315 ceramics, 600-watt metal halides with blue
spectrum, or induction lighting.
All plants will be tracked by scanning RFID tags and documented into the SIS upon
being transferred from V2 to V3. Data will be recorded.
As the cannabis plant grows in size, the root zone will need to expand. When seeking to
achieve MGP, the substrate demands increase to allow for larger more robust root
zones. The vegetative manager shall ensure pre-flowering vegetative plants are
transplanted so that there will be 25-30 gallons of substrate per flowering light. During
the pre- flowering stage, plants are transplanted into the final container size to allow for
larger growth. Conditions in pre-flowering need to mimic flowering conditions so plants
can be prepared to produce large healthy flowers in their final phase of growth.
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Once the root zone has matured, a plant is ready to be transplanted into a larger
container. A plant can only flourish while its roots zone is healthy and growing. The
vegetative manager will transplant into the final phase container a minimum of two
weeks prior to flowering.
Container Size: The vegetative manager will utilize 20-30 gallons of substrate per light
for final phase growth in order to achieve MGP.
Choosing container size: Determine how many plants will be grown under each light
in the flowering zone. Plant numbers are based on a plant growth speed; i.e. if a
cannabis strain grows very slowly, the number of plants must be increased to meet the
timeline of the dispensary.
Indicas typically grow slower so it is assumed there may be smaller plants per light,
whereas sativa plants grow quicker so there may be fewer larger plants per light.
Once the number of plants per light is determined, calculate the amount of substrate
and container size:
1. Thoroughly clean the transplanting area and any containers that are not new.
2. Move the batch of plants to be transplanted into the transplant area.
3. Fill several containers half way with substrate.
4. Sprinkle mycorrhizae onto surface of substrate and mix with fingers.
5. Place the stem of the plant between your fingers and turn the plant upside down.
6. If the plant does not slip out of the container with ease, gently squeeze the sides
of the container.
7. Once the plant slips out, place your fingers under the root ball in the center and
gently spread the roots.
8. Place the plant in the large container.
9. Using the small shovel, cover the small plant until the stem is covered a minimum
of 1 inch by substrate. There should be 1.5-2 inches of space left at the top of
the pot.
10. Hand water with vegetative nutrient solution.
11. Scan tag and move into the V3 zone designated for the batch. Record data.
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The pre-flowering phase is the final phase of vegetative growth. During this phase, we
are focused on creating a full canopy before plants enter the flowering zone. The
vegetative manager shall ensure plants have strong lighting, CO2, quality nutrients, and
ample space in order to gain sufficient size. 1,000-watt metal halide lamps with blue
spectrum bulbs are currently recommended for this phase of growth.
Prior to being transferred from V3 to any flowering zone, all plants must have their RFID
scanned and location moved within the SIS. All data will be recorded at the time of
transfer.
Flowering F1-F20
The designated flowering zone is where a batch will be induced into a flowering state by
receiving 12 hours of un-interrupted darkness. The flowering manager shall ensure all
lighting is of the highest quality, the environmental controls are perfectly set and
working, and each zone remains clean. The flowering manager shall ensure proper
plant manicuring and fertilization occur within each flowering zone. Flowering zones are
separated into nine distinct rooms based on the average length of time plants spend
producing flowers.
Late Flowering
During the late flowering stage, the flowering zone manager will prepare the plant for
harvest via the following processes:
Flushing: During the flushing phase, the flowering zone manager will stop giving plants
all nutrients and instead seek to purge all remaining nutrients from the substrate by
forcing fresh water through the plant's root system. The following process shall be used
through each flowering zone to prepare plants for harvest and ensure the highest quality
finished product:
Materials for flushing finished plants: 2 gallons of living water for every gallon of
substrate within each zone.
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Biosecurity
In order to prevent pest and disease infestations within the dispensary it has been
designed with levels of biosecurity. Upon entering the building, all persons shall step on
a sanitation mat and pass through an air shower. All employees must then enter locker
rooms where they change into clean uniforms and have the opportunity to shower if
they have been out doors prior to coming into work. Each section of the warehouse will
be compartmentalized to prevent any cross contamination between departments. In
addition, within each department there shall be redundant compartments to ensure
small out breaks can be contained. The Vegetative department will have three distinct
phases each with two compartments, flower department will have 20 separate flowering
compartments, the kitchen and laboratory shall be separate and distinct compartments,
and all product processing shall be contained within distinct compartments for drying,
curing, secured storage, packaging and transportation. Each compartment will be
equipped with its own cooling and heating source to prevent air exchange between
compartments. All employees shall remain within their designated working areas to
further prevent potential chances for cross- contamination. All walls between
compartments shall be adequately sealed, and all air entering the dispensary shall be
screened through a high-micron filtering system.
The dispensary manager shall keep a schedule for all pest and disease control
prevention. All data pertaining to pesticide applications and other crop inputs shall
be recorded and the record maintained at the dispensary for a minimum of six years.
All crop input records will be made available to the department upon request. The
application record will include the following information:
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IPM Program
Infestation level
The dispensary cultivation manager shall pre-determine an action threshold for each
potential pest and disease. The action threshold will determine the type of pesticide and
the rate of application.
Prevention
The cultivation team will follow a standard prevention protocol at all times. This protocol
will include preventing pests from entering each growing space, preventing cross
contamination from zone to zone, closely following environmental protocol for each
zone, maintaining cleanliness standards at all times, using preventive
biological/microbial controls, growing pest and disease resistant strains, and growing
with organic methods and quantum cannabis methods that produce maximum plant
health thus remaining resistant to pests and disease.
Monitoring
Plants will be monitored daily by each zone manager. At the first sign of any pest or
disease, the cultivation team shall determine a treatment protocol for the affected zone
and the entire dispensary.
Immediate action
Plants will be monitored for new signs of pest and disease so they can be treated
immediately. Immediate action reduces the chance of complications within the growth
cycle that will reduce quality, yield, and consistency of dose. Immediate action also
reduces the amount and frequency of pesticide applications.
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IPM Training
The dispensary cultivation manager will train all vegetative agents in IPM practices and the
proper application standards for all crop inputs. All individuals responsible for applying
pesticides on the premises shall obtain the appropriate license from the department prior to
making any applications. Cultivation operations must follow the EPA Worker Protection
Standard 4 when preparing and applying pesticides. Indoor cultivation operations must comply
with the pesticide manufacturer’s published re-entry interval time periods when applying
pesticides. Initial training shall include at a minimum:
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All regulators and environmental control systems that regulate carbon dioxide emissions must
be maintained in good working order and be serviced in accordance with the manufacturer’s
recommendations.
Equipment used for measuring, regulating, or recording temperatures, pH, humidity, or other
conditions related to the cultivation and processing of cannabis must be accurate and
adequately maintained. Cultivation and processing tools that come in direct contact with
cannabis plants should be disinfected as needed to protect plant health. Scales used for the
weighing of cannabis must be calibrated at regular
Pesticide Storage
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All protective gear used during the pesticide application process will be laundered
directly after the application process. Protective gear will be washed separately from the
rest of the laundry. Any clothing soaked in pesticide shall be discarded. The sanitation
manager shall ensure the following processes are followed at all times when laundering
protective gear after pesticide applications:
Disposal of all unused pesticide product shall be performed in compliance with all state
and federal laws and regulations and all directions on the product label.
All pesticides applied at the dispensary shall be from the department's approved list and
shall be OMRI certified. A list of pesticides approved for use shall be maintained and
displayed, by the dispensary cultivation manager, in the pesticide storage area of the
dispensary. The dispensary cultivation manager shall monitor and post any updates to
the approved list from the Department's website. All pesticide products applied in the
dispensary shall be registered with the department except for those products classified
as 25(b) pursuant to the Federal Insecticide Fungicide and Rodenticide Act
administered by the USEPA.
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The product must only contain active ingredients from the list below.
Certain products, as noted, must only be used in the vegetative stage of growth.
All ingredients, including both active and inactive, must be listed on the label.
Active must be listed by name and percentage of weight, and inert must be listed by
name. Labels cannot contain false or misleading statements.
Azadirachtin
Azadirachtin is clarified hydrophobic extract of neem oil. Combined with cold pressed
neem oil, it controls a wide variety of common pests and also acts as a fungicide.
Neem oil
Neem oil works well to control most common pest populations. Look for brands that
combine neem with Azadirachtin for the most effective applications.
Garlic oil/Powder
Garlic is antifungal, anti-bacterial, and insecticidal. Garlic spray can be made and used
every few days as a preventative.
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Bacillus pumilus
Strain GB34 grows on roots and is used to prevent soil-born fungus spores from
germinating.
Bacillus subtilis
Colonizes the roots and protects against pathogens by inhibiting spore germination and
preventing pathogens from attaching to the plant.
Bacillus thuringiensis
A bacterial insect disease and when colonized within soil, it can protect against a wide
variety of pests and their larvae. BT works great to control fungus gnat populations.
Isaria fumosorosea
A fungus that infects and kills whiteflies, thrips, aphids, and spider mites.
Pythium oligandrum DV 74
When applied to soil, Sl protects against a wide range of root decay fungi.
Naturally occurring and helps protect plants from fusarium oxysporum, a pathogenic
soil-born fungus.
Prevents soil-born fungal pathogens by competing for nutrients and space. Tg also
attacks the cell walls of pathogenic fungi by utilizing enzymes.
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A naturally occurring fungus that is utilized to prevent harmful plant fungi that cause
disease.
Reynoutria sachalinensis
White Flies
Thrips
Thrips are common in cannabis gardens. They appear in three different colors and are
visible with the naked eye. Thrip damage will most likely be seen before the insect is
detected. Thrips cut into the leaf and feed off the sap. A heavy thrip infestation will result
in shiny silver streaks on fan leaves. A heavy infestation shall require topical treatments,
however, they breed in the soil, and so biological/microbial regimens will keep out
breaks from having negative effects on crops.
Thrips Treatment:
Spider Mites
Spider mites are by far the most important infestation to avoid. Mites are microscopic
therefore plant damage will most likely be the first sign of infestation. Mites double
breed very quickly doubling their population daily, so just one mite can easily turn into
thousands and thousands into millions. Outdoors spider mites have natural predators
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Treatment:
Foliar - Spray miticide
Aphids
Aphids are common in cannabis gardens. They are visible to the naked eye and appear
in an array of colors. Aphids are nasty little bugs; heavy infestations will cause serious
crop damage rotting large flowers and deeming them waste.
Aphids Treatment:
Aphids breed in the soil so they are easily prevented through biological/microbial
controls in the soil. If aphids become visible, the above ground population should be
treated immediately and applications of soil fungi should be increased.
Fungus Gnats
Fungus gnats eat plant roots and weaken the plant thus reducing the plant's ability to
achieve maximum results. Gnats are visible to the naked eye and once spotted, it is
essential to increase the beneficial fungi applied to the soil. Adult gnats do not need to
be sprayed; simple sticky traps will collect the majority, and the rest should be controlled
in the soil.
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Powdery Mildew
Powdery Mildew is a fungal disease appears on medical cannabis plants as a white, powdery
film common to both certain strains of hops and also cannabis plants. It begins as bumps on
the top of the leaves. It can be caused by poor circulation in the grow room.
Root Rot/Pythium
This fungal disease can destroy the roots of the medical cannabis plant, particularly in those
plants that have already been weakened by other sources of stress or disease. Plant leaves
begin to wilt and turn yellow at the edges. This fungus can be carried by gnats. The best
prevention for root rot is to keep the grow room clean, well-ventilated, and pest-free.
Mold/Botrytis
This necrotic fungus often attacks the flowers of the medical cannabis plant approximately a
month before harvest. It can be diagnosed by examining the interior of the flower for grey,
white, or blue-green moldy hairs protruding. These spores live in the air, therefore it is
important to prevent an outbreak of the disease by keeping the grow room clean and well
ventilated.
Fusarium Wilt
Fusarium is a fungus that lives in the soil of the medical cannabis plant and attacks root
systems during an outbreak. It can be diagnosed by small dark spots on the leaves, which can
quickly turn the leaves yellowish before wilting. The disease prevents nutrients from traveling
through the plant. Plants infected with a fusarium outbreak must be separated from the rest
immediately and destroyed.
Environmental Stresses
The following environmental stressors can affect the growth of cannabis. It is imperative to
maintain a consistent environment in order to prevent the following:
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Nutrient burn occurs when a plant has been fed too many nutrients, especially nitrogen.
Leaves will turn a deep, dark green, wilt or begin to show burnt tips. Overfeeding does
not make the plant grow faster or bigger. When a plant is given too many nutrients, or
not enough, then it starts showing signs of stress. This is caused by mineral imbalances
which prevent the plant from carrying out its normal functions. Common signs of nutrient
stress are burnt brown or yellow leaf tips, yellowing leaves or other unusual
coloring/spotting, leaves falling off and slowed growth. As plants get older, they need
fewer nutrients and may be more likely to show signs of nutrient stress. An older
cannabis plant will need fewer nutrients than a younger one.
Sometimes plants appear to be suffering from a nutrient deficiency but treatment fails to
solve the problem. This creates chemical reactions that lock up nutrients, making them
insoluble and preventing them from being absorbed by the roots. When this occurs,
balance can be restored by flushing the plant with twice the amount of water as the size
of the container. Salts will wash out of the medium and the plant will be able to absorb
the proper amount of nutrients again.
Root Bound
The roots of a cannabis plant require enough grow medium to stretch out and absorb
nutrients. When a plant is in a container that is too small to allow the roots to grow, the
plant is root bound. Growth is stunted and the plant suffers. Transplanting the plant into
a larger container will allow the roots to develop and revive the growth of the plant. The
minimum requirement for root zone size is approximately 1 gallon per month of growth,
but is also dependent on final size and energy input.
Light burn
Light burn occurs when the cannabis plant is too close to the grow lights, or touches the
bulb. Plants use light as energy. Chloroplasts are special organs inside leaf cells that
capture the red and blue spectrum waves and use them to power photosynthesis. In this
process plants take elements from water and air to make sugar while releasing free
oxygen. The sugar is used to build tissue, including flowers. The more light the plant
has the faster the chloroplasts can function. As long as the plant is supplied with
enough water, carbon dioxide and nutrients it will increase production when it receives
more light. Cannabis plants require, at a minimum, 50 watts of HPS or MH light per
square foot, but if the lights are too close to the plants, any wattage will scorch the
plants.
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When cannabis plants are over watered, an anaerobic condition is created where the
roots of the plant are receiving no oxygen. Roots don’t use carbon dioxide, but they do
use oxygen. They obtain it from the air spaces between the soil particles. When they
are deprived of oxygen they cannot function properly and gradually lose their vigor. The
roots are easily attacked by pathogens when the plant is overwatered, as well as
becoming more likely to develop mold issues.
Under-watering
Cannabis roots should never dry out. An under watered cannabis plant will quickly wilt,
dry up and die. The amount of water that a plant needs and how often it should be
watered depend on its size, the size of the container, canopy, root level and room
temperature, humidity and the stage of growth. Larger plants require more water and
larger containers need to be watered less frequently. Plants use less water in the last
few weeks of flowering.
Heat burn
Indoors, cannabis plants prefer moderate temperatures - between 70-75 degrees when
the lights are on, and a slightly cooler set point, no more than 15 degrees, when the
lights are off. Plants can withstand high temperatures when they have a large and
healthy root system that can draw up enough water to keep the plant cool through
transpiration. During vegetative growth, when the plant is growing bigger and stronger
and not yet producing flowers, temperatures in the 80’s and 90’s will result in stem
elongation, preventing the plant from developing a strong and compact stem. During the
flowering phase of growth, high temperatures result in airy, undeveloped flowers that do
not provide quality medicine.
The room temperature of the grow space is not as important as the temperature
between the lights and the plants. If this space is too warm, increasing air conditioning,
ventilation and raising the lights will get the temperature to return to normal levels.
CO2 burn
Cannabis plants absorb carbon dioxide and release oxygen. The plant uses the CO2 for
growth and is the essential building block for photosynthesis. Increasing CO2 in the
grow space increases yields and plant growth. Supplemental levels of CO2 over 1,200
PPM will increase growth and yields by up to 20% by assisting the plant in absorbing
more light. CO2 also assists the plants and growers by allowing the plant to tolerate
higher temperatures and maintain normal growth cycles in temperatures that are not
ideal, which can lower HVAC and power costs. When Co2 ppm is too high, cannabis
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All regulators and environmental control systems that regulate carbon dioxide emissions
must be maintained in good working order and be serviced in accordance with the
manufacturer’s recommendations in order to regulate CO2 usage and efficiency.
pH Imbalance
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Topping
Topping a plant consists of removing the top shoot or shoots in order to force a plant to send
its energy to lower branches. When a plant is topped, each lower branch becomes a main
stem, thus turning one plant into multiple smaller plants that share one main stem and root
system. All topping occurs in the vegetative stages of plant growth. The vegetative manager
will ensure all plants are topped in order to achieve the appropriate branching structure.
Correct topping procedure follows:
1. The first topping shall be done when the plant has achieved 3-4 nodes.
2. With scissors, snip off the tip of the plant between the 3rd and 4th node.
3. Remove the bottom nodes so that four branches remain.
Super Cropping
Super cropping is similar to topping a plant in that the goal is to slow down the growth of an
aggressive stem in order to allow the lower foliage to catch up, resulting in a bushier plant with
more overall colas. The vegetative manager shall utilize super cropping after the plant has
been topped several times, i.e. in the pre-flowering stage of growth to prepare the plant for
SCROGing in the flowering stage.
Super cropping process: Super cropping involves the bending of the highest stems in order
to equalize the plant's energy between branches resulting in an even upper canopy. The
vegetative manager shall super crop plants in the pre-flowering phase by the following
process:
SCROG
"Screen of green" is a variant of the traditional "sea of green" where the goal is to have an all
cola garden. The main difference between the two methods is in sea of green, each plant only
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Each flowering zone manager will ensure that the plants within their designated zone are
properly SCROG’d by the following processes:
Netting
The first step in SCROGing is preparing the screen. Two flowering zone employees
shall install a net from the frame surrounding each table in the zone.
1. Unwrap netting material and unwind it along the side of the table to be netted.
2. One person on each end will stretch the net open at its width.
3. Carry the net over the top of the plants on both ends.
4. Wiggle the net down into the canopy so that the upper five inches are exposed.
5. Affix the net evenly to the framing using zip ties.
SCROGing
The SCROGing process involves weaving the plants through the net so that each
flowering top receives an equal amount of light in the optimal light zone. The flowering
zone manager will SCROG each area so that the maximum numbers of flowering tops
receive optimal lighting. SCROGing occurs during the early flowering phase (weeks two
to three).
1. Once Plants in the Flowering Room reach a height where the plants branch
structure has been pruned enough to determine which branches will be most
likely to reach their MGP, netting should be stretched over the plants and
anchored to the poles mounted on the outside of the tables. This netting is to
provide a structural trellis through which branches may be placed in order to
spread the flowers out ensuring each Flower receives optimal lighting.
2. Determine which branches will be threaded through the netting. Be sure to utilize
the Step Stool to view the Canopy as a whole.
3. Without damaging or over stressing the plants, gently thread the branches
through the netting making sure to utilize the entire surface area of the net.
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All plants shall immediately have their leaves removed to allow adequate airflow around the
flower while it is hung to dry in a room with a humidity level below 50%. Fans move the air
while humidity is reduced further over the next few days allowing all flowers to decrease their
moisture content to below 15%.
Flowers are then safe to place in containers where their moisture content is reduced to less
than 10%. During this time, the bud is slowly turned allowing all plant terpenes to be released
and evenly coat the entire batch creating a consistent smell and flavor profile.
Prior to being trimmed and cured, the processing team will segregate all harvested cannabis
flower into their designated pre-determined homogenized batches. All segregated batches will
be maintained in a secure, climate-controlled location suitable for the prevention of product
contamination or efficacy loss.
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The processing manager will ensure each batch remains segregated to avoid cross
contamination and in order to maintain strict inventory control. Each batch will be clearly
labeled and tagged with RFID and its exact location will be clearly defined and tracked at all
times.
Processing/Wet Trimming
Immediately after harvest all products from a selected batch are processed for drying. The
processing manager shall follow the following process for trimming all cannabis:
Materials/tools for trimming and processing: Sharp/clean spring loaded scissors, vinyl
gloves, stainless steel working tables, rubbing alcohol, hanging rack, hangers, etc.
Processing/Dry Trimming
Immediately after harvest all products from a selected batch are processed for drying. Dry
trimming is ideal for smaller crops. The processing manager shall follow the following process
for dry trimming all cannabis:
1. Ensure adequate staff members are available to trim the given batch.
2. Ensure that all work surfaces and tools are clean and sanitized.
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Materials/tools for trimming and processing: Sharp/clean spring loaded scissors, vinyl
gloves, stainless steel working tables, rubbing alcohol, hanging rack, hangers, etc.
Drying
The drying process consists of slowly removing the majority of moisture from finished cannabis
in a manner that preserves and increases the efficacy of each batch. Harvested cannabis has
moisture content of approximately 80%. During the drying process the moisture is slowly
reduced to 15% and then moved into the curing phase to further reduce the moisture content
to 8% so it can be safely sealed.
Cannabis that has been trimmed on the stem can also be dried on the stem. Stem
drying ultimately creates the highest quality finished product.
1. Prepare hanger by labeling with batch RFID and all pertinent information
including strain.
2. After trimming, hang individual stems on a hanger until the hanger is loosely full.
3. Hang hangers on wall rack designed for stem drying.
4. Scan batch tag and record location and all pertaining data in SIS.
Materials for stem drying: Hangers, vinyl gloves, wall hanging system
When it is necessary to trim cannabis flowers off the stem, the processing manager will
utilize a screen drying system to remove moisture from the flowers and prepare each
batch for final curing.
1. Label screen with batch RFID and all pertinent information including strain type
and harvest date.
2. After flowers are trimmed, place on drying screen and insert screen into racking
system.
3. Scan batch RFID and record location and all pertaining data in SIS.
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Curing
Curing is the process of slowly removing moisture content from 15% down to 8% in order to
remove the remaining chlorophyll and sugars from flowers and prepare them for packaging or
processing into extraction form. The processing manager will utilize the following process to
ensure cannabis is cured properly:
1. Label container with batch tag and all pertinent information including strain and harvest
date.
2. Place cannabis into container no higher than the fill line.
3. Seal the container and log moisture level.
4. Scan Batch barcode tag and record location and all other pertinent information.
5. When moisture level increases by 10 points, open the valve on the lid and allow
moisture level to reduce. May take one to five hours.
6. When moisture level holds firm at pre-determined level for two days, cannabis is
properly dried.
7. Open lid valve every two days for remaining days in the 14-day period.
8. Rotate container daily.
9. After 14 days, cannabis shall be sealed to await testing and test results.
Secured Storage
After the processing manager has determined that a batch has been fully dried and cured, that
batch will be weighed, sealed, and secured within the storage vault until the batch has been
tested and approved for distribution. The processing manager shall scan each batch and
record all data in the SIS.
Sealing Product
Each batch of cannabis must be sealed and stored after it has dried and cured in order to
maintain optimal moisture content. The processing team will seal each batch of dried and
cured cannabis through the following process:
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Testing
After curing and before any processing or packaging, the processing manager shall make
samples from each batch available to an independent laboratory for testing. The sample shall
be weighed, RFID scanned, and all data shall be recorded on the SIS prior to be removed from
the secured curing area. The laboratory employee will select and prepare several random
samples from every batch sample in order to ensure the quality, purity, and consistency of
dose through a statistical approach. The laboratory staff will then test each random sample for
harmful microbiological contaminants, mycotoxins, heavy metals and pesticide chemical
residue. In addition, each sample will also be tested for active ingredients including but not
limited to cannabinoid profiling for the following: THC, THCa, CBD, CBDa, and CBN. Under no
circumstances shall cannabis batches awaiting contamination results and active ingredient
analysis be included in a cannabis product or sold to a retail dispensary facility prior to the time
that the laboratory has provided those results, in writing, to the dispensary management team.
If samples from a batch are tested and do not fall within state accepted health and safety
levels for any of the above mentioned contaminants or any additional contaminants the state
does not deem for distribution, it is the dispensary's policy to destroy and remove any
contaminated product in a manner consistent with state compliance for the policy for disposal
of green waste.
As soon as a batch sample passes the microbiological, mycotoxin, heavy metal and pesticide
chemical residue test, the entire batch will be released for immediate manufacturing,
packaging and labeling for transport and sale to a dispensary facility.
An electronic copy of all test results will be filed by laboratory staff for any batch that does not
meet the standards set for microbiological, mycotoxin, heavy metal or pesticide chemical
residue tests. These results will also be sent to dispensary staff within the same time frame.
The laboratory staff will also maintain a comprehensive record of test results and make them
available to state and local officials, and or the public, as needed.
The dispensary compliance manager will provide test results for each batch of cannabis used
in any product purchased by a dispensary facility to that dispensary facility to be made
available upon request to all qualifying patients, primary caregivers, and any physician who
has certified a qualifying patient.
Packaging
The dispensary shall not release or sell any part of a lot of usable cannabis until all required
assurance testing has been completed in compliance with §11-850-85 subsection (j) . All
cannabis is to be held in the secured pre-testing storage vault while awaiting test results.
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Labeling specifications
Pursuant to 11-850-92 subsection (b), each package will be labeled using only black
lettering on a white background with no pictures or graphics and shall include:
1. Information about the contents and potency of the cannabis and cannabis product,
including but not limited to:
A.Net weight in ounces and grams or volume and also the equivalent weight of the
cannabis used to produce the cannabis product
2. The dispensary’s license number and name of the production center where the
cannabis was produced
3. The batch number and the date of packaging
4. A computer tracking inventory identification number barcode generated by tracking
software
5. Date of harvest or manufacture and “Use by date”
6. The instructions for use
7. The specific phrases “For medical use only” and “Not for resale or transfer to
another person”
8. Warnings must be included in labelling:
A. “This product may be unlawful outside the State of Hawaii and is unlawful to
possess or use under federal law”
B. “This product has intoxicating effects and may be habit forming”
C. “Smoking is hazardous to your health”
D. “There may be health risks associated with consumption of this product”
E. “This product is not recommended for use by women who are pregnant or
breast feeding”
F. “Cannabis can impair concentration, coordination, and judgment. Do not
operate a vehicle or machinery under the influence of this drug”
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Opening Responsibilities
The opening responsibilities will primarily be comprised of getting the manufactured cannabis
products facility ready for the day's production. This will consist of the following:
Closing Responsibilities
The closing responsibilities will primarily be comprised of closing the manufactured cannabis
products facility and securing product for safe storage throughout the night. Closing
responsibilities will consist of the following:
Safety Checks
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Preparation
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A dispensary facility shall comply with state and county health, safety, and sanitation
regulations and may be subject to inspection to affirm that no health or safety concerns are
present which may contaminate the products.
State Regulations
The manufactured cannabis products facility will be in full compliance with all applicable state
and local laws and regulations regarding health, safety and sanitation. It will be the
responsibility of the manufactured cannabis products facility manager to insure the creation
and implementation of policies for regulatory compliance.
General Standards
General Sanitary Requirements. Our cannabis products facilities will take all reasonable
measures and precautions to ensure the following:
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Collect raw medical cannabis material from which you will create the concentrate.
Collect all necessary equipment needed for entire extraction process.
o Bubble bags
o Container or wash machine
o Mixer
o Ice and water
Start extraction process by setting up the bubble bags in proper micron order.
Mix raw medical cannabis material in the bubble bags with ice and water.
Mix the bubble bag mixture thoroughly with mixer or in wash machine.
Lift bubble bags and let water and ice drain from bags.
o Repeat this process a few times.
When you feel you have extracted all the desired cannabinoids from raw
material, take bubble bags out of water mixture or wash machine.
Pull all concentrate from bubble bags and use pressing screen to extract all
remaining water from concentrate.
Let concentrate dry and cure.
Report all quantities and types of concentrates produced.
Inventory management and compliance
Packaging and labeling
Transfer to retail facility(s)
CO2 Extraction
Extracting cannabinoids and other essential components of medical cannabis.
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Solvent Extraction
Solvent extraction methods use various solvents to capture the plant cannabinoids for the
concentrate production.
The most common solvent used for this extraction method is alcohol.
Typically, medical cannabis products being used to make the concentrate will be soaked in the
solvent for a period of time.
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Disposal of Waste
Dispose of any waste produced during the processing of medical cannabis in accordance with
all applicable local, state and federal laws, rules and regulations.
Grinding and incorporating the cannabis waste with non-consumable, solid wastes listed
below such that the resulting mixture is at least 50 percent non- cannabis waste:
o Paper waste;
o Plastic waste;
o Cardboard waste;
o Food waste;
o Grease or other compostable oil waste;
o Bokashi, or other compost activators;
o Other wastes approved by the department that will render the medical cannabis
and medical cannabis-infused product waste unusable and unrecognizable as
cannabis; and
o Soil.
A licensee shall not dispose of medical cannabis and medical cannabis-infused product
waste in an unsecured waste receptacle not in possession and control of the licensee.
Quality Control
The quality and consistency of cannabis and manufactured cannabis products is critical for the
success of the organization. Facility management shall ensure that only medical cannabis and
medical manufactured cannabis products of the highest, pharmaceutical grade quality are
wholesaled, transported and dispensed within the state of Hawaii.
Quality control procedures designed to maximize safety for owners and occupational licensees
and minimize potential contamination will be utilized within our dispensary facility. Quality
control procedures will pertain to cultivated raw cannabis and manufactured cannabis
products. Facility employees will be properly trained on quality control measures and protocols.
For quality control, facility employees will at a minimum:
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Fire Emergency
If fire is small and isolated, try to exhaust the fire with one of the fire extinguishers.
In case of a fire emergency, dial 911 for Fire Department.
Chemical Spill
Try to use chemical spill kit for smaller incidents of chemical spill.
If chemical spill is large or you do not know how to handle the situation, escalate to
your manager.
Other Emergencies
Contact 911 for break-ins or burglaries.
Record Keeping/Documentation
This section will detail how to maintain clear and comprehensive records of the name,
signature, and owner or occupational license number of every individual who is engaged in any
step related to the creation/production of a production batch of medical cannabis and the step
that individual performed.
Documentation/Records Needed
These records will be kept by the manager and stored in the office.
Make sure you are following all laws, rules and regulations.
Fill out daily production logs for our records.
Fill out daily transfer to center logs for our records.
Fill out daily wholesale logs for our records.
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The laboratory shall file with the Department an electronic copy of each laboratory test result
for any batch that does not pass the microbiological, mycotoxin, or pesticide chemical residue
test, at the same time that it transmits those results to the dispensary center. In addition, the
laboratory shall maintain the laboratory test results for at least six years and make them
available at the Department's request.
A dispensary center shall provide to a dispensary organization the laboratory test results for
each batch of cannabis product purchased by the dispensary organization, if sampled. Each
dispensary organization shall have that laboratory results available upon request to qualifying
patients, designated caregivers and a physician who has certified a qualifying patient.
State Regulations
Per §11-850-85 subsections (a)-(i):
Each batch of cannabis or manufactured cannabis products shall be made available at the
dispensary center for an employee of an approved laboratory pursuant to §11-850-85
subsections (a)-(i) to select a random sample, which shall be tested by the approved
laboratory for:
microbiological contaminants;
mycotoxins;
pesticide active ingredients;
residual solvent; and
purposes of conducting an active ingredient analysis.
A laboratory shall immediately return or dispose of any cannabis upon the completion of any
testing, use or research. If cannabis is disposed of, it shall be done in compliance with HAR
§11-850-85(j).
Microbiological Test
For purposes of the microbiological test, a cannabis sample shall be deemed to have passed if
it satisfies the recommended microbial and fungal limits for cannabis products in colony
forming units per gram (CFU/g) set forth in §11-850-85(F).
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If samples from a batch are tested and do not fall within state accepted health and safety
levels for any of the above mentioned contaminants or any additional contaminants the state
does not deem for distribution, it is the dispensary and manufactured cannabis products
facility's policy to destroy and remove any contaminated product in a manner consistent with
state compliance for the policy for disposal of waste. Pursuant to HAR §11-850-85 subsection
(j) the batch will be retested or destroyed if the retesting confirms that the batch is non-
conforming. The batch will be quarantined until such time that the department lifts the
quarantine.
As soon as a batch sample passes the microbiological, mycotoxin, heavy metal and pesticide
chemical residue test, the entire batch will be released for immediate processing
manufacturing, packaging and labeling for transport and sale to a manufactured cannabis
products facility or a dispensary facility.
An electronic copy of all test results shall be filed by laboratory staff for any batch that does not
meet the standards set for microbiological, mycotoxin, heavy metal or pesticide chemical
residue test. These results will also be sent to the dispensary facility staff and/or the
manufactured cannabis products facility staff within an adequate time frame. The laboratory
staff will also maintain a comprehensive record of test results and make them available to state
and local officials, and or the public as needed.
The dispensary facility and/or manufactured cannabis products facility compliance manager
shall provide test results for each batch of cannabis used in any product purchased by a
dispensary facility to that dispensary facility to be made available upon request to all qualifying
patients, primary caregivers, and any physician who has certified a qualifying patient.
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State Regulations
Packaging and Labeling Per §11-850-92: Packaging and Labeling of Medical Cannabis
and Manufactured Cannabis Products.
Labeling specifications
Pursuant to HAR §11-850-92(b), each package will be labeled using only black lettering on a
white background with no pictures or graphics and shall include:
Information about the contents and potency of the cannabis and cannabis product,
including but not limited to:
Net weight in ounces and grams or volume and also the equivalent weight of the
cannabis used to produce the cannabis product
The concentration of tetrahydrocannabinol or Δ9 tetrahydrocannabinol, total
tetrahydrocannabinol and activated tetrahydrocannabinol-A, and cannabidiol
The dispensary’s license number and name of the production center where the
cannabis was produced
The batch number and the date of packaging
A computer tracking inventory identification number barcode generated by tracking
software
Date of harvest or manufacture and “Use by date”
The instructions for use
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Storage:
Not produce or maintain cannabis in excess of the quantity required for normal, efficient
operation;
Store all cannabis and manufactured cannabis products in a safe, vault or secured room
and in such a manner as to prevent diversion, theft or loss;
Maintain all cannabis that is not part of a finished product in a secure area or location
within the dispensary center accessible only to specifically authorized personnel, which
shall include only the minimum number of employees essential for efficient operation;
Keep all approved safes, vaults, or other equipment or areas used for the production or
storage of cannabis securely locked or protected from entry, except for the actual time
required to remove or replace cannabis;
Keep all locks and security equipment in good working order;
Not allow keys to be left in the locks and not store or place keys in a location accessible
to persons other than specifically authorized personnel;
Not allow other security measures, such as combination numbers, passwords or
electronic or biometric security systems, to be accessible to persons other than
specifically authorized personnel; and
Keep the dispensary center securely locked and protected from unauthorized entry at all
times.
If a dispensary center presents special security issues, such as extremely large stock of
cannabis, exposed handling or unusual vulnerability to diversion, theft or loss, the
department may require additional safeguards, such as supervised Watchman service.
If a loss, theft or diversion of cannabis has occurred from a dispensary center, the
dispensary center shall notify the department and the nearest SP district immediately.
The department and SP shall determine the appropriate storage and security
requirements for all cannabis in the dispensary center, and may require additional
safeguards to ensure the security of the cannabis. If a reduction in the amount of
medical cannabis in the dispensary center's inventory is due to suspected criminal
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All cannabis and manufactured cannabis products offered for sale at registered retail
dispensing organizations shall be labeled in accordance with HAR §11-850-92(b). In
accordance with §11-850-31 subsections (d),(e), and (f), a dispensary will not transfer any
cannabis or manufactured cannabis products to any other dispensary nor accept any cannabis
or manufactured cannabis products from any other dispensary.
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Pursuant to HAR §11-850-61(a), the record of clear and unbroken chain of custody needs to
be maintained at all stages. Prior to transporting any cannabis or cannabis-infused product,
our dispensary center shall in accordance with HAR §11-850-36:
Complete a shipping manifest using a form prescribed by the department that lists the
components required by the department’s tracking system.
Only the cannabis products that are listed on the manifest shall be transported.
Cannabis products that are being transported shall:
o Only be transported in a locked, safe and secure storage containers.
o Have a copy of the manifest in the interior and on the exterior of the container.
Any motor vehicle transporting cannabis shall travel directly from the dispensary center
to the dispensary facility, or a testing laboratory, and shall not make any stops that are
not on the manifest. Exceptions will include a stop for refueling or, in case of an
emergency. In case of emergency, the agents will report the emergency immediately to
law enforcement through the 911 emergency system and the dispensary center, which
will immediately notify the department.
Our dispensary center shall ensure that all delivery times and routes are randomized
and reduce the possibility of theft or diversion.
Each delivery team member shall have access to a secure form of communication with
personnel at the dispensary center and the ability to contact law enforcement through
the 911 emergency systems at all times that the motor vehicle contains cannabis.
Our dispensary center shall staff all transport motor vehicles with a minimum of two
employees. At least one delivery team member shall remain with the motor vehicle at all
times that the motor vehicle contains cannabis.
For the transport between or among dispensary facilities, the transport package shall be
packed, secured, and loaded and unloaded and unpacked in front of full view of security
surveillance cameras.
If there are any discrepancies between what is received and the manifest, they will be
reported immediately to the department.
Each delivery team member shall possess his or her department issued identification
card at all times when transporting or delivering cannabis and shall produce it for the
department or department's authorized representative or law enforcement official upon
request.
The dispensary will not transport cannabis or manufactured cannabis products:
1. Off site to patients or caregivers
2. To another county or another island within the same county
3. To, from, or within any federal fort or arsenal, national park or forest,
Firms often learn of potential product safety problems at an early stage. For this reason,
companies involved in the manufacture, importation, distribution, or sale of consumer products
should develop a system for maintaining and reviewing information about their products that
might suggest that their product has a defect or poses an unreasonable risk of serious injury or
death. Such information includes, but is not limited to, consumer complaints, reports of
production problems, product testing, or other critical analyses of products.
Experts have shown that one of the best ways to ensure that a product recall is effective is to
have a recall plan already in place and to execute the plan as quickly as possible. A well-
thought out, well-executed recall plan can save lives and prevent injuries in addition to limiting
damage our company’s brand and bottom line.
The Consumer Product Safety Commission (CPSC) has compiled resources to assist
companies that manufacture, import, distribute, retail, or otherwise sell consumer products.
CPSC has developed a Recall Handbook that can be utilized in case a product recall needs to
be ordered. The Recall Handbook details how to recognize potentially hazardous consumer
products as soon as possible. The book explains how to develop and implement a “corrective
action plan” (called a CAP) to address the hazards; it explains CPSC’s Fast Track Program.
The Recall Handbook also discusses how to communicate recall information to consumers and
how to monitor product recalls. The Consumer Product Safety Commission’s Recall Handbook
will be a valuable tool utilized by MMMD if the need for a product recall ever arises.
The Recall Handbook should be referenced to determine exact protocol for recall and the
requirements from the Consumer Product Safety Commission. The Recall Handbook can be
obtained online from http://www.cpsc.gov/PageFiles/106141/8002.pdf. MMMD will carefully
review the Recall Handbook in order to:
Become familiar with their reporting requirements under sections 15(b) and 37 of the
Consumer Product Safety Act, and Section 102 of the Child Safety Protection Act, Pub.
L. 103-267;
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Recall Regulations
Per §11-850-85(j):
Dispensary centers shall establish, maintain and comply with the policies and procedures
contained in the Operations and Management Practices Plan, approved by the Department, for
the production, security, storage, inventory and distribution of cannabis products. The policies
and procedures shall include methods for identifying, recording and reporting diversion, theft
and loss, and for correcting all errors and inaccuracies in inventories. We will include in our
written policies and procedures a process for the following:
Recall:
A dispensing organization must establish a policy for communicating a recall for cannabis or a
cannabis-derived product that has been shown to present a reasonable or a remote probability
that use of or exposure to the product will cause serious adverse health consequences. Our
policy will include:
A mechanism to contact all customers who have, or likely have, obtained the product from the
dispensary. The communication will include information on the policy for return of the recalled
product;
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Dispensary center will post notifications about the product recall on its website as well
as making partnering dispensary centers and dispensing organizations aware of the
product recall. The actual recalling processes will be handled by the dispensing
organizations with help and support from the dispensary center.
As the dispensing organization issuing a recall notice it will be important to reach the
end users or the recalled product. MMMD will post notification about the recall on
MMMD websites and social media as well as post written notices of the recall on
location for patients and customers to view. The recall notice will include all pertinent
information regarding the product being recalled, contact information and other
information relating to the recall. Information will include but not be limited to:
Product name
Product batch number
Dispensing date range of recalled product
Dispensing organization locations
Once the recall notification has been issued to all applicable dispensing organizations
and medical cannabis patients, MMMD will wait to receive recalled products from
dispensing organizations and/or licensed medical cannabis patients. Once recalled
products have been received, MMMD will properly dispose of all recalled products.
The dispensing organization issuing a product recall to medical cannabis patients will
need to be ready to obtain and secure recalled products from patients. Patients should
be able to bring in the products being recalled to the dispensing organization's location.
It will be at the dispensing organization's discretion whether to issue a refund, replace
the recalled product at no cost, or to take other measures.
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MMMD will maintain all documentation and records regarding any and all product
recalls issued.
MMMD will ensure that any and all recalled cannabis products are disposed of
according to all state and local regulations. MMMD will follow waste destruction and
disposal procedures outlined below for proper disposal of recalled cannabis and
manufactured cannabis products.
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Disposing of Waste
A minimum of seven days prior to rendering the secured green waste unusable and disposing
of said waste, an agent from the dispensary facility team shall utilize the traceability system.
Immediately before the green waste is processed for disposal it shall be re-weighed by the
quality control manager and at least one other staff member and all information will be
recorded including, weight, time, date, employee names and signatures. After capturing all
pertinent data, logging, and entering into the company SIS, all waste shall be rendered
unusable and prepared for either compostable or non-compostable disposal. The dispensary
facility compliance manager shall oversee the entire waste disposal process and ensure it in
done. All waste processing and disposal shall be recorded on video surveillance.
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Non-compostable materials: Paper waste, cardboard waste, plastic waste, soil or other waste
approved of by the Department.
Mix the cannabis thoroughly with other ground materials so that the resulting mixture is a
minimum of 50% non-cannabis waste from the above list or other waste approved by the
department.
Liquid Waste
The dispensary center compliance manager will ensure all liquid waste is disposed of in
a manner consistent with requirements placed within the Illinois Environmental
Protection Act specific to the substance being disposed of.
Hazardous Waste
The dispensary center compliance manager will ensure that all hazardous and chemical
waste is disposed of in a manner consistent with federal, state, and local laws.
State Regulations
Cannabis and manufactured cannabis products shall be destroyed by rendering them
unusable following the methods set forth in this section.
At least seven days prior to rendering cannabis unusable and disposing of it, the
dispensing organization shall notify the Division and SP. Notification shall include the
date and time the cannabis will be rendered unusable and disposed. If the dispensing
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PATIENT EDUCATION................................................................................................. 35
REQUIRED MATERIALS AND INFORMATION .................................................................................. 35
EDUCATION MATERIAL RESTRICTIONS ......................................................................................... 35
DOCUMENTATION .............................................................................................................................. 35
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Our Dispensing Locations will provide qualifying patients the highest quality Cannabis
and manufactured Cannabis products in a safe a secure environment. It is our intent to
provide our patients with the latest information available from the medical community,
warnings and requirements provided by the Department, as well as custom materials
and information covering strain specific medical uses in order to assist them in choosing
the safest and most effective medication prescribed by their physician. These
medications will be dispensed in forms and quantities that comply with all of the
Departments requirements. Unauthorized persons will be prevented from entering our
dispensaries by our highly trained security staff using physical barriers, strict
Identification documentation requirements, as well as 24-hour video surveillance of the
entire facility.
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Dispensary Manager
The Dispensary manager reports to the Director of Retail Dispensary Operations. The
Dispensary manager will oversee all aspects of the Dispensing Location including but
not limited to inventory controls, security concerns, cash handling procedures, patient
education and satisfaction, good neighbor relations, employee training and certification,
and any other procedures carried out by the Dispensing Location or as requested by the
Director of Retail Dispensary Operations.
Security Manager
The Security Manager will report to the Director of Security. They will be responsible for
the hiring, certification, training, scheduling and managing of Security Agents. They will
be responsible for ensuring the security of employees, patients, and all company
property. They will be responsible for ensuring safe delivery and of all cannabis and
manufactured cannabis products. They will be responsible for the operation, regular
maintenance, and storage of all video surveillance equipment and data. The security
manager will ensure all agents are operating within the parameters set forth by the
Department and the Department of Commerce and consumer Affairs Professional and
Vocational Licensing Law.
Dispensary Agent
Dispensary agents will report to the Dispensary Manager. They will be responsible for
day to day operations of the Dispensary. They will receive training on all aspects of
patient care, retail sales, safe handling practices, OSHA, HIPAA, and all other
requirements of the Department. They will receive ongoing training and recertification as
required by the Department. Dispensary Agents will not have access to patient data or
secure storage areas unless accompanied by a Manager.
Security Agent
Security Agents will report to the Security Manager. They will be charged with the safety
of patients, employees, and company property at all times. Security Agents will monitor
the Dispensary using line of sight, as well as a video surveillance system that will
operate 24 hours a day. Security Agents will oversee the facility to ensure that no
unauthorized persons are allowed access to the Dispensary at any time. Security
Agents will receive initial and ongoing training to ensure that they are always operating
within the parameters set by the Department and the Department of Commerce and
Consumer Affairs Professional and Vocational Licensing Law.
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PayChex Services
Payroll Services
In addition to processing the organizations regular payroll for both exempt, and non-
exempt employees, Paychex will ensure compliance with federal and state regulations
in regards to payroll taxes by managing withholdings for federal, social security,
Medicare, state & local taxes, and also provide end of year W-4 processing.
Employee Handbook
Paychex offers a service that will assist in writing the employee handbook that
implements company specific policies, and matches company culture, while still
maintaining regulatory compliance with local, state, and federal law.
In addition, the EAP program offers a wellness program. The wellness program includes
a comprehensive health risk assessment, up to three sessions with a personal wellness
coordinator hot help navigate wellness services, 24/7 access to a virtual fitness trainer,
and wellness tools, trackers, and articles.
Recruiting and applicant tracking will be streamlined through the use of the Paychex
applicant tracking system to assist in creating a positive candidate & new hire
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Safety Plan
Training
Maui Medical Marijuana Dispensary LLC, will provide training upon hire as well as
annually to each employee including but not limited to:
Record keeping
Maui Medical Marijuana Dispensary, LLC, will retain all records, both physical and
electronic for a minimum of six years. Electronic data will be encrypted and stored on
secure servers in secure storage areas under 24-hour video surveillance. Physical
records will also be stored in a secure storage room under 24-hour surveillance. The
secure storage room will have limited access. The Dispensary may utilize biometric
security measures as well as pin number protection. Access Logs will be analyzed daily
to ensure no unauthorized entry has occurred. Access Logs, as well as all other
records required by the department in HAR §11-850-41, will be stored for a minimum of
six years including but not limited to:
Inventory Tracking
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Sales records will be retained for each individual qualifying patient and primary
caregiver to reflect compliance with dispensing limitations as required by HAR
§11-850-42.
Financial Records
Logs recording every individuals entrance and exit from the Dispensary.
Employee Records
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Robbery or Theft
If being robbed at gunpoint or you feel your life is in danger, comply with all
requests from perpetrator. Give them whatever they ask for.
Try to signal for help through security panic buttons provided or through the panic
button or police services button located on the alarm panel.
Contact police as soon as possible
Notify any required state or local authorities
Fire Emergency
If fire is small and isolated, try to exhaust the fire with one of the fire
extinguishers.
In case of a fire emergency, dial 911 for Fire Department or push the symbol on
the alarm panel for fire emergency.
Chemical Spill
Try to use chemical spill kit for smaller incidents of chemical spill.
If chemical spill is large or you do not know how to handle the situation, get the
Dispensary Manager to handle the situation.
Other Emergencies
Contact 911 for break-ins or burglaries.
Contact any required state or local authority in cases of theft, break-ins or
burglaries.
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The intent is one of mutual respect between neighbors; to avoid adversarial positions, to
treat others as one would like to be treated; to keep an open mind; and be willing to
cooperate with neighbors with a goal of creating a safe and healthy neighborhood
environment.
MMMD, LLC has worked hard to build positive relationships with the residents and
businesses in our neighborhood. To be a qualified patient or primary caregiver
associated with MMMD, LLC you are required to agree and comply with the following
rules:
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Environmental Plan
Conservation and the reduction of our carbon footprint within the communities we
operate in is a primary objective of the organization. This will be implemented
throughout the entire organization and at every facility. We will look for new and
innovative ways to reduce our carbon footprint within the dispensing facility and/or the
Cultivation organization facility. ‘Reduce, Reuse, and Recycle’ will be implemented on
an organization-wide scale.
The Retail Dispensing Location management will also create and implement an
employee conservation plan. The employee conservation plan will detail specific actions
employees can take for conservation efforts to try and reduce their carbon footprint. A
possible reward program may be created and implemented to reward facility employees
for conservation efforts.
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Employee Conservation
Team members within the dispensary facility will recycle all paper and plastic waste
products. Energy efficient lights and equipment will also be utilized within the facility. We
will also create programs within the organization that will encourage and reward
employees for their personal conservation efforts, such as carpooling and riding a bike
to work.
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Inventory Management
Inventory management is a critical factor in every area of the dispensary. The tracking
of all medical cannabis from seed-to-sale will be done through an advanced inventory
control system with multiple checks and balances in place to allow our staff to have a
complete awareness of all inventory including: Pre-packaged Cannabis Flowers, Pre-
packaged cannabis infused products, and waste. All data collected shall be recorded
through the use of template log sheets, computer systems, BioTrack, and Point-of-Sale
systems (POS). Physical inventory counts will be done on a daily, weekly, and monthly
basis at the Dispensary. In addition to scheduled inventory checks, random audits will
be performed. Inventory control procedures shall be utilized as the primary way of
determining whether there has been any product diversion and ensuring that all medical
cannabis and cannabis-infused products are only being distributed to valid state
approved medical cannabis patients.
Physical inventory template log sheets will be filled out each morning before the start of
business and again at the closure of business. All weekly inventory procedures shall be
conducted in full compliance with HAR §11-850. Data collected during daily, weekly,
annual and random inventory procedures shall be logged and input into computer,
BioTrack, and POS systems. Inventory figures will be cross-referenced with the POS
system inventories and data to determine that there are no quantity discrepancies. In
the case of a discrepancy within inventory, we will investigate the root cause of the
discrepancy to determine the cause. If the discrepancy is due to employee theft or
diversion, we will act quickly to terminate the employment of the perpetrator and contact
all necessary authorities for further action. All inventories, procedures, and other
documents required by the department shall be maintained on the premises for six
years and made available to the department at all times.
Inventory Control
Our organization shall designate in writing, a Dispensary Agent who has oversight of the
inventory control system of the Dispensary. The compliance manager will be
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The compliance manager is the designated agent who shall oversee the Dispensary
facility inventory control system at all times in order to ensure that daily inventory
documentation, product transfers, inventory discrepancies, and record keeping are
always maintained and up to the minute. The appropriate Dispensary facility staff
member shall document the following items as they occur:
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Per HAR §11-850-36, the compliance manager shall ensure documentation of all
medical cannabis sold or otherwise disposed, including but not limited to:
o The date of sale;
o The name of the state approved patient to which the medical Cannabis
was sold;
o The batch number, product name and quantity of Cannabis sold; and
o If applicable, the date, quantity, manner in which, and reason why any
Cannabis was destroyed.
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All data pertaining to the disposal of all Cannabis that is not usable shall be
tracked in the inventory control system including:
o A description of and reason for the Cannabis being disposed of;
o The date of disposal;
o Confirmation that the Cannabis was rendered unusable before disposal;
o The method of disposal; and
o The name and medical Cannabis establishment agent registration card
number of the employee responsible for the disposal.
Loss or Theft
Chain of custody
The chain of custody of all Cannabis and manufactured Cannabis products shall be
documented, through scanning and logging, at all times as it moves through each
process within the dispensing location. Chain of custody documentation shall be
maintained for six years and shall be made available to the Department and local law
enforcement upon request.
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If a loss, theft, or diversion of Cannabis has occurred from the dispensing location, the
dispensing location manager shall notify the Department and the nearest police district
immediately. The Department and Local Law Enforcement shall determine the
appropriate storage and security requirements for all Cannabis in the Dispensing
Location, and may require additional safeguards to ensure the security of the Cannabis.
If a reduction in the amount of medical Cannabis in the dispensing location inventory is
due to suspected criminal activity, the Dispensing Location agent in charge shall
immediately report the reduction to the Department and Local Law Enforcement.
All areas of the Dispensing Location containing Cannabis, including any rooms with
approved safes or approved vaults, shall have a sign posted at all entryways, which
shall be a minimum of 12 inches in height and 12 inches in length and shall state: "Do
Not Enter − Limited Access Area – Access Limited to Authorized Personnel Only" in
lettering no smaller than one inch in height.
Dispensary employees shall provide current copies of the Dispensary center floor plan to
any local law enforcement that have jurisdiction in the area where the Dispensary
Location is located.
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All inventories, procedures and other documents required by the State shall be
maintained on the premises and made available to the Department at all times.
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Patients should be welcomed by name when possible. Make eye contact while
speaking politely and smile often. Be attentive, and listen when patients are speaking.
Our security department has two main functions that should be kept in mind at all times:
All Security employees must remain aware of their surroundings at all times
and take immediate preventative measures to reduce or remove the likelihood
of injury to anyone at the facility.
All Security employees should take steps to protect all company assets from
theft, damage, or acts of violence while providing a safe physical environment
for all staff, patients, and visitors.
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Incident Response
This section will describe the process through which the Dispensary security staff will
manage incidents reported, witnessed, or suspected at the Dispensing Location. Once
security personnel have been advised of an on-site threat or act of aggression:
Investigate and verify that the threat or act of violence has, is, or will occur
and assess the seriousness.
Approach the threat maker if safety permits, and advise the individual of the
policy concerning threats and that they must leave the premises immediately.
If the threat maker refuses to leave or cannot be removed safely, notify local
law enforcement (911) immediately.
Contain the threat by sealing off the affected area.
Evacuate the immediate area surrounding the threat. If a full facility
evacuation is required, initiate the emergency evacuation plan.
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Video Surveillance
The Video surveillance system utilized at the dispensary will comply with all Department
requirements as stated in HRS §329D and HAR §11-850. Video resolution will be
sufficient to make a clear and certain photo identification of anyone under observation.
The Video surveillance system will have a secure backup. The entire facility will be
under observation with the exception of restroom facilities. Any area with the potential to
contain Cannabis or manufactured Cannabis products will be under surveillance. Any
area where the packing or unpacking of secure containers carrying Cannabis or
manufactured Cannabis products will occur, will be under video surveillance. All
entrance and exits from the dispensary will be under video surveillance from interior and
exterior views. Data collected from the cameras will be securely stored for a minimum
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Dispensing Limit
Patient Records
The Dispensing Location Manager must ensure that all patient Identification and
State registration documents are current and documented in the point of sale
system. In addition, all activity concerning patients in the dispensary will be
recorded including but not limited to:
Arrival times and dates;
Departures times and dates;
Amount, strain, and tracking ID of purchased Cannabis or manufactured
Cannabis products and;
Educational materials covered.
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The Dispensing Location will make interpretative services available that are
appropriate for the local population being served, including for the visually- and
hearing-impaired. These services will be applied by any effective means that do
not violate any privacy considerations.
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Documentation
All Educational materials presented to a qualifying patient will require the patients
signature and date that they received the materials as well as the signature and unique
ID of the presenter. These records will be kept for six years and presented to the
Department upon request.
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Not procure or maintain cannabis in excess of the quantity required for normal,
efficient operation;
Store all cannabis and cannabis-infused products in a safe, vault or secured
room and in such a manner as to prevent diversion, theft or loss;
Maintain all cannabis product in a secure area or location within the Dispensing
Location accessible only to specifically authorized personnel, which shall include
only the minimum number of employees essential for efficient operation;
Keep all approved safes, vaults, or other equipment or areas used for the storage
of cannabis securely locked or protected from entry, except for the actual time
required to remove or replace cannabis;
Keep all locks and security equipment in good working order;
Not allow keys to be left in the locks and not store or place keys in a location
accessible to persons other than specifically authorized personnel;
Not allow other security measures, such as combination numbers, passwords or
electronic or biometric security systems, to be accessible to persons other than
specifically authorized personnel; and
Keep the Dispensing Location securely locked and protected from unauthorized
entry at all times.
If a loss, theft or diversion of cannabis has occurred from the Dispensing Location, the
Dispensary Manager shall notify the Department and the nearest Law Enforcement
district immediately. The Department and local law enforcement shall determine the
appropriate storage and security requirements for all cannabis in the Dispensing
Location, and may require additional safeguards to ensure the security of the cannabis.
If a reduction in the amount of medical cannabis in the Dispensing location’s inventory is
due to suspected criminal activity, the Dispensary manager shall immediately report the
reduction to the Department and local law enforcement.
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Dispensing Location Agents shall provide current copies of the Dispensing Location
floor plan to local law enforcement that have jurisdiction in the area where the
Dispensing Location is located.
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Hours of Operation
The Retail Dispensing Location will be open from 8:00 a.m. until 8:00 p.m., Monday
through Saturday. The Location will be closed on Sundays, as well as official state and
federal holidays.
Identification Requirements
Upon entry to the Retail Dispensing Location, all patients and caregivers must present
to the Security Agent, a medical use of marijuana registration card issued by the
department and a valid government issued form of photo identification. The registration
card will be verified in the Department data base to ensure that no unregistered
individual is permitted to enter the Dispensary. Forms of identification accepted:
Lawful Transactions
The dispensary manager will be responsible for all sales transactions taking place
inside the Dispensary Locations. The dispensary manager must ensure that all
dispensary agents working in the dispensary facility are properly trained on all operating
procedures. Maui Medical Marijuana Dispensary, LLC, will ensure that no unlawful
sales transactions are permitted or tolerated in accordance with state laws and
regulations. Where possible, engineered controls will be established to ensure that it is
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Display of Product
The Dispensary will display no more than one sample of each product offered for sale.
These products will be displayed in locked cases, behind the counter, and will be
inaccessible to patients.
Refusal of Sale
Suspected Diversion
Cash Management
Internal Controls
The General manager shall ensure that a system of controls is maintained for
cash handling and accounting functions. Tight controls must remove
opportunities for unauthorized access to cash.
Dual Custody is required any time cash is transferred from the registers to
the safe and from the facility to the bank.
Any petty cash will be under the control of the Dispensary Manager and
reconciled daily. The petty cash account should not exceed $1000. All
receipts and vouchers will be accounted for and the drawer should be in
balance at all times.
ATM and debit card transactions must be reconciled weekly.
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Each Dispensing Location is responsible for keeping and maintaining records that
clearly reflect all financial transactions and the financial condition of the business. The
following records must be kept and maintained on the permitted premises for a six-year
period and must be made available for inspection if requested by the Department, and,
when applicable, the Hawaii Department of Taxation:
Purchase invoices, bills of lading, manifests, sales records, copies of bills of sale
and any supporting documents, including the items and/or services purchased,
from whom the items were purchased, and the date of purchase;
If applicable, bank statements and canceled checks for all accounts relating to
the Dispensary center;
Accounting and tax records related to the Dispensary center and each producer
backer;
Records of all financial transactions related to the Dispensary center, including
contracts and/or agreements for services performed or received that relate to the
Dispensary center;
All employee records, including training, education, discipline, etc.;
Transportation records;
Inventory records;
Records of any theft, loss, or other unaccountability of any Cannabis or
manufactured Cannabis products, or other items containing Cannabis.
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Visitor Log
Cleaning Log
The Retail Dispensing Location manager is responsible for overseeing the use of
a daily cleaning log to track cleaning within all zones of the facility.
Maintenance Log
A facility maintenance log will be utilized to track maintenance and upkeep on all
equipment within the facility.
Sales Records
All sales must be recorded accurately and completely and entered in the POS system.
The Dispensary Manager will ensure that, should the POS system fail or become
unavailable for any reason, all sales should be halted and the Department notified of the
problem. The Department should again be notified when the POS system becomes
available before sales can resume.
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Each plant shall be tracked by its physical grid location in the premises at all times. All
significant dates and observations will be recorded as key data points in the BioTrack
for referencing needs throughout the plant's life cycle. This information can be used to
recall any contaminated medium, nutrient, or issue that may occur during the stages
listed above and allows for easy removal from production or inventory of any product
that does not meet the requirements of the state.
An inventory of Cannabis in the cultivation stage shall be conducted each week. During
the cultivation process, physical location will be broken up into a grid system and each
square will have a designated number of plants per grid area.
Auditing the inventory of all plants shall be effectively and efficiently accomplished with
spot checks done daily to mitigate any diversion during cultivation, processing and/or
packaging, as well as detecting any human error that may have occurred while entering
information during the plant’s life cycle.
After the flowering cycle has been completed and the plant is harvested, inventory shall
be transitioned from the flowering zone to the processing department, and prepared for
trimming. During this transfer, all product will be scanned, tracked and logged. At this
point, a pre-trimming weight will be determined and logged.
After being weighed and logged, all flowers will be cleaned, trimmed, and prepared for
drying in the secured vault. Each batch is transferred through each state with the
entirety of the batch. All green waste from the trimming process shall be weighed,
logged and disposed of according to our policy for managing waste from cannabis
plants (see transportation protocol).
After drying and curing, each batch shall be tested for efficacy. Once a batch has
passed all regulated testing protocol and our standards set forth by business
management, it shall be released for packaging and labeling. Before being transferred
to packaging, the entire batch will be weighed again, scanned and logged into BioTrack.
As each package is wrapped and processed, each individual package will be weighed
again and reconciled against the total batch weight. Once packaged, all product shall be
scanned and logged into the second vault designated for all approved and packaged
products and stored until transfer.
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When a Qualifying patient purchases products, the transaction will be recorded by our
POS system as well as BioTrack.
This entire process from seed to sale will be recorded on high definition cameras, and
all recordings will be stored for six years.
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professionals whose substantial aggregate net worth and access to financial resources assures the
future financial stability of the business. MMMD has performed deep due diligence and research
on the medicinal cannabis industry, which has informed its financial modeling framework and
strategy to ensure that the business will be properly funded and operated in a financially prudent
(A) Pursuant to HAR §11-850-15-6, on October 2nd, 2015, more than 90 days prior to the
opening of the licensing application process, MMMD opened a checking account at the Central
This capital has been deposited by MMMD managing members Shep Gordon
and have remained in the account continuously since the date of deposit. These funds are
immediately available for MMMD to begin operating a licensed medical cannabis dispensary.
See Addendum 3-1 for the official letter from the Central Pacific Bank verifying the date of
As shown below, Table 1 provides a summary of net worth figures of all managing
members of the company. MMMD has provided official letters from CPAs serving each
individual managing member of the MMMD that support these net worth figures (See
Addendum 3-2).
These statements clearly demonstrate the strong financial position of each of the
members further supporting and enhancing MMMD's ability to adequately capitalize the
business as well as create and execute a sound financial strategy for operating a dispensary.
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 3 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
Net Worth
Shep Gordon
Ken Ota
Anthony Takitani
Howard Takishita
TOTAL
Additionally, MMMD has obtained a letter of intent from a state-chartered bank to secure
of debt financing in the form of a fixed-interest loan, providing the company with
immediate access to operating and investment capital upon award of the license. The ability of
MMMD to secure such debt financing speaks highly of MMMD’s proven commercially
successful track record and its ability to execute on the business plan (See Addendum 3-3.)
Therefore, upon award of the application, MMMD will have immediate access to $9,200,000.
by the applicant are provided in Addendum 3-4. As evidenced by the statements, MMMD
members own and operate various businesses with substantial net assets and income. All of the
businesses are in good standing, and none of the businesses have any back taxes, liens,
(C) MMMD's objective is to build and operate a long-term financially viable medical cannabis
production, manufacturing, and retail dispensary platform in Hawaii. To that end, MMMD has
1. Financial planning and forecasting of MMMD's income, including, but not limited to:
a. expectations of patient demand, MMMD’s market share, expected product pricing and
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 3 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
implement the real estate strategy (property acquisition, build out, etc.) as well as overall
2. Capital formation strategy designed to ensure that all capital and operating expenses of
Revenue Forecast
Patient Demand. As a base case, MMMD assumed that the adoption rate will initially
amount to 1% of total Maui population of 163,000 people (as of Q4 2015). Based upon
conservative estimates, MMMD estimates the patient population in Maui will be 2,445 at the end
of the fourth quarter of 2017, increasing at a rate of 1.5% until Hawaii begins to allow for
visitors to the island with a medical cannabis card from another state to purchase medical
cannabis at the first quarter of 2018. At the end of the fourth quarter of 2018, MMMD anticipates
the island will have 4,614 qualifying patients, and the patient population will continue to grow at
a rate of 2% through the fourth quarter of 2019. As a holder of one of the two medical cannabis
licenses in Maui County, MMMD assumed 50% of total market share. MMMD has studied other
regulated medical cannabis markets to determine the expected patient population (including
historical trends in other states), expected patient consumption patterns, product price dynamics
Expense Forecasting
CAPEX. As specified in the business plan, MMMD is planning to develop two state-of-
the-art, 3,000 plant capacity production centers and two retail dispensary locations.
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 3 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
increasing patient demand. To that end, MMMD plans to utilize a 44,000 square foot building,
production and manufacturing facilities. The available capital and existing infrastructure of the
main production center allows MMMD to proceed with construction in a timely manner and
Upon award of a license, meeting the requirements of HAR §11-850-32, and satisfying
the Department of Health inspection, MMMD will commence cultivation operations within a
pre-existing prefabricated building, which is attached to the main (first) production center on the
proposed premises. This initial production space will be utilized for operations while
improvements are being made to the main production center in order to provide cannabis
medicine to qualified patients in a timely manner. The attached prefabricated building is secure,
enclosed, compliant with Department regulations per HAR §11-850-32, and will be ready for
approval to produce and manufacture medical cannabis by May 15th, 2016. This will provide for
an initial harvest and distribution of approximately 20 pounds of safe and consistent cannabis
medicine as early as August 29, 2016. MMMD has negotiated contracts for two retail dispensary
OPEX. According to the financial plan, the majority of operating expenses (both at the
corporate level and for cost of goods sold) is driven by the payroll. As specified in the business
plan, MMMD is planning to adopt a gradual ramp up strategy in terms of staffing of both
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 3 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
production and retail dispensary facilities to ensure adequate coverage of both production and
retail operations, including security personnel. The human resources and staffing strategy will be
consistent with patient demand dynamics and on-going development of the facilities. At the
corporate level, MMMD is planning a similar gradual increase in payroll expenses, as none of
the managing members and senior operating professionals will receive full salaries until the
financial plan has conservatively allowed for additional operating expenses such as legal,
Capital Formation
aggregate net worth and access to the real estate loan provide ample
capital to support the operating strategy of the business and related budget. Additionally,
MMMD members are able utilize their vast personal network of high net worth individuals,
family offices and other qualified investors, as well as various qualified intermediaries and legal
advisors to supplement the already plentiful financial resources with external capital as needed.
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
The following Addenda are provided as supporting documents in accordance with the "FAQs-
for-MMJ-Dispensary-licensing-program-12-22-2015-005-FINAL.pdf" file found at
http://health.hawaii.gov/medicalmarijuana/
Q: Can I submit letters of support for my application, for example from community members
and professionals?
A: You may submit information or documentation that you consider relevant in support of the
representations you make in your application, but all materials in support of your application
have to be submitted at the time you apply, and may not be submitted separately. Anything not
received with your application will not be considered as part of your application. Information or
documentation that is not specifically requested may or may not be considered in determining
your qualification as an applicant. Letters of support may also be subject to public disclosure.
Page 1 of 25
Addendum 3-5
PROFORMA Q1 2016 Q2 2016 Q3 2016 Q4 2016 Q1 2017 Q2 2017 Q3 2017 Q4 2017 2018 2019
EXPENSES 172,000 6,318,430 6,354,472 1,533,606 1,411,243 1,332,968 1,403,505 1,804,132 8,152,056 8,775,733
CAPEX (Real Estate & Development) 60,000 5,684,000 5,645,000 350,000 150,000 - - -
Real Estate - Purchase / Acquisition (Total) $ 10,000.00 989,000 - - - - - -
Construction - Cultivation / Processing 3,520,000 3,520,000 - - - - -
Construction - Retail Dispensaries 500,000 500,000
Laboratory Equipment 1,200,000
Interior Fixtures 250,000 250,000 200,000 - - - -
Utilitites - Offsite 250,000 - - - - - -
Misc./Contingency 50,000 175,000 175,000 150,000 150,000 - - -
Cost of Goods Sold - 258,930 431,122 905,256 990,293 1,061,843 1,132,380 1,533,007 7,067,556 7,691,233
- Cultivation & Processing - 258,930 431,122 665,256 750,293 821,843 892,380 1,293,007 6,107,556 6,731,233
Crop Inputs 45,987 45,987 57,484 57,484 68,981 106,046 509,764 578,269
Payroll (Production, Retail, Security) 258,930 258,930 383,110 397,610 469,160 469,160 642,380 2,979,980 3,183,360
Utilities 121,019 121,019 151,273 151,273 181,528 279,068 1,341,485 1,521,759
Packaging and Labeling 37,343 46,679 46,679 56,014 86,112 413,944 469,571
Secured transportation - - - - - - -
Product Formulation 69,154 86,442 86,442 103,730 159,467 766,563 869,577
Cultivation Waste 1,037 1,037 1,297 1,297 1,556 2,392 11,498 13,044
Processing Waste 3,458 4,322 4,322 5,187 7,973 38,328 43,479
Processing Inputs 4,149 4,149 5,187 5,187 6,224 9,568 45,994 52,175
- Dispensary (Flower & Derivative) - - - 240,000 240,000 240,000 240,000 240,000 960,000 960,000
Derivative
Flower -
Operating Expenses 77,000 340,500 243,350 243,350 270,950 271,125 271,125 271,125 1,084,500 1,084,500
Lobbyist 5,000 5,000 5,000 5,000 5,000 5,000 20,000 20,000
Corporate Payroll Expenses 128,500 128,500 128,500 144,500 153,750 153,750 153,750 615,000 615,000
Staffing/HR/Insurance 12,850 12,850 14,450 15,375 15,375 15,375 61,500 61,500
Dispensary Lease (Pa'ia) 27,000 27,000 27,000 27,000 27,000 27,000 27,000 27,000 108,000 108,000
Travel 30,000 30,000 30,000 30,000 30,000 30,000 30,000 30,000 120,000 120,000
Consulting Fees 15,000 150,000 15,000 15,000 15,000 15,000 15,000 15,000 60,000 60,000
Legal Fees 5,000 5,000 10,000 10,000 20,000 10,000 10,000 10,000 40,000 40,000
Office Expense 5,000 5,000 5,000 5,000 5,000 5,000 20,000 20,000
Other Operating Expenses 10,000 10,000 10,000 10,000 10,000 10,000 40,000 40,000
QUARTER Q4 2016 Q1 2017 Q2 2017 Q3 2017 Q4 2017 Q1 2018 Q2 2018 Q3 2018 Q4 2018 Q1 2019 Q2 2019 Q3 2019 Q4 2019
Annual Maui Visitors 2,000,000 2,020,000 2,040,200 2,060,602 2,081,208 2,102,020 2,123,040 2,144,271 2,165,713 2,187,371 2,209,244 2,231,337 2,253,650
Reciprocity Medical Card Holders Rate (Start Q1 2018) 0.75% 0.75% 0.75% 0.75% 1.00% 1.00% 1.00% 1.00%
Total Monthly Visitation Patient Population - - - - - 1,314 1,327 1,340 1,354 1,823 1,841 1,859 1,878
Local Maui Population 163,000 163,000 163,000 163,000 163,000 163,000 163,000 163,000 163,000 163,000 163,000 163,000 163,000
Local Maui Adoption Rate 1% 1% 1.25% 1.25% 1.50% 1.50% 1.75% 1.75% 2.00% 2.00% 2.00% 2.00% 2.00%
Total Local Patient Population 1,630 1,630 2,038 2,038 2,445 2,445 2,853 2,853 3,260 3,260 3,260 3,260 3,260
Combined Monthly Visitation & Local Patient Pop. 1,630 1,630 2,038 2,038 2,445 3,759 4,179 4,193 4,614 5,083 5,101 5,119 5,138
Company Maui Market Share 50% 50% 50% 50% 50% 50% 50% 50% 50% 50% 50% 50% 50%
# of Company Patients 815 815 1,019 1,019 1,223 1,879 2,090 2,096 2,307 2,541 2,551 2,560 2,569
Monthly Consumption Per Patient (LBS) 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375
Monthly Patient Demand (LBS) 76 76 96 96 115 176 196 197 216 238 239 240 241
Retail Price Per Pound (LBS) $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200
Quarterly Flower Revenue $ 1,191,938 $ 1,191,938 $ 1,489,922 $ 1,489,922 $ 1,787,906 $ 2,748,595 $ 3,056,186 $ 3,065,889 $ 3,373,674 $ 3,716,804 $ 3,730,133 $ 3,743,596 $ 3,757,193
Quarterly Derivative Product (Oil) Revenue $ 246,456 $ 246,456 $ 308,070 $ 308,070 $ 369,684 $ 568,325 $ 631,925 $ 633,932 $ 697,572 $ 768,521 $ 771,277 $ 774,060 $ 776,872
Quarterly Revenue $ 1,438,394 $ 1,438,394 $ 1,797,992 $ 1,797,992 $ 2,157,590 $ 3,316,920 $ 3,688,112 $ 3,699,821 $ 4,071,246 $ 4,485,325 $ 4,501,410 $ 4,517,656 $ 4,534,065
Page 25 of 25
Question 4 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
Security Plan demonstrating its ability to comply with HRS §329D-7. It is MMMD’s goal to
prevent theft and diversion, while maintaining patient, public, and product safety. MMMD will
utilize the services of Revolution Managed Services (RMS) to assist with the design and
implementation of security systems and operating procedures for the dispensary operation.
MMMD selected RMS for its proven ability to maintain effective security systems and
procedures in the highly regulated Illinois medical cannabis market. RMS-managed facilities
contain over
covered under video surveillance. Furthermore, RMS facilities are equipped with advanced
access control features restricting access onto the premises, into the facility and between
compartments, intrusion alarm systems, adequate perimeter and site lighting, and a secure
MMMD’s Security Plan utilizes security benchmarks and standards that are expertly
applied and adapted to HRS §329D and HAR §11-850, as they relate to physical security and
control measures to prevent diversion, abuse, and other illegal or unauthorized conduct relating
to medical cannabis. This plan will ensure compliance, and exceed the requirements found in
HAR §11-850-4 and HRS 329D-7 paragraph (6) (See Addenda: Security Plan).
MMMD Production Centers & Retail Dispensing Locations will employ a professionally-
installed video surveillance system, allowing for 24-hour continuous video monitoring and
recording of all production centers and retail dispensary locations. These systems will be
equipped with
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 4 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
All recorded images will clearly and accurately display the time and date. The surveillance
system storage devices and cameras will utilize internet protocol (IP), providing MMMD the
capability to provide the Department, or Law Enforcement, with real-time or archived video
footage upon request. Cameras have been carefully selected for the environment where they are
to be located, as well as the activities they will be capturing. The camera resolution shall allow
for the clear and certain identification of any person and activities in any area where cannabis
products are produced, moved, or stored; all points of sale areas; any room used to transport
cannabis or manufactured cannabis products; any room or area storing a surveillance system
storage device; and all exits and entrances to a dispensary or production center facility from both
indoor and outdoor locations. The video server will be locked in a secure server rack, protecting
detect unauthorized entry and notify law enforcement in an emergency situation. MMMD will
utilize
containing an exterior wall, and rooms with exterior windows will be incorporated into the alarm
system using devices such as contacts, glass break sensors, and motion detectors.
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 4 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
movement between compartments, mitigating theft and diversion. The doors to restricted areas
All devices will be hardwired to network devices and attached to the IT infrastructure
through switches. This enables the access control system the ability to generate reports and send
important notifications or alarm signals by email, SMS, lights, sirens, or recorded messages
through speakers. The intended system provides for a mobile application to trigger a lockdown
from any authorized mobile device utilizing the application. Mustering reports are also generated
in the event of an evacuation during emergency operations, and they can be controlled through
A locked entry point to screen individuals for authorized entry to the centers will be
utilized at retail and production center locations. The locked entry point will contain a sign-in
system to record the names of persons entering, date and time of entry and exit, purpose for
entry, and identity of escort if applicable. The system will store the entry point records for a
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 4 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
period of 6 years. MMMD’s production centers and retail dispensaries will allow only the
the licensee of those persons who are allowed into that retail dispensary’s or production center’s
facilities for a specific purpose for that facility in accordance with sections 329-15 and 329-16,
HRS; and
(b) Other approved individuals with government issued photo identification including:
qualifying patients; primary caregivers; a government employee or official acting in the person’s
official capacity; retail dispensary or production center employees provided that qualifying
patients and primary caregivers may only be authorized to enter retail dispensing locations.
All finished, packaged medical cannabis products within the production centers and retail
dispensaries will be stored in a secured locked room, vault, or locked container securely affixed
to a wall or floor, as described in the Security Plan. MMMD will implement any other reasonable
security measures to deter and prevent diversion as deemed necessary by the Department.
In addition to the security systems, MMMD will employ several trained and qualified
security officers at the production centers and retail dispensaries to prevent diversion. Security
guards will be registered and trained as required by HAR §16-97, HRS §463, and HRS §436B.
MMMD’s Security Manager will create post duties and additional standard operating procedures
for the security department as a Security Management Plan. Guards will undergo continuous
training and evaluation in accordance with MMMD’s commitment to the community and the
medical cannabis patients, striving to set the standard for medical cannabis security (See
Addenda: Standard Operating Procedures.) Production Centers: Security measures that are
unique to MMMD’s production center location include secure chain-link fencing, containing
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 4 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
privacy screening and barbed wire outriggers at the top surrounding the operational area
perimeter, which will reasonably deter intruders and prevent anyone outside the premises from
viewing any cannabis in any form. MMMD will implement any other reasonable security
measures to deter and prevent intruders as deemed necessary by the Department. (See Addenda:
Facility Layouts, Production Center Lighting and Fencing, Security Command Center.)
Retail Dispensaries: Security measures that are unique to MMMD’s retail dispensary
locations include utilizing a protocol pursuant to Chapter 329 §, HRS for admitting qualifying
cannabis registration cards prior to allowing them access to the secured room for sales.
Additional security measures at MMMD’s retail locations include a separate secured room for
sales, which shall include secured and locked display cases for cannabis and manufactured
cannabis products; a maximum occupancy limit ratio in the secured sales room of two customers
to every one retail dispensing location employee; and exterior lighting that illuminates all entries
and exits to allow for the clear and certain identification of any person and activities
locations or testing laboratories. Product will be packed and unpacked within secure shipping
containers under view of the video surveillance system and according to a manifest.
Transportation will be performed by two trained and authorized dispensary agents, within a
secured transport vehicle, utilizing random predetermined routes. All transportation of medical
cannabis will be in accordance with HAR §11-850-36 and as detailed in the Security Plan (See
Page 5
Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
The following Addenda are provided as supporting documents in accordance with the "FAQs-
for-MMJ-Dispensary-licensing-program-12-22-2015-005-FINAL.pdf" file found at
http://health.hawaii.gov/medicalmarijuana/
Q: Can I submit letters of support for my application, for example from community members
and professionals?
A: You may submit information or documentation that you consider relevant in support of the
representations you make in your application, but all materials in support of your application
have to be submitted at the time you apply, and may not be submitted separately. Anything not
received with your application will not be considered as part of your application. Information or
documentation that is not specifically requested may or may not be considered in determining
your qualification as an applicant. Letters of support may also be subject to public disclosure.
Table of Contents
Security Plan ................................................................................................................. 2
Facility Layouts .............................................................................................................46
Page 1 of 82
Question 5 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
A.) Maui Medical Marijuana Dispensary, LLC (MMMD) shall inform qualified patients
with Department-approved debilitating medical conditions about the potential risks and benefits
of using medical cannabis, and medical cannabis products that will be available at MMMD’s
Under guidance of the Director of Patient Education (See Addenda: Pressman Bio),
MMMD’s retail dispensary agents shall inform the patient of the following: debilitating medical
conditions for which medical cannabis has been shown to be specifically indicated or may
provide therapeutic benefits; the common, uncommon, and rare adverse reactions of medical
cannabis; known drug interactions of medical cannabis with other prescribed medicines,
especially absolute contraindications versus combinations to watch closely for versus those
combinations where the effects of either drug or medical cannabis will be enhanced or
diminished; those conditions known to respond to certain specific strains of medical cannabis
available to qualifying patients from MMMD; products available from MMMD (cannabis
pistillate inflorescence, capsules, lozenges, pills, oils or oil extracts, tinctures, ointments or skin
lotions); specific medical cannabis manufactured products and delivery systems that may
enhance or decrease the effectiveness of any cannabis strain or product; and dosage/titration for
manufactured medical cannabis products based on patients’ weight, metabolism, and tolerance.
of sale to any patients requesting medical cannabis; an understanding of as much is known of the
appropriate doses and adverse reactions, drug interactions, pharmacology, and pregnancy safety
of medical cannabis; the crucial importance of receiving signed consent forms prior to
dispensing medical cannabis; patient confidentiality (See Addenda: HIPAA Privacy and Security
Question 5 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
SOP); the importance of reviewing patient handouts with patients prior to receiving medical
cannabis; and safety issues regarding the use of medical cannabis. (See Addenda: Safe Dosing
and Available Products). Other handouts include providing a list of clinicians in the local
community experienced with individuals using medical cannabis; providing a handout with a list
of common, uncommon and rare adverse reactions to the use of medical cannabis; providing
contact information for community poison control centers; and providing a list of telephone
B.) MMMD performed months of due diligence assessing current and forecasting future
medical cannabis market conditions in Maui County, Hawaii. Based on this research, the team
has produced a comprehensive market analysis and pro forma to identify qualifying patient
demand, and establish a strategy to produce a supply of medical cannabis sufficient to meet the
Patient demand projections maintain conservative growth through 2017, then increases
after the Department of Health enters into reciprocity agreements in the predicted year of 2018.
MMMD anticipates that its market share of patient demand will grow to a predicted annual
manufacturing over 3,000 pounds of medical cannabis annually. This analysis is based on
incorporating the maximum regulated plant count of 3,000 plants per production center, as well
cultivation method, capable of continuously harvesting and processing over 250 pounds of
product each month, as needed. The main production center will adequately produce, process and
manufacture medical cannabis to serve qualified patient needs beyond the year 2020.
Question 5 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
Construction of the second, separate production center on the existing premises will commence
once the main (first) production center is producing at a rate of 50% of capacity. This will ensure
an uninterrupted supply of medical cannabis to qualified patients (See Addenda: Risk Mitigation
SOPs).
In order to produce and maintain a consistent supply of medical cannabis products, all
manufacturing processes shall be controlled through strict written standard operating procedures
for each unique formulation. The production centers have been designed with the capacity and
ability to mitigate risk, maintain high levels of quality and inventory control, and to prevent
MMMD’s retail dispensary locations exceed 2,000 square feet of space and provide
adequate secure storage areas to maintain a constant supply of medicine. MMMD will track
patient purchases and incorporate patient feedback tools to ensure that MMMD produces,
medical cannabis by implementing proven cultivation and processing systems, strict written
standard operating procedures, integrated pest and disease management methods, and biosecurity
features within the premises. In order to meet future demand, the premises provide for expansion
C.) MMMD and its team of medical cannabis industry real estate, security and
construction specialists thoroughly considered all of the safe, smart, and beneficial requirements
provided within part HRS §329D-22, HAR §11-850-8, and they have identified two ideal retail
dispensary locations providing easy access and a safe environment to Maui’s qualified patients.
Question 5 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
Both the and proposed properties are distanced well beyond 750’ lineal
feet from any school, playground or public housing property pursuant to HRS §329D-22.
Additionally, both properties are zoning compliant and approved for use. The proposed
properties are located on main thoroughfares within close proximity to major population centers,
and they both contain adequately sized, stand-alone buildings, with safe exterior illumination.
population, as is a central hub for the Island. The location was selected as
provides access for a majority of the side of the island. Please see the proposed property
The proposed retail dispensary properties contain stand-alone buildings with unfinished
interiors, which MMMD will improve to contain safe and segregated waiting, dispensing, and
private consultation areas. All improvements will be made compliant to local and federal
building code, as well as ADA requirements. Security will consist of solid, locking doors
protected by access control and alarm, recording video surveillance throughout the exterior, and
within every interior room except bathrooms. Additionally, the retail dispensaries will contain
secure storage rooms constructed of reinforced walls, ceilings, and doors. Additionally, a
All potential property locations have been professionally assessed by MMMD’s security
personnel for site security, who have applied past knowledge and experience to develop,
establish, and will constantly improve MMMD's security posture to ensure its retail dispensing
Additionally, MMMD will employ and train qualified dispensary agents to follow
specific written standard operating procedures to keep the product, patients, and the public safe.
Question 5 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
Dispensary agents will verify qualified patients’ credentials, provide safe and secure premises
through monitoring and standard operating procedures, compliantly serve qualified patients, and
D.) Maui Medical Marijuana Dispensary, LLC is greatly concerned with customer
satisfaction. MMMD will use best practices when designing and implementing patient survey
tools that capture customer feedback. Survey tool options that may be utilized include email
surveys, SMS messages, and in-store paper surveys. MMMD shall only use digital tools that are
certified to protect PHI, such as SurveyMonkey Platinum Business Plan which includes the
Services, are highly experienced in designing and implementing scientific observational research
studies conducted within licensed dispensaries which collect patient data regarding personal
experiences and preferences for medical cannabis products. These studies are designed to gather
market data without collecting any identifying information about the individual patient, thereby
eliminating any exposure to protected health information. MMMD shall implement this same
research within its dispensaries using best practices in collecting observational data following
IRB guidelines, and shall make the results of this research available to the public and to
individual qualifying. MMMD shall utilize this feedback to predict market demand for specific
strains and manufactured products. The data collected from these tools shall be stored in a secure
manner that safeguards the customer's protected health information. When patients report
adverse effects or product complaints, MMMD shall follow written procedures modeled after 21
CFR § 211.198 regarding Complaint files (See Addenda: Complaint Files SOP). In the event that
a recall is necessary, MMMD shall follow written procedures for initiating a recall to ensure that
customers' concerns and needs are handled expeditiously and to their satisfaction.
The following Addenda are provided as supporting documents in accordance with the "FAQs-
for-MMJ-Dispensary-licensing-program-12-22-2015-005-FINAL.pdf" file found at
http://health.hawaii.gov/medicalmarijuana/
Q: Can I submit letters of support for my application, for example from community members
and professionals?
A: You may submit information or documentation that you consider relevant in support of the
representations you make in your application, but all materials in support of your application
have to be submitted at the time you apply, and may not be submitted separately. Anything not
received with your application will not be considered as part of your application. Information or
documentation that is not specifically requested may or may not be considered in determining
your qualification as an applicant. Letters of support may also be subject to public disclosure.
Dr. Pressman will be responsible for the strategic direction and implementation of medical education
programs to support MMMD’s goal to provide safe, compassionate care to the patients of Maui.
Dr. Pressman believes it is vitally important for the medical and lay communities to have a broader
appreciation of the established and potential value of medical cannabis and to support the removal of
current barriers that impede research in this field. He is especially excited about the potential for using
medical cannabis to treat a variety of debilitating conditions, including but not limited to post-traumatic
stress disorder, with significantly fewer short- and long-term adverse effects compared with current
psychotropic medications.
Dr. Pressman received his B.S. from the University of Maryland, College Park, in 1969, and received his
M.D. from University of Maryland, Baltimore, in 1973.
His professional training includes: a straight pediatric residency from 1973-1975 at University of
Connecticut; a fellowship in behavioral pediatrics from 1975-1976 at University of Connecticut; a general
psychiatric residency from 1976-1978 at Georgetown University; and a fellowship in child psychiatry
from 1978-1979 at Georgetown University.
Dr. Pressman is board certified with the American Academy of Psychiatry and Neurology, Adult
Psychiatry (1980), Child Psychiatry (1982), and is board eligible with the American Academy of Pediatrics
(1975).
His teaching appointments include but are not limited to clinical assistant professor of psychiatry and
pediatrics at Georgetown University Hospital from 1982-2000 and clinical assistant professor of
psychiatry at University of Maryland School of Medicine from 1985-1989.
Dr. Pressman’s extensive work experience as the consulting psychiatrist at more than a dozen
organizations---including housing and homeless shelters, children community centers, adolescent and
family organizations, centers for disabled adults, and more---positions him as not only a compassionate
steward of patients, but supports his ability to oversee all professional education activities. Education
activities with MMMD shall include ownership over successful participation rates, pre/post metrics
tracking, and post education follow ups.
Page 2 of 100
PROFORMA Q1 2016 Q2 2016 Q3 2016 Q4 2016 Q1 2017 Q2 2017 Q3 2017 Q4 2017 2018 2019
EXPENSES 172,000 6,318,430 6,354,472 1,533,606 1,411,243 1,332,968 1,403,505 1,804,132 8,152,056 8,775,733
CAPEX (Real Estate & Development) 60,000 5,684,000 5,645,000 350,000 150,000 - - -
Real Estate - Purchase / Acquisition (Total) $ 10,000.00 989,000 - - - - - -
Construction - Cultivation / Processing 3,520,000 3,520,000 - - - - -
Construction - Retail Dispensaries 500,000 500,000
Laboratory Equipment 1,200,000
Interior Fixtures 250,000 250,000 200,000 - - - -
Utilitites - Offsite 250,000 - - - - - -
Misc./Contingency 50,000 175,000 175,000 150,000 150,000 - - -
Cost of Goods Sold - 258,930 431,122 905,256 990,293 1,061,843 1,132,380 1,533,007 7,067,556 7,691,233
- Cultivation & Processing - 258,930 431,122 665,256 750,293 821,843 892,380 1,293,007 6,107,556 6,731,233
Crop Inputs 45,987 45,987 57,484 57,484 68,981 106,046 509,764 578,269
Payroll (Production, Retail, Security) 258,930 258,930 383,110 397,610 469,160 469,160 642,380 2,979,980 3,183,360
Utilities 121,019 121,019 151,273 151,273 181,528 279,068 1,341,485 1,521,759
Packaging and Labeling 37,343 46,679 46,679 56,014 86,112 413,944 469,571
Secured transportation - - - - - - -
Product Formulation 69,154 86,442 86,442 103,730 159,467 766,563 869,577
Cultivation Waste 1,037 1,037 1,297 1,297 1,556 2,392 11,498 13,044
Processing Waste 3,458 4,322 4,322 5,187 7,973 38,328 43,479
Processing Inputs 4,149 4,149 5,187 5,187 6,224 9,568 45,994 52,175
- Dispensary (Flower & Derivative) - - - 240,000 240,000 240,000 240,000 240,000 960,000 960,000
Derivative
Flower -
Operating Expenses 77,000 340,500 243,350 243,350 270,950 271,125 271,125 271,125 1,084,500 1,084,500
Lobbyist 5,000 5,000 5,000 5,000 5,000 5,000 20,000 20,000
Corporate Payroll Expenses 128,500 128,500 128,500 144,500 153,750 153,750 153,750 615,000 615,000
Staffing/HR/Insurance 12,850 12,850 14,450 15,375 15,375 15,375 61,500 61,500
Dispensary Lease (Pa'ia) 27,000 27,000 27,000 27,000 27,000 27,000 27,000 27,000 108,000 108,000
Travel 30,000 30,000 30,000 30,000 30,000 30,000 30,000 30,000 120,000 120,000
Consulting Fees 15,000 150,000 15,000 15,000 15,000 15,000 15,000 15,000 60,000 60,000
Legal Fees 5,000 5,000 10,000 10,000 20,000 10,000 10,000 10,000 40,000 40,000
Office Expense 5,000 5,000 5,000 5,000 5,000 5,000 20,000 20,000
Other Operating Expenses 10,000 10,000 10,000 10,000 10,000 10,000 40,000 40,000
QUARTER Q4 2016 Q1 2017 Q2 2017 Q3 2017 Q4 2017 Q1 2018 Q2 2018 Q3 2018 Q4 2018 Q1 2019 Q2 2019 Q3 2019 Q4 2019
Annual Maui Visitors 2,000,000 2,020,000 2,040,200 2,060,602 2,081,208 2,102,020 2,123,040 2,144,271 2,165,713 2,187,371 2,209,244 2,231,337 2,253,650
Reciprocity Medical Card Holders Rate (Start Q1 2018) 0.75% 0.75% 0.75% 0.75% 1.00% 1.00% 1.00% 1.00%
Total Monthly Visitation Patient Population - - - - - 1,314 1,327 1,340 1,354 1,823 1,841 1,859 1,878
Local Maui Population 163,000 163,000 163,000 163,000 163,000 163,000 163,000 163,000 163,000 163,000 163,000 163,000 163,000
Local Maui Adoption Rate 1% 1% 1.25% 1.25% 1.50% 1.50% 1.75% 1.75% 2.00% 2.00% 2.00% 2.00% 2.00%
Total Local Patient Population 1,630 1,630 2,038 2,038 2,445 2,445 2,853 2,853 3,260 3,260 3,260 3,260 3,260
Combined Monthly Visitation & Local Patient Pop. 1,630 1,630 2,038 2,038 2,445 3,759 4,179 4,193 4,614 5,083 5,101 5,119 5,138
Company Maui Market Share 50% 50% 50% 50% 50% 50% 50% 50% 50% 50% 50% 50% 50%
# of Company Patients 815 815 1,019 1,019 1,223 1,879 2,090 2,096 2,307 2,541 2,551 2,560 2,569
Monthly Consumption Per Patient (LBS) 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375 0.09375
Monthly Patient Demand (LBS) 76 76 96 96 115 176 196 197 216 238 239 240 241
Retail Price Per Pound (LBS) $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200 $ 5,200
Quarterly Flower Revenue $ 1,191,938 $ 1,191,938 $ 1,489,922 $ 1,489,922 $ 1,787,906 $ 2,748,595 $ 3,056,186 $ 3,065,889 $ 3,373,674 $ 3,716,804 $ 3,730,133 $ 3,743,596 $ 3,757,193
Quarterly Derivative Product (Oil) Revenue $ 246,456 $ 246,456 $ 308,070 $ 308,070 $ 369,684 $ 568,325 $ 631,925 $ 633,932 $ 697,572 $ 768,521 $ 771,277 $ 774,060 $ 776,872
Quarterly Revenue $ 1,438,394 $ 1,438,394 $ 1,797,992 $ 1,797,992 $ 2,157,590 $ 3,316,920 $ 3,688,112 $ 3,699,821 $ 4,071,246 $ 4,485,325 $ 4,501,410 $ 4,517,656 $ 4,534,065
Page 4 of 100
Page 6 of 100
Removal
1. Detain and Segregate all Products to be Recalled which are in your Firm's Control –
(TBD, Title) – is responsible to ensure that all products to be recalled in the firm's
control are not distributed (identify, detain, and segregate products on-site, in transit,
off-site storage, and off–site distribution).
2. Control the recalled product(s) – (TBD, Title) is responsible to ensure that recalled
products do not re-enter commerce. Responsibilities include:
a. Quarantine and clearly identify recalled products.
b. Reconcile quantities, identification codes, and monitor recalled products.
c. Document the returned products.
3. Decide what to do with the recalled product(s) – (TBD, Title) is responsible for
determining the action to be taken on the recalled product (destruction, reworking, and
redirection). Other related responsibilities include:
a. Determine if the regulatory authority requires actions such as witnessing
destruction of the recalled product.
b. Verify that the action taken has been effective.
c. Document the action(s) taken.
4. Verify Recall Effectiveness – (TBD, Title) – is responsible for verifying the
effectiveness of the recall. Responsibilities include:
a. Verify that distribution of recalled products has ceased.
b. Verify that all consignees at the recall depth specified by the recall strategy have
received notification about the recall.
c. Verify that consignees have taken appropriate action.
d. Document all verifications.
Page 86 of 100
Question 6 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
The MMMD owner, consultant, or employee undergoing the background check shall
provide written consent and all applicable processing fees to the department and to MMMD to
conduct the background checks pursuant to HAR §11-850-17(c) and internal SOPs.
Any future MMMD owner, consultant and employee shall be subject to internal and
external background checks pursuant to HAR §11-850-17(a). If they have a felony conviction, or
if they do not meet the requirements according to HAR §11-850-17, that individual shall be
disqualified from entering MMMD production centers and retail dispensaries, and additionally
compounds, a conviction for a crime involving violence, a conviction for a crime involving a
firearm, and any conviction for a crime involving theft, or business or commercial fraud.
Additionally, any other background history that MMMD or the Department finds would pose a
risk to the health, safety, or welfare of the public or a qualifying patient will disqualify any future
owners, subcontractors or consultants, considering the nature of the offense, the time elapsed
since the offense occurred, and evidence of rehabilitation. MMMD will exceed the Department’s
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 6 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
and responsible character, such as checking county and federal criminal records, civil records,
MMMD shall conduct timely and compliant internal and state criminal background
checks according to MMMD’s standard operating procedures. MMMD SOP’s include written
policies and procedures on conducting and maintaining current background checks on all of the
persons listed in HAR §11-850-17(a) which shall include, but not be limited to, notifying the
Department immediately of any conviction for an offense listed in HAR §11-850-17(b). All
personnel will be informed they are required to report any arrest to their manager within 3 days
MMMD’s Director of Security shall conduct all necessary internal background checks.
Each individual requiring internal background screenings shall be required to provide pertinent
background checks. The internal authorization form will not expire for the term of employment,
or contract employment, and will serve as authorization until such relationship is terminated.
MMMD is committed to being compliant with the Fair Credit Reporting Act, and will ensure to
receive individual consent prior to background screenings, and provide the reason for the
screenings to the employee via written forms. Pursuant to 15 U.S.C. §1681k (a)(1), in the event
adverse effect takes place, MMMD will provide the individual with a copy of the report, and
provide individuals with the opportunity to dispute the information contained within the report
before making a final adverse decision. In conclusion, MMMD has established and implemented
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
The following Addenda are provided as supporting documents in accordance with the "FAQs-
for-MMJ-Dispensary-licensing-program-12-22-2015-005-FINAL.pdf" file found at
http://health.hawaii.gov/medicalmarijuana/
Q: Can I submit letters of support for my application, for example from community members
and professionals?
A: You may submit information or documentation that you consider relevant in support of the
representations you make in your application, but all materials in support of your application
have to be submitted at the time you apply, and may not be submitted separately. Anything not
received with your application will not be considered as part of your application. Information or
documentation that is not specifically requested may or may not be considered in determining
your qualification as an applicant. Letters of support may also be subject to public disclosure.
Table of Contents
e-Crim Certified Reports ............................................................................................... 2
Ken Ota ..................................................................................................................................................... 2
Shep Gordon ............................................................................................................................................. 3
Tony Takitani ............................................................................................................................................. 4
Howard Takishita ...................................................................................................................................... 5
Ashley Takitani Leahey ............................................................................................................................. 6
Russell Yamane ........................................................................................................................................ 7
Dustin Shroyer .......................................................................................................................................... 8
Daniel Lohse ............................................................................................................................................. 9
Timothy Sutton ........................................................................................................................................ 10
Gina Crosley-Corcoran ........................................................................................................................... 11
Bradley Vallerius ..................................................................................................................................... 12
Dr. Howard Pressman ............................................................................................................................. 13
Timothy McGraw ..................................................................................................................................... 14
Fingerprinting Response from HCJDC...................................................................... 15
Background Check SOP ............................................................................................. 16
Page 1 of 17
Question 7 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
patient registration, and tracking of patient sales limits pursuant to HRS §329D-13. Ken Ota,
founding member and CEO of MMMD, owns and operates Pacific Pipe Company, which utilizes
accurate tracking and inventory procedures to ensure timely delivery of products to contractors,
making Pacific Pipe one of the largest, most successful pipe suppliers in Hawaii. MMMD has
also contracted Revolution Managed Services (RMS), which possesses substantial experience
managing cannabis inventory and sales using BioTrackTHC, the Department’s selected
computer software tracking system. BioTrackTHC will enable MMMD to submit real-time
information about inventory and patient purchases to the Department as required by HRS
§329D-6(k). All operational areas containing medical cannabis in MMMD’s Production Centers
and Retail Dispensaries will be under constant video surveillance, and live access and archived
MMMD will use BioTrackTHC to track each cannabis plant from its genesis as a seed or
cutting until harvested as a batch with plants of a similar strain. Agents will add new plants to the
BioTrackTHC inventory system, through the “new plant” shortcut button under the “growhouse”
tab (See Addenda: BioTrack Screenshots). MMMD categorizes new plants by source, strain,
quantity, birthdate, and location within its Production Centers. After a seed or clone has rooted
and survived to vegetative stage, it will be moved into a vegetative room, and the change of
physical location and status will be recorded into BioTrackTHC. Each plant will receive a unique
identification number and barcode tag at this time, enabling electronic tracking of each plant’s
location, status, and other vital attributes throughout its life cycle. When a plant becomes ready
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 7 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
to flower, it will be transferred into a flowering room, and its change of location will be recorded
in BioTrackTHC.
When a group of plants is harvested, they become a batch. The batch will be weighed and
recorded into BioTrackTHC. To mitigate loss and diversion, any accumulated cannabis waste
will be weighed, recorded, and segregated. BioTrackTHC will assign a unique batch number to
each batch of cannabis inflorescence, then will record information to reflect the batch’s change
in physical location from a flowering room to a humidity-controlled drying room. In the drying
After a batch has dried long enough to reach appropriate moisture content, small leaves
will be removed through dry trimming. The weights of the trimmed cannabis inflorescence,
trimmings, and waste will be recorded into BioTrackTHC. Cannabis inflorescence and
curing rooms, and their change in location will be recorded in BioTrackTHC. Harvesting and
processing operations shall be performed under video surveillance and overseen by a compliance
manager, who will be trained to prevent and detect theft and diversion.
A random sample from each batch will be chosen by a certified independent laboratory in
order to test the batch for cannabinoid content, microbiologicals, mycotoxins, and pesticides.
BioTrackTHC assigns a unique sample ID number to each random sample, which is used to track
the chain of custody of the sample during transfer to the independent lab, and to correctly
identify the results of each batch test. After a sample has passed all required testing, the
conforming test results and its correlating batch number will be printed on product labels and
affixed to packaging containers. Cannabis packages prepared for shipment will be sealed with
tamper-proof-tape, and will either be transferred to the secured storage vault, or be securely
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 7 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
transported to an MMMD Retail Dispensary location. During this process, the change in product
If a testing laboratory’s certificate of analysis for a batch does not conform to the testing
requirements of HAR §10-850-85, then MMMD shall quarantine the batch. The batch will
Pursuant to HAR §11-850-33, MMMD will not transport medical cannabis products from
its Production Centers to its Retail Dispensing locations until approved to possess and dispense
within its Retail Dispensaries. Final packaged product will be securely transported within a
secure transport vehicle, with the product being accompanied by two dispensary agents.
Additionally, record of clear and unbroken chain of custody will be recorded using
MMMD will use a transportation manifest to ensure integrity in the chain of custody of
cannabis products. Required entries for creating shipping manifests in BioTrackTHC include
administrative users, transport agents, and transport vehicle information. Additionally, the
printed shipping manifest page contains pertinent chain of custody information including, but not
limited to, date and time information, contact information, origin and designation information,
transport agent information, barcode and batch information, and number, size and quantity
information. The shipping manifest will require signatures of the shipper and receiver upon
transfer of custody of a shipment to the Retail Dispensary, while recording the transfer on video
Two members from MMMD’s compliance team will check each manifest as the
dispensary order as it filled, which will take place within the Production Centers’ secured storage
area under video surveillance. The following is an example of how MMMD will maintain
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 7 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
Page 4
Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 7 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
patients, check-in of existing patients, query of patient and product information, and tracking of
inventory and sales limits to qualifying patients, pursuant to HRS §329D-6. MMMD’s Retail
Dispensaries will be able to register a new patient by scanning the qualified patient’s driver’s
license and the unique bar code on the qualifying patient’s medical cannabis ID card. After
confirming the qualifying patient’s identity, the Retail Dispensary agent will enter the patient’s
During the registration process, a Retail Dispensary agent will track information using
BioTrackTHC, including the purchase limit of four ounces of cannabis during a fifteen
consecutive day period, or eight ounces of cannabis during a thirty-day consecutive day period,
as per section HRS §329-D-7(A) and (B). A Retail Dispensary agent will use BioTrackTHC to
identify and track the last place and time a qualified patient purchased medical cannabis toward
their sales limit, as well as the quantity remaining for the period, ensuring that no sales are
MMMD will utilize their comprehensive Standard Operating Procedures to train Retail
Dispensary agents to identify any fraudulent, or unlawful, attempts to procure medical cannabis
products from its Retail Dispensary locations. If a Retail Dispensary agent suspects fraudulent
activity, the agent must report the incident to the Retail Dispensary manager. The Retail
Dispensary manager will then either request additional identification, very registration status by
Page 5
Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
The following Addenda are provided as supporting documents in accordance with the "FAQs-
for-MMJ-Dispensary-licensing-program-12-22-2015-005-FINAL.pdf" file found at
http://health.hawaii.gov/medicalmarijuana/
Q: Can I submit letters of support for my application, for example from community members
and professionals?
A: You may submit information or documentation that you consider relevant in support of the
representations you make in your application, but all materials in support of your application
have to be submitted at the time you apply, and may not be submitted separately. Anything not
received with your application will not be considered as part of your application. Information or
documentation that is not specifically requested may or may not be considered in determining
your qualification as an applicant. Letters of support may also be subject to public disclosure.
Table of Contents
BioTrackTHC Screenshots ........................................................................................... 2
Add Vendor ............................................................................................................................................... 2
Creating Manifest ...................................................................................................................................... 2
Customer Lookup ...................................................................................................................................... 3
Growhouse ................................................................................................................................................ 3
New Plant Creation ................................................................................................................................... 4
Patient Additional Information ................................................................................................................... 4
Patient Basic Information .......................................................................................................................... 5
Preferred Vendor List ................................................................................................................................ 5
Purchase Limit .......................................................................................................................................... 6
Return Manifest ......................................................................................................................................... 6
Page 1 of 35
Question 7 Addenda
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
BioTrackTHC Screenshots
Add Vendor
Creating Manifest
Page 2 of 35
Question 7 Addenda
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
Customer Lookup
Growhouse
Page 3 of 35
Question 7 Addenda
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
Page 4 of 35
Question 7 Addenda
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
Purchase Limit
Return Manifest
Page 6 of 35
Question 8 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
Maui Medical Marijuana Dispensary, LLC shall maintain and protect confidentiality of
all patient's Protected Health Information (PHI) through environmental and administrative
controls, and proper employee training utilizing MMMD Standard Operating Procedures that are
modeled after HIPAA standards defined under 45 CFR §160.103 and Section D of the HITECH
Act of 2009. The patient's confidential information, health conditions, and medical cannabis
purchases shall be protected from the point of entering the Retail Dispensaries through final sale
Medical cannabis patients visiting the Retail Dispensing locations shall enter through a
secure door where they will be greeted by trained security personnel. There, the qualified
patient's state-issued identification or medical cannabis registry card shall be verified and
securely logged. MMMD shall only require minimal personal information on the sign-in sheet.
Once logged, the qualified patient shall enter a waiting room until the patient’s registry number
is called. Patients will have the option of a consultation with a Retail Dispensary agent within a
private consultation room. The patient will then proceed into the restricted dispensing area to
purchase medical cannabis product (See Addenda: Retail Dispensary Layouts, Dispensing
At no time shall the Retail Dispensary agent share or openly discuss any patient's
qualifying condition, health status, or medical cannabis purchase with other patients or
contractors present, and the agent shall take care when conversing with a patient or discussing a
patient on the phone. MMMD shall require that all Retail Dispensary agents who come into
contact with Protected Health Information (PHI) shall take HIPAA training and certification, and
shall maintain HIPAA certification for the duration of their employment (See Addenda: HIPPA
Training SOP).
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 8 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
MMMD shall also provide training, upon hire and annually, to all employees pursuant to
Administrative Rules. No Retail Dispensary agent shall access protected health information
MMMD shall ensure that the eighteen elements of PHI are securely stored in accordance
with 45 CFR Part 164, Subpart C - Security Standards for the Protection of Electronic Protected
Health Information. MMMD's Compliance Officer shall maintain the organization's HIPAA
In instances where patient records are maintained, MMMD shall de-identify all PHI,
when applicable. If PHI is required for record-keeping purposes, storage of files occurs within
password-protected (with biometrics) computers in a safe and secure lock-and-key office. Any
transmission of PHI data (facsimile, e-mail, text, etc.) is always communicated with encryption.
In addition, no data or records shall be released without the written consent of a patient with the
authorization to release medical information. Company policy shall state that no licensed Retail
Dispensary agent or Business Associates shall be permitted to disclose any activity relating to
patients or the dispensing of medical cannabis on any social media platform, or discuss such
topics with family or friends. Additionally, MMMD will prohibit photography or video recording
inside the retail dispensaries by anyone other than the dispensary licensee, the Department, law
Agents shall discuss and access only the minimum amount of PHI to accomplish the
purpose of counseling the patient on medical cannabis or activities related to dispensing medical
cannabis. Retail Dispensary agents and Business Associates may not discuss or store any PHI on
personal, non-secure devices such as phones, computers, or tablets. Employees shall be trained
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 8 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
on the protocol for breaches in privacy, including the Breach Notification Rule, risk assessment,
MMMD shall identify all Business Associates who may reasonably come into contact
with PHI and shall have all such organizations sign a Business Associates Agreement to ensure
that they are HIPAA-compliant and are using proper safeguards to protect PHI.
Hawai'i-approved medical cannabis computer software tracking system, which maintains patient
registry data, and confidential Point-of-Sale customer information on the MMMD's own SSAE
16 certified, Open-IX, HIPAA-compliant data centers. In this system, only licensed and
authorized Retail Dispensary agents can access customer information using a unique employee
PIN or biometric fingerprint scan. MMMD's partner, Revolution Managed Services (RMS),
processing and manufacturing facilities and is experienced with the high level of patient
Prior to opening or operating the Retail Dispensary location, MMMD shall conduct a
HIPAA Security Risk Assessment offered by the United States Department of Health and
Human Services Information Technology Security Risk Assessment Tool (Found at:
the protection of electronic PHI shall be detailed in the Security Plan (See Addenda: IT Security
Plan). MMMD shall conduct a Security Risk Assessment annually prior to the anniversary of the
licensure date to ensure compliance & patient confidentiality procedures are current and
maintained.
Page 3
Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
The following Addenda are provided as supporting documents in accordance with the "FAQs-
for-MMJ-Dispensary-licensing-program-12-22-2015-005-FINAL.pdf" file found at
http://health.hawaii.gov/medicalmarijuana/
Q: Can I submit letters of support for my application, for example from community members
and professionals?
A: You may submit information or documentation that you consider relevant in support of the
representations you make in your application, but all materials in support of your application
have to be submitted at the time you apply, and may not be submitted separately. Anything not
received with your application will not be considered as part of your application. Information or
documentation that is not specifically requested may or may not be considered in determining
your qualification as an applicant. Letters of support may also be subject to public disclosure.
Table of Contents
Page 1 of 12
Question 10 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
Signage: Maui Medical Marijuana Dispensary, LLC (MMMD) will uphold the signage
rules of HAR §11-850-91 by using only one sign at each retail dispensary. MMMD does not plan
to use a sign at its production center but reserves the right to install one at the entry gate of the
perimeter fence if later needed. MMMD has searched the local ordinances and found no outdoor
signage rules more restrictive than HAR §11-850-91, therefore any sign will be smaller than
1600 square inches and display only MMMD’s business name and no images (See Addenda:
Retail Dispensary Signage Mockup.) MMMD will post a copy of its dispensary operating license
in the retail dispensaries and production centers, required by HAR §11-850-32(c)(2), and a copy
of other necessary state and county permits and licenses in the production center facilities,
required by HAR §12-850-73(c). Inside the production centers and retail dispensaries, MMMD
will post signs that provide necessary occupational safety, life safety, and restricted access
notices following ADA, OSHA, and state law guidelines. (See Addenda: Production Center
Signage.) Additionally, the retail dispensaries will post signs that provide vital health notices to
registered patients. In keeping with the spirit of Hawaii law, MMMD will refrain from posting
Packaging: MMMD has chosen to work with Revolution Managed Services (RMS),
which has experience managing safe, innovative packaging of medical cannabis in Illinois under
rules similar to HAR §11-850-92(a). RMS provides expertise compiling and training employees
to follow Standard Operating Procedures for packaging operations including safe handling,
accurate weighing, analysis of moisture content, and optimum packing of products and shipping
containers (See Addenda: Packaging SOP). With RMS’s guidance, MMMD has identified
preferred container options for various unit sizes of cannabis and manufactured products it will
produce in Hawaii (See Addenda: Medical Cannabis Containers). Before using any container,
Page 1
Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 10 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
MMMD reviews Certificates of Compliance from the manufacturer or supplier to verify that the
container is opaque, child resistant under ASTM standard D3475-12, and composed of non-
toxic, food-safe materials that protect contents from contamination. MMMD ensures further
quality and safety by performing packaging operations using specialized fixtures and equipment.
serving, or single-wrapped item shall contain more than 10 mg of THC, and no containers of oil
or manufactured cannabis products that are sold in a pack of multiple doses, servings or single
wrapped items shall contain more than 100 mg of THC per container. Finally, after labeling,
MMMD makes every product tamper-proof by adding a shrink band or safety seal to its
container.
Labeling: MMMD has chosen to work with RMS, which has experience managing
honest, accurate labeling of medical cannabis in Illinois under rules similar to HAR §11-850-
92(b). MMMD will train its employees to follow Standard Operating Procedures for engaging
the inventory management system, printing accurate chemical analysis information, and affixing
labels cleanly onto containers (See Addenda: Labeling SOP). Every container will receive a label
that is printed and applied by an agent who has been properly trained to incorporate correct data
Analysis).
MMMD has identified preferred labels, materials, printers, applicators, and other
equipment to ensure labeling operations commence on schedule. MMMD’s labels show all
information required by HAR §11-850-92(b) using only black letters on a white background with
no images (See Addenda: Product Labels). MMMD’s labels will show additional pertinent
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
Question 10 Merit Criteria Response
Medical Marijuana Dispensary License Application – MMMD, LLC – Maui County
information including that a product’s batch was tested on a specific date for purity from heavy
products will show the product’s batch was tested to ensure residual solvent levels are within
accepted standards. When necessary, MMMD will print the required warnings and disclosures of
HAR §11-850-92(b)(8-10) and additional information on an insert placed inside the container.
Chain of Custody: MMMD is guided by RMS, which has experience ensuring chain of
custody, integrity, and accountability in the production and sale of medical cannabis. MMMD
can maintain clear, unbroken chain of custody records through all stages of production – from
propagation to dry, trim, process, manufacture, packaging, disposal or destruction – and during
by HAR §11-850-61. In both production and retail, MMMD’s video surveillance, access
restrictions, and computer software tracking system (BiotrackTHC) function as the foundation of
that only authorized agents can enter data. What transporting products or lab samples, agents will
use BioTrackTHC to print shipping manifests that list specific identifying information such as
date, time, agent names, items being transferred, and unique batch or sample numbers. Standard
Operating Procedures require two delivery agents and recipients to sign forms witnessing and
verifying integrity of transfer, and to perform custody exchanges under video surveillance. All
cannabis plants, products, and processes shall be monitored and recorded using video
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Maui Medical Marijuana Dispensary, LLC • Medical Marijuana Dispensary License Application • Maui County
The following Addenda are provided as supporting documents in accordance with the "FAQs-
for-MMJ-Dispensary-licensing-program-12-22-2015-005-FINAL.pdf" file found at
http://health.hawaii.gov/medicalmarijuana/
Q: Can I submit letters of support for my application, for example from community members
and professionals?
A: You may submit information or documentation that you consider relevant in support of the
representations you make in your application, but all materials in support of your application
have to be submitted at the time you apply, and may not be submitted separately. Anything not
received with your application will not be considered as part of your application. Information or
documentation that is not specifically requested may or may not be considered in determining
your qualification as an applicant. Letters of support may also be subject to public disclosure.
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Medical Cannabis Label Mockups
Cannabis Pistillate Inflorescence
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Labeled Medical Cannabis Containers
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