New Massachusetts training program helps cannabis companies avoid hefty noncompliance fines

It was down to the wire for some Massachusetts marijuana companies to meet a Jan. 1 deadline to train managers and employees under a new compliance and safety program that is the first of its kind in the nation.

The state’s Responsible Vendor Training Program is designed to support licensee compliance and enhance the safety of customers and employees.

Most cannabis businesses report they see the program as an investment in employees that also allows them to avoid large noncompliance fines.

However, required training on some topics might not pertain to all employees’ job duties, and some Massachusetts marijuana businesses point to the fact that people are being trained on state-mandated topics that don’t necessarily apply to their current job duties.

Marijuana training solutions provider Cannabis Trainers added three classes on Dec. 30 to ensure its clients met the deadline, said Maureen McNamara, founder of the Denver-based company.

“We trained over 1,000 people between Oct. 16 and Dec. 30,” McNamara said. “We had three trainers on the ground, including me, leading classes all across Massachusetts, including Nantucket. We had an additional three trainers leading live webinar classes.”

What’s covered in the training?

In October, the Cannabis Control Commission (CCC) gave four companies, including Cannabis Trainers, the greenlight to begin training. The selected companies offer interactive programs, either live or online, that provide instruction on:

  • Operating in accordance with state laws, regulations and local rules.
  • Seed-to-sale tracking compliance.
  • Preventing diversion and sales to minors.
  • The effects of cannabis on the human body.

Compliance training is mandated for all employees of adult-use marijuana businesses, but it’s not required for medical facilities.

“After class, employees have a depth of knowledge about the rules and how to play by the rules and never break them,” McNamara said. “There is no room for error or dancing on the edge of a rule.”

The downside of the training is that not all employees need to learn every aspect of the business, said Rick Gilbert, founder of Boston-based Stoker Consulting.

Rick Gilbert of Stoker Consulting providing training in Massachusetts.

“Requiring one type of training for people in different parts of the industry is a little bit of a challenge,” Gilbert said. “To train dispensary agents on cultivation METRC requirements has little impact on their being responsible.

“Unless they move between parts of a company that’s a vertically integrated business, they’re never going to be in a cultivation facility. They’re being trained on topics that don’t pertain their current job duties and are not likely to.

Gilbert added that he believes the goals of the CCC in creating the core curriculum are good, but “the practice on the ground can be a challenge given that people work in different parts of the industry.”

An investment in employees

The cost of the training ranges from $99 a person to $150 a person. The companies also offer discounted rates for larger groups.

“People don’t look at it as a cost,” McNamara said. “They look at it as an investment. The risk of noncompliance is so expensive that investment in training moves a business forward.”

Cannabis Trainers has trained all 49 employees at Lee, Massachusetts-based Canna Provisions, CEO Meg Sanders said.

Lessons include everything from how to read labels to ensure products are compliant to pie charts that illustrate the flower equivalent of concentrates and infused products.

“We know how vital her information is and how well she trains,” Sanders said. “It was a critical part of our business model to have employees who know how to check IDs properly and handle a customer throughout the process.”

Stoker Compliance trained all Haverhill, Massachusetts-based Stem employees at no charge because the company is participating in the state’s economic empowerment program, which is designed to engage people from communities that have been disproportionately harmed by marijuana law enforcement.

The economic empowerment program was available to companies that met certain criteria, including:

  • Being majority owned by people who lived in areas of disproportionate impact for five of the past 10 years.
  • At least 51% of employees or subcontractors have drug-related Criminal Offender Record Information but are otherwise employable in a cannabis-related enterprise.
  • Majority of ownership consists of people who are of black, Hispanic or Latino descent.
  • Owners can demonstrate significant past experience in business practices promoting economic empowerment in areas of disproportionate impact.  Program participants are eligible for training and technical assistance.

“It was a really great opportunity for the staff to engage with each other before we open our doors,” Stem Haverhill owner and CEO Caroline Pineau said.

Pineau plans to have Stoker conduct training sessions quarterly to work with Stem’s new hires.

The state mandates that workers in the cannabis industry be trained in compliance within 90 days of starting their jobs.

While Stoker offers online training for clients in remote locations or who have a small number of employees, Gilbert prefers for the training to be face-to-face.

“I firmly believe that in-person training is more effective than training online because people are easily distracted,” Gilbert said. “Being in a room together forces you to engage.”

Margaret Jackson can be reached at [email protected]

2 comments on “New Massachusetts training program helps cannabis companies avoid hefty noncompliance fines
  1. Anthony Bartucca on

    Good afternoon,
    I know I am late to the party on this, but as one of the four certified trainers in Massachusetts, your readers may benefit from the information that was provided to me by the CCC. As the only trainer that has direct hands on experience as a former Senior Compliance Officer for the Massachusetts Medical Marijuana Program, I suggested to possible clients that there actually did not appear to be a set deadline of December 31, 2019. However, I did offer to train anyone who requested training prior to December 31, 2019. I agree that the sooner agents are trained , the better, but as dispensaries in Massachusetts as well as across the country have different levels of funding, I suggested that delaying training to 2020 could possibly save them capital that they could use elsewhere while still being in compliance. Please see the CCC clarification below:

    Hi, Mr. Bartucca,
    There have been multiple commonly asked questions by certified RVT vendors. These questions have now been reviewed by the Commission’s working group and the Executive Director, please see responses below:

    I. RVT Questions—Certified RVT Applicants

    ? Question 1: There has been mention that current licensees are required to complete Responsible Vendor Training by January 1, 2020 but I have found no mention of that in the Adult-Use Regulations or Guidance. Is there a deadline for current licensees?

    ? Answer 1: The January 1, 2020 date is not in the Regulations or Guidance. It is a target date set during a Commission public meeting. Marijuana Establishments should provide a plan for how they will ensure their staff(s) have been through training and/or how many staff members have been through training. Renewal applications submitted on or after January 1, 2020 must identify whether their registered Agents have completed, enrolled in a Responsible Vendor Training program or are still seeking enrollment in a vendor training program.

    ? Question 2: [Similar to 1] I was recently approved by the CCC to conduct responsible vendor training. I have received numerous questions concerning when training may commence. The only information I have is from a MassLive report In the new which quotes Shawn Collins as saying “As of Jan. 1, all dispensaries operating in the state will require training from a commission approved trainer.” Is this the case, and if so does this mean that all current employees required to be trained, be trained by the end of March 2020?

    ? Answer 2: The January 1, 2020 date is not in the Regulations or Guidance. It is a target date set during a Commission public meeting. Renewal applications submitted on or after January 1, 2020 must identify whether their registered Agents have completed, enrolled in a Responsible Vendor Training program, or are still seeking enrollment in a Responsible Vendor Training program.

    Massachusetts Cannabis Control Commission


    Anthony Bartucca R.Ph.

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