(Editor’s note: This story is part of a recurring series of commentaries from professionals connected to the cannabis industry. Alex Lamphier is an associate attorney in the Boston office of Vicente Sederberg, a cannabis-focused law firm.)
As a result of the recommendations of various state and federal agencies, cannabis operators across the United States are taking proactive measures to assure patients, customers, regulators and other constituents that they are taking appropriate steps to ensure, preserve and promote public health.
The following is a nonexhaustive list of steps that cannabis operators might consider implementing, to the extent possible, to encourage physical distancing in an effort to reduce the potential for the COVID-19 virus to spread through the cannabis community:
Reducing person-to-person interaction
- Consider moving to preorder and pickup only or conducting retail sales by appointment. Patrons can place orders or reserve an appointment via an online platform or by phone. For pickup orders, have patrons book pickup times (and encourage them to show up only at the scheduled time) to further limit the number of individuals at the dispensary. It also will help control the flow of visits to reduce the potential for bottlenecking, which elevates the potential for exposure.
- In the event a line forms, whether inside or outside the dispensary, utilize space indicators (chalk, tape or stations) that are placed 6 feet apart to provide patrons with a guide on how to follow best public health practices while in a queue. As an alternative to having patrons wait in lines, they could wait in their vehicles, and queueing notifications could be communicated via text.
- Where allowable, consider implementing curbside pickup for preorders.
- Cannabis delivery businesses should consider working together with other cannabis operators to promote their delivery services and encourage patrons to avoid traveling to and congregating at retail establishments. To the extent practicable, cannabis delivery outfits should consider expanding the geographic scope of their services.
- Consider utilizing a door attendant at entrances and exits to mitigate patient exposure to the facility’s most commonly touched points. Where permissible, inspect IDs visually by having patrons hold them up for presentation to security personnel in lieu of handling patron identification.
- Remind patrons of maximum purchasing limits, and consider promotions that encourage and incentivize patrons to purchase larger quantities in an effort to reduce the frequency of individual visits.
- Consider implementing specific hours for at-risk populations, in particular seniors, veterans and those suffering from respiratory disorders and immunodeficiencies.
- Limit the number of employees in the facility to a skeleton crew capable of safe and effective operations.
Sanitation and hygiene
- Discourage patrons from using cash as a form of payment, and implement tap-and-pay technology where possible.
- Remove all handheld menus, tablets and iPads used at the facility. Menus can be displayed on TVs and other large-format visual media, and patrons should be encouraged to view product menus from their own phones or handheld devices. QR codes linked to the product menu can be posted in various locations within the dispensary for ease of access.
- Eliminate the use of aroma jars and promote prepackaged products as opposed to deli-style service wherever possible. Encourage patrons to avoid the direct sharing of products and to keep personal accessories clean.
- Increase the frequency of cleaning and sanitization of the entire facility, including door handles, floors, bathrooms, common areas, ATMs, handheld devices and all counters and surfaces. It is strongly recommended to sanitize payment pads and counters in between each sales transaction, and other points of common contact should be cleaned at least every half hour. To further minimize exposure at the point of sale, place markers on the floor to encourage patrons to stay a few steps away and refrain from touching the counter.
- Ensure there is an adequate supply of hand sanitizer available for all employees and patrons, and put hand sanitizer in conspicuous locations throughout the facility, particularly at entrances and exits, to encourage frequent hand-washing.
- Require all agents to wear gloves while handling consumer identification materials and all forms of payment. Gloves should be changed after each interaction. Encourage patrons to use their own pens for items requiring a signature, and consider alternatives to public-use pens.
- Consider possible adjustments or alterations to HVAC systems to increase ventilation throughout the facility, and consider implementing physical barriers to separate patrons from agents, such as sneeze guards or teller-style windows.
- Emphasize that agents should stay home when sick, following respiratory etiquette (covering coughs and sneezes) and practicing good hand hygiene. Reminders should be placed liberally throughout the facility.
Alex Lamphier is an associate attorney with Vicente Sederberg’s Boston office. He can be reached at alex@vicentesederberg.com.
The previous installment of this series is available here.
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