malty/ca-grow-ops-manager
1
0
Fork 0
Code Issues Pull requests Projects Releases Packages Wiki Activity Actions
ca-grow-ops-manager/docs/compliance-notes-ca.md
fullsizemalt da7729d6e4
Some checks failed
Deploy to Production / deploy (push) Failing after 0s
Details
Test / backend-test (push) Failing after 0s
Details
Test / frontend-test (push) Failing after 0s
Details
Initial commit: Spec Kit foundation complete 
- Constitution and project spec (spec.yml)
- 7 comprehensive feature specs (tasks, batches, labor, compliance, inventory, integrations, comms)
- Phase 1 implementation plan (6-week roadmap)
- Week 1 task breakdown (15 concrete tasks)
- Architecture and compliance documentation
- Backend and frontend setup guides
- Deployment guide for nexus-vector
- CI/CD workflows (Forgejo Actions)
- Quick start guide for developers

Project is ready for implementation with:
- Automated testing on every push
- Automatic deployment to nexus-vector on push to main
- Database migrations handled automatically
- Health checks and monitoring

Stack: TypeScript, Fastify, React, Vite, PostgreSQL, Prisma, Docker
2025-12-08 23:54:12 -08:00

8.9 KiB
Raw Blame History

California Cannabis Compliance Notes

Last Updated: 2025-12-08
Applies To: CA Grow Ops Manager v0.1.0

Overview

This document summarizes how CA Grow Ops Manager supports California cannabis cultivation operations while deferring to METRC as the system of record for track-and-trace compliance. It provides context on California DCC (Department of Cannabis Control) requirements and how this platform fits into the compliance landscape.

Regulatory Context

California Department of Cannabis Control (DCC)

The DCC regulates all commercial cannabis activity in California, including cultivation, manufacturing, distribution, testing, and retail. Licensed cultivators must comply with:

  • Track-and-Trace: METRC (Marijuana Enforcement Tracking Reporting Compliance) is the state-mandated system for tracking cannabis from seed to sale
  • Recordkeeping: Financial, inventory, labor, and operational records must be maintained and available for inspection
  • Inspections: DCC and local agencies conduct announced and unannounced inspections
  • Reporting: Quarterly and annual reports required for license renewal

METRC (System of Record)

METRC is the authoritative system for California cannabis track-and-trace. All licensed cultivators must:

  • Tag all plants and batches with METRC-issued RFID tags
  • Log all lifecycle events (planting, vegetative, flowering, harvest, destruction) in METRC
  • Record all transfers (sales, donations, destruction) in METRC
  • Maintain accurate inventory in METRC at all times

CA Grow Ops Manager does NOT replace METRC. It supports internal operations and compliance-adjacent recordkeeping while maintaining alignment with METRC data.

How CA Grow Ops Manager Supports Compliance

1. Internal Batch Tracking with METRC Mapping

  • Internal Batch IDs: CA Grow Ops Manager uses internal batch IDs for operational tracking (tasks, weights, labor, photos)
  • METRC Tag Mapping: Internal batches are mapped to METRC plant/batch tags for cross-reference
  • Read-Only in v1: METRC tags are stored but not synced; users manually enter tags from METRC
  • Phase 2 (Future): METRC connector will sync tags and allow writes with explicit user confirmation

Compliance Benefit: Facilities can use intuitive internal IDs (e.g., "Batch #123 - Blue Dream") while maintaining METRC compliance.

2. Compliance Document Storage

CA Grow Ops Manager provides a centralized repository for compliance-adjacent records:

  • Monthly Taxes: Excise, sales, and cultivation tax filings
  • Utility Bills: SMUD, PG&E, water, gas (required for energy usage reporting)
  • Rent/Lease: Facility lease agreements
  • Invoices: CO₂, nutrients, materials, packaging
  • Bills of Sale: Sales records
  • Payroll Summaries: Labor cost references (not full payroll data)
  • Hours Tracking: Exports from the Labor module
  • Licenses and Permits: Current and historical
  • Inspection Reports: DCC and local agency inspections
  • SOPs: Standard Operating Procedures

Compliance Benefit: All records organized by month/quarter with DCC-aligned checklists; audit packet generation for inspections.

3. Labor and Hours Tracking

California labor laws require detailed recordkeeping:

  • Hours Worked: Clock in/out timestamps for all employees
  • Wage Rates: Historical wage rates for each role
  • Labor Costs: Hours × wage rate for cost analysis
  • Payroll Exports: CSV exports compatible with payroll systems

Compliance Benefit: Meets California labor recordkeeping requirements (4 years minimum); supports cost-per-batch analysis.

4. Audit Readiness

CA Grow Ops Manager supports audit preparation:

  • Audit Packet: ZIP export with all documents and indexes (CSV, JSON) for a date range
  • Compliance Checklists: Monthly/quarterly checklists based on DCC guidance
  • Immutable Audit Logs: All critical operations logged with user and timestamp

Compliance Benefit: Facilities can generate audit packets in minutes; proactive checklists reduce missing records.

What CA Grow Ops Manager Does NOT Do

1. Replace METRC

  • METRC is the system of record for track-and-trace
  • CA Grow Ops Manager does not sync with METRC in v1 (read-only mapping only)
  • Phase 2 will add METRC connector with explicit user confirmation for writes

2. Process Payroll

  • CA Grow Ops Manager tracks hours and wage rates but does not process payroll (taxes, deductions, direct deposit)
  • Exports are provided for external payroll systems (ADP, Gusto, QuickBooks)

3. File Taxes

  • CA Grow Ops Manager stores tax records but does not file taxes
  • Facilities must use external accounting systems or CPAs for tax filing

4. Guarantee Compliance

  • CA Grow Ops Manager is a tool to support compliance workflows
  • Facilities are responsible for ensuring all data is accurate and complete
  • Consult with legal and compliance professionals for regulatory guidance

DCC Recordkeeping Requirements

Per California Code of Regulations, Title 4, Division 19, licensed cultivators must maintain:

Financial Records (7 years)

  • Bank statements
  • Sales invoices and receipts
  • Purchase invoices and receipts
  • Tax filings (excise, sales, cultivation)
  • Payroll records

Inventory Records (7 years)

  • METRC reconciliation reports
  • Internal inventory logs
  • Transfer manifests
  • Destruction records

Labor Records (4 years minimum)

  • Employee hours worked
  • Wage rates and payroll summaries
  • Workers' compensation records

Operational Records (7 years)

  • Licenses and permits
  • Inspection reports
  • Standard Operating Procedures (SOPs)
  • Pest management logs
  • Waste disposal records

DCC Inspection Preparation

Quarterly Self-Audits (Recommended)

  1. Review METRC Data: Ensure all plants, batches, and transfers are logged
  2. Check Compliance Documents: Verify all required documents are uploaded and categorized
  3. Reconcile Inventory: Physical count vs. METRC vs. internal records
  4. Review Labor Records: Ensure all hours and wage rates are accurate
  5. Update SOPs: Ensure SOPs reflect current practices

Audit Packet Contents

For a DCC inspection, prepare an audit packet with:

  • METRC Reconciliation Report: Exported from METRC
  • Financial Records: Invoices, receipts, tax filings for the period
  • Labor Records: Hours, wage rates, payroll summaries
  • Licenses and Permits: Current and historical
  • Inspection Reports: All DCC and local inspections
  • SOPs: Current versions with change history
  • Inventory Logs: Internal records aligned with METRC

CA Grow Ops Manager can generate this packet (minus METRC data) in minutes.

METRC Integration Strategy (Phase 2)

Read Operations (No User Confirmation Required)

  • Sync METRC plant/batch tags to internal batches
  • Sync inventory data for reconciliation
  • Sync transfer data for cross-reference

Write Operations (User Confirmation Required)

  • Create plant tags in METRC
  • Update plant stages (vegetative, flowering, harvest)
  • Log harvests and weights
  • Create packages for transfer
  • Log destructions

Safety Measures

  • Explicit User Confirmation: Preview changes before writing to METRC
  • Audit Trail: Log all METRC operations with user and timestamp
  • Rollback: Attempt rollback on failure; flag for manual review if rollback fails
  • Rate Limiting: Respect METRC API rate limits; exponential backoff on errors

Official Resources

California DCC

METRC

California Labor Laws

Disclaimer

This document is for informational purposes only and does not constitute legal or compliance advice. Cannabis regulations are complex and subject to change. Facilities should consult with legal counsel, compliance professionals, and the California DCC for authoritative guidance.

CA Grow Ops Manager is a tool to support compliance workflows but does not guarantee compliance. Facilities are responsible for ensuring all data is accurate, complete, and aligned with METRC and DCC requirements.

Changelog

  • 2025-12-08: Initial version for v0.1.0