Issue 7 of The Federal Cannabis File: DEA has issued no implementation guidance on the April order. Why waiting for it is not a compliance strategy, under either rescheduling outcome.
The guidance that may never come Read Post »
Issue 6 of The Federal Cannabis File: the six-part, 109-check compliance audit framework, state, local, federal DEA, federal beyond DEA, privacy and AI, and program hygiene, and how to use it.
An expanded compliance audit framework that includes federal requirements Read Post »
Issue 5 of The Federal Cannabis File: why 21 C.F.R. § 1301.13(k) makes a state compliance program carry federal weight, and the four-part audit to run through a federal lens.
Your state compliance program has been promoted Read Post »
Issue 4 of The Federal Cannabis File: the 26-question follow-up DEA’s Rocky Mountain Division sent Colorado dispensaries, with what to think about before answering, and the Operator Retainer launch.
DEA sent dispensaries 26 questions. Here they all are. Read Post »
Issue 3 of The Federal Cannabis File: the eight stops a DEA investigator would work at a state-licensed medical cannabis operation, in order, as a checklist you can run yourself.
The checklist I’d carry if I were a DEA inspector Read Post »
Issue 2 of The Federal Cannabis File: a mock DEA inspection of a fictional California retailer, going wrong in real time, with the fix for every mistake.
How a DEA inspection goes wrong, minute by minute (and how to fix each mistake) Read Post »
Issue 1 of The Federal Cannabis File: DEA has begun inspecting registered medical cannabis operators. The DEA Inspection Starter Checklist, in full.
DEA inspections have started. Here’s your starter checklist. Read Post »