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oxalis integrative support services 

Hello Humboldt,

 

We hope everyone has been able to enjoy how particularly gorgeous our rivers are right now. While the late rains gave us growing pains, we are looking forward to taking advantage of the waters in the coming heat. Same goes for preparing yourself for onsite compliance and pending inspections, a little growing pain now will translate into cool waters come agency calls.

 

For this edition of The Understory, we’ve teamed up with the compliance experts at Margro Advisors (info@margroadvisors.com) to bring you some preparedness highlights; check out their “Top Ten Tips for Inspections”. Make sure to take a look at the informative workshops they are bringing to SoHum in partnership with the International Cannabis Farmers Association (ICFA). Knowledge is power.

 

 


Inspect me? You just met me!


Exactly. Inspections are a component of permits, licenses, land and business operations. County and state agencies have their own criteria they will be looking for annually onsite, per your operations and application information. For Humboldt County, Permit and License inspections are conducted by our local Agriculture Department. Currently they are prioritizing approved permits with state licenses for inspections, but might also be visiting some state license holders with temporary permits. Typically they will give advanced notification prior to visiting sites. Humboldt County inspections are usually scheduled one week to 24 hours in advance, but the BCC and CDFA are not required to give any advance notice prior to visiting. Because the Ag Department has been linking both county and state inspections in the same day, it seems likely most operators will have advanced notice for the rest of this year, though perhaps not  much more than an email the night before. After these initial “outreach” inspections, annual inspections will be scheduled with the Ag Department during their yearly scale calibration and recertification visits.

 

Besides the CDFA, (or the BCC, and CDPH depending on your license type) and County Planning you will also need to be prepared for inspections from the Water Boards and the Department of Fish and Wildlife. Keep reading for a breakdown of key points for each agency.

 

 


Onsite Record Requirements

CDFA: § 8400. Record Retention.

For the purposes of this chapter, “record” includes all records, applications, reports, or other supporting documents required by the department.

(a) Each licensee shall keep and maintain the records listed in section 8400(d) of this chapter for at least seven (7) years from the date the document was created.

(b) Licensees shall keep records, either electronically or otherwise, identified in section 8400(d) of this chapter on the premises of the location licensed. All required records shall be kept in a manner that allows the records to be examined at the licensed premises or delivered to the department, upon request.

(c) All records are subject to review by the department during standard business hours or at any other reasonable time as mutually agreed to by the department and the licensee. For the purposes of this section, standard business hours are deemed to be 8:00am - 5:00pm (Pacific Time). Prior notice by the department to review records is not required.

(this section continues, link above)

 

 


We have heard from Scott Peacock of the Humboldt County Agriculture Department that initial inspections are primarily "outreach" inspections; informative for both the operator and the agencies. Matters of non-compliance will be noted, and sent back to the corresponding agencies. Anything seen visually amiss onsite will be spoken to and encouraged to be rectified with a non-compliance checklist.  

 

Your Licensing Authorities

BCC, CDFA, and/or CDPH

Per CDFA initial inspections, it seems the agency is most interested in finding your shipping manifests readily available, and square footage measurements match your application declarations. Here’s a link to the temporary license inspection form used last year to give you a sense of what might be covered. The CDFA has not released an annual inspection form available to licensees. As we learn more about the BCC and CDPH inspections, we’ll be sharing that as well.  

 

There is much to consider for onsite compliance and what you’ll need to have ready. The following highlights are not exhaustive, but will get you going on the right track. Now that permits and licenses are being issued it’s up to every operator to actively implement requirements in the face of penalties and potential loss of a permit and/or license. A little preparation goes a long way to avoid fines and ensure the longevity of your operations. It is the responsibility of all owners to follow state regulations, and we highly recommend reading the full link to the records regulations for CDFA license types, linked above,and reach out to us, Margro Advisors, or your consultant/s if you need more information.

 

Humboldt County

Per County permit inspections, the focus has been on cultivation and structure layouts matching stated plans and maps. You will also want to be familiar with your permit conditions, ensuring timelines for conditions are met. Be aware, some conditions are given immediate or otherwise shorter implementation time than the more standard two years. Here’s a link to the County permit inspection form.

 

Water Boards

The water board will be looking for water monitoring logs, meters at correct locations, verifiable storage capacities, sediment and waterway protection measures, and mitigations as per agreements.  

 

Department of Fish and Wildlife

They will be checking for habitat and environmental protections, and any CDFW conditions outlined in your permits. This agency will inspect based on suspected or reported violations, and they, like all agencies above have the ability to levy fines.

 

Main Onsite Postings

  • Remember to have your license(s) and permit(s) posted and easily visible onsite. You are required to post each license once, regardless of different sites or areas under the same license.

  • You will also want to have your weighmaster license and scale certification readily accessible and/or visible.

  • Safety data sheets (SDS) are also required for any inputs (pesticides and fertilizers) onhand and easily accessible to all of your employees. If you like more information on pesticide compliance there are links and outlines our last edition of The Understory Pesticide Edition here.

  • Required labor law employee postings (if employees are a part of your operations).

 

Main Onsite Compliance

  • Site diagrams for both state and county available

  • Track and Trace records, especially shipping manifests. Any tags that have been previously activated need to be retained onsite for six months post retiring the tags.

  • Compliance record binder . Oxalis has a table of contents template, and can help you build yours if needed.

  • Nutrient and pesticide logs (for reporting to the Ag Department, and will also come into play when creating your annual water board report).

  • Proper storage of fuels, chemicals and hazardous materials (secondary containment, safety, stored where stated and away from any personal protective equipment), and compost, amendments, soils contained and covered

  • Clean, well maintained sites and surrounding areas

 

Margro Advisors Top Ten Tips for Inspections
(follow link for full pdf)



 

 


Thanks to all our readers doing the work to bring Humboldt sungrown cannabis to the rest of California. Remember to be prepared, be organized, and be kind!

 

All the best,

 

Alison Rivas

Holly Carter

Ashley Brookens

upcoming events
 

OSHA 30 by Safety Logistics

June 14-17th, Redwood Playhouse, see pdf for details

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Community Revival Road Show by Redwood Roots

Three dates remaining, 3-7 pm, in Mattole June 15, Laytonville June 16th and Benbow June 22nd

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Education Series by Margro Advisors / CalCann Licensing

Previously scheduled June 27th has been postponed

//

Track & Trace chat sessions by Oxalis

Oxalis is hosting Non-technical track and trace workshops in Garberville to discuss supply chain considerations, harvest batching, inventory uploads and transfer prepertion.  All are welcome to attend, $25/person. Optional: bring site diagram(s), plant strain & count info and a curious mind.

June 11, 3pm, June 15, 11am, more dates TBD

434 Church Street (ICFA office)

Copyright © 2018 Oxalis Integrative Support Services, LLC, All rights reserved.

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Email us at // office@oxaliscalifornia.com
Our mailing address is:
901 A Redwood Drive // Garberville CA 95542

 

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