DCR issues new guidance on administrative holds

DCR issues new guidance on administrative holds

 

The Division of Cannabis Regulation (DCR) issued new guidance today, introducing a dedicated section for communications and guidance related to administrative holds on marijuana products. The new section includes several critical documents for licensees:

Understanding the new guidance

The Product Returns and Storage; Products on Administrative Hold FAQ clarifies several key points:

    
  • Storage of returned marijuana products: Dispensary licensees are not required to store marijuana products returned by patients or consumers. According to 19 CSR 100-1.180(2)(G), returned marijuana products may only be accepted for disposal.
  • Processing recalled products for disposal: Licensees should refer to MO Bulletin 24 – Receiving Recalled Product for guidance on handling recalled marijuana products. Patients who return recalled products within 30 days of purchase will have their patient allotment credited.
  • Storage of products on administrative hold: Licensees must quarantine and store marijuana products placed on administrative hold until they receive written guidance from DCR. As per 19 CSR 100-1.100(4)(P), recalled items must be pulled from inventory immediately and quarantined until the DCR provides further instructions on whether the item can be remediated, is safe for use, or must be destroyed.

Options for managing products on administrative hold

Licensees now have additional options for dealing with products under administrative hold:

  • Transfer of product: Licensees may request to transfer marijuana products on administrative hold to another licensed facility for quarantine and storage. This requires completing the Administrative Hold Product Transfer Request and submitting it to the assigned compliance officer, with a copy sent to CannabisCompliance@health.mo.gov.
  • Voluntary destruction of product: Licensees may choose to voluntarily destroy marijuana products on administrative hold. To do so, they must complete the Administrative Hold Product Voluntary Destruction Request and submit it following the same protocol as the transfer request.

For further guidance, licensees should contact their assigned compliance officer or visit the DCR’s Facility Communications and Guidance webpage.