TOP 5 METRC TIPS FOR MICHIGAN GROWERS

Explosive Michigan Cannabis Market

2021 has been a banner year for the Michigan cannabis market. Record-breaking sales in December, topped $135 million in recreational cannabis purchases and about $33 million in medical marijuana sales.

“Michigan’s marijuana industry grew substantially in 2021 and seems to be entering an era where the stability of supply and consumer prices appears to have been achieved,” says Andrew Brisbo, director of the Marijuana Regulatory Agency.

Cultivation licenses nearly tripled in 2021

In 2021, the number of Michigan cultivation licenses drastically increased. In January, 451 licenses had been issued, and by December, that number spiked to  1,130 licenses. In plant numbers, the state went from an allotment of 1 million plants to 1.75 million by end of the year. 

Michigan selected Metrc as their track and trace system. And because the state has had a caregiver program for many years, the regulatory agency, MRA, issues both Medical and Adult-Use licenses.

While regulations might be clear, the workflows in Metrc may not. When the policymakers who author compliance requirements have never grown cannabis, the resulting regulations may not be the most practical for cultivators.

In working with cultivators in Michigan, there are some valuable tips and suggestions we’ve gathered.

5 Metrc Tips for Michigan Cultivators

1.      Establish Good Record Keeping Practices

If you’re a cultivator operating under both Medical and Adult-Use licenses, it’s important to maintain separate records for each side of the operation. This includes logs of all cash flow, invoices and receipts. In addition, a monthly reconciliation between Metrc inventory vs what’s in your general ledger will surface errors and process changes that need to be made.

If the state sees a discrepancy in your data and you aren’t able to explain it and present documentation to back up your process, you could be audited and severely fined.

2.    Get Approval from MRA First!

Cultivators with both license types (Medical and Adult-Use) transfer cannabis between each license from time to time.

While seeds, tissue cultures and clones can be transferred via the regular method in Metrc, plants are a different case. Businesses transferring from their Medical to Adult-Use facility, can only transfer up to 50% of all plants in the Medical facility. In order to transfer plants, operators must get approval from MRA.

Simply send an email to [email protected] with the subject line “Request to transfer product to equivalent license”. In the body, make sure to include:

•        License numbers of both the transferring facility and the one receiving the plants
•        The package tag number, weight, and name of product
•        Statement that this transfer request doesn’t exceed 50% of current plant inventory

Good record keeping and accurate inventory balances bring confidence that your transfers are compliant.

3.    Dispose of Cannabis Waste the RIGHT Way

Waste comes in many forms at a cultivation facility. It can be a giant bag of leaves after a proper de-leafing day, plants that just aren’t going to make it, or the stems and leaves from harvesting.

In Michigan, any cannabis material that you plan to dispose of needs to be converted into actual waste, per the state’s regulations. Cannabis waste must be mixed with either food waste, yard waste, vegetable-based grease or oils, or other compostable wastes that have been pre-approved.

As described in #2, pre-approval is required for any instances that are ‘out of the norm’.

The proportion of the listed dilutants must be higher than 50% of the resulting mixture and disposal can be made at a variety of locations, like landfills, composting facilities or municipal incinerators.

The regulations also allow for disposal as compost feedstock or another organic method at the cultivation facility but be sure to receive agency approval first.

4.    Establish Metrc Reporting Process and Team Roles

As the saying goes, too many cooks in the kitchen can hamper the results. If the operation is a large one, hiring a compliance manager is standard practice. For smaller teams, the cultivation manager can act as the Metrc admin. 

The fewer people messing with compliance data, the less human error and miscommunication that will occur. Most mistakes can be reverted, but they will cause headaches and time dealing with the Metrc team.

Building an efficient and profitable operation rests on the strength and clarity of a company’s processes. In addition to assigning the role and responsibility for compliance reporting, define when the data is to be physically entered. A solid workflow might be to have your compliance officer or admin review the daily work performed by the cultivation team, and then report those events at the end of each day.

5.    Make Friends with Your Local Regulators

Perhaps this should have been tip #1, but in any case, it’s an important one to remember. In a new and evolving industry, we are all adapting to the regulations. That includes the regulators themselves! We’ve seen regulators adjust guidelines to help cultivators save time in their process flows. Simply because the way it was written didn’t make real-world sense.

Get on good terms with your local regulator! There are many kinks to iron out in regulating cannabis. Cultivators might find that Metrc and reporting instructions in their state are overly cumbersome and not representative of how it’s actually done at the grow. Other times, regulations can be interpreted in several ways and need clarification. By connecting with your area’s regulator, you can foster a conversation about best practices.

A good acronym to remember is CYA. Cover. Your. Ass. If you get approval for a specific process, get it in writing. Email or physical letter works. Foster a familiar relationship so you can be in good standing. You want to facilitate an open line of communication.

Want more Metrc guidance for cultivating in Michigan?