Bulletin | Licensees’ Preparation for COVID-19 | March 18, 2020

On March 15, 2020, Governor Charlie Baker expanded upon the preventative measures required as part of the Commonwealth’s response to COVID-19. The Cannabis Control Commission (“Commission”) is providing this bulletin to licensees, certifying health care providers, patients, caregivers, and the public for information and assistance. This bulletin supplements and updates the Commission’s March 13, 2020 bulletin.

Licensees are encouraged to review their standard operating procedures to ensure consistency with the Governor’s State of Emergency declaration, restrictions on gatherings of 25 or more people, and continued adherence to the State Sanitary Code. The Commission directs licensees to implement appropriate mitigating measures to ensure, preserve, and promote public health, consistent with the Governor’s recent order. In particular, the Commission urges licensees to consider designating specific hours to protect at-risk groups, requiring employees to stay home if/when they feel sick, mandating mobile or pre-ordering, strictly limiting the size of lines with six feet between patients, caregivers, and customers, cleaning surfaces every 30 minutes or sooner as needed, and wearing personal protective equipment at all times.

The health and wellbeing of individuals is of paramount importance. The Commission therefore asks licensees to be mindful of the needs of patients who may have conditions that compromise their immunity and make accommodations as necessary for these individuals when voluntarily notified of a condition.

Colocated Marijuana Operators are further reminded to ensure compliance with patient supply protections pursuant to 935 CMR 502.140(9) and the need to use best efforts to prioritize patient and caregiver identification verification and physical entry into retail areas pursuant to 935 CMR 502.140(6)(d).

The Commission continues to urge licensees to appropriately publicize protocols relative to agent interactions with patients, caregivers, and customers and the handling and processing of plants and products. Similarly, where applicable, Medical Marijuana Treatment Centers that offer patient delivery may consider the promotion and geographic expansion of their service and remind patients of the ability to acquire up to a 60-day supply.

At all times, licensees are required to follow standard operating procedures demonstrating compliance with the Commission’s operational sanitary requirements. See regulations 935 CMR 500.101(1)(c)(10): Management and Operations Profile; 935 CMR 500.105(3)(b): Requirements for the Handling of Marijuana; and 105 CMR 590.000: State Sanitary Code, Chapter X – Minimum Sanitation Standards for Food Establishments. Licensees should also remain in touch with the local Board of Health in their host municipality to determine any further measures that may be necessary for ongoing operations.

Licensees and certifying health care providers may contact the Commission at Commission@CCCMass.com regarding questions about this bulletin.

References

Baker-Polito Administration Announces Emergency Actions to Address COVID-19

Governor Baker’s State of Emergency

COVID-19 Guidance and Recommendations for Massachusetts Businesses/Employers

CDC Interim Guidance for Businesses and Employers

OSHA Guidance on Preparing Workplaces for COVID-19