Iowa and New Mexico Opens Dispensary and Manufacturer Applications

Iowa Dispensary Applications

The Iowa Department of Public Health is looking to replace two dispensaries in an application round that began on April 17, 2020. Submissions are due June 8, 2020, by certified mail. The dispensaries are required to operate in accordance with Iowa Code chapter 124E and 641 Iowa Administrative Code (IAC) Chapter 154.

There is a section dedicated to security: 

Security Requirements Form. The applicant must complete multiple sections and include the following: 

A. Security Requirements Section: 

1. In a narrative format, provide a plan to meet the restricted access requirements of administrative subrule 154.42(1). There is an upload field available for this area for the applicant to attach information that supports or further describes the narrative response. 

2. In a narrative format, provide a plan to meet the perimeter intrusion detection system requirement of administrative subrule 154.42(2), including a floor plan noting location of all cameras, and including a description of the storage capabilities for the onsite retention of historical recordings. There is an upload field available for this area for the applicant to attach information that supports or further describes the narrative response. 

3. In a narrative format, provide a plan to meet the security alarm system requirements of administrative subrule 154.42(3). There is an upload field available for this area for the applicant to attach information that supports or further describes the narrative response. 

4. Provide a plan to meet the personnel identification system requirements of administrative subrule 154.42(4). There is an upload field available for this area for the applicant to attach information that supports or further describes the narrative response. 

B. Security Contractors Section:

Provide the names and addresses of any contractors hired or planned to provide security. There is an upload field available for this area for the applicant to attach information that supports or further describes the narrative response.

Because security intertwines with operations, many other sections may require consultation with a security expert – not only to add content to your submission but also to ensure compliant and consistent written communication in your application. This aspect is especially true for sections that directly mention security such as Employee Security and Safety Training or Procedures for the implementation of appropriate security measures to deter and prevent the theft of medical cannabidiol and unauthorized entrance into areas containing medical cannabidiol. Therefore, although the Security Requirements Form is only worth 50 of 1000 points, security expertise plays a role in enough other sections to take it seriously.

Final Application FormsWeightPotential Maximum Score
Business Organization, Ownership, and Financial Structure Form1575
Business Overview and Plan Form30150
Dispensary Facility Form1575
Security Requirements Form1050
Advertising and Marketing Form525
Storage Form525
Dispensing Information Form1575
Market Withdrawal and Recall Procedures Form1050
Disposal of Medical Cannabidiol Form525
Record-Keeping Requirements Form20100
Inventory Control Form1575
Personnel Background and Training Form25125
Operating Documents Form30150
Total Maximum Points1,000

The thoroughness and quality of these sections could allow you to open your business – or prevent you from opening at all if you’re unprepared. 

Not sure what to do or unsure of where to start? Hire an expert consultant with experience in the cannabis industry! 

Sapphire Risk Advisory Group has written over 300 city/state applications for dispensaries and cultivation facilities in 24 states, including Illinois in the dispensary round. Our professionally written security sections have received an average score of 94%. Additionally, we have managed the build-outs of 60 successful cannabis businesses and trained several staffs on security awareness and protocols. Let our success be your success! How can we help you open your business?

New Mexico Manufacturer Applications

The New Mexico Department of Health has opened up applications for cannabis businesses for the first time since 2015, this time for manufacturers. There is momentum in New Mexico towards adult-use legalization, so while the current program is restricted to medical purposes, there is reason to believe that the market will expand in the coming years. Manufacturers must comply with 7.34.4 NMAC among other rules and regulations. 

Because security intertwines with operations, many other sections may require consultation with a security expert – not only to add content to your submission but also to ensure compliant and consistent written communication in your application. The Medical Cannabis Program has outlined application requirements with several including security elements directly (in bold) or indirectly: 

(1) proof that the manufacturer applicant is in good standing with the New Mexico Taxation and revenue department; 

(2) copies of the manufacturer applicant’s articles of incorporation and by-laws, applicable; 

(3) a complete written description of the means that the manufacturer applicant shall employ to safely manufacture cannabis-derived products, including but not limited to hygiene standards consistent with the requirements of this rule; 

(4) a list of all persons or business entities having direct or indirect authority over the management or policies of the manufacturer applicant; 

(5) a list of all persons or business entities having any ownership interest in any property utilized by the manufacturer applicant, whether direct or indirect, and whether the interest is in land, building(s), or other material, including owners of any business entity that owns all or part of land or building(s) utilized; 

(6) a description of the facilities that shall be used in the manufacture of cannabis-derived products; 

(7) a description of how the manufacturer applicant will obtain cannabis or cannabis concentrates from a licensed non-profit producer, and how the manufacturer applicant will transport cannabis-derived products to a licensed non-profit producer, including but not limited to a chain of custody documentation; 

(8) testing criteria and procedures, which shall be consistent with the testing requirements of this rule; 

(9) a general written security policy, to address at a minimum: 

  • a. safety and security procedures; 
  • b. personal safety; and 
  • c. crime prevention techniques. 

(10) an attestation that no firearms will be permitted on any premises used for the manufacture of cannabis derived products by the manufacturer applicant; 

(11) a description of the methods and device or series of devices that shall be used to provide security; 

(12) training documentation prepared for each employee of the manufacturer applicant, statements signed by employees indicating the topics discussed (to include names and titles of presenters) and the date, time, and place the employee received said training; 

(13) employee policies and procedures to address the following requirements: 

  • a. job descriptions or employment contracts developed for every employee of the manufacturer applicant that identifies duties, authority, responsibilities, qualifications, and supervision; and 
  • b. training materials concerning adherence to state and federal confidentiality laws. 

(14) personnel records for each employee of the manufacturer applicant that include an application for employment and a record of any disciplinary action taken; 

(15) employee safety and security training materials provided to each employee of the manufacturer applicant at the time of his or her initial appointment, to include: 

  • a. training in the proper use of security measures and controls that have been adopted; and 
  • b. specific procedural instructions regarding how to respond to an emergency, including robbery or a violent accident. 

(16) such other materials as the department may require. The MCP requires each of the following items to be submitted with this application: 

  • Regulation and Licensing Division LPG Gas approval of use (if applicable) 
  • Proof that no buildings to be used by the applicant is located within 300 feet of any school, church, or daycare center. 

The thoroughness and quality of these sections could allow you to open your business – or prevent you from opening at all if you’re unprepared. 

Not sure what to do or unsure of where to start? Hire an expert consultant with experience in the cannabis industry! 

Sapphire Risk Advisory Group has written over 300 city/state applications for dispensaries and cultivation facilities in 24 states, including Illinois in the dispensary round. Our professionally written security sections have received an average score of 94%. Additionally, we have managed the build-outs of 60 successful cannabis businesses and trained several staffs on security awareness and protocols.

Let our success be your success! How can we help you open your business?