The County of Los Angeles Department of Public Health’s (“DPH”) has developed a Cannabis Compliance and Enforcement Program for licensed commercial cannabis businesses (“CCEP”). CCEP provides for issuance of an Emblem Placard to licensed commercial cannabis businesses that pass the required DPH inspection for display at the business premises. The Emblem Placard shall serve as notice to the public and applicable enforcement and regulatory agencies that such business is licensed and in compliance with all applicable public health laws and regulations. The City of Los Angeles has contracted with DPH to administer the Emblem Program for Authorized Cannabis Stores (“Program”) in Los Angeles as a cross-jurisdictional effort to deter the operation of unlicensed cannabis businesses.
To maintain compliance, a commercial cannabis business operating in the City of Los Angeles must obtain a Public Health Permit (“PHP”) for each cannabis facility under its control by successfully passing either a Site Evaluation (for pre-existing cannabis facilities) or a Plan Check (for new cannabis facilities, or pre-existing cannabis facilities that fail to pass a Site Evaluation). The following summary outlines the PHP application process and reviews key details regarding the planned roll-out of inspections.
Applicants for a PCP (“Applicants”) should review CCEP’s Site Evaluation Requirements and verify requirements for critical items are met before the Site Evaluation occurs. Critical items include:
(1) essential sinks (handwashing, ware-washing, mop, etc.);
(2) hot and cold water at essential sinks;
(3) an approved water heater with adequate rating and drainage;
(4) a toilet (with the exact number determined by local building and plumbing ordinances); and
(5) certain additional requirements for manufacturing (ex. approved closed-loop extraction, approved hood).
Once an Applicant has reviewed and confirmed the Site Evaluation Requirements, it may email a Site Evaluation Application to CCEP. CCEP will then email the Applicant an invoice ($334 per commercial cannabis activity). An Applicant may either bring its invoice with payment to CCEP’s Baldwin Park office or send the invoice and payment to CCEP via U.S. mail. CCEP will then contact the Applicant to schedule a Site Evaluation.
If the Applicant fails to pass a Site Evaluation, it will need to submit a plan to CCEP and pay a Plan Check Fee. An Applicant submitting a plan should review the Cannabis Facility Plan Review Checklist to ensure all requirements are met before doing so. Plans are reviewed on a first-come, first-served basis, and an Applicant will be notified of plan approval or disapproval within twenty (20) working days after receipt of payment by CCEP.
If the Applicant passes the Site Evaluation, it may then apply for a PHP. A PHP application will be issued via email, or a hard copy can be provided at the end of site evaluation. CCEP will process the completed PHP application and forward an invoice for payment. An Applicant may bring its invoice to CCEP’s Baldwin Park office, send both the invoice and payment to CCEP via U.S. mail, or pay the invoice online by e-check or credit card.
Following invoice payment, a routine inspection of the Applicant’s cannabis facility will be conducted within two (2) weeks. If no critical violations are observed during the inspection, the Applicant will receive (1) a valid PHP, (2) an Emblem (for retailers, pursuant to the Program, and (3) health-education materials. Each Emblem Placard will have a quick-response (QR) code that will link to all existing inspection reports and results. A PHP, once received, must be renewed annually. There will be two (2) unannounced routine inspections per fiscal year.
CCEP plans to implement the PHP and inspection processes described above in three (3) phases:
Phase 1 is open to licensed commercial cannabis businesses (“Licensees”) with on-site retail sales that have received Temporary Approval from Los Angeles Department of Cannabis Regulation (“DCR”). These Licensees may choose to pursue an Emblem and PHP for their retailer activities only, or for all commercial cannabis activities they are engaged in. If a Licensee is not ready to have CCEP review its non-retailer activities, the Licensee may save those activities for review during Phase 2 or 3 (as described below). There will be three (3) geographical regions for roll-out of Phase 1, organized by Community Plan Area. Phase 1 is voluntary, but Licensees will need to secure required health permits to renew Temporary Approval or an Annual License for 2024.
Phase 2 is open to all Licensees and Applicants that have a status of Local Compliance Underway (“LCU”) by June 30, 2022. Review during Phase 2 will be available for all commercial cannabis activities a Licensee or Applicant is engaged in.
Finally, Phase 3 is open to all Licensees and Applicants that have a status of LCU on or after July 1, 2022. Review during Phase 3 will be available for all commercial cannabis activities a Licensee or Applicant is engaged in.
Commercial cannabis businesses that are eligible to apply under Phase 1 may begin submitting PHP applications at any time. DPH has already started accepting applications for the initial site evaluation and anticipates beginning inspections in September 2022. DCR estimates review of Phase 1 applications will take approximately 3-6 months. DCR plans to email retailers eligible for Phase 1 with additional information in the near future.
If you have any questions about any of the above, please feel free to contact Katchko, Vitiello & Karikomi, PC for more information and a member of the team will be happy to assist.
By Patrick Babajanian, September 13, 2022.
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