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TRELLIS COMPLIANCE WITH CALIFORNIA CULTIVATION REGULATIONS

The purpose of this document is to demonstrate how Trellis software meets regulatory compliance requirements in the State of California. All references to Trellis software compliance is highlighted in orange text within each Section.

The Department of Consumer Affairs’ Bureau of Cannabis Control, Department of Public Health’s Manufactured Cannabis Safety Branch, and Department of Food and Agriculture’s CalCannabis Cultivation Licensing Division each developed new regulations to reflect the law defined in California’s Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA).

The California Department of Food & Agriculture issued emergency cultivation licensing regulations for commercial medicinal and adult-use cannabis on November 16, 2017, which included guidance on cultivation track-and-trace requirements.

Trellis has compiled this document to assist customers and regulators to ensure compliance with state track-and-trace requirements.
ARTICLE 3: Cultivation License Fees and Requirements | Section 8213

Section 8213 Requirements for Weighing Devices and Weighmasters

(a) Weighing devices used by a licensee for commercial purposes shall be approved, tested and sealed pursuant to Chapter 5 (commencing with Section 12500) of Division 5 of the Business and Professions Code, and registered with the county sealer consistent with Chapter 2 (commencing with 12240) of Division 5 of the Business and Professions Code. Approved and registered devices shall be used whenever:

  1. Cannabis and non manufactured cannabis is bought or sold by weight or count;
  2. Cannabis and non manufactured cannabis is packaged for sale by weight or count;
  3. Cannabis and non manufactured cannabis is weighed or counted for entry into the track-and-trace system; and
  4. The weighing device is used for commercial purposes as defined in Section 12500 of Business and Professions Code.
Trellis is compatible with weights and measures certified scales and records weight directly from the scale without manual user entry. This integration reduces the risk of user error in the data input process.
ARTICLE 4: Cultivation Site Requirements | Section 8300

Section 8300 Cultivation Requirements for Specialty Cottage, Specialty, Small, and Medium Licenses

(a) Cannabis plants maintained outside of the designated canopy area(s) are prohibited from flowering. Should plants outside of the canopy area(s) begin to flower, a UID shall be applied, the plant(s) shall be moved to the designated canopy area without delay, and reported in the track-and-trace system.
Trellis is compatible as UIDs are assigned to individual plants and used to track the plant through the cultivation process. If a plant begins to flower the plant UID will be used to track the plant to ensure it is in the correct canopy area. Trellis reports changes in location via integration with the state track-and-trace system, Metrc.

Section 8302 Research and Development Requirements for Nurseries

Nurseries may maintain a research and development area, as identified in their cultivation plan, for the cultivation of mature plants. All mature plants shall be tagged with a UID pursuant to section 8403 of this Chapter. All products derived from these plants are prohibited from entering the commercial distribution chain.
In the ‘Location Management’ module of Trellis, nurseries may configure a research and development area. Plant UIDs can be transferred to a new location, which is reported to the state track-and-trace system, Metrc.
ARTICLE 5: Records and Reporting | Section 8400

Section 8400 Record Retention

(a) Each licensee shall keep and maintain the records listed in subsection (d) for at least seven (7) years from the date the document was created.

(b) Records shall be kept in a manner that allows the records to be provided at the licensed premises or delivered to the department, upon request.

(c) All records are subject to review by the department during standard business hours, or at any other reasonable time, or as otherwise mutually agreed to by the department and the licensee. For the purposes of this section, standard business hours are deemed to be 8:00am - 5:00pm (Pacific Standard Time). Prior notice by the department to review records is not required.

(d) Each licensee shall maintain all of the following records on the licensed premises, including but not limited to:
  1. Department issued cultivation license(s);
  2. Cultivation plan;
  3. All records evidencing compliance with the environmental protection measures pursuant to sections 8304, 8305, 8306 and 8307 of this Chapter;
  4. All supporting documentation for data or information input into the track-and-trace system;
  5. All UIDs assigned to product in inventory and all unassigned UIDs. UIDs associated with product that has been retired from the track-and-trace system must be retained for six (6) months after the date the tags were retired;
  6. Financial records, including but not limited to, bank statements, tax records, sales invoices, and sales receipts;
  7. Personnel records, including each employee’s full name, social security, or individual tax payer identification number, date of beginning employment, and date of termination of employment if applicable;
  8. Records related to employee training for the track-and-track system or other requirements of this Chapter. Records shall include, but are not limited to, the date(s) training occurred, description of the training provided, and the names of the employees that received the training;
  9. Contracts with other state licensed cannabis businesses;
  10. Permits, licenses, and other local authorizations to conduct the licensee’s commercial cannabis activity;
  11. Security records; and
  12. Records associated with composting or disposal of cannabis waste.
  13. Documentation associated with loss of access to the track-and-trace system prepared pursuant to section 8402 (d) of this Chapter.
(e) All required records shall be prepared and retained in accordance with the following conditions:
  1. Records shall be legible; and
  2. Records shall be stored in a secured area where the records are protected from debris, moisture, contamination, hazardous waste, fire and theft.
Trellis records and stores all track-and-trace records, including cannabis waste disposals, on servers hosted by Amazon Web Services (AWS). All records are accessible via a web portal and administrators can configure user permissions to grant various users access to the software. Inventory, Plant and Disposal records are accessed via user-generated reports in the ‘Reports’ module. Reports can be exported and saved locally on licensed premises or at a different location designated by the user.
ARTICLE 5: Records and Reporting | Section 8401

Section 8401 Sales Invoice or Receipt Requirements

The licensee shall prepare a sales invoice or receipt for every sale or transport of cannabis or non manufactured cannabis product to another licensee. Sales invoices and receipts may be retained electronically but must be readily accessible for examination by the department, other state licensing authorities, any state or local law enforcement authority, and the California Department of Tax and Fee Administration. Each sales invoice or receipt shall include all the following:

(a) Name, business address, and department issued license number of the seller;

(b) Name, business address, and department issued license number of the purchaser;

(c) Date of sale or transfer (month, day and year). The date of any sale or transfer of cannabis and non manufactured cannabis products shall be the date of transfer to the licensee receiving it;

(d) Invoice or receipt number;

(e) Weight or quantity of cannabis and non manufactured cannabis products sold;
  1. Weight. For the purposes of this section a licensee must use wet weight or net weight. Wet weight and net weight shall be measured, recorded and reported in U.S. Customary units (e.g., ounce or pound); or International System units (e.g., kilograms, grams, or milligrams).
  2. Weighing Devices. A licensee shall follow weighing device requirements pursuant to section 8213 of this Chapter.
  3. Count. For the purposes of this section count means the numerical count of the individual plants or units.
(f) Cost to the purchaser, including any discount applied to the total price, shall be recorded on the invoice.

(g) Description for each item including strain or cultivar, and all of the applicable information below:
  1. Plant;
  2. Flower;
  3. Leaf;
  4. Shake;
  5. Kief; and
  6. Pre-rolls.
(h) Signature of the seller, or designated representative of the seller, acknowledging accuracy of the cannabis and non manufactured cannabis products being shipped.

(i) Signature of the purchaser, or designated representative of the purchaser, acknowledging receipt or rejection of the cannabis or non manufactured cannabis products.
Trellis’ ‘Orders’ module fulfills transport reporting requirements and generates a ‘Transport Manifest’ for each sales order. The ‘Transport Manifest’ includes the transporter and purchaser license information, product type, quantity, weight, UID, transport method and timestamp. An order can only be initiated with a licensed purchaser and UIDs are recorded for each transfer. Detailed descriptions for items can be configured in the ‘System Settings’. Completed order information and transport manifests are stored under ‘Order History’.
ARTICLE 5: Records and Reporting | Section 8402

Section 8402 Track-and-Trace System

Except as provided in section 8405 (e) of this Chapter, each licensee shall report in the department’s track-and-trace system the disposition of immature and mature plants, non manufactured cannabis products on the licensed premises, any transfers associated with commercial cannabis activity between licensees, and any cannabis waste pursuant to this Chapter.

(a) The licensee is responsible for the accuracy and completeness of all data and information entered into the track-and-trace system. Data entered into the track-and-trace system is assumed to be accurate and can be used to take enforcement action against the licensee if not corrected.

(b) Each licensee shall use the track-and-trace system for recording all applicable commercial cannabis activities. Each licensee shall:
  1. Designate an owner or other party(ies) in the licensee’s organization that can legally represent the licensee, to be the licensee’s track-and-trace account manager(s);
  2. Require the track-and-trace account manager to complete track-and-trace system training as required by the department. If the designated account manager did not complete department required track-and-trace training prior to receiving their annual license, the account manager will be required to register for state mandated system training, as prescribed by the department, within five (5) business days of license issuance;
  3. Designate track-and-trace system users, as needed, and require the users to be trained by the licensee’s track-and-trace account manager in the proper and lawful use of the track-and-trace system before the users are permitted to access the track-and-trace system;
  4. Require the track-and-trace account manager to maintain an accurate and complete list of all track-and-trace system account managers and users and update the list immediately when changes occur;
  5. Cancel any track-and-trace users from the licensee’s track-and-trace system account if that individual is no longer a licensee representative; and
  6. Correct any data that is entered into the track-and-trace system in error within three (3) business days of discovery of the error.
(c) The licensee is responsible for all actions any licensee representatives take while logged into the track-and-trace system or otherwise conducting commercial cannabis activities.

(d) If a licensee loses access to the track-and-trace system for any reason, the licensee shall prepare and maintain comprehensive records detailing all required inventory tracking activities conducted during the loss of access.
  1. Once access to the track-and-trace system is restored all inventory tracking activities that occurred during the loss of access shall be entered into the track-and-trace system within three (3) business days.
  2. A licensee shall document the date and time when access to the track-and-trace system was lost and when it was restored and the cause for each loss of access.
  3. A licensee shall not transfer cannabis or non manufactured cannabis products to a distributor until such time as access to the system is restored and all information is recorded into the track-and-trace system.
Trellis integrates with Metrc, the designated state track-and-trace system, to synchronize UIDs and necessary compliance data. Synchronization occurs daily at a minimum, but can be customized for a more frequent synchronization schedule. Client implementation averages between one and seven days, which includes training users, entering existing inventory into the system and ensuring all hardware (weighing scales and barcode scanners) are configured properly.

Trellis requires all users to configure a unique profile, including a login username and password. Administrators can configure user permissions to grant access to the software. Users are assigned a 4-digit authorization code used to track chain of custody, dual approvals, and enforce supervision during the cultivation process. Additional backup services are available to ensure loss of access is quickly remedied and licensees can access track-and-trace records in Trellis. In the event that users lose access to Metrc, users can continue to maintain accurate inventory records in Trellis, which will synchronize historical data once the Metrc system becomes available.
ARTICLE 5: Records and Reporting | Section 8403

Section 8403 Track-and-Trace System Unique Identifiers

(a) Within five (5) business days of the date the licensee’s designated account manager(s) was credentialed by the department to use the track-and-trace system, the licensee shall request UIDs using the track-and-trace system as prescribed by the department.
  1. The licensee shall only use UIDs provisioned and distributed by the department, or the department’s designee.
  2. The licensee shall maintain a sufficient supply of UIDs in inventory to support tagging in accordance with this section.
  3. The licensee shall use the track-and-trace system to document receipt of provisioned and distributed UIDs within three (3) business days of physical receipt of the UIDs by the licensee.
  4. Except as provided in section 8407 of this Chapter, all cannabis shall be entered into the track-and-trace system by the licensee starting with seed, clone propagated onsite or purchased from a licensed nursery, or seedling purchased from a licensed nursery pursuant to this Chapter.
(b) The UID shall accompany the cannabis products through all phases of the growing cycle, as follows:
  1. Licensees with immature plants shall assign a UID to each established lot respectively. The lot UID shall be placed in a position so it is visible and within clear view of an individual standing next to the immature lot to which the UID was assigned, and all UIDs shall be kept free from dirt and debris. For the purposes of this subsection, each lot of immature plants shall not have more than one-hundred (100) immature plants, at any one time. All immature plants in a lot shall be labelled with the corresponding UID number assigned to the lot and shall be contiguous to one another in order to facilitate identification by the department. Immature plants are assigned to lots in Trellis and assigned a batch UID used to track the lot during the cultivation process. Plants also receive an internal plant UID from Trellis to track each plant until flowering. Users are limited to assigning a maximum of 100 plants in any given lot.
  2. Immature plants transferred from a licensed nursery, via a distributor, to a licensed cultivator shall meet requirements of subsection (b)(1) above. Each immature plant intended for retail sale shall have a UID affixed, or be labeled with the corresponding UID number of the lot, and be recorded in the track-and-trace system prior to transfer from the licensed nursery. Immature plants are assigned a UID at the time they are assigned to a lot, which can be applied to the individual plant at any phase during the cultivation process. Users are able to generate sufficient lot UIDs to identify each immature plant prior to distribution.
  3. The licensee shall apply a UID to all individual plants at the time any plant is moved to the designated canopy area or when an individual plant begins flowering, as defined in Section 8000 (l). UIDs are assigned to individual plants and used to track the plant through the cultivation process. Plant UIDs are associated with their respective lot UIDs. The plant ‘Barcode Lookup’ and ‘Activity Log’ provides a comprehensive overview of each plant, including the UID of the lot it was derived from. Once the plant enters the flowering stage or is moved to the canopy area, users will tag each plant with Metrc UIDs and update the UID in Trellis.
  4. UIDs are required for each mature plant. UIDs shall be attached to the main stem, at the base of each plant. The UID shall be attached to the plant using a tamper evident strap or zip tie and placed in a position so it is visible and within clear view of an individual standing next to the mature plant to which the UID was assigned and UIDs shall be kept free from dirt and debris. Licensees are prohibited from removing the UID from the mature plant to which it was attached and assigned until the plant is harvested, destroyed or disposed. Plant and lot UIDs are tracked and recorded in Trellis’ cultivation modules. Tags are placed at the base of each plant. Trellis is hardware agnostic and compatible with most barcode scanners. Trellis is compatible with Metrc UIDs.
(c) Each harvest batch shall be assigned a unique harvest batch name which will be associated with all UIDs for each individual plant, or portion thereof, contained in the harvest batch.
In the ‘Harvest’ modules, all harvest batches are assigned a UID that is associated with all plant UIDs contained in the harvest batch.
(d) UIDs are required for all cannabis and non manufactured cannabis products and shall be associated with the corresponding harvest batch name from which the cannabis and non manufactured cannabis products were derived.
UIDs are assigned to all cannabis and non manufactured cannabis products. UIDs are associated with their respective harvest batch UID from which the cannabis and non manufactured cannabis products were derived. The ‘Activity Log’ for all UIDs provides a comprehensive view of the product, including the harvest batch UID the lot was derived from.
(e) Upon destruction or disposal of any cannabis or non manufactured cannabis products, the applicable UIDs shall be retired in the track-and-trace system by the licensee within three (3) business days of the destruction or disposal and be performed in accordance with the licensee’s approved cannabis waste management plan.
Upon destruction or disposal of cannabis or non manufactured cannabis products, Trellis collects and records a time stamp, reason for destruction, waste information and disposal method of all cannabis waste. Users can generate disposal reports in the ‘Reports’ module and track active disposal data in the ‘Disposal’ dashboard. To process waste, Trellis requires users to input a supervisory authorization code and a witness authorization code.
ARTICLE 5: Records and Reporting | Section 8404

Section 8404 Track-and-Trace System User Requirements

(a) All track-and-trace account managers or users, as identified by the licensee pursuant to section 8402 of this Chapter, shall enter all commercial cannabis activities in the track-and-trace system.

(b) Each track-and-trace account manager and user shall have a unique log-on, consisting of a username and password, which shall not be used by or shared with any other person.
Trellis requires all users to configure a unique profile, including a login username and password. Additionally, users are assigned a 4-digit authorization code used to track dual approvals, and enforce supervision during the cultivation process. Users maintain separate accounts within Metrc and Trellis.
(c) No track-and-trace account manager, user, or other licensee representative shall intentionally misrepresent or falsify information entered into the track-and-trace system.

(d) The account manager shall monitor all notifications from the track-and-trace system and resolve all issues included in the notification in the timeframe specified in the notification. An account manager shall not dismiss a notification from the track-and-trace system until the issue(s) included in the notification has been resolved.
When users are prompted with a notification in Metrc, they have the ability to leverage the ‘Activity Log’ in Trellis which tracks the chain of custody of each cannabis product including which account manager, user, or other licensee representative handled the product at each stage to remedy the notification.
ARTICLE 5: Records and Reporting | Section 8405

Section 8405 Track-and-Trace System Reporting

(a) Except as provided in section 8405 (e) below, the track-and-trace account manager or users shall report in the track-and-trace system any and all transfers of cannabis or non manufactured cannabis products to another licensed entity prior to the movement of the cannabis or non manufactured cannabis product off the licensed premises.
Transfers to licensed entities are tracked via the ‘Orders’ module. An order can only be initiated with a registered licensed customer that has a valid permit. Users record each UID, quantity and weight of cannabis or cannabis products for transfer. The fulfillment method, including delivery and pick up, is recorded and once completed, a record of the order and chain of custody is stored in ‘Order History’. An ‘Transport Manifest’ is available for reporting purposes. Users can use the Trellis ‘Transport Manifest’ to report the required compliance data to the state via Metrc.
(b) The track-and-trace account manager or users shall report in the track-and-trace system, any and all cannabis or non manufactured cannabis products physically received or rejected from another licensed within twenty-four (24) hours of receipt or rejection of the products.
Trellis tracks and reports the inbound transfer of cannabis goods in the ‘Purchasing’ module. Once a cannabis product is received or rejected, the user will update the status or their ‘Purchase Order’ in Trellis. Users can use the ‘Purchase Order’ to report required compliance data to the state via Metrc.
(c) The track-and-trace account manager or users shall report in the track-and-trace system any change in the disposition of cannabis plants, as applicable, on the licensed premises. All changes in disposition shall be made within three (3) business days of the change in disposition of the cannabis plants. Changes in disposition of cannabis plants include but are not limited to:
  1. Flowering; Changes in disposition during the flowering stage are tracked in the ‘Flowering’ module via plant UIDs. Trellis reports flowering changes by integrating with the state track-and-trace system, Metrc.
  2. Destruction or disposal; Changes in disposition during destruction or disposal are tracked in the ‘Disposal’ module via disposal UIDs. Trellis reports destruction or disposal changes by integrating with the state track-and-trace system, Metrc.
  3. Harvest; Changes in disposition during harvest are tracked in the ‘Harvest Batch’ and ‘Wet Harvest’ modules via plant and harvest batch UIDs. Trellis reports harvest changes by integrating with the state track-and-trace system, Metrc.
  4. Processing; Changes in disposition during processing are tracked in the ‘Dry Harvest’, ‘Trim Harvest’ and ‘Cure Harvest’ modules via inventory UIDs. Trellis reports processing changes by integrating with the state track-and-trace system, Metrc.
  5. Storage; and Changes in disposition during processing are tracked in the ‘Storage’ module via inventory UIDs. Trellis reports storage changes by integrating with the state track-and-trace system, Metrc.
  6. Packaging. Changes in disposition during packaging are tracked in the ‘Packaging’ module via inventory UIDs. Trellis reports packaging changes by integrating with the state track-and-trace system, Metrc.
(d) The account manager or user shall be required to record information for each transfer of cannabis or non manufactured cannabis products to, or cannabis or non manufactured cannabis products received from, other licensed premises. Required information to be entered includes, but is not limited to:
  1. Name, business address, and department issued license number of the seller;
  2. Name, business address, and department issued license number of the purchaser;
  3. Name and department issued license number of the distributor;
  4. Date of sale, transfer or receipt (month, day and year). The date of any sale, transfer or receipt of cannabis or non manufactured cannabis products shall be the date of transfer to the licensee receiving it;
  5. Weight or count of individual units of cannabis or non manufactured cannabis products sold, transferred or received;
    1. Weight. For the purposes of this section a licensee must use wet weight or net weight. Wet weight and net weight shall be measured, recorded and reported in U.S. Customary units (e.g., ounce or pound); or International System units (e.g., kilograms, grams, or milligrams).
    2. Weighing Devices. A licensee shall follow weighing device requirements pursuant to section 8213 of this Chapter.
    3. Count. For the purposes of this section count means the numerical count of the individual plants or units.
  6. Estimated departure and arrival time;
  7. Actual departure time;
  8. Description for each item including strain or cultivar, and all of the applicable information below:
    1. Plant;
    2. Flower;
    3. Leaf;
    4. Shake;
    5. Kief; and
    6. Pre-rolls.
  9. UID(s).
(e) Temporary Licensees. A licensee operating under a temporary license, issued by the department pursuant to section 8100 of this Chapter, is not required to record commercial cannabis activity in the track-and-trace system as otherwise required by this Chapter. Temporary licensees shall record all commercial cannabis activity in accordance with section 8401 of this Chapter.

(f) Annual licensees may continue to conduct commercial cannabis activities with temporary licensees pursuant to section 8401 of this Chapter.
The ‘Orders’ module fulfills transport reporting requirements and generates a ‘Transport Manifest’ for each order. An order can only be initiated with a registered licensed customer that has a valid permit on file. Users record each UID and quantity for transfer. Descriptions for each item can be configured in the ‘Inventory Type Management’ and ‘Strain Type Management’ modules. The fulfillment method, including delivery or pick up, is recorded and once completed, a record of the chain of custody is stored in ‘Order History’. A ‘Transport Manifest’ is available for reporting purposes, which includes permit information for transporting and receiving entities, cannabis product weight, product type and timestamp of the transfer. Descriptions for each item are configured in inventory type management.
ARTICLE 5: Records and Reporting | Section 8406

Section 8406 Track-and-Trace System Inventory Requirements

Licensees shall use the track-and-trace system for all inventory tracking activities at a licensed premises, including, but not limited to all the following:

(a) Reconcile all on-premises and in-transit cannabis or non manufactured cannabis products inventories pursuant to the time frames defined by the department; and
The ‘Reports’ module generates customizable reports for all active inventory, plants, waste and other cannabis related material. Transfer and order reports maintain records of in-transit cannabis and non manufactured cannabis products. All reports in Trellis can be configured by time-frame, product type, location, strain, authorizer, etc. Trellis produces an activity log for each UID. The activity log includes time stamped record of each activity (e.g. transfer, waste creation, etc.) and the authorizer’s user ID. Reports can be exported for reconciliation and reporting requirements. The ‘Reconciliation’ process allows users to reconcile physical inventory of cannabis goods with inventory reported in the track-and-trace system. Each adjustment to the system requires a reason and user authorization.
(b) Record the net weight of all harvested cannabis once the majority of drying, trimming and curing activities have been completed, or within sixty (60) calendar days from the initial harvest date, whichever is sooner.
Trellis logs net weight for each harvest batch at the drying, trimming, and curing stages. Once a harvest is completed, a harvest manifest is generated with calculations for moisture loss and yield loss to monitor inventory discrepancy thresholds.
(c) Licensee’s shall close-out their physical inventory of all cannabis and non manufactured cannabis products, and UIDs, if applicable prior to the effective date of any of the following changes to their license:
  1. Voluntary surrender of a temporary license or annual license.
  2. Expiration of an annual license.
  3. Revocation of a license.
    (d) Close-out of physical inventory includes, but is not limited to, all of the following items:
    1. Immature plants and their corresponding lot UID(s);
    2. Mature plants and their corresponding plant UID(s);
    3. Harvest batches and their corresponding UID(s);
    4. Non manufactured cannabis products and their corresponding UID(s); and
    5. UIDs in the licensee’s possession which have not been assigned in the track-and-trace system.
      The ‘Adjust Inventory’, ‘Remove Inventory’, ‘Remove Plants’ and ‘Create Waste’ processes may be used to close-out physical inventory and plant UIDs in Trellis.
      ARTICLE 5: Records and Reporting | Section 8407

      Section 8407 Track-and-Trace System Requirements for Product in Licensee Possession at the Time of Annual License Issuance

      (a) Within thirty (30) business days of receipt of the UIDs ordered pursuant to section 8403 of this Chapter, the licensee shall enter into the track-and-trace system and assign and apply a UID to each existing immature plant lot, each individual mature plant, and all non manufactured cannabis products physically located on the licensed premises.

      (b) After the thirty (30) day time frame referenced in subsection (a) above expires, all cannabis at the licensed premises shall be entered into the track-and-trace system starting with seed, clone propagated onsite or purchased from a licensed nursery, or seedling purchased from a licensed nursery pursuant to this Chapter. This section shall remain in effect until July 1, 2019.
      Users are able to create inventory from the Storage module for existing inventory at the time of receiving UIDs. Trellis can also import bulk inventory using a CSV upload template to expedite the onboarding process. The Trellis customer success team is available for on-site and remote implementation to ensure users are using Trellis effectively and compliantly.
      ARTICLE 5: Records and Reporting | Section 8408

      Section 8408 Inventory Audits

      The department may perform an audit of the physical inventory and inventory as reported in the track-and-trace system of any licensee at the department’s discretion. Audits of the licensee shall be conducted during standard business hours or at other reasonable time, or as otherwise mutually agreed to by the department and the licensee. For the purposes of this section standard business hours are 8:00am – 5:00pm (Pacific Standard Time). Prior notice of audit is not required.
      The ‘Reports’ module provides administrators the tools to self-regulate and perform in-house inventory audits. It also provides configurable reports for regulators to ensure an accurate and timely audit. Users can self-regulate with the ‘Reconciliation’ process to reconcile physical inventory of cannabis goods with inventory reported in the track-and-trace system.
      ARTICLE 5: Records and Reporting | Section 8409

      Section 8409 Notification of Diversion, Theft, Loss, or Criminal Activity

      Licensees shall notify the department and law enforcement authorities, within three (3) business days of discovery of any diversion, theft, loss of, or criminal activity related to licensee’s cannabis or non manufactured cannabis products.
      To assist licensees in discovery of diversion, theft, loss of, or criminal activity, users may access the ‘Activity Log’ that includes time stamped record of each activity (e.g. transfer, waste creation, etc.) and the authorizer’s user ID.

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