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Micro Dispensary Listening Session

Updated:

Micro dispensary defined 

Alcoholic Beverages & Cannabis Article § 36-401(c)(2)(iii) authorizes a micro dispensary to operate a delivery service that sells cannabis or cannabis products without a physical storefront, provided that the licensee employs not more than 10 employees.

Micro dispensary license 

A micro dispensary license is authorized to:

  • Deliver cannabis to residences and medical facilities in its authorized service area
  • No dispensing from the storage facility 
  • May repackage bulk cannabis into pre-rolls in accordance with COMAR 14.17.13.11.

See COMAR 14.17.07.07

Authorized service area

  • A micro dispensary’s authorized service area includes the region in which its license was awarded, i.e. central, eastern, southern, or western
  • A micro dispensary may only make deliveries in its authorized service area
  • May store cannabis in a facility outside of the service area
  • May transit outside of the service area for stocking/restocking or when it is most efficient, as part of a planned delivery route
  • Petition to expand 

See COMAR 14.17.07.07

Possible operational models 

  • Model 1 (Own-Storage Model): Operates and secures its own storage facility in accordance with COMAR 14.17.12.03C; manages and controls its own inventory.
  • Model 2 (Grower/Processor Storage Sharing): Stores cannabis at a grower/processor premises in accordance with COMAR 14.17.12.03C. Micro licensee's inventory must be stored separately from the host licensee's inventory.
  • Model 3 (Dispensary Storage Sharing): Micro dispensary manages and controls its own inventory using a separate vault on the premises of another standard dispensary (complying with COMAR 14.17.12.02G(2)). Products must be separated from the standard dispensary's inventory.
  • Model 4 (Delivery Partnership with Standard Dispensary): Micro dispensary does not maintain its own inventory. Instead, it partners with one or more standard dispensaries to deliver cannabis to medical and adult-use consumers on behalf of the standard dispensary.

Who is an employee?

Storage facility requirements

General requirements

  • Must be located in Maryland.
  • Must maintain relevant and current building codes and standards.
  • Must be constructed to prevent unauthorized entry.
  • Storage areas must provide adequate lighting, ventilation, temperature, humidity, space, and equipment to maintain product quality.
  • Must be maintained in a clean, orderly condition and be free from pests/infestation.

See COMAR 14.17.12.03C

Security requirements

  • Access must be limited exclusively to the micro dispensary's owner/agents (and host licensee owner/agents, if applicable).
  • Must include lighting fixtures adequate to ensure proper surveillance.
  • Security Alarm System: Must cover perimeter entry points, rooms holding cannabis, and record storage locations (on- and off-site). Must be continuously monitored, capable of detecting smoke/fire/power loss, and include panic alarms.
  • Video Surveillance: Motion-activated system capable of clearly revealing facial detail. Must operate 24/7/365 without interruption, provide timestamped frames, and capture all areas/entrances where cannabis is packaged, stored, or prepared for transport.
  • All locks and security systems must be kept in good working order.

See COMAR 14.17.12.03C

Vehicle requirements

  • Operated by at least one agent & only agents may occupy the delivery vehicle while it contains cannabis or cannabis products 
  • Have & display current vehicle registration
  • Insured as required by State law
  • Equipped with: 
    • GPS that enables vehicle location monitoring for all delivery routes 
    • Locked and secure storage containers anchored to the inside of the vehicle cannabis or cannabis products
    • A motion-activated video-surveillance system that captures activity around all storage containers that contain 
  • Conceals storage containers so they are not visible or identifiable from outside of the vehicle; and
  • Does not display any sign or illustration related to cannabis, cannabis products, or a cannabis licensee 

See COMAR 14.17.12.03D(10)

Hours of operation 

No deliveries should occur before 8am or after 11pm – MCA will apply a 30-minute grace period for deliveries after 11pm. 

Example: If delivery driver expects to complete its final delivery by 11pm but gets stuck in traffic on the way, it can complete the delivery until 11:30pm. 

Any order received after 11pm should be scheduled for delivery the following day. 

See COMAR 14.17.12.09

Ordering system

  • Prior to order placement, must validate the individual ordering is 21+ or patient/caregiver 
  • Include a notice that valid, government-issued photo ID required to order 
  • Collect the name and DOB of the individual submitting order 

See COMAR 14.17.12.03D(1) & .08

Delivery operations

  • Travel only in Maryland, between licensees, registrants, or from one delivery address to another delivery address 
  • Only make deliveries to residences as defined in COMAR 14.17.01 and medical facilities in authorized service area 
  • Agents conducting deliveries shall wear a body camera while they are operating a delivery vehicle that contains cannabis 
  • While in transit, agents may not wear clothing or symbols that indicate ownership/possession of cannabis 
  • Transport cannabis in one or more locked and secure containers that may not be accessible while in transit

Delivery restrictions

  • May not carry more than $5,000 worth of cannabis at any time 
  • No deliveries should occur without: 
    • A prior order submitted to the dispensary 
    • Proper manifest in Metrc 
  • No dispensing from the storage facility, i.e. no “ice cream truck” model 
  • No transport of products not associated with an active invoice, order, or product manifest

Required SOPs

Included but not limited to: 

  • Inventory control 
  • Receiving cannabis
  • Storage
  • Cleaning, maintenance 
  • Handling, packaging, labeling
  • Green waste
  • Security and visitor procedures
  • Dispensing
  • Delivery
  • Repackaging 

Agents must be trained on SOPs. SOPs must accurately reflect current procedures & be available on-site for inspection. 

See the full list: COMAR 14.17.12.11

Metrc

What is Metrc? 

  • Metrc = Marijuana Enforcement Tracking Reporting & Compliance 
  • The seed-to-sale tracking system for Maryland's cannabis program 
  • Tracks cannabis from growth to sale 
  • Ensures chain of custody, compliance, and diversion prevention

Metrc core functions

  • Inventory Transfers 
    • All cannabis and cannabis products must be transferred into the licensee's control in Metrc 
  • Manifest Creation
    • A manifest is required before deliveries or inventory movement 
  • Sales Reporting
    • Licensees must log all sales within Metrc to maintain compliance

Key Metrc responsibilities

  • Accept product into system BEFORE:
    • Deliveries 
    • Transportation 
    • Storage 
  • Maintain accurate logs:
    • Inventory levels 
    • Delivery manifest details 
    • Daily reports

Metrc hardware & tools

  • RFID tags for inventory 
  • Online dashboard access 
  • Use of third-party integrators possible (POS, logistics) Dutchie etc. 
  • Training and support offered via Metrc Learn website 
    • MCA will schedule reporting special training for micro dispensaries as they use unique functions for Metrc 

More information about Metrc

Summary & next steps

  • Review all applicable regulations, laws, and compliance guidance 
  • Choose an operational model that fits your resources 
  • Look for Metrc training invitation 
  • Start outreach for vault or storage partners if needed