NY Cannabis Inspection Checklist: Prepare for OCM Audits

The New York Office of Cannabis Management (OCM) conducts routine and unannounced inspections of licensed cannabis facilities. Being prepared for these inspections is crucial—violations can result in fines, mandatory corrective action plans, or license suspension.

This comprehensive checklist will help you prepare for OCM inspections and maintain ongoing compliance.

What Inspectors Look For

OCM inspectors evaluate your facility across several key areas:

1. Security systems and protocols
2. Record-keeping and documentation
3. Inventory tracking and control
4. Product storage and handling
5. Employee compliance and training
6. Facility maintenance and safety

Security Checklist

Video Surveillance

• [ ] Cameras cover all entry/exit points
• [ ] Cameras cover all areas where cannabis is stored, handled, or sold
• [ ] Camera resolution meets minimum 720p requirement
• [ ] 90-day footage retention verified
• [ ] Remote access capability for OCM is functional
• [ ] Cameras have date/time stamps visible
• [ ] Backup power for surveillance system
• [ ] No blind spots in coverage areas

Access Control

• [ ] All doors to limited access areas are locked
• [ ] Badge/key access logs are maintained
• [ ] Visitor log is up to date
• [ ] Employee access list is current
• [ ] Former employee access has been revoked
• [ ] Safe(s) for cash and high-value product secured

Alarm Systems

• [ ] Intrusion alarm is functional and tested
• [ ] Panic buttons accessible to staff
• [ ] Alarm company contact information on file
• [ ] Recent alarm testing documentation available
• [ ] Police notification protocols documented

Record-Keeping Checklist

Required Documentation

• [ ] Current cannabis license posted visibly
• [ ] Operating plan on file and current
• [ ] Security plan on file and current
• [ ] Employee training records for all staff
• [ ] Background check documentation
• [ ] Age verification training records

Transaction Records

• [ ] All sales recorded in seed-to-sale system
• [ ] Customer ID verification logs maintained
• [ ] Voided transaction documentation
• [ ] Daily sales reconciliation records
• [ ] Cash handling procedures documented

Inventory Records

• [ ] Real-time inventory in seed-to-sale system
• [ ] Physical inventory counts documented (daily/weekly)
• [ ] Discrepancy investigation records
• [ ] Waste/destruction logs with witness signatures
• [ ] Transfer manifests complete and filed

Inventory Control Checklist

Product Tracking

• [ ] All products tagged in seed-to-sale system
• [ ] Package IDs match physical labels
• [ ] Quarantined products separated and labeled
• [ ] Recalled products removed from inventory
• [ ] Sample products properly documented

Storage Conditions

• [ ] Temperature monitoring in storage areas
• [ ] Humidity control where required
• [ ] Products stored off floor on shelving
• [ ] Pest control measures in place
• [ ] Clean and organized storage areas

Product Compliance Checklist

Labeling

• [ ] All products have compliant labels
• [ ] THC/CBD content matches lab results
• [ ] Required warnings present
• [ ] Universal cannabis symbol displayed
• [ ] Batch numbers traceable

Testing

• [ ] Lab test results on file for all products
• [ ] No expired products on sales floor
• [ ] COAs (Certificates of Analysis) accessible
• [ ] Failed/quarantined products properly handled

Employee Compliance Checklist

Documentation

• [ ] All employees have completed required training
• [ ] Training certificates on file
• [ ] Background checks current
• [ ] Agent cards/employee IDs displayed

Operations

• [ ] Staff can demonstrate age verification procedures
• [ ] Staff knows inventory system procedures
• [ ] Staff understands product limits and regulations
• [ ] Staff knows emergency procedures

Facility Checklist

General Conditions

• [ ] Facility is clean and well-maintained
• [ ] No structural hazards or safety issues
• [ ] Adequate lighting in all areas
• [ ] Fire extinguishers present and inspected
• [ ] Emergency exits clearly marked and unobstructed

Signage

• [ ] "No minors" signage at entry
• [ ] Required health warnings posted
• [ ] License posted in visible location
• [ ] Emergency contact information posted

Day-of-Inspection Protocol

When inspectors arrive:

1. Verify inspector credentials - Ask for OCM identification
2. Designate a point person - One manager should accompany inspectors
3. Document everything - Take notes on what's examined
4. Be cooperative - Answer questions honestly but don't volunteer excess information
5. Request copies - Get copies of any citations or notes

What NOT to Do

• Don't deny access to inspectors during business hours
• Don't attempt to hide or move products
• Don't argue with inspector findings on-site
• Don't sign anything you don't understand

After the Inspection

If Citations Are Issued

1. Review citations carefully
2. Understand the deadline for corrective action
3. Document your remediation efforts
4. Submit required responses on time
5. Consider consulting with a cannabis attorney

Ongoing Compliance

• Schedule monthly self-inspections
• Keep this checklist updated as regulations change
• Train new employees on compliance requirements
• Address minor issues before they become violations

Need Help Preparing for Inspections?

CannAdvisor's Inspection Checklist Tool provides a digital, interactive version of this checklist customized to your license type. Our AI can also answer specific questions about OCM inspection requirements.

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Last updated: January 5, 2024. This article is for informational purposes only and does not constitute legal advice. Consult with a licensed attorney for legal guidance.