METRC Enforcement and Penalties 3 — Questions and Answers
Question 1: Which of the following actions would most likely result in an immediate license suspension rather than a warning?
- Forgetting to log a batch tag for one day
- Operating while a required license fee payment is overdue by two weeks
- Selling cannabis to an unlicensed entity outside the METRC system (Correct answer)
- Failing to update employee credentials in the system
Correct answer: Selling cannabis to an unlicensed entity outside the METRC system
Selling cannabis to unlicensed entities bypasses the entire tracking system and constitutes diversion, which is among the most serious violations warranting immediate suspension.
Question 2: What does 'manifest variance' mean in METRC enforcement contexts?
- A discrepancy between the quantity listed on a transfer manifest and the quantity actually received (Correct answer)
- A difference in the strain name between two facilities
- An error in the package tag barcode format
- A delay in uploading lab test results
Correct answer: A discrepancy between the quantity listed on a transfer manifest and the quantity actually received
Manifest variance occurs when the quantity recorded on a METRC transfer manifest does not match the quantity verified upon receipt at the destination facility.
Question 3: A cannabis cultivator receives a Notice of Alleged Violation (NOAV) from the state. What is the typical first required response?
- Cease all cultivation operations immediately
- Submit a written response or corrective action plan within the specified deadline (Correct answer)
- Transfer all inventory to a compliant facility
- Request a federal investigation
Correct answer: Submit a written response or corrective action plan within the specified deadline
Upon receiving a NOAV, licensees are typically required to submit a written response or corrective action plan by a specified deadline to address the alleged violations.
Question 4: Under METRC rules, untagged cannabis plants discovered during an inspection are treated as:
- Automatically grandfathered into the current inventory
- Untracked product subject to seizure and potential penalties (Correct answer)
- Exempt if they are immature seedlings
- Legal if the licensee can verbally account for them
Correct answer: Untracked product subject to seizure and potential penalties
Untagged cannabis plants cannot be tracked in METRC and are therefore considered untracked product, subject to seizure and administrative or criminal penalties.
Question 5: Which penalty structure is most commonly used for first-time minor METRC reporting violations?
- Automatic license revocation
- Criminal referral to the state attorney general
- Monetary fine scaled to the severity and scope of the violation (Correct answer)
- Immediate product destruction order
Correct answer: Monetary fine scaled to the severity and scope of the violation
First-time minor violations typically result in scaled monetary fines, with amounts proportional to the nature and scope of the reporting failure.
Question 6: If a METRC package tag is damaged and unreadable during transit, what is the compliance-required response upon delivery?
- Reject the shipment and send it back without documentation
- Destroy the damaged package immediately upon arrival
- Notify the state regulator and document the issue, then request a tag replacement (Correct answer)
- Accept the shipment and sell it without re-tagging
Correct answer: Notify the state regulator and document the issue, then request a tag replacement
Damaged package tags must be reported to the state regulator, documented in METRC, and a replacement tag must be requested to maintain chain-of-custody integrity.
Question 7: A state inspector discovers that a dispensary has been manually altering METRC data after the fact to cover inventory shortages. This constitutes:
- A minor bookkeeping error
- Falsification of records, a serious compliance offense often triggering license revocation (Correct answer)
- An acceptable correction method if the error is under 5%
- A correctable issue if disclosed voluntarily
Correct answer: Falsification of records, a serious compliance offense often triggering license revocation
Deliberately altering METRC records to conceal shortages is falsification of government-required records, one of the most serious violations that typically results in license revocation.
METRC Enforcement and Penalties 3
Which of the following actions would most likely result in an immediate license suspension rather than a warning?