New OMMA Emergency Rules – Employee Badges

September 2024

By: John M. Hickey

On August 16, 2024, OMMA issued new Emergency Rules.  As a reminder, each medical marijuana business license holder is required to ensure that all individuals employed under its license have an active, unexpired employee credential.  Each business license holder must maintain the Employee Roster located in its OMMA business portal.  If you have more than one license and certain of your employees work at different locations, or rotate between a processor facility and grow facility at the same location, the employee should be listed under the Employee Roster of both licenses at issue.

Pursuant to the new Emergency Rules, all employees credentials are to be worn or displayed on their person during the employee’s hours of work.  See 442:10-5-1.1(13)(C)

As a reminder, for purposes of OMMA’s business license rules, the term "employee" means any natural person who: (i) Grows, harvests, dries, cures, purchases, sells, transfers, transports, processes, produces, manufactures, creates, or packages medical marijuana, medical marijuana products, and/or medical marijuana waste on behalf of or for a medical marijuana licensed commercial grower, processor, or dispensary; (ii) Samples, trains, or educates on behalf of or for a medical marijuana licensed education or research facility; (iii) Disposes of or transports medical marijuana, medical marijuana products, and/or medical marijuana waste on behalf of a medical marijuana waste disposal facility licensee; (iv) Tests and/or conducts research on medical marijuana and/or medical marijuana products on behalf of a medical marijuana licensed testing laboratory; (v) Transports, stores, distributes, but does not take ownership of, medical marijuana and/or medical marijuana products on behalf of a medical marijuana licensed commercial transporter; (vi) Tracks, traces, reports, and/or inputs any information into the State inventory tracking system on behalf of a medical marijuana commercial licensee; or (vii) Conducts any other additional business for the benefit of a medical marijuana commercial licensee authorized under OAC 442:10, with the exception of professional services not involved in the handling of medical marijuana, medical marijuana concentrates, or medical marijuana products.

If you have any questions or concerns, please feel free to contact a member of our team.