Operating Requirements and Inspections

Operating Requirements and Inspections

NYCRR Title 9, Part 125 sets the day-to-day operational standards every adult-use cannabis licensee in New York must follow. These are the rules inspectors use when evaluating whether your business is operating legally.

What This Covers

  • Operational standards inspectors enforce
  • Required plans, systems, and procedures
  • Security, sanitation, and inventory rules
  • Transport and waste requirements
  • Inspection, audit, and recordkeeping obligations

Energy and Environmental Standards (Section 125.1)

Licensees must operate in a way that reduces environmental impact.

Requirements include:

  • Using efficient lighting, equipment, and HVAC where required
  • Following water-use and waste-management rules
  • Complying with any sustainability requirements set by OCM
  • Maintaining documentation showing compliance when requested

Site and Operating Plans (Section 125.2)

Every licensee must maintain written plans explaining how the business operates.

Plans must cover:

  • Site layout and workflow
  • Security procedures
  • Waste disposal methods
  • Environmental and sanitation practices

Plans must be updated when operations change. OCM may review or require revisions at any time.

Security and Storage of Cannabis (Section 125.3)

Cannabis must be protected from theft, diversion, and contamination.

Core requirements:

  • OCM-approved cameras, alarms, and access controls
  • Locked, restricted storage areas
  • Organized and traceable storage systems
  • Immediate reporting of security incidents to OCM

Employee Requirements and Training (Sections 125.4, 125.5)

Employees who handle cannabis must meet minimum standards.

Requirements include:

  • Employees must be at least 21 years old
  • Training must be completed before handling cannabis
  • Training must cover compliance, safety, security, and contamination prevention
  • Refresher training is required
  • Licensees must maintain employee records and training logs

Worker Health and Safety Standards (Section 125.6)

Licensees must protect workers from unsafe conditions.

This includes:

  • Providing protective equipment when required
  • Following ventilation and air-quality rules
  • Handling chemicals safely
  • Maintaining injury-prevention programs
  • Recording and reporting workplace injuries as required by law

Sanitary Facility, Equipment, and Handling Standards (Section 125.7)

Facilities must be clean and sanitary at all times.

Requirements include:

  • Regular cleaning and sanitizing of equipment
  • Preventing contamination of cannabis
  • Maintaining hand-washing facilities
  • Enforcing hygiene standards
  • Documenting cleaning schedules and procedures

Inventory and Tracking (Section 125.8)

All cannabis must be tracked from receipt through sale or disposal.

Licensees must:

  • Use the state seed-to-sale tracking system
  • Log all movements, adjustments, transfers, and waste
  • Investigate and report discrepancies
  • Ensure records match physical inventory

Quarantine and Recalls (Section 125.9)

Unsafe or noncompliant cannabis must be isolated immediately.

Requirements include:

  • Quarantining expired, damaged, mislabeled, or failed products
  • Following OCM recall procedures when required
  • Maintaining detailed quarantine and recall logs

Transport of Cannabis (Section 125.10)

Cannabis transport is tightly regulated.

Requirements include:

  • Using authorized vehicles and registered drivers
  • Maintaining transport manifests
  • Keeping cannabis locked and out of public view
  • Reporting transport incidents to OCM

Management of Cannabis and Other Waste (Section 125.11)

Cannabis waste must be destroyed so it cannot be reused or diverted.

Requirements include:

  • Mixing cannabis waste with non-cannabis waste
  • Documenting all destruction events
  • Securely storing waste until destruction
  • Following environmental and hazardous-waste rules

Inspections and Audits (Section 125.12)

OCM may inspect or audit any licensed business at any time.

Key points:

  • Inspections may be unannounced
  • Licensees must provide full access to premises, records, and inventory
  • Failure to cooperate can result in enforcement

General Recordkeeping Requirements (Section 125.13)

Licensees must maintain complete and accurate records.

Records must cover:

  • Purchases and sales
  • Employees and training
  • Security systems
  • Inventory and waste
  • Transport and incidents

Records must be organized, accessible, and retained for the required period.

Internal Quality Control Samples (Section 125.14)

Processors may create internal samples for quality control.

Conditions include:

  • Samples must be logged in the tracking system
  • Samples may not be sold or given to consumers
  • All safety and contamination rules apply

Consumption Facilities (Section 125.15)

Additional rules apply to licensed consumption areas.

Requirements include:

  • Age restrictions and access controls
  • Ventilation and safety standards
  • Inventory tracking for consumed cannabis
  • Procedures to prevent overconsumption and impaired driving

Licensed Premises Verification Tools (Section 125.16)

Licensees must verify other licensees before transfers.

Verification tools may include:

  • OCM databases
  • QR codes or online verification systems

This prevents diversion and illegal market activity.

What Operators Usually Miss

  • Plans must stay current, not just submitted once
  • Logs are inspected as closely as physical spaces
  • Training gaps are violations
  • Inventory errors escalate quickly
  • Inspectors rely on Part 125 as their checklist

When This Comes Up

  • Daily operations
  • Staff onboarding and training
  • Inventory management
  • Transport and waste handling
  • Inspections and audits

What Happens If You Ignore This

Violations may result in:

  • Written violations and fines
  • Product quarantine or destruction
  • License suspension or revocation
  • Failed renewals
  • Increased inspection frequency

Related Pages

  • Inspection and Audit Preparation
  • Dispensary Operations
  • Municipality Rulemaking
  • State and Local Requirements

Related NYCRR Section Pages

  • Social and Economic Equity (SEE) (Part 121)
  • Adult-Use Applications and Licensing (Part 120)
  • Rules by License Type (Part 123)
  • Business Requirements (Part 124)
  • Operating Requirements and Inspections (125)
  • CAURD (Part 119)
  • Definitions (116.1 and 118)
  • Municipality Rulemaking (Part 119)

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