Compliance Audit from the Department of Cannabis Control at Off the Charts San Francisco

A DCC inspection is an in-person compliance check in which California Department of Cannabis Control (DCC) inspectors review a dispensary's products, inventory records, security, and recordkeeping against state regulations. Many arrive unannounced. When the DCC made a surprise visit to Off the Charts (OTC) San Francisco, store manager Jordan Kuhl walked three inspectors through every shelf and back room. We spoke with him about what the team got right, what got flagged, and how to prepare for your own inspection. PLUS Download our California DCC Inspection Checklist below

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Here's a quick look at what DCC inspectors check during a routine inspection, and who is primarily responsible for each area:

Area What inspectors check Primary responsibility
Product labels and testing Current COAs and lab-test labels on every shelf Distributor (retailer must verify)
Packaging No designs that could appeal to children Distributor (retailer must verify)
Vape labeling No "disposable," trash, or recycling claims (AB 1894) Distributor and brand
Inventory and Metrc Physical counts match Metrc; no ghost inventory or negative packages Dispensary
Backstock Blue Metrc tags on all backstock, including drawers and cabinets Dispensary
Trade samples and donations Correct Metrc adjustments with employee details Dispensary
Expired product Removed from sale and disposed of as waste Dispensary
Security and surveillance 90 days of footage, coverage during guard breaks, locked restricted areas Dispensary
Employee badges License number, employee number, and cannabis license number Dispensary
Off the Charts San Francisco dispensary, a Meadow POS client

About Off the Charts San Francisco

Off the Charts (OTC) San Francisco is a proud member of the Off the Charts family, a cannabis franchise that started in Vista, California. Known for their commitment to providing high-quality cannabis at reasonable prices, OTC has expanded to over 20 locations across California, with additional stores in New Mexico and Ohio.

As the first Northern California location, OTC San Francisco is dedicated to serving the local community by ensuring accessibility to cannabis, while maintaining stringent compliance with state regulations. Their mission is to offer the lowest prices possible, making cannabis accessible to all, and fostering a welcoming environment for both medical and recreational users.

💡 Learn more about How Off the Charts Opened 30+ Locations in 2 Years with Meadow

The DCC's Arrival at Off the Charts San Francisco

On a routine morning, the team at Off the Charts (OTC) San Francisco was met with an unexpected visit from the Department of Cannabis Control (DCC). Three inspectors arrived promptly at 10 a.m., equipped with badges. It's important that before you begin the inspection as a cannabis retailer, you confirm the inspectors are affiliated with the state to protect security at your store. Anyone can walk in with a badge claiming they're on official business.

Following proper protocol, the inspectors signed in and engaged with the security guard to understand the facility's security measures, including break coverage and access protocols.

Once inside, the inspectors met with Jordan Kuhl, the store manager. Prepared for the inspection, Jordan grabbed a pen and notepad to document the proceedings. It's important that whoever from your staff is leading the inspection takes diligent notes, as a notice to comply will be issued. In the notice to comply, any flags should be addressed by the retailer with an update to standard operating procedures.

The DCC team began their inspection by entering the bud room, where they immediately started examining product labels, cannabis testing information, and Certificates of Analysis (COAs) on every shelf. Their meticulous approach set the tone for a comprehensive compliance check, aiming to confirm that OTC was adhering to all state regulations.

Here Are OTC's Key Takeaways and Lessons Learned

The notes below can help other cannabis retail operators stay ahead of regulatory requirements.

Distributor-Determined Compliance Issues

These compliance issues are primarily influenced by the distributors and their adherence to state regulations. Even so, retailers must stay vigilant and confirm that every product received from a distributor meets Department of Cannabis Control (DCC) standards before it reaches the shelf.

Product Inspection and Labeling

Cannabis Testing: COA Compliance

Products without COAs or current lab-test result labels were quarantined. "One of the investigators pulled an ounce from the shelf and showed me that the item was missing the necessary COA that the DCC requires the vendor to upload to Metrc prior to shipping," Jordan explained.

Cannabis product quarantined by DCC inspectors during a compliance inspection

Packaging Standards

Products with cartoonish packaging, which could appeal to children, were embargoed. In one example, a product's packaging was described as "too cartoony," with an illustration of a woman with exaggerated features. "They pulled everything that could be deemed attractive to children," said Jordan.

The DCC emphasized that marketing practices must comply with regulations designed to avoid marketing toward minors. This product was removed from the shelves, put into a paper bag, and placed in view of the cameras. The DCC inspectors instructed Jordan not to interact with these products until further notice, otherwise the store could face an expensive fine.

Vape Labeling: No "Disposable" Claims

California prohibits labeling or packaging cannabis vape cartridges and integrated vaporizers in a way that says or implies they are "disposable," can be thrown in the trash, or can be added to recycling streams. This rule comes from Assembly Bill 1894 and took effect July 1, 2024. Advertising and marketing for these products must also include proper hazardous-waste disposal messaging.

Distributors and brands carry the labeling obligation, but retailers should avoid stocking vapes that still read as "disposable," since non-compliant packaging can be flagged during an inspection. As of the writing of this article, the DCC has emphasized education and moving non-compliant stock out of the supply chain. Confirm the current enforcement status before relying on it.

These compliance issues, though largely outside the retailer's direct control, must be strictly adhered to according to the Department of Cannabis Control's guidance.

Following the inspection, Jordan was tasked with contacting the distributors for necessary corrections and awaiting further notice from the DCC on outstanding issues.

Inside Off the Charts San Francisco during a DCC compliance inspection

Dispensary-Managed Compliance Responsibilities

The following responsibilities fall directly under the dispensary. Retailers need rigorous standards and processes to stay in full adherence with the Department of Cannabis Control's regulations. During the audit, the DCC highlighted several critical areas. Some notes were reminders, while others were urgent corrections that all retailers should implement immediately in preparation for a compliance audit.

Inventory Tracking and Compliance

Backstock Labeling

All backstock items must have the blue Metrc tag, or a copy of the blue Metrc tag, attached to the container holding those items. This enhances traceability and helps the DCC recognize which items belong to which packages. "Their team also advised me that any items located in a drawer or cabinet on the floor is also considered backstock, and would also require the tag associated with those products," Jordan noted. Keeping backstock tagged and your Metrc inventory reconciled is the fastest way to pass this part of an inspection.

💡 How Meadow handles this: Meadow keeps your physical counts and Metrc in sync with daily uploads and built-in cycle counts, so backstock and the floor always match. How to Reconcile Metrc for Your Dispensary →

Handling Trade Samples and Donations

The inspectors advised Jordan on the proper procedures for processing trade samples and donations. Employee details and transaction records must be recorded on the adjustment. Read more in the DCC regulations on §15041.2. Trade Samples and the DCC's Trade Samples FAQ.

Retailers should also refer to this Metrc Support Bulletin: Providing a Trade Sample to An Employee.

"When providing cannabis goods to employees as trade samples, you must adjust the quantity in the trade sample package and utilize the 'Trade Sample' package adjustment reason. In addition, you must include the name or licensee-assigned employee number of the employee and the date and time the cannabis goods were provided to the employee in the Required Note field."

Expired Products

The inspectors verified product packaging and confirmed that Jordan knew how to manage expired products and dispose of them properly as waste.

Retailers can easily identify expired products in Metrc by filtering packages by their received date. Regular checks prevent non-compliant sales. "They advised that anything that's received more than a year ago is very likely past its certificate of analysis test date," said Jordan. "Luckily, we did not have any expired products for sale."

Retailers have to comply with §15406. Cannabis Goods for Sale (b): "The licensed retailer has verified that the cannabis goods have not exceeded their best-by, sell-by, or expiration date if one is provided."

Retailers utilizing Meadow can also verify and record product expiration dates and reception dates within the POS system in just a few clicks, avoiding Metrc entirely. "We use Meadow reports and dashboards to regularly check on upcoming expiration dates, it's that easy," Jordan added.

Off the Charts San Francisco dispensary sales floor

Security and Access Protocols

Security is a critical aspect of cannabis retail operations. The DCC inspection at OTC included a detailed review of security measures.

Security Guards and Surveillance

Inspectors examined security guard protocols and the surveillance system, confirming that 90 days of footage was available. Guards should not leave the dispensary unattended, which means there should be coverage during guard breaks as well. A documented security and loss-prevention plan keeps this part of an inspection simple.

💡 Learn more: Dispensary Loss Prevention 101

Restricted Access

The inspectors verified that all necessary doors were locked and only employees could access these areas. "They did want to check out the distro as well because we are a micro business; however, we haven't started our distribution yet," Jordan explained, showing the inspectors' meticulous attention to detail across the licensed premises. The inspectors toured the entire space, from the front door to the manager's office. They were mainly looking for out-of-place cannabis products. Cannabis products should not be stored in non-secure areas like break room fridges, offices, or common areas.

Employee Identification

Employee badges must include their license number, employee number, and the cannabis license number. "Ours are compliant. We just updated them," Jordan confirmed.

Meadow POS Dispensary Software Compliance Features

OTC San Francisco runs its operation on Meadow's point-of-sale system. During the audit, several features were particularly beneficial.

✔️ Built-in Purchase Limit Controls

Meadow's purchase limit controls, complete with a progress bar, prevented sales that exceeded recreational and medical limits. "Meadow has a great tracking system, that anything you scan, it displays a little bar that fills up as you build the order, and it'll prevent you from going over," Jordan demonstrated.

✔️ Medical Verification Tools

The ability to upload patient ID cards directly into the system ensured that all medical sales were properly verified and documented. "We can take a picture and upload it into Meadow so it's permanently and securely stored there," Jordan said.

✔️ Accurate Metrc Reporting

When the inspectors randomly selected a product from the shelves, every unit was accounted for in Metrc. With daily account monitoring and no ghost inventory or negative packages, OTC's records matched the shelf exactly, which is the moment an inspection is won or lost.

💡 Learn more: Key Features of Meadow's Smart Metrc-Compliant Dispensary Software

Blue Metrc tags on backstock at Off the Charts San Francisco

Next Steps for Compliance

In light of the DCC audit, OTC San Francisco outlined several next steps to strengthen their compliance efforts:

  • Blue Sticker System: Implement a system for blue sticker copies on all backstock items to ensure batch traceability.
  • Refine Procedures: Tighten procedures for handling trade samples, promos, and donations to include all necessary details and employee information.
  • Dispose of Embargoed Products: Properly dispose of any products with non-compliant packaging, such as those with cartoonish designs. "They instructed me how to handle them and placed everything in evidence bags and sealed them with tape," Jordan recounted.
  • These details will be included in their response to the notice to comply.

Common Questions

What happens during a DCC inspection?

During a DCC inspection, Department of Cannabis Control inspectors review your products, labels, and Certificates of Analysis, confirm that your physical inventory matches Metrc, inspect security and surveillance, verify employee badges, and check how you handle expired, embargoed, trade-sample, and donated product. They sign in, often start in the bud room, and issue a notice to comply listing anything that needs correction.

Are DCC inspections announced or unannounced?

Many DCC inspections are unannounced surprise visits, as Off the Charts San Francisco experienced. Others are scheduled, such as the pre-license inspection the DCC conducts before issuing a retail or delivery license. Either way, confirm that anyone presenting a badge is actually a DCC official before the inspection begins.

What do DCC inspectors look for in a dispensary?

DCC inspectors look for current COAs and compliant labels on every product, accurate Metrc records with no ghost inventory or negative packages, blue Metrc tags on all backstock, at least 90 days of security footage, compliant employee badges, and proper disposal of expired or embargoed product. Packaging that could appeal to children is embargoed on the spot.

What is a notice to comply?

A notice to comply is the document a DCC inspector issues at the end of an inspection listing any compliance issues found. The retailer is expected to address each flagged item, usually by correcting the issue and updating standard operating procedures, then responding to the notice within the timeframe it specifies.

How many days of security footage does California require?

California requires licensed cannabis retailers to retain at least 90 days of video surveillance footage. During an inspection, the DCC will confirm that footage is available and that camera coverage and security-guard protocols meet state requirements, including coverage during guard breaks.

How should a dispensary prepare for a DCC inspection?

To prepare for a DCC inspection, keep COAs and labels current on every shelf, reconcile your Metrc inventory regularly, tag all backstock with blue Metrc tags, retain at least 90 days of footage, confirm employee badges are compliant, and keep clear SOPs for expired, embargoed, trade-sample, and donated product. Running regular cycle counts and using your POS to monitor expiration dates keeps you inspection-ready year-round.

Conclusion

Off the Charts San Francisco's DCC audit underscores the importance of meticulous compliance in the California cannabis market. By following these insights and leaning on tools like Meadow's POS system, cannabis retailers can better navigate state regulations, keep operations running smoothly, and avoid costly fines.

Click Here to Download our California DCC Inspection Prep Checklist!
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