Theresa Dobrash: [00:00:00] there's one for every little alphabet right now.
Tommy Truong: really?
Theresa Dobrash: We don't have to go that far, but let's definitely talk about E, which is enforcement. What are you gonna do when you get a surprise inspection? is your manager gonna freak out and have a panic attack?
are they gonna feel confident? Are you gonna drive two hours from your house, make the regulators wait for you to walk through that facility? And you know what happens if there's a serious infraction? You might need legal help to get through that. Enforcement is important
Welcome to the Kayak Cast, the podcast for cannabis businesses looking to launch, grow, and scale their operations.
Tommy Truong: Believe it or not, I am actually quite excited to talk to you about compliance.
I talk to a lot of dispensary owners that are just starting out or have started, and they always ask me. What are the ABCs of [00:01:00] compliance? It's such a loaded word The regulations are hundreds of pages. So when somebody is building out their compliance playbook, what are the foundation that they should think about?
Theresa Dobrash: Awesome. I love the ABCs of compliance. So accountability. You need to have someone. Like designate one person ideally to be responsible for compliance for the licensing. Someone that is gonna be there when things go wrong to answer for that.
Tommy Truong: Is that typically the owner or it could be anybody, the senior.
Theresa Dobrash: The owner needs to be heavily involved they can delegate a lot of the compliance like day-to-day stuff or more specialized. I always recommend to source that person from cannabis rather than hiring from another industry.
A lot of industries do have compliance, but there's a lot of things that are very unique to cannabis.
Tommy Truong: Is this a specific compliance [00:02:00] role or could it be, say my inventory manager who's inept in reading law, is this a full-time thing or a part-time thing in your
Theresa Dobrash: Yeah, there's a couple of different facets of cannabis compliance for sure. Inventory management is a huge part of it. Definitely. But then there's also licensing that maybe an inventory management per se might not. Be suitable for. So that person like helping renew your licenses, a lot of times, legal professionals are heavily involved in that.
So that's a big bulk of what we do at Select and Law is licensing. And then there can be some non-inventory related questions or like specifics that come up. As well. Things with like your floor plan if you're a retail dispensary, et cetera. And it also can depend on the size of your operation.
If you know [00:03:00] you've got like a simple, we do specialize in one thing, we only take care of that small team. Maybe that person. Takes care of all of those things and inventory. But if you've got a more robust complex you may need a couple of people on that compliance team.
Tommy Truong: Okay, I'm just thinking through average dispensary owner that just starts,
Theresa Dobrash: Mm-hmm.
Tommy Truong: uh, maybe two people that are owners and they have a team of 10 in that environment, I'm guessing is one of the owners needs to just bite the bullet and, Hey, you're the compliance officer.
Theresa Dobrash: I would definitely recommend that because their name is on the hook for that. And then, work closely with their legal team.
Tommy Truong: So where does somebody start? I'm an owner. I'm opening up, where do I start? What do I do? What are my first 10 moves?
Theresa Dobrash: legal team for sure. And a lot of cannabis lawyers don't have [00:04:00] a compliance wing. We at Selects and Law do, so that's my specialty, is focusing on the nitty gritty of compliance. Anything you could need from, application to operation and beyond.
Tommy Truong: How would you set up a program
Theresa Dobrash: how would I set up a program? Yeah, again, it's a lot with your operation style. If you have someone who's really skilled in compliance on staff already, we can set you guys up with some like tools, resources to walk you through the regulations so that you're not just reading like 200 pages of rules.
It's a, you can actually absorb it and it's not as cut and dry and boring. So we have some great resources for that. I can do a bootcamp with staff, so I could come in a couple of days. Even for longer and really support on training. And then, even past your opening day, I like to provide support with, when people are, they've [00:05:00] got questions that they've never, things they've never came across before.
So that's been pretty big in New York since that industry and that market is, just launching. A lot of people are really interested in that
Tommy Truong: What should a owner have in place with regards to compliance before opening day?
Theresa Dobrash: for opening day. Be fully prepared.
Tommy Truong: It's easier said than done.
Theresa Dobrash: Right.
Tommy Truong: you're in the business
Theresa Dobrash: shortlist wise. Know what kind of IDs you can accept. So every state. They're gonna have a different criteria for IDs. And you might read that list and think, oh, this is simple. But go over those scenarios in practice, Because it's tech, you're gonna come across some unique things, especially if you've advertised your launch and you've got a huge crowd out front.
There's gonna be people who have different types of IDs and you wanna be prepared for that. And. Have a system in place [00:06:00] for questions too. Know, your staff comes across something that they've never came across before. Have a manager, somebody ready to answer those questions without causing a disruption to sales flow.
And procedures, training and procedures. I didn't mention that earlier, but we do write pretty thorough operation plans for people. That's kind of part of the training too. And just having those procedures standardized. So this is what a sales would like. This is what a return looks like, et cetera.
Tommy Truong: Are there different areas that are consistent across states? And you've made a really good point earlier, make sure that you are accepting the right IDs, and I'm guessing you're selling the right quantity. You understand the quantity in your state, you understand how to accept inventory, how to account inventory, all those things.
What are the common. Top 10 things [00:07:00] that you should train your employees on, but also have a manual for.
Theresa Dobrash: Yeah, we could call this B for boundaries. So there's gonna be like a handful of things like IDs, sales limits that are mildly consistent state to state, but definitely very specific and change state to state.
Tommy Truong: I was thinking to myself as somebody that's the outside looking in, I have a peripheral view. We work with so many customers in the cannabis space. And compliance is always the thing that GNAs at the back of. Their minds. I would guess as an operator, you are obsessed over customer experience, retail experience, all of these things that are involved in merchandising and then you have, compliance is such a big part of the industry, but I feel as though there's a skillset that's lacking for operators.
In that field. And that's where somebody like you come in, that's an expert that people can lean [00:08:00] on to kickstart their compliance. And I think that's, it's so needed because it's not a skillset that you're naturally born with. I have no idea starting off where to even start. I look at the regulations for New York, for example, it's hundreds of pages.
And how does that, hundreds of pages, what is needed to turn that into a manual that. The team can be trained on and also that it's stale to what's actually really important from an operational perspective. Hey, out of the things that are in here, we need to be compliant on these things.
Theresa Dobrash: Yeah, there's definitely some non-negotiables. I think it's really interesting that for me compliance feels like very second nature. I understand it, there's no questions for me and I want other people to feel that same way too. Just that level of confidence. Because it is pretty scary.
There's some serious repercussions that can happen if you get it wrong. And I don't want that fear to overshadow, running your [00:09:00] business. Like I want you to still have a lot of brain space for that creativity to pour into your marketing and other areas. I like working with my clients to make them feel confident.
So definitely if I could create a list of like non-negotiables to have your procedures sales, you think it's pretty simple oh, it's like another cashier job, but you have to be careful about what you talk about even at the sales register. So different states have different. Rules for, can we mention medical cannabis?
Can I provide you medical advice? How do we, what's the best way to phrase that? And even your state will provide bud tenders with some guidance on this is how we deal with, this is recreational and this is medical. And they even have different words for it, like adult use sometimes rather than recreational anyways.
Sales aren't as cut and dry. [00:10:00] Same with returns. Sometimes you're gonna have to destroy those products. So sales accuracy, having your team be confident in that too. Also inventory management for sure. Very important. You gotta be very organized. Having someone very detailed, diligent in your inventory management, reduce those inventory discrepancies.
Key. Then I would say also labeling. Labeling is very important for products. A lot of people think that's a supplier's job. It's also a dispensary's job and sometimes maybe a lot of states move past this, but there's labels you had to apply at the point of sale. Warning labels, you don't wanna sell a product.
Mis sell a product to a customer. Things could go really bad with that. Imagine if you thought you were buying a 10 milligram gummy or maybe a five milligram gummy, and it turns out to be a 10 milligram gummy. You don't read the package, you just [00:11:00] pop one. That customer's gonna have a bad experience.
So we wanna make sure the product's labeled, we've sold it to them correctly and very clearly. Our safety and a lot of things was with compliance, which kind of. I hope, I think helps people feel more confident is that it's essentially just really running a business well having the airtight inventory, having that airtight sales experience to product, for safety and documenting everything.
That's really what it is just keeping really good records, documenting really good inventory and focusing on safety.
Tommy Truong: Is there any playbook that. Owners can use when creating their standard operating system. And how big is that? So what does that look like? What does distilling the regs into an operating system that employees can be [00:12:00] trained on? And maybe that's a loaded question because that's, there's a lot of work involved in that, and that's where you come in to, as a consultant, do you come in to help?
Owners start that. The SOPs.
Theresa Dobrash: Yeah I love SOPs. How they've evolved over the years is really interesting to me. Because you had to know someone who knew someone who is a really good operator back in the day. Or, 10 years ago or so to get your hands on really good SOPs, maybe more so in cultivation than in retail.
And they were very valuable. And now we've gotten more and more procedures as our industry nationwide Canada included, has matured. But. As far as the baseline for it, there's definitely, training modules and key things that need to be [00:13:00] in there, and you just expand upon that.
Our retail operating procedure tends to be over a hundred pages long. Um,
Tommy Truong: That's what I was gonna ask you. When it gets that long, does it become practical anymore? I find sometimes when I go into an environment and. The SOPs are really big and it's really restrictive and it's very specific. And I think to myself, when you get audited and you force yourself to these rules that are so strict that's gonna come to hurt you on the back end because it's so strict now.
and I was gonna ask you, when somebody comes in, the regulars come in, are they looking at your SOPs? does it abide by the regulations? And then are they testing? Are you abiding by your SOPs? So if your SOPs are more strict than the regulations, you shot yourself in the foot.
Theresa Dobrash: That's really important and very fascinating for me is making sure that [00:14:00] you, these SOPs are detailed, they're standardized, but they're also not going to shoot yourself in the foot if you use a red clipboard instead of a green clipboard to. Write your visitor log as a basic example so that they're like adaptable to basic small changes in your operation.
And that's something I really focus on and I see as a mistake sometimes in procedures, especially honestly, shorter procedures. Sometimes they end up being too specific. Just a general observation I've made taking a look at other SOPs. And those procedures are normally shorter. They're less than the a hundred pages that we've been able to produce, and sometimes theytailor this so that it's not so specific so that in case you do use that green clipboard instead of the red, you're not getting in trouble because I don't think regulators are going to care if it's something as.
Random the color [00:15:00] of your clipboard, but if it's something like, you're operating hours or where you check IDs, they're gonna care that you're not following those SOPs.
Tommy Truong: So how you mentioned it's a hundred pages long. How can somebody ensure that their team is compliant on such a large document of rules?
Theresa Dobrash: So first of all, breaking it down and having people have that general overview. Okay, so these are the sections of the operating plan. This is the table I normally give everybody the table of contents. Walk everybody through quickly, table of contents, how to read each SOP like the parts of the SOP, this is the scope this is the procedure.
Here's where you can find the references, et cetera. And then [00:16:00] Break it down all the way to the entire book. Show them this is where you can find all this stuff, but then breaking it down a little bit more into specializations for your role. So having maybe a front of the house manager and a back of the house manager that can just really grasp those different things, come specialized in those things, and eventually get that cross training and, become masters of the whole procedure.
Tommy Truong: So if I was starting out and I'm opening up. The first step, I think the most prudent step for a business owner is align yourself with the right legal team that can help you create the SOPs. That's like number one. Number two is make sure that your SOPs are not too restrictive in the way that you have to operate, so it's compliant, but it gives you the flexibility to teeter off just a, flexible flexibility. And I think that comes probably with experience on somebody from your [00:17:00] team or who you're working with. And then it comes down to employee training. So what does the initial training, and you've mentioned a little bit of this to make sure that your team's at the speed, but is there a closed loop validation that, Hey, my team is following up with these SOPs. What does that look like?
Theresa Dobrash: You mean making sure that the SOPs are actually being followed?
Tommy Truong: Mm-hmm.
Theresa Dobrash: Um. Regular audits for sure. And that's another thing we do too. We'll audit, we'll come in and make sure couple weeks in or a month in or a few months in once you've got the grip on everything that you're following the SOPs or maybe something needs to be tailored to where you are and the stage of the growth of your company too.
That's another thing that I think is important. The SOPs can't really stifle your growth. And they may change and adapt. Maybe you're carrying more inventory, maybe you're carrying less. [00:18:00] Maybe you found a more efficient way to do stuff.
Tommy Truong: What are instances that you've seen that, hey, this what you have today is gonna stifle your ability to grow.
Theresa Dobrash: let's see a lot in inventory management and sometimes in the. I think a better example is sales. So let's say you have been getting really busy and you decide we wanna implement these kiosks, and most of our business is gonna flow through these kiosks. That's probably, going to fit in your SOPs and not, you might not need to change them, but you might wanna look at, when you're checking IDs in your SOP to change that and make sure that kind of change can adapt to the volume of business that you see.
Tommy Truong: No, that is a really good example because that's true. Typically, you're checking IDs in the front, [00:19:00] but maybe you had it in the sale stage Also, I guess you're checking IDs twice. And if the second time you're not doing it, I don't know why you would be doing it twice, but I see what you mean.
does your SOPs if you're changing your sales flow are your existing SOPs current?
Theresa Dobrash: And it's, are they still gonna prevent you from risks too?
Tommy Truong: How often should somebody check to see if their SOPs are relevant today and are they're being followed?
Theresa Dobrash: I think once you've got those SOPs, you've got your team trained, and they're following them. You will know when there's a time for change. When you're considering, maybe you're gonna change point of sale systems or maybe your point of sale system has come out with a new feature.
Maybe that's the time to check on your SOPs if you've had a lot of turnover. If your team is, providing you some feedback that things are [00:20:00] impractical or they found a more efficient way to do stuff, if you are coming up with a lot of inventory discrepancies, you're having a lot of returns, probably the biggest one.
If you've ever had a audit. From the regulatory body, they've given you advice, or if you've had a compliance incident, that's a big time where you need to take a look at your SOPs and make sure you're protected from that risk.
Tommy Truong: Okay. I see.
Theresa Dobrash: Mm-hmm.
Tommy Truong: the person that's in charge of compliance definitely needs to be heavily involved in operations.
Theresa Dobrash: Yeah.
Tommy Truong: So your compliance officer should be there on the floor or, working in the business. It appears, and it shouldn't be somebody that's at head office, for example.
Theresa Dobrash: Definitely I've seen a lot of, different scenarios where there is a compliance department that, maybe it's a chain of stores, there's a compliance department that [00:21:00] they can't visit every store. So you generally can communicate with them via email, and in those scenarios your manager, your team should be, very heavily trained
And, the level of training I like to provide the teams. I think that would be suitable for having a compliance manager who may be remote or only stops in for audits every once in a while. But you're gonna need that compliance control available. And definitely part of day-to-day operations.
Tommy Truong: That makes sense. You mentioned earlier about the ABCs of compliance and I cut you off. I'm so sorry. I should ask this question because it's important, but let's talk about that. What are the ABCs of compliance?
Theresa Dobrash: Okay, great. I love the ABCs of compliance because I have a daughter, I'm teaching her the ABCs and everything is the ABCs to me right now. So we've talked about a accountability, talked about B boundaries.
Tommy Truong: [00:22:00] So can you speak a little bit more about boundaries?
Theresa Dobrash: okay. So yeah. There should be like events that trigger compliance question. Can we do this? Can we do that? Know the basics of your boundaries, you gotta check IDs, all that kind of stuff. Very basic stuff. And know, your limits on them, sales limits included. So that's boundaries. Did that make sense?
Tommy Truong: So there's certain thresholds that employees should know that this may be a compliance risk. What is the compliance risk for it? So IDs, sales limits, and et cetera.
Like compliance triggers, guess.
Theresa Dobrash: Yeah. Somebody says something. It should trigger, oh, this is a safety thing, or, oh. I learned about this in compliance
Tommy Truong: Do you recommend having a list of boundaries that employees should be aware of?
Theresa Dobrash: Checklists are great. [00:23:00] Keeping it simple for sure.
And same thing employees and also more of like the management level and ownership level. There should be some key. Lists of things that to keep out, keep an eye out for,
Tommy Truong: Gotcha.
Theresa Dobrash: and then I think c huge chain of custody. That's a big part of compliance is just preventing diversion. That's why it got started and became so complex. How do we prevent diversion for this product? We're creating a new market for it. Erasing the black market trying to put it on a legal market.
So tracing that chain of custody became a big deal, track and trace seed to sale, whatever we want to call it. Just not letting a single spec out of that chain of custody.
Tommy Truong: So what does that look like for a dispensary in a dispensary [00:24:00] environment?
Theresa Dobrash: Everything has to be recorded in your inventory management system. Sales have to go through your point of sale. In most states, including samples. So if you're gonna give your staff some samples, gonna do some research and development, most of the times that has to go through your point of sale.
And beyond sales and inventory, also in the receiving side. So I went backwards a little. When you receive products making sure that you've got that manifest, you've got that invoice and it goes into your inventory tracking system accurately.
Tommy Truong: Do you recommend when you're receiving product to have two people present?
Theresa Dobrash: Definitely. It's helpful for efficiency. It's helpful for accountability. Ken, our founding attorney, it rings in my head, have two sets of eyes on everything. Hmm. And that could be one of the areas of boundaries too, because if you are [00:25:00] receiving something that could be a compliance issue, if the manifest does not agree with the actual physical product being received, Right. And it leads me to D, which might be my favorite because I think it gives people a lot of confidence, which is documentation.
Tommy Truong: But did you document it?
Theresa Dobrash: did you document it? If there was an incident, you got some new inventory?
Is it documented? That's why my SOPs are a hundred pages. Very important. And I, like I said, I think it makes people a little bit more confident because if it's documented even if you don't know the answer, we could figure it out.
Tommy Truong: So what does, when would that occur? Can you give some examples of, is it just an incident or is it just an on anywhere that there are inventory, movement or potential risks? when does documentation matter? Like how do you, how would I train the sales [00:26:00] associates on when to document.
Theresa Dobrash: Documentation is really everything, every sale you conduct, you document it through your point of sale system. If someone is discussing something that doesn't feel quite right, but you don't know the answer to right off the bat, maybe you need to document that. May that be an adverse reaction?
That's probably the best example. Someone says, this product made me feel really ill. Different states handle this a little differently but you definitely want to document that you might wanna get that customer's phone number and if your manager's not available to handle it at that time, or you've never came across that issue before, you might wanna get that person's phone number so you can reach out to them and really resolve that complaint.
Tommy Truong: Is there a platform or software that dispensary owners should use for DOC documentation?
Theresa Dobrash: Definitely for complaint logging. Yeah. [00:27:00] I think most of the people I work with use, like Google but there's probably better ones that control that, that complaint a little bit better.
Tommy Truong: Which Google platform.
Theresa Dobrash: Just Google Sheets. Having a complaint log. That's probably the most basic is just a, Google Sheets complaint log or a Google form. So that, you can't really edit those responses or lose that data.
Tommy Truong: Shameless plug, you can use logs, right?
Theresa Dobrash: logs for Kay Push.
Tommy Truong: Yeah. Kind of
Theresa Dobrash: I was really hoping you would say that. That's wonderful. I love that. I'm excited. I wanna check it out.
Tommy Truong: Okay, I see. So it's really the ability to log in and I'm thinking about the perfect system is being able to categorize what it is,
The types of things that you're logging, being able to log in, then finding it. So being able to search, Hey, how common is this particular type of incident?[00:28:00]
Over the last year and, being able to pull that out.
Theresa Dobrash: I love that. That's great. Your point of sale systems. Kay. Push logs. Those are definitely important ways. Probably a lot better than Google Sheets for security.
Tommy Truong: So we have accountability, which is who's really ultimately accountable for compliance.
Theresa Dobrash: Boundaries.
Tommy Truong: Boundaries. Yeah. So what are some of the areas that you may be outta compliant? So what does that list look like? A checklist for the team. Then you have C, which is
Theresa Dobrash: Chain of custody.
Tommy Truong: chain of custody, which is everything needs to be really much, there needs to be a chain of custody with inventory.
So all the way through, we have to know. How much we receive all the way through selling and even returns, and then documentation.
there's one for every little alphabet right now.
really?
Theresa Dobrash: We don't have to go that far, but let's definitely talk about E, which is [00:29:00] enforcement. What are you gonna do when you get a surprise inspection? is your manager gonna freak out and have a panic attack?
are they gonna feel confident? Are you gonna drive two hours from your house, make the regulators wait for you to walk through that facility? And you know what happens if there's a serious infraction? You might need legal help to get through that. Enforcement is important
Tommy Truong: So what does, and I was gonna ask you this, you've probably been through so many audits in your career. What do regulators care about? What are the things that, as an operator, I need to make sure that I have my ts crossed, my i's dotted.
Theresa Dobrash: that you're adhering to the details, the plan that you gave them. So if you say on your application, you're open nine to five. And you're open 10 to 2:00 AM that's gonna be a problem. Just as an example. So adhering to all of those details that you [00:30:00] gave them, most jurisdictions, they make you tell them everything about your operations and you should adhere to that.
So if there's a change in operations, you have to submit it to the regulator. That's like f or floor plan, which we can talk next. Make sure your floor plan and you're abiding by that. That's pretty key. And then making sure that there's no serious issues going on. We all wanna ace our inspection, but the inspectors, even if they're gonna find something, no matter how little it is, no matter how many years in business you've been doing this, and they're gonna find a little something they wanna make you do better and help you do better.
Most of the times they're very supportive. But you definitely wanna make sure that there's no major issues, surveillance. Is probably huge if you don't have surveillance just close your doors for a little while until you get that call your surveillance guy in right away.
Most jurisdictions are gonna be really strict about making sure all [00:31:00] cannabis is visible on camera.
Tommy Truong: Are there a checklist, a common checklist that regulators look at no matter what, so they're probably looking at, Hey based on what you've submitted, Are you abiding by that? Do you have your surveillance? Do they do inventory checks? What are the things that you know for sure that they're checking when they come through that door?
Theresa Dobrash: Definitely yeah, there's definitely a checklist. And that's what. Yeah, that's when like having an experienced professional comes in handy or, having a good network and just oh, you were inspected. Tell me how did it go? What did they check you on? What was that list like? A lot of times that's passed down information.
they might not publish their audit checklist publicly.
Tommy Truong: But you know what, actually they probably published all of the incidents, right? So incident that previous audits and infractions and incidents [00:32:00] of dispensaries in your state. You might have that information and if you mind through that, maybe that's a good start.
Theresa Dobrash: Definitely, yeah. For recalls they'll post all the recalls, so make sure if someone else is getting recalled, for a similar thing that you're doing, definitely reevaluate. And yeah, a lot of times they will post it, especially if they didn't.
state it explicitly enough or they felt like they haven't trained their operators on it, they'll post a bulletin about it. So make sure you're getting all of those communications.
Tommy Truong: So you spoke a little bit about floor plan. Why is floor plan important?
Theresa Dobrash: That's a big infraction. So if you're, say for example, you were able to buy up the unit next to you, and you don't tell the regulators, Hey, we're expanding our floor plan. Big oops. More common than you'd think. Or, your floor plan's not [00:33:00] properly labeled another, issue.
What do you mean by properly labeled?
So on the floor plan, there's gonna be an area designated for each licensed activity. In most states, they're gonna wanna see that. So where your point of sale systems are, even if you expand and you get a third point of sale system, they're gonna wanna know that most of the times.
Tommy Truong: It seems like any change in your business, just pick up the phone, send him an email, let him know.
Theresa Dobrash: Yeah. That's why I say just document it and report, If you something as simple as another point of sale maybe you got a better vault for where you can store your cannabis.
Tommy Truong: What if you got another vault?
Theresa Dobrash: Yeah. If you got another vault, you're gonna have to tell 'em that too.
Tommy Truong: Wow. So what should, and I should have asked you this earlier when we were talking about enforcement how can somebody prepare for an Inspection? What should somebody do?
Theresa Dobrash: Mock audits, I [00:34:00] definitely recommend that. A lot of times, if I come in I'll use what I know the inspectors are looking at, which sometimes changes seasonally if they've got a new issue that's arising that they wanna make sure. It isn't widespread.
So a mock audit would be really good and,
Tommy Truong: you are, if you're doing a mock audit, and you've failed that mock audit. Do you document that?
Theresa Dobrash: I'm not gonna tell the regulators, hey, we're definitely, that's why it's a good internal control, having those internal controls that stop gap. Between you and having to disclose it to the regulators. Obviously there's some infractions that you are gonna have to disclose, like you've got a ton of inventory on hand that you can't trace back somehow.
Maybe it's just a missed sale, but if it's over a certain percentage, most jurisdictions you'll have to report that. But yeah, making sure you've got those internal controls in place [00:35:00] you don't have to have the regulators find out about it first.
Tommy Truong: Talk to sales associates and personnel to see if they understand, to just have conversations say, do you do this or that, or, walk me through a sale, or show me an inventory account.
Theresa Dobrash: Hello. I would say most of the times they're gonna stick with your management team. They're not gonna ask, unless they can do anything, but they might not, come to your brand new staff member and be like, how did they train you?
They might just stick with your management team and, Hey, manager, show me how you conduct sales.
Tommy Truong: Gotcha.
Theresa Dobrash: a point about that is they can conduct secret shopping. So that's why it's important, never laps up even on your front of the line. Whoever you're talking to could be a spy from the OCM.
Tommy Truong: That's so true. Wow. Okay, so we have, I don't think we have time to go through all of the letters, but the [00:36:00] remaining letters. What are the most important to you in terms of staying compliant?
Theresa Dobrash: In terms of staying compliant I'm gonna say as for standard operating procedures doing things the same way in a standard way over and over, and just standardizing it. It's gonna save you so much headache. A lot of times we're just like running to the next goal. We're sprinting, we're flying by the seat of our pants.
We have different staff members taking care of a specific responsibility and they do it differently. But just really standardizing that,
Tommy Truong: And I always thought about, okay, what's practical as an operator? would a good way to think about what to train your staff on and what to prioritize, be the types of client interactions. And the flow of inventory. What I mean by that is there's only so [00:37:00] many different types of interactions that you have at the door, what do you do at the door?
What do you do with customers on the floor? what is the communication like on the product? What can you say at the cash register? So there's only certain points of communication that you have with customers and the flow of inventory from receiving it all the way to storing it, all the way to counting it and then selling it.
Are those the points where an operator should focus on
Theresa Dobrash: Yeah, definitely. You've got it right there. Very rarely is there gonna be something, if you've been in business for long enough, it's gonna be rare that you come across something you haven't before. And then you're inventory system should be very routine.
There shouldn't be any surprises.
Tommy Truong: How often should somebody count inventory and what would, yeah. In [00:38:00] your opinion, what should that look like? Their inventory account strategy.
Theresa Dobrash: I have a really good system from managing dispensaries for a long time. that kind of depends also on your jurisdiction. The volume of business how much staff you have, et cetera, But it's definitely recommended, I think, to do it every day and just having a really efficient system in place for opening and closing your store.
Closing down your inventory in a similar way, you close down your cash drawer. So you know, when you count down your cash drawer, oh, it's up $50. We have this product here that's not matching physical inventory. If you do both of those checks, you can pretty much identify, oh, this person got the wrong product, or they were discharged.
And not only can it keep your inventory more accurate, keep your staff more accountable, you can have a better customer experience because instead of that customer. Having to call you or come back the next day and say, Hey, [00:39:00] something went wrong. You can call them and say, Hey, we already know something went wrong.
Let me fix it.
Tommy Truong: it.
Theresa Dobrash: Yeah.
So would that be where you prioritize end of day? Yeah.
Tommy Truong: Of that.
Theresa Dobrash: Knowing what was sold, it's more okay, for inventory reconciliation, it would be more likedid the inventory go away that we expected to go away physically on hand to what we sold or said We sold in the management system.
Tommy Truong: Gotcha.
Theresa Dobrash: sense. I said it more detailed.
Tommy Truong: Yeah. And would you recommend having also random inventory checks.
Theresa Dobrash: Yeah. Most of the times your jurisdiction may require you do monthly audits or weekly audits. You know that you gotta check what that timeframe is. So I don't know if necessarily if that's random, but if you're not doing so, [00:40:00] definitely abide by that audit timeline from your regulator. And if you're not doing nightly audits, random may come into play at that point.
Tommy Truong: Yeah, I was thinking of, let's say your regular needs you to recount all of the inventory every month. So you pick SKUs and it'll be random Tuesday. We're gonna do this. Away you go. And throughout the month everything's been counted.
Theresa Dobrash: Yeah, that's a great way to do it, I think rather than having one day where your inventory manager's like really stressed out, he's gotta count the whole building.
Tommy Truong: Yeah.
Theresa Dobrash: The floor is disrupted. Do a little bit randomly, little bit by little.
Tommy Truong: And it keeps things what I've heard was that you don't want predictability. If employees understand predictability, hey, you always count inventory on this day, then there's the risk of them planning something Does that make sense?
Theresa Dobrash: Yeah, [00:41:00] that's a good point. I think that's a really good point. That's very interesting. I'm interested in that.
Tommy Truong: Yeah, so it's just the more random you have, it keeps everybody, okay. We don't know what's gonna be counted on Tuesday. We don't know who's counting on Tuesday. And it's blind. I'm fascinated. By internal controls and internal efficiencies, and that's why this conversation to me is really fascinating because there's a fine line between what is practical, right?
What is not practical. So the more strict you are, the less practical it is, but the more accurate you are. And there's always a balancing act between that and the risk of not being compliant. And you always have, as an operator, you have to walk this fine line of being compliant, but making sure that it also is practical as well.
Theresa, thank you so much. Is, was there anything that we didn't go over that you feel, hey, we should definitely touch on.
Theresa Dobrash: no, this was [00:42:00] an awesome conversation. This was great. I think we gave people a lot of tools to compliantly operate and, feel confident in their dispensary operations and, go get it.
Tommy Truong: Before I let you go, how can our listeners find you?
Theresa Dobrash: Oh. So you can find me on LinkedIn. I push a lot on LinkedIn, a lot of free resources for the markets we focus on in California and New York. You can email metheresa@seligsonlaw.com?
Tommy Truong: We'll drop your handle in the body of the pod when we release it. Thank you so much for coming today.
Theresa Dobrash: Thank you for having me. I'm really excited for KayaPush.
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