On October 27, 2019, the California Department of Public Heath’s Manufactured Cannabis Safety Branch (CDPH) issued a notice stating that it is permissible for cannabis businesses who lose access to California Cannabis Track-and-Trace (CCTT-Metrc) as a result of the PG&E power shutdowns to continue operating. This permission is subject to two conditions:
maintaining comprehensive off-line records regarding all activities during the power shutdown; and
entering the records into the CCTT-Metrc system within three days of power being restored.
Additionally, if a company loses access to CCTT-Metrc for more than 72 hours, such loss must be reported to the CDPH. In the report to CDPH, an affected business must include the following information:
Date and time when access to the CCTT was lost;
Cause of loss of access;
Best contact information.
Even if you are not sure if you will lose power, if there is a chance you will, taking a few minutes and figuring out a system for maintaining your records offline for future input into CCTT-Metrc in case you do lose power will be well worth it. If you lost power during the last shutdown and did not have a system in place, or if in the future you find yourself in a situation where you do not have records of activities that took place during a power outage, contact counsel as soon as possible.