New York operators are facing OCM inspections on a schedule that doesn’t wait for anyone to catch up. I’ve sat in on enough compliance conversations to know the answer people give first isn’t usually the true one.
Ask a facility manager if they’re ready for an OCM inspection and most will say yes. Ask a follow-up question: when’s the last time someone actually walked the SOPs against what’s happening on the floor, and you’ll get a pause.
That pause is the answer.
An inspection isn’t really about the binder. Anyone can build a binder. What OCM is checking is whether the binder matches reality: whether the batch records reflect what actually happened in that batch, whether the recall procedure you’d pull out in an emergency is the one your team was actually trained on, whether the signature on last Tuesday’s cleaning log means someone was actually in the room last Tuesday.
Not to mention the obvious, but all too often number one mistake I see during these compliance inspections: are the plants and products tagged and labeled and does the physical inventory match the METRC inventory.
Where Gaps Come From
And here’s the thing about compliance gaps, they rarely come from someone trying to get away with something. They come from growth. A facility that was doing 200 units a month a year ago is now doing 2,000, and somewhere in that scale-up, a process shifted a little and the SOP didn’t shift with it. Or the person who used to sign off on equipment calibration left, and the new hire wasn’t looped in on the exact protocol. Or METRC entries got a little behind during a busy stretch and nobody circled back to reconcile them.
None of that is malicious. All of it is exactly what an inspector is trained to find.
This is the part of the business we live in at Bay Kinetic. We go through documentation the way an inspector would from:
- SOPs
- Batch production records
- Chain of custody
- Security protocols
- Training records
- GMP Certs
- METRC records
All of it; and we flag what wouldn’t survive a close look. Sometimes that’s a rewrite. Sometimes it’s just tightening language so it actually matches what’s happening on the ground. Sometimes it’s realizing a whole category of records hasn’t been touched in months or even created or thought about.
The operators who come out of an inspection clean aren’t the ones with the fanciest paperwork. They’re the ones who did this work before the knock on the door, not after.
If you’re not sure where your gaps are, that’s usually the first sign you have some. Let’s find them before OCM does.