New York’s Cannabis Retail Dispensary Regulations, Part 3: Hiring and Training Your Employees

As we previously broadly summarized on October 31, 2022, the Office of Cannabis Management (OCM) released its “Guidance for Adult-Use Dispensaries” (the Regulations) on Friday, October 28, 2022. The Regulations provide guidance for Conditional Adult-Use Retails Dispensary (CAURD) licensees and applicants. Last week, at a hearing with the Cannabis Control Board, it was announced that 36 CAURD applicants were granted a license.

The information contained in the Regulations is a mix of substantive requirements, operational guidance and insight into the OCM’s plans for the issuance of licenses and operation of New York’s cannabis industry. As part of our series explaining and detailing the Regulations, this post is to provide licensees with guidance on the best practices for training employees working at your retail dispensary. Of course, this post cannot go into each and every detail of the Regulations; however, it should serve as a basis for your knowledge going forward. As usual, we encourage you to review the Regulations and consult with an attorney.

Employee Hiring

First and foremost, a Licensee cannot hire anyone under the age of eighteen (18) and only workers who are at least twenty-one (21) years of age can have direct interactions with customers inside the

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