Delivery Rules

What rules apply when you deliver cannabis from your dispensary to a customer?

Delivery is part of retail operations.
OCM applies the same retail rules to delivery that apply inside the store, plus additional requirements for drivers, identity checks, tracking, and security.

If you offer delivery, you must follow all of the requirements below every day.

Who Can Deliver

Delivery must be completed by your employees only.

No contractors
No gig workers
No third-party courier companies

All delivery staff must be W-2 employees on your payroll.

All delivery staff must be properly trained on:

ID verification
Safety procedures
Recordkeeping and documentation

If someone is not your employee, they cannot touch or transport cannabis for your dispensary.

Vehicle and Transport Requirements

Cannabis must be transported in compliance with your approved security plan.

Requirements include:

Cannabis stored in locked compartments or secured containers
Product kept out of public view
No access by unauthorized persons
Vehicles must match those approved in your security plan
Cannabis may not be stored in vehicles overnight
Drivers may not make unapproved stops
Cannabis may not be left unattended

Unsecured or visible cannabis is treated as a diversion and security violation.

Order Verification and Customer Requirements

Delivery is only permitted to eligible customers.

You must:

Deliver only to customers 21 and over
Check a valid government-issued ID at delivery (not just online)
Hand off cannabis only to the person who placed the order

Cannabis may never be left with:

Doormen
Front desks
Neighbors
Unattended locations

Additional rules:

Deliver only to the address entered at checkout
No rerouting or alternate locations
If ID cannot be verified, cancel the order and return it to the store

Delivery Limits and Prohibited Activity

All standard retail limits apply to delivery.

You may not:

Add items or modify orders at the door
Conduct additional transactions at delivery
Offer promotions or discounts that violate OCM rules

Delivery is prohibited to:

Public parks
Playgrounds
Schools
Transit stations
Federal property

Delivery Logs and Tracking

Delivery activity must be logged at every step.

Logs must include:

Customer name
Delivery address
Products and quantities
Batch or lot numbers
Driver name
Time out and time delivered
Failed delivery attempts
Returned products

All logs must be stored on-site and immediately available for inspection.

Handling Returns During Delivery

Returned or refused items must be handled as regulated inventory events.

You must:

Log the return
Return products to the store immediately
Place returned items into quarantine or waste
Enter the event into the inventory system before the end of the day

Cash Handling During Delivery

If accepting cash at delivery, your SOP must clearly define:

How cash is stored during transport
How cash is returned to the store
Who reconciles and verifies cash

Cash must remain locked and secure at all times.
Drivers are not mobile ATMs.

Safety and Incident Requirements

Drivers must be trained to:

Avoid unsafe delivery locations
Stop delivery if they feel unsafe
Document and report incidents immediately

OCM and law enforcement may review:

Delivery logs
Incident reports
Security footage

At any time.

Inspection Rights

OCM may, during an inspection:

Inspect delivery logs
Interview delivery drivers
Check delivery vehicles and storage
Review delivery SOPs
Compare delivery activity against POS and inventory records

Delivery is part of your retail inspection, not a separate process.

Why This Matters

Delivery violations can result in:

Diversion
Sales to minors
Inventory discrepancies
Custody and security failures

Which can lead to:

Fines
Stop-sale orders
Suspension of delivery privileges
License risk or loss

Delivery must be treated as a core compliance function, not an add-on.

Source Material

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