Operating Requirements and Inspections
NYCRR Title 9, Part 125
Part 125 sets the day-to-day operational standards every adult-use cannabis licensee in New York must follow. These are the rules inspectors use when evaluating whether your business is operating legally.
This section covers safety, sanitation, security, inventory tracking, transport, waste, inspections, and recordkeeping. These are not optional guidelines. They are enforceable requirements.
What This Covers
- Operational standards inspectors enforce
- Required plans, systems, and procedures
- Security, sanitation, and inventory rules
- Transport and waste requirements
- Inspection, audit, and recordkeeping obligations
Energy and Environmental Standards (125.1)
Licensees must operate in a way that reduces environmental impact.
Requirements include:
- Using efficient lighting, equipment, and HVAC where required
- Following water-use and waste-management rules
- Complying with any sustainability requirements set by OCM
- Maintaining documentation showing compliance when requested
Site and Operating Plans (125.2)
Every licensee must maintain written plans explaining how the business operates.
Plans must cover:
- Site layout and workflow
- Security procedures
- Waste disposal methods
- Environmental and sanitation practices
Plans must be updated when operations change. OCM may review or require revisions at any time.
Security and Storage of Cannabis (125.3)
Cannabis must be protected from theft, diversion, and contamination.
Core requirements:
- OCM-approved cameras, alarms, and access controls
- Locked, restricted storage areas
- Organized and traceable storage systems
- Immediate reporting of security incidents to OCM
Employee Requirements and Training (125.4, 125.5)
Employees who handle cannabis must meet minimum standards.
Requirements include:
- Employees must be at least 21 years old
- Training must be completed before handling cannabis
- Training must cover compliance, safety, security, and contamination prevention
- Refresher training is required
- Licensees must maintain employee records and training logs
Worker Health and Safety Standards (125.6)
Licensees must protect workers from unsafe conditions.
This includes:
- Providing protective equipment when required
- Following ventilation and air-quality rules
- Handling chemicals safely
- Maintaining injury-prevention programs
- Recording and reporting workplace injuries as required by law
Sanitary Facility, Equipment, and Handling Standards (125.7)
Facilities must be clean and sanitary at all times.
Requirements include:
- Regular cleaning and sanitizing of equipment
- Preventing contamination of cannabis
- Maintaining hand-washing facilities
- Enforcing hygiene standards
- Documenting cleaning schedules and procedures
Inventory and Tracking (125.8)
All cannabis must be tracked from receipt through sale or disposal.
Licensees must:
- Use the state seed-to-sale tracking system
- Log all movements, adjustments, transfers, and waste
- Investigate and report discrepancies
- Ensure records match physical inventory
Quarantine and Recalls (125.9)
Unsafe or noncompliant cannabis must be isolated immediately.
Requirements include:
- Quarantining expired, damaged, mislabeled, or failed products
- Following OCM recall procedures when required
- Maintaining detailed quarantine and recall logs
Transport of Cannabis (125.10)
Cannabis transport is tightly regulated.
Requirements include:
- Using authorized vehicles and registered drivers
- Maintaining transport manifests
- Keeping cannabis locked and out of public view
- Reporting transport incidents to OCM
Management of Cannabis and Other Waste (125.11)
Cannabis waste must be destroyed so it cannot be reused or diverted.
Requirements include:
- Mixing cannabis waste with non-cannabis waste
- Documenting all destruction events
- Securely storing waste until destruction
- Following environmental and hazardous-waste rules
Inspections and Audits (125.12)
OCM may inspect or audit any licensed business at any time.
Key points:
- Inspections may be unannounced
- Licensees must provide full access to premises, records, and inventory
- Failure to cooperate can result in enforcement
General Recordkeeping Requirements (125.13)
Licensees must maintain complete and accurate records.
Records must cover:
- Purchases and sales
- Employees and training
- Security systems
- Inventory and waste
- Transport and incidents
Records must be organized, accessible, and retained for the required period.
Internal Quality Control Samples (125.14)
Processors may create internal samples for quality control.
Conditions include:
- Samples must be logged in the tracking system
- Samples may not be sold or given to consumers
- All safety and contamination rules apply
Consumption Facilities (125.15)
Additional rules apply to licensed consumption areas.
Requirements include:
- Age restrictions and access controls
- Ventilation and safety standards
- Inventory tracking for consumed cannabis
- Procedures to prevent overconsumption and impaired driving
Licensed Premises Verification Tools (125.16)
Licensees must verify other licensees before transfers.
Verification tools may include:
- OCM databases
- QR codes or online verification systems
This prevents diversion and illegal market activity.
What Operators Usually Miss
- Plans must stay current, not just submitted once
- Logs are inspected as closely as physical spaces
- Training gaps are violations
- Inventory errors escalate quickly
- Inspectors rely on Part 125 as their checklist
When This Comes Up
- Daily operations
- Staff onboarding and training
- Inventory management
- Transport and waste handling
- Inspections and audits
What Happens If You Ignore This
Violations may result in:
- Written violations and fines
- Product quarantine or destruction
- License suspension or revocation
- Failed renewals
- Increased inspection frequency
Related Pages
Source Material
