Maine Track and Trace - Introduction & Overview

Maine is progressing towards their regulated Adult Recreational and Medical cannabis track-and-trace program. The OMP will be the agency regulating this environment. The state has selected BioTrackTHC as their software vendor.

Track and Trace Crash Course

Track-and-Trace, also called Seed-to-Sale, is the documented accounting for nearly everything in the production process of cannabis.

Each inventory-lot of Seeds or Clones will have an Government Unique Identifier assigned to that lot, representing some quantity of material.

Each Plant (as determined by the legislation (eg 12 inches tall)) that is created from these Source material lots will have an identifier for it. One identifier per Plant. Be prepared for lots of busy work tagging plants and then checking those tags at every next step.

When materials are collected from these trees -- regardless of class of material (eg: A-Grade, B-Grade, Waste) -- it will be tracked. These large bulk lots of material (in BioTrack they are called "Flower" and "Other Material") will have an identifier representing this bulk-net weight of material collected from one (or more) plants.

Next, these materials are sorted into Production Lots. Flower Lots will have a weight limit of XX pounds (YY grams) and must be tested by a Laboratory before being sold. Other Material Lots will have a weight limit of XX pounds (YY grams) and can be sold without testing.

These Flower Lots and Other Material Lots may be further processed, via Conversion, by the business into various intermediate or retail-packaged products. Bulk oils, hash, keif, rosin, CO2 Extract and others are considered this class of bulk processing materials.

Flower Lots are the material that becomes Usable Marijuana in the system -- that is packaged flower, or pre-rolls. This Usable Marijuana, along with another packaged class of products, are sold to a retail store/dispensary.

This B2B sales process is executed through the BioTrackTHC system provided by OMP. The selling licensee will create the Transfer Manifest and the buyer will find this electronic record in their system to accept. During this process each party will be responsible to double check the work of the other party. Each will review the quantities described, product descriptions and pricing.

A Rollout Story

We've observed, or directly participated in the early stage of cannabis regulation in many states. No introduction of seed-to-sale has gone smoothly but, they seem to get a little better each time.

There is a lot of new material for everyone involved to learn. New legislation to permit state business to directly violate federal statues. New oversight-agencies, with these new laws, are learning an entirely new class of operations which they need to regulate. New technology for the agency and the businesses which everyone must integrate with. New regulations for businesses, from the new agency, with the new laws to match with their new work-flows and changing business model. New regulations at the county and city level as well.

All that NEW creates a, lets say dynamic environment. Policy, procedures, board-rulings, city and county laws -- all these things will be changing rapidly in the first few months (years?). These regulations are built into the track-and-trace platform which means that new technology is directly touching your business workflow.

Business feedback will shape OMP policy, that will change their software, which will change business workflow. Industry associations will form, and lobby the legislators to modify the laws and create another cycle of policy and technology. This cycle will repeat many times before there is some stability. Sure, there is an advantage for going first -- but also some advantage to maybe going second (or third).

If you choose to go first, be prepared to spending a lot of time figuring things out. You will likely have to go much slower than you'd expect. You may even be completely blocked waiting on OMP to define policy or for their software vendor to make modifications.

Further Information

The best source of information is, naturally, the agency that oversees the entire operation, for Maine that's OMP. Get on their mailing list, subscribe to their announcements and pay attention to their meetings.

Our observations are that both OMP and BioTrack are making good efforts to get out and educate the population. Making it to at least one of these events is critical.