Bulletin | COVID-19 Agent Reporting Requirements | January 25, 2021

To: Marijuana Establishments and Medical Marijuana Treatment Centers licensed pursuant to 935 CMR 500.000 and 935 CMR 501.000
From: Shawn Collins, Executive Director
Date: January 25, 2021
Subject: COVID-19 Agent Reporting

The Cannabis Control Commission (the “Commission”) issues this Bulletin to all Marijuana Establishments and Medical Marijuana Treatment Centers (collectively, the “licensees”) to clarify requirements regarding COVID-19 Agent Reporting.

The Commission’s Amended Administrative Order Allowing Curbside Operations requires licensees to monitor and comply with all Commission-issued guidelines and bulletins. Consistent with 935 CMR 500.105(1)(r) and 935 CMR 501.105(1)(r), licensees must have and follow written operating procedures promoting workplace safety, which includes protocols addressing COVID-19 (Coronavirus). Licensee COVID-19 Standard Operating Procedures should include reports to the Commission of any instance of an employee work-related illness resulting in a confirmed COVID-19 case immediately after obtaining actual knowledge of a confirmed case, but in no event later than twenty-four (24) hours. Licensees are to report this information using the Agent COVID-19 Reporting Form on the Commission website.

The Commission has learned that licensees are unclear about the meaning of “employee work-related illness” for purposes of reporting agents who have tested positive for COVID-19. Licensees are advised that the term “work-related illness” means an illness that affects an employee or workplace, or that poses a risk of transmission between employees or within the workplace. The phrase “work-related illness” does not mean “work-caused illness.” In order to protect the public health, safety, and welfare, the Commission expects licensees to report all cases in which a Marijuana Establishment or Medical Marijuana Treatment Center Agent tests positive for COVID-19.

Further information regarding COVID-19 and agent reporting can be found on the Commission webpage dedicated to COVID-19. Licensees are also advised and encouraged to consult the Commonwealth’s guidance for businesses. Licensees may also direct questions about this Bulletin to their assigned Investigator or Compliance Officer, or to Inspections@CCCMass.com.