Delivery is truly a mixed bag (pun intended 🙂 ). Some states allow it, some are rolling it out, others are taking a wait and see approach. The constant—a lack of standards and lots of holes in current processes. With first-hand experience of the delivery process in California and Nevada, I was left reminded of the days before legalization. There was no means to confirm that who placed the order, received the order—the chain of custody. Nothing more than a cursory ID check in NV (none in CA) and transfer of product—curb-side through the car window. A new-fangled drug deal?
Let’s add into the mix the demand for accelerated delivery implementation because of the COVID pandemic and we have the ingredients for a lot of unintended consequences—not all of the good variety.
When the experience is articulated in simple and concise terms, it’s hair-raising, business, and the customer experience cringe-worthy. Having engaged in the working sessions around drafting regulations for delivery, the discussion was focused on how to overlay existing dispensary processes onto delivery. Why would we apply oversight of a controlled environment (dispensary) to an open environment (delivery)? What is the common thread in the process, beyond the product itself?
- Process Hole
The advantages of a physical facility include the ability to control a large percentage of environmental variables, contain the customer purchase process flow and confirm procedures are being followed. None of which matter with delivery. The infrastructure to facilitate the front end of the delivery—online or phone ordering—has a couple of significant holes that impact safety and security. The chain of custody begins with the order. How is age verified at the point of order? Perhaps clicking ‘yes I’m 21” on the website or app, or uploading a photo ID, or maybe storing a picture of the ID in your POS system? Actually, none of these produce a secure chain-of-custody. This gap is easy to address with technology. It is possible to create a secure online purchase process that requires identity validation and age verifiable before completing the online order, which then can be technically matched with the individual at the point of delivery—true chain-of-custody. Closing the biggest holes in current processes. It can even track the identity of the packing and delivery personnel to boot. Assuming the purpose of delivery is at least 2-fold (3-fold considering COVID restrictions): 1) consumer convenience, 2) retailer efficiency, and 3) reducing points of contact for transmission risk reduction. It is imperative that chain-of-custody and safety take priority without undermining convenience in its application.
- Regulatory Hole
From a practical standpoint, current age and ID verification requirements are not being fulfilled at the point of online ordering, and controls at the point of delivery are fragile and exposed to a trove of human error. This is due in part to the explosive growth, rate of change the industry has experienced, and a case of “not knowing what we don’t know”—or having the bandwidth to think through an entirely new delivery channel system. The implementation of PII compliant digital, dual-key identity validation and age verification system plugs this hole with a closed-loop chain-of-custody process, and more importantly, protects you and your customers from identity theft risks associated with data breaches. Breaches like those experienced by firms such as THSuite or MJ Freeway are the tip of an iceberg. With physical on-site security being the primary focus as the industry grew, many regulatory authorities haven’t been able to get a handle on the vast differences in a physical versus distributed chain of custody and product transfer procedures.
While a great deal of work has gone into the development of regulatory guidelines, a lot has been done by way of trial and error. As most have experienced, this leads to what feels like a constant series of changes, updates, and new guidance that impacts the whole operation. Being a ‘new’ industry that is not federally acknowledged and regulated at the state level has brought us to crossroads—lead in establishing standards or stay on the treadmill of real-time trial and error and all the economic impact that comes with the approach. Developing regulatory process standards proven in other industries from an applied perspective with an eye toward exceeding current standards will help the industry as a whole, therefore increase credibility, improve profitability, and a trusted and comfortable consumer experience.
The first step to the successful deployment of a new delivery channel is recognizing the key differences it represents to business operations and anticipating or exceeding the regulatory challenges that will ensue. Self-developing an increased level of consistency and rigor in security, safety, auditing, and traceability benefits every stakeholder, current, and future.