As of this Thursday, December 5th, Ballot Measure 119 requires all OLCC licensed retailers, processors and labs to provide a signed labor peace agreement (LPA) with a bona fide labor organization, to renew or apply for an OLCC license.
In the totally avoidable, unduly compressed timeline since BM 119 passed, we have been advising our Oregon cannabis clients to renew their license applications ahead of the December 5th deadline if possible. Same deal for new applicants– get everything in before the deadline. This will allow qualifying businesses to avoid the LPA issue for another year (or maybe forever, if the courts get ahold of BM 119).
OLCC marijuana licensees are required to renew their licenses annually. Licensees are notified 90 days prior to their license expiration date that it’s time for license renewal. According to my wizard paralegal, this notice automatically posts in CAMP, which is the OLCC’s online licensing software. Specifically, a licensee will receive an “Actions Required” notification on their dashboard.
OLCC has confirmed that licenses set to expire after December 5th, will not require an LPA submission until the following year’s renewal, provided that the license has been renewed prior to the December 5th deadline. Same deal with any new license applicant. To that point, OLCC’s most recent BM 119 Bulletin is here. It answers some basic questions and contains no surprises.
OLCC also recently Updated its Labor Peace Agreement Attestation Form. This is a form that applicants may submit in lieu of actually filing their LPA with the Commission. Somebody asked me what the repercussions might be if they were to submit this form without having a signed LPA in place. The short answer is “don’t do that.” The longer answer is that there are many administrative rules dealing with “false statements”, “material false statements” and the submission of “false or misleading information” to OLCC. License revocation or non-renewal is a real possibility there.
For more information on this topic, the Cannabis Industry Alliance of Oregon has a guide here, and has been sending out helpful emails on its listserv (you can sign up for those here). The relevant OLCC materials are linked above, and I’ll provide links to our previous posts on this topic just below. For now, get those license renewals and applications in!
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