Diversion Control Division, US Department of Justice, Drug Enforcement Administration

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Marihuana Growers Q&A

Marihuana Growers

Question: What size of vault is needed for a Bulk Marihuana registration?

Answer: The size of the vault or safe is determined by the applicant in accordance with the requirements of 21 CFR 1301.72(a). This provision explains the requirements for safes or vaults of various sizes, including the specifications for minimum times required to obtain various types of entry, requirements for securing or constructing the safe or vault, and alarm and electronic monitoring requirements.

In selecting a safe, the applicant should bear in mind that, under the Memorandum of Agreement executed between the Drug Enforcement Administration (DEA) and each registered bulk manufacturer of marijuana, a registered grower must demonstrate to DEA's satisfaction that it can prevent the commingling of marihuana stocks owned by DEA on behalf of DEA with stocks of marihuana that DEA has subsequently distributed back to the grower pursuant to a DEA-issued procurement quota. EO-DEA234, October 28, 2021

Question: What type of fencing is needed for a Bulk Marihuana registration?

Answer: DEA requires that applicants and registrants provide effective controls and procedures to guard against theft and diversion of controlled substances set forth in 21 CFR 1301.71. Title 21 CFR 1301.73 requires that manufacturers securely lock processing areas for in-process substances where the process cannot be terminated at the end of each workday, with adequate security for the area or building. If alarms are required, they must alert a 24-hour monitoring station. 21 CFR 1301.72–1301.76 set forth the security requirements the standards for the physical security controls and operating procedures necessary to prevent diversion. Materials and construction which will provide a structural equivalent to the physical security controls set forth in 21 CFR 1301.72, 1301.73 and 1301.75 may be used in lieu of the materials and construction described in those sections. EO-DEA234, October 28, 2021

Question: What type of starting material can be used and where can I obtain it?

Answer: Applicants determine what starting material they need and how to obtain it. EO-DEA234, October 28, 2021

Question: If starting material is imported, do I need a DEA import registration?

Answer: If the starting material is a controlled substance then a DEA import registration is required. EO-DEA234, October 28, 2021

Disclaimer: Guidance documents, like this document, are not binding and lack the force and effect of law, unless expressly authorized by statute or expressly incorporated into a contract, grant, or cooperative agreement. Consistent with Executive Order 13891 and the Office of Management and Budget implementing memoranda, the Department will not cite, use, or rely on any guidance document that is not accessible through the Department's guidance portal, or similar guidance portals for other Executive Branch departments and agencies, except to establish historical facts. To the extent any guidance document sets out voluntary standards (e.g., recommended practices), compliance with those standards is voluntary, and noncompliance will not result in enforcement action. Guidance documents may be rescinded or modified in the Department's complete discretion, consistent with applicable laws.

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