Commencement Inspections

Licensees must request and pass a commencement inspection before they may do any of the following:

  • Begin operations under a new license/certification or new location.
  • Occupy or utilize new space for which the licensee has not previously received approval to operate, including vehicles.
  • Share space with another licensee located at the same facility.
  • Change the use of spaces within their facility.
  • Begin cultivating or manufacturing where that activity was not already approved after inspection (microbusiness wholesale facilities only). 1

Licensees should also be aware of the following requirements related to commencement inspections.

  • For new license/certification and new locations, the licensee must be within 30 days of being ready to begin operations before they request their commencement inspection. 2
  • Licensees may not commence any operations that are subject to a commencement inspection without written approval from the Department. 3

Instructions

To request a commencement inspection, a licensee must submit the following documentation to the Facility Development Team at CannabisCompliance@health.mo.gov. Include in the Subject line: Licensee Name, License Number CI request.  For shared space requests, each licensee must submit a request to share the space. 

  • Commencement Inspection Request.
  • Blueprint of the facility/vehicle.
  • Applicable checklist.

Documents

Process

The general licensee process for a commencement inspection includes the following:

  1. The licensee gathers all necessary documentation, including blueprints of the facility. The blueprints must be labeled with the room names, intended use of all spaces, and how those spaces comply with the physical security requirements applicable to them.
  2. The licensee requests a commencement inspection through CannabisCompliance@health.mo.gov, including commencement inspection request, blueprint of the facility/vehicle and applicable checklist.
  3. Licensee begins work on the change. New license/certification or new location are not required to submit request prior to beginning work.
  4. After the licensee has completed the change, the licensee notifies their Facility Specialist that the change requested is ready for inspection.
  5. A virtual or physical inspection is completed. If a physical inspection is required, the licensee's Compliance Officer contacts the licensee to schedule and complete an inspection.
  6. After the inspection is completed and compliance with the rule is confirmed, an Approval to Operate letter is sent via email to the designated contact for the license.

For questions regarding commencement inspections, email CannabisCompliance@health.mo.gov.

1 19 CSR 100-1.030(3)(A) Licensees must request and pass a commencement
inspection before they may do any of the following: begin
operations under a new license or certification; occupy or
utilize new space for which the licensee has not previously
received approval to operate, including vehicles; share space
with another licensee; change the use of spaces; or, in the
case of microbusiness wholesale facilities, begin cultivating or
manufacturing where that activity was not already approved
after inspection.

2 19 CSR 100-1.030(3)(A)1 Requests to begin operations under a new license or
certification or new location after change request is approved
must be submitted when the licensee believes it will, within
thirty (30) days, be ready to begin operations at the facility

3 19 CSR 100-1.030(3)(D) Licensees may not commence any operations that are
subject to a commencement inspection until the department
issues written approval to do so.