HomeMy WebLinkAboutCSE-20-64 Triple E Lab RedactedApplication Type
Social Equity Criteria
Applicant (Entity) Information
Social Equity Cannabis Business
Permit Application
CSE-20-64
Submitted On: Nov 13, 2020
Applicant
Tara Gray
5594417929
taralynngray@fmbcc.com
In order to qualify as a social equity applicant, applicants must
satisfy at least one of the following criteria:
1. Low income household and either:
a. A past conviction for a cannabis crime, or
b. Immediate family member with a past conviction for a
cannabis crime.
2. Low income household in a zip code identified as at least
60% according to the CalEnviroScreen for five (5) consecutive
year period and either:
a. A past conviction for a cannabis crime, or
b. Immediate family member with a past conviction for a
cannabis crime.
3. Low income household and either:
a. Five (5) years cumulative residency in a zip code identified as
at least 70% according to the CalEnviroScreen, or
b. Ten (10) years cumulative residency in a zip code identified
by CalEnviroScreen.
4. Business with no less than fifty-one percent (51%) ownership
by individuals who meet Criteria 1 and 2 above.
5. Cannabis social enterprise with no less than fifty-one percent
(51%) ownership by individuals who meet Criteria 1 and 2
above.
6. An individual with a membership interest in a cannabis
business formed as a cooperative.
Do you meet the above criteria, and want to apply as a Social
Equity Applicant?
Yes
Please state your annual income:Do you have a past cannabis conviction?
No
Do you claim eligibility based on a family member past
cannabis conviction?
No
Do you represent a cannabis social enterprise?
Yes
Do you have a membership interest in a cannabis cooperative?
No
Application Type
Proposed Location
Supporting Information
Applicant (Entity) Name:
Fresno Metro Black Chamber
DBA:
--
Physical Address:
1444 Fulton Street Ste 206
City:
Fresno
State:
CA
Zip Code:
93721
Primary Contact Same as Above?
Yes
Primary Contact Name:
James Archie
Primary Contact Title:
Board Director
Primary Contact Phone:
559-441-7929
Primary Contact Email:
james@fmbcc.com
HAS ANY INDIVIDUAL IN THIS APPLICATION APPLIED FOR
ANY OTHER CANNABIS PERMIT IN THE CITY OF FRESNO?:
No
Select one or more of the following categories. For each
category, indicate whether you are applying for Adult-Use (“A”)
or/and Medicinal (“M”) or both
Medicinal
Please make one selection for permit type. If making multiple
applications, please submit a new application for each permit
type.
Permit Type
Testing
Business Formation Documentation:
Corporation
Property Owner Name:
--
Proposed Location Address:
--
City:
--
State:
--
Zip Code:
--
Property Owner Phone:
--
Property Owner Email:
--
Assessor's Parcel Number (APN):
--
Proposed Location Square Footage:
--
List all fictitious business names the applicant is operating under including the address where each business is located:
Fresno Metro Black Chamber of Commerce 1444 Fulton Street Ste 206, Fresno, CA 93721
Business Name: Triple E Lab SOCIAL EQUITY APPLICANT - IF SUBMISSION REQUIREMENTS MET, APPLICATION PASSES
Application #: CSE-20-64 ADVANCEMENT IS NOT BASED ON PHASE II SCORE PER APPLICATION PROCEDURES.
CANNABIS BUSINESS PERMIT APPLICATION REVIEW - TESTING Points
Possible
All or
None Exceptional Good Acceptable
Applicant
Score
Evaluation Notes (Explain each time points are
deducted)
SECTION 1: BUSINESS PLAN 300 Points Possible for Section 1
Resume:
Resumes Provided for All Owners: Score 5 5 5
Resumes Provided in 2-page Format: Score 2 2 2
Education: (select highest academic level among ownership team, cannabis specific education
separately)
Cannabis specific education/training (accredited)2 2 -
High School Degree Reported: Score 4 4 -Education not mentioned for Owner
Bachelor's Degree Reported: Score 6 6 -
Master's Degree or Higher Reported: Score 8 8 -
Experience: (among ownership team, select one at highest level)
Cannabis Testing Facility Ownership Experience CA (ISO/IEC 17025 accreditation?)13 13 -
Cannabis Testing Facility Experience CA (management level or below): Score 10 10 -
Other Business Experience (cannabis or laboratory) Reported, More than 5 years: or 8 8 -
Other Business Experience (cannabis or laboratory) Reported, Less than 5 Years: Score 5 5 -
1.1 Sub-Total:30 7
Construction Cost Estimate:
Construction Cost Estimate Provided: Score 8 8 6 4 6 Renovations listed as line item, not very detailed
Construction Contingency Factor Included: Score 6 6 0 None listed
All Labor, Trades, Materials, Supplies and Permits and other Cost Factors Identified: Score 6 6 4 2 4 Some costs listed, no details
Reference Data Provided for Unit Cost Factors: Score 5 5 3 1 0 No reference data listed
Operation and Maintenance Cost Estimates:
Operation and Maintenance Cost Estimate Provided: Score 8 8 6 4 6 Figures listed but not explained, no detail
All Labor, Trades, Materials, Supplies, Utilities, and other Cost Factors Identified: Score 6 6 4 2 4 Figures listed but not explained, no detail
Annual Cost Escalators for Operating Costs Provided: Score 6 6 4 2 2
Some figures listed as increasing but nothing
explained
Reference Data Provided for Unit Cost Factors: Score 5 5 3 1 0 No reference data listed
1.2 Sub-Total:50 22
Proof of Capitalization Specific to one or more Owners: Score 5 5 -
No proof of capitalization specific to any of the
named owners/stakeholders
1.1 Owner qualifications. Resumes are not to exceed two (2) pages per owner. (30 points possible)
1.2 A budget for construction, operation, and maintenance, compensation of employees, equipment costs, utility cost, and other operation costs.(50 points possible)
1.3 Proof of capitalization in the form of documentation of cash or other liquid assets on hand, Letters of Credit or other equivalent assets which can be verified by the City. (50 Points Possible)
Criteria Narrative: Owner's experience is as a contractor. Management team has business experience, chemisty education/experience, financial expertise
Criteria Narrative:
Proof of Capitalization Specific to Business Name/Address: Score
5 5 5
Proof of capitalization is in the name of Fresno
Metropolitan Black Chamber of Commerce which is
also listed as the applicant name/ but they are
listing Triple E labs as the proposed buisness name.
No proposed address as of yet.
Proof of Capitalization Sufficient to Cover Proforma (3 months) and Construction Costs: Score
15 15 0
Proof of capital bank and
credit line, but proposed numbers for
operating costs show for start up, and
3 month of operations, short. They do
mention DPO to members to raise additional capital
Certified Audited Financial Report Provided for one or more Owners: Score 5 5 -
Score one of the following for a maximum 20 points:
Capital source is 100% liquid (cash in owners bank, no debt obligation)20 20 -
Capital souce is debt obligation (letter of credit/loan from individual or institution) 10 10 -
Capital consists of non-liquid assets (i.e. real property)8 8 -
Capital consists of a mixture of liquid and non-liquid assets 15 15 15
1.3 Sub-Total:50 20
Three Years of Data Provided: Score 10 10 8 6 8 Needs more detail re: taxes paid, utilities, benefits
Total Gross Revenue Estimates Provided:3 3 3
Total Gross Revenue by Product Type (flower and manufactured) Identified:3 3 0
Total Personnel Costs Provided:5 5 4 3 4 Needs breakout details of benefits
Total Property Rental or Purchase Costs Provided:2 2 2
Total Utilities Costs Provided:2 2 0 None listed
Total Cannabis Product Purchase Expense Provided 2 2 2
All Contract Services Identified:2 2 0
Annual Net Revenue Identified:3 2 2
Annual Cost Escalators Identified:4 4 3 2 3
Shows increase in some costs but no
detail/identification
Annual Estimated Sales Tax Payments to State Provided:2 2 2 Has income tax catagory listed
Annual Estimated Sale Tax Payments to City of Fresno Provided:5 2 2 Has income tax catagory listed
Annual Business Tax License and Cannabis Permit Fee Provided:2 2 0 Not listed in pro forma
Annual Net Income Provided:5 5 5
Scoring Guidance: full points for realistic figures for all three years. Dock points for severe
miscalculations, unrealistic estimates, or providing less than the request three years.
1.4 Sub-Total:50 33
Hours of Operation Provided: Score 5 5 5 says per ordinance (24 hours/7 days)
Hours of Operation Provided for all 7 days of the week: Score 3 3 3
Hours of Operation Provided for Holidays: Score 2 2 0 holidays not mentioned
Opening and Closing Procedures Provided: Score 10 10 8 6 6 says per ordinance but doesn't describe details.
1.4 Pro forma for at least three years of operation.
1.5 Fully describe hours of operation and opening and closing procedures. (20 points possible)
Criteria Narrative: Do they plan on raising additional capital they are short via DPO to members of the Chamber board?
Criteria Narrative:
Scoring Guidance: full points for describing information in detail. Dock points for leaving information out
or not providing enough detail.
1.5 Sub-Total:20 14
1.10. Fully describe the day-to-day operations if you are applying for a TESTING permit:
i. Describe the sampling standard operating procedures 20 20 15 10 20
ii. Describe procedures for transporting cannabis field samples 10 10 8 6 10
iii. Describe the chain of custody for field samples 20 20 15 10 20
iv. Describe the quality control procedures 20 20 15 10 20
v. Describe the Laboratory Supervisor/Manager responsibilities and qualifications 20 20 15 10 20
vi. vi. Identify location and procedures for storing cannabis products 10 10 8 6 10
1.6 Sub-Total:100 100
Section 1 Total:300 196
SECTION 2: SOCIAL POLICY AND LOCAL ENTERPRISE 400 Points Possible for Section 2
Description of Commitment to pay a Living Wage provided: Score 10 10 8 6 10
Definition of Living Wage Provided: Score 5 5 4 3 3 defined but did not provide rate
Living Wage Defined as Greater than Minimum Wage: Score 5 5 0 did not provide rate
2.1 Sub-Total:20 13
Wages and Salary
CCB Entry-Level Hourly Wage Greater than Minimum Wage 5 5 0 did not provide rate
CCB Entry-Level Annual Salary Greater than Median Household Income ($50,432)5 5 0
Health Care Benefits
CCB Offers Medical Coverage to All Employees: Score 5 5 5
CCB Offers Dental Coverage to All Employees: Score 3 3 3
CCB Offers Vision Coverage to All Employees: Score 3 3 3
CCB Offers Health Reimbursement Account for Qualified Medical Expenses: Score 1 1 0
Employee Pays $0 for Employee Medical Premium: Score 3 3 0 premium not mentioned
Employee Pays $0 for Employee Dental Premium: Score 2 2 0
Employee Pays $0 for Employee Vision Premium: Score 2 2 0
Employee Pays less than $500 per month for Family Health Care Coverage (Medical, Dental, Vision):
Score 2 2 0
Leave Benefits
Number of Paid Vacation/PTO Days Per Year: (10+ days = excep; 6-9 days = Good; 3-5 days Acceptable)5 5 4 3 5
Number of Paid Holidays Per Year: (10 or more paid holidays = excep; 4-10 = Good; 1-3 Acceptable)5 5 4 3 3 mentions holidays but not how many or which days
1.6 Daily operations. With as much detail as possible, the Business Plan should describe the day-to-day operations which meet industry best practices. This should include at a minimum the following criteria for each permit type in
which you are applying for a permit. (100 points possible)
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
2.1 Describe whether the Commercial Cannabis Business is committed to offering employees a Living Wage. (20 points possible)
Scoring Guidance: https://livingwage.mit.edu/counties/06019
2.2 Briefly describe benefits provided to employees such as health care, vacation, and medical leave, to the degree they are offered as part of employment. (50 points possible)
Number of days paid time off for Sick/Medical time: (7+ days= Exceptional, 4-6 days = Good, 3 days =
acceptable (8 hour day))5 5 4 3 3 mentions sick days but not how many
Retirement
Offers employee retirement plan 2 2 0 does not mention
Offers company match for employee retirement plan 2 2 2 mentions equity sharing with employees but not %
2.2 Sub-Total:50 24
CCB Provides Tuition Reimbursement for Certificates: Score 3 3 0
CCB Provides Tuition Reimbursement for associate degrees: Score 3 3 0
CCB Provides Tuition Reimbursement for bachelor's degrees: Score 3 3 0
CCB Provides Tuition Reimbursement for master's degrees: Score 3 3 0
CCB Provides Tuition Reimbursement for Specialized Commercial Cannabis Business Operations
Training: Score 3 3 3
mentions reasonable reimbursement for required
continuing education
CCB Offers General Training for Health and Safety, Workplace Environment, Customer Service, etc. 5 5 4 3 3 mentions training but not specific topics
2.3 Sub-Total:20 6
General Recruitment Plan Provided: Score 10 10 8 6 6
Social Policy Recruitment Plan Provided: Score 10 10 8 6 10
Recruitment Plan Includes Demographic Data for District, City or County: Score 10 10 8 6 0
Recruitment Plan Includes List of CBOs, Non-Profits and Public-Agency Hiring Partners: Score 10 10 8 6 10
Recruitment Plan Includes Hiring Targets (percentages) by Demographic Groups: Score 10 10 8 6 0
2.4 Sub-Total:50 26
Owners
Number of Owners:1
Number of Owners that live within the City of Fresno:1
Number of Owners that live in the County of Fresno:0
Number of Owners that Own a Business in the City of Fresno:0
51%+ ownership interest percent of the Owners live or own a business in the City: Score 80 80 80
51%+ ownership interest percent of the Owners live or own a business in the County: Score 40 40 -
Less than 50 percent of the Owners live or own a business in the Cityf no owners are local, score zero)20 20 -
Managers
Number of Managers (salaried, non-owners)
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
Data, non-scored. Write response in Evaluation Notes
column.
Data non-scored Write response in Evaluation Notes
IF full points achieved for Ownership category, don't score managers.
Section is total of 80 points possible.
2.3 Describe compensation to and opportunities for continuing education and employee training.(20 points possible)
2.4 Describe the Commercial Cannabis Business plan to recruit individuals who meet the criteria listed in the Social Policy Section 9-3316 (b) (1) of the Fresno Municipal Code (FMC) and the percentage of local employees it hires. (50
points possible)
2.5 Describe the extent to which the Commercial Cannabis Business will be a locally managed enterprise whose owners and /or managers reside within or own a commercial business within the City of Fresno, for at least one year prior
to March 2, 2020.(80 points possible)
Number of Managers that live in the City of Fresno:
Number of Managers that Own a Business in the City of Fresno:
100 percent of the Managers live or own a business in the City: Score 20 20 20
75 to 99 percent of the Managers live or own a business in the City: Score 15 15 -
50 to 74 percent of the Managers live or own a business in the City: Score 10 10 -
Less than 50 percent of the Managers live or own a business in the City: Score 5 5 -
2.5 Sub-Total:80 80
Responsibilities Described for All Titles/Positions: Score 20 20 15 10 20
2.6 Sub-Total:20 20
Does CCB have more than five employees: 5 5 5
CCB has signed a peace agreement: Score 5 5 5
2.7 Sub-Total:10 10
Work Force Plan Provided: Score 10 10 8 6 10
Commitment to Local Hire Provided:10 10 8 6 10
Commitment to Offer Apprenticeships Provided:10 10 8 6 6 made commitment but no specifics
Commitment paying for continuing education provided 10 10 8 6 6
no specific committment other than "reasonable
required continuing education"
Description of commitment to paying a living wage provide. (Score same as sec. 2.1)10 10 8 6 10
2.8 Sub-Total:50 42
CCB is willing to serve as Social Equity Business Incubator: Score 100 100 80 60 N/A This is a social equity application
Mentorship and Training: Score
Equipment Donation: Score
Shelf Space: Score
Legal Assistance: Score
Finance Services Assistance: Score
Other Technical Assistance: Score
Criteria Narrative:
2.9 Describe whether the business is willing to serve as a Social Equity Business Incubator by offering support to local cannabis social equity businesses in the form of mentorship, training, equipment donation, a percentage of shelf
space dedicated to Fresno equity business products, legal assistance, financial services assistance, or other technical assistance support.(100 points possible)
Criteria Narrative:
Data, non-scored. Write response in Evaluation Notes
column.
Data to inform score on first line of this section. Write
response in Evaluation Notes column.
2.8.3. Commitment to pay a living wage to its employees
2.6 Describe the number of employees, title/position and their respected responsibilities.(20 points possible)
2.7 Describe whether the CCB has five (5) or more employees and whether it has signed a labor peace agreement allowing employees to unionize without interference. (10 points possible)
2.8 Provide a workforce plan that includes at a minimum the following provisions: (50 points possible)
2.8.1. Commitment for 30% of employees to be local hires; the business must show that it has either hired or made a good faith effort to hire bona fide residents of Fresno who have not established residency after the submission of an
application for employment with the applicant/permittee.
2.8.2. Commitment to offer apprenticeships and/or compensation for continuing education in the field; and
Criteria Narrative:
Criteria Narrative:
Scoring Guidance: full points for willingness to serve with detailed plan offering at least three aspects
mentioned above or of similar benefit. Less points for willingness to serve but vague or unclear
commitment. Zero points if there is no clear commitment to serve as Incubator.
2.9 Sub-Total:100 0
Section 2 Total:400 221
SECTION 3: NEIGHBORHOOD COMPATIBILITY PLAN 300 Points Possible for Section 3
CCB will document complaints (time of complaint, nature of complaint, resolution of complaint): Score 10 10 8 6 6 Need more detail.
CCB will established a dedicated contact person to receive complaints: Score 10 10 0 Info not provided.
CCB will establish a dedicated phone number to receive complaints: Score 5 5 0 Info not provided.
CCB will establish a dedicated email address to receive complaints: Score 5 5 0 Info not provided.
CCB will establish a response time standard for returning complaint calls and emails: Score 5 5 0 Info not provided.
CCB will schedule or participate in periodic community meetings to engage with residents about the CCB
operation: Score 10 10 0 Info not provided.
Other measure unique to business (i.e. website complaint form)5 5 0 Info not provided.
Scoring Guidance: full points for detailed proactive plan addressing all aspects mentioned. Dock points
for leaving out aspect, vagueness, or reactive plans.
3.1 Sub-Total:50 6
CCB will maintain a listserv of community residents to update and information residents of business
operations.
10 10 0 Info not provided.
CCB will schedule or attend periodic community meetings (at least annually) to engage with residents
about the CCB operation: Score 10 10 0 Info not provided.
CCB will prepare a community outreach and engagement plan: Score 50 50 40 30 0 Info not provided.
CCB will issue periodic Newsletters to community providing information about CCB operations 10 10 0 Info not provided.
CCB will hire residents from the community work at the CCB: Score 20 20 0 Info not provided.
Scoring Guidance: full points for detailed proactive plan. Dock points for leaving out aspect, vagueness,
or reactive plans.
3.2 Sub-Total:100 0
CCB has identified sensitive receptors to nuisance odors in vicinity of business operations: Score 5 5 0 Info not provided.
CCB has prepared a nuisance odor control plan: Score 10 10 8 6 10
Nuisance odor control plan identifies locations where fugitive emissions may exit the premise boundary:
Score 5 5 0 Info not provided.
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
3.1 Describe how the CCB will proactively address and respond to complaints related to noise, light, odor, litter, vehicles, and pedestrian traffic.(50 points possible)
3.2 Describe how the CCB will be managed to avoid becoming a nuisance or having impacts on its neighbors and the surrounding community.(100 points possible)
3.3 Describe odor mitigation practices.(40 points possible)
Nuisance odor control plan describes specific odor control measures to reduce fugitive emissions exiting
the premise boundary: Score 5 5 5
CCB has established an odor reporting system: Score 5 5 5
CCB will install a nuisance odor monitoring system: Score 10 10 0 Info not provided.
3.3 Sub-Total:40 20
CCB has identified the potential sources of nuisance odors for the business operation: Score 10 10 8 6 0 Not provided.
Scoring Guidance: full points for detailed proactive plan. Dock points for vagueness or reactive plans.
3.4 Sub-Total:10 0
Nuisance odor control plan describes specific odor control equipment: Score 10 10 8 6 8 Need more detail.
Nuisance odor control plan describes specific odor control measures/techniques: Score 10 10 8 6 8 Need more detail.
Odor control measures are identified for different nuisance odor sources: Score 10 10 10
3.5 Sub-Total:30 26
Nuisance odor control plan describes the operation, monitoring, and maintenance requirements for
odor control measures: Score 10 10 10
Nuisance odor control plan describes the staff training required for system operations, maintenance,
repair, and troubleshooting.10 10 10
3.6 Sub-Total:20 20
CCB has identified the sources of waste generated by the business operation: Score
10 10 0 Info not provided.
CCB has prepared a source-separation plan to segregate different sources of waste generated by
business operations: Score 10 10 0 Info not provided.
The source-separation plan identifies policy, procedures, and locations where different sources of waste
are to be collected for disposal: Score 10 10 8 6 0 Info not provided.
The source-separation plan describes specific measures to control the collection and disposal cannabis
waste: Score 10 10 10
The name of licensed cannabis disposal company provided: Score 10 10 0 Info not provided.
3.7 Sub-Total:50 10
Section 3 Total:300 82
SECTION 4: SAFETY PLAN 300 Points Possible for Section 4
Criteria Narrative:
3.7 Describe the waste management plan. (50 points possible)
Criteria Narrative:
3.4 Identify potential sources of odor. (10 points possible)
3.5 Describe odor control devices and techniques employed to ensure that odors from cannabis are not detectable beyond the permitted premises. (30 points possible)
3.6 Describe all proposed staff odor training and system maintenance.(20 points possible)
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
Safety Plan Prepared by Consultant: Score 10 10
Safey Plan Assessed by Consultant: Score (if prepared by, also give points for assessed by)10 10
Safety Plan Prepared for CCB Address (specific proposed location): Score 10 10
Safety Plan includes Site Plan of Premise: Score 10 10
Safety Plan includes Building Layout Plan: Score 10 10
4.1 Sub-Total:50 0
Written Accident/Incident Procedure Provided: Score 20 20 15 10
Procedures Address Multiple Accident/Incident Scenarios: Score 10 10 8 6
Total Number of Scenarios Described: Score
Active Shooter Incident Described: Score 10 10
Robbery Incident Described: Score 10 10
4.2 Sub-Total:50 0
Evacuation Plan Provided: Score 20 20 15 10
Adequate Number of Evacuation Routes Identified: Score 20 20 15 10
Evacuation Route Distance to Public Right of Way: Score 10 10 8 6
4.3 Sub-Total:50 0
Location of Fire Suppression System Elements Identified: Score 10 10
Type of Fire Suppression System Elements Identified: Score 20 20 15 10
Location of Fire Extinguishers Identified: Score 10 10
Adequate Number of Fire Extinguisher Locations Identified: Score 10 10 8 6
4.4 Sub-Total:50 0
Written Procedure for Fire Emergencies Provided: Score 20 20 15 10
Written Procedure for Medical Emergencies Provided: Score 20 20 15 10
Cardiac Arrest Medical Emergency Described: Score 20 20 15 10
Gunshot Wound Medical Emergency Described: Score 20 20 15 10
Other Medical Emergency Conditions Described: Score 20 20 15 10
4.5 Sub-Total:100 0
Section 4 Total:300 0
SECTION 5: SECURITY PLAN 300 Points Possible for Section 5
4.3 Describe evacuation routes. (50 points possible)
4.2 Describe accident and incident reporting procedures. (50 points possible)
Criteria Narrative:
4.5 Describe procedures and training for all fire and medical emergencies.(100 points possible)
4.1 The Safety Plan shall be prepared and/or assessed by a professional fire prevention and suppression consultant. (50 points possible)
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
4.4 Location of fire extinguishers and other fire suppression equipment. (50 points possible)
Criteria Narrative:
Data-write response in Evaluation Notes Column
Security Plan Prepared by Consultant: Score 10 10
Security Plan Assessed by Consultant(if prepared by, also give points for assessed by): Score 10 10
Security Plan Prepared for CCB Address (specific proposed location): Score 10 10
Security Plan includes Site Plan of Premise: Score 10 10
Security Plan includes Building Layout Plan: Score 10 10
5.1 Sub-Total:50 0
Premises (Security) Diagram Provided: Score 20 20 15 10
Diagram is drawn to correct scale: Score 5 5
Diagram provides required details for premise: Score 5 5
Diagram shows the location of all security cameras: Score 5 5
Descriptions of activities to be conducted in each area of the premise 5 5
Limited-Access Areas Clearly Marked: Score 5 5
Number and Location of All Security Cameras Identified: Score 5 5
5.2 Sub-Total:50 0
Intrusion Alarm and Monitoring System Identified: Score 15 15
Name and Contact Information for Monitoring Company Provided: Score 5 5
Total Points of Entry into Premise Identified: Score 5 5
All Points of Entry to be Alarmed Identified:5 5
Type of Alarm Identified (motion, infrared, glass break, etc.): Score 10 10
Backup Power Supply Identified: Score 10 10
5.3 Sub-Total:50 0
Written Cash-Handling Procedure Provided: Score 30 30 20 15
Dual-Custody is Practiced for all cash handling: Score 10 10
Video Surveillance Used to Monitor All Cash Handling: Score 20 20
Armored Car Service Used for Bank Deposits: Score 10 10
5.2.3 Description of cannabis activity that will be conducted in each area of the premise. Commercial cannabis activities that must be identified on the diagram/site plan may include but are not limited to the following if applicable to
the business operations; storage areas, batch sampling areas, loading/unloading of shipment areas, packaging and labeling, customer sales areas, training areas, employee break room areas, extractions, infusions, processing, and
testing areas.
5.1 The Security Plan shall be prepared and/or assessed by a professional security consultant.(50 points possible)
5.2.4 Limited-access areas, defined as areas in which cannabis goods are stored or held and only accessible to permittees, or its employees or contractors and areas used for video surveillance monitoring and storage devices
(Pursuant to CCR Title 16, Division 42, §5000 (m) Limited-Access Area and §5042 Limited-Access Area.
5.2.5 Number and location of all video surveillance cameras. (50 points possible)
5.4 Briefly describe cash handling procedures which covers day to day transactions with customers, vendors armor carrier vehicles and transporting it to the bank.(100 points possible)
5.3 Identify intrusion alarm and monitoring system including the name and contact information for the monitoring company (if the company has been selected).(50 points possible)
Criteria Narrative:
Criteria Narrative:
5.2 Premises (Security) Diagram. In addition to diagrams submitted for other sections of the application, applicants are expected to submit a premises diagram (or site plan) which, focuses on the proposed security measures and how
they relate to the overall business. (Pursuant to CCR Title 16, Division 42, §5006. Premises Diagram).
5.2.1 The diagram shall be accurate, dimensioned and to scale (minimum scale ¼"). The scale may be smaller if the proposed location exceeds more than a 1/2-acre parcel but must not be printed on larger than an 11" x 17" sheet of
paper. (Blueprints and engineering site plans are not required at this point of the application process)
5.2.2 The diagram must be drawn to scale and clearly identify property boundaries, entrances, exits, interior partitions, walls, rooms, windows, and doorways. The activity in each room and the location of all cameras must be
identified in the diagram.
Criteria Narrative:
All Cash Deposited weekly with Bank: Score 10 10
Onsite Vault Provided to Secure Cash Prior to Bank Deposit: Score 20 20
5.4 Sub-Total:100 0
CCB will use onsite security guards: Score 10 10
All onsite guards will be licensed and bonded: Score 10 10
All onsite security guards will be licensed to carry firearms: Score 10 10
Onsite security guards will be on duty before CCB opens for business: Score 10 10
Onsite security guards will be on duty after CCB closes for business: Score 10 10
5.5 Sub-Total:50 0
Section 5 Total:300 0
Section 1: Business Plan Total Points:300 196
Section 2: Social Policy & Local Enterprise Total Points:400 221
Section 3: Neighborhood Compatibility Total Points:300 82
Section 4: Safety Plan Total Points:300 0
Section 5: Security Plan Total Points:300 0
Total Points Achieved:1600 499
PASS
TOTAL SCORE
5.5 Discuss whether the CCB will utilize the services of on-site security guards. Include in the discussion: (50 points possible)
5.5.1 Number of guards.
5.5.2 Hours guards will be on-site.
Criteria Narrative:
Criteria Narrative:
5.5.3 Locations at which they will be positioned.
5.5.4 Guards' roles and responsibilities.
1/29/2021 Fresno Metro Black Chamber of Commerce Mail - ZIL for Social Equity Application
https://mail.google.com/mail/u/0?ik=80cbca0532&view=pt&search=all&permmsgid=msg-f%3A1690261556776356726&simpl=msg-f%3A16902615567…1/1
Tara Lynn Gray <taralynngray@fmbcc.com>
ZIL for Social Equity Application
Erik Young <Erik.Young@fresno.gov>Fri, Jan 29, 2021 at 2:23 PM
To: Tara Lynn Gray <taralynngray@fmbcc.com>
Thank you, Tara. I was able to push the applica on through on my end and waived the fee. The new official Zoning
Inquiry Applica on number is P21-00601, which you will see when you log back into FAASTER. The applica on has
been accepted, and is currently with Planner Marisela Mar nez for review and issuance of the zoning inquiry le er.
Should you have any ques ons, you can email Marisela.Martinez@fresno.gov.
Thanks again.
[Quoted text hidden]
1/29/2021 Fresno Metro Black Chamber of Commerce Mail - ZIL for Social Equity Application
https://mail.google.com/mail/u/0?ik=80cbca0532&view=pt&search=all&permmsgid=msg-f%3A1690261556776356726&simpl=msg-f%3A16902615567…1/1
Tara Lynn Gray <taralynngray@fmbcc.com>
ZIL for Social Equity Application
Erik Young <Erik.Young@fresno.gov>Fri, Jan 29, 2021 at 2:23 PM
To: Tara Lynn Gray <taralynngray@fmbcc.com>
Thank you, Tara. I was able to push the applica on through on my end and waived the fee. The new official Zoning
Inquiry Applica on number is P21-00601, which you will see when you log back into FAASTER. The applica on has
been accepted, and is currently with Planner Marisela Mar nez for review and issuance of the zoning inquiry le er.
Should you have any ques ons, you can email Marisela.Martinez@fresno.gov.
Thanks again.
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INDEMNIFICATION AND HOLD HARMLESS AGREEMENT
FOR COMMERCIAL CANNABIS BUSINESS PERMIT APPLICATION
To the fullest extent permitted by law, the City of Fresno (City) shall not assume any liability whatsoever with respect to
having issued a commercial cannabis business permit pursuant to Fresno Municipal Code Section. 9-3333 or otherwise
approving the operation of any commercial cannabis business or cannabis retail business.
In consideration for the submittal of an application for a commercial cannabis business permit application and/or issuance
of a cannabis business permit, and to the furthest extent allowed by law, Applicant does hereby agree to indemnify, hold
harmless and defend the City and each of its officers, officials, employees, agents and volunteers from any and all loss,
liability, fines, penalties, forfeitures, costs and damages (whether in contract, tort or strict liability, including but not limited
to personal injury, death at any time and property damage) incurred by City, Applicant or any other person, and from any
and all claims, demands and actions in law or equity (including reasonable attorney's fees and litigation expenses), arising
or alleged to have arisen directly or indirectly out of the issuance of a cannabis business permit. Applicant’s obligations
under the preceding sentence shall not apply to any loss, liability, fines, penalties, forfeitures, costs or damages caused
solely by the gross negligence, or caused by the willful misconduct, of City or any of its officers, officials, employees,
agents or volunteers.
Applicant must, at the time of permit issuance, maintain insurance at coverage limits and with conditions thereon
determined necessary and appropriate from time to time by the City Manager.
Applicant shall conduct all defense at his/her/its sole cost. The fact that insurance is obtained by Applicant shall not be
deemed to release or diminish the liability of Applicant, including, without limitation, liability assum ed under this Agreement.
The duty to indemnify shall apply to all claims regardless of whether any insurance policies are applicable. The duty to
defend hereunder is wholly independent of and separate from the duty to indemnify and such duty to defend exists
regardless of any ultimate liability of Applicant. The policy limits do not act as a limitation upon the amount of defense
and/or indemnification to be provided by Applicant. Approval or purchase of any insurance contracts or policies shall in no
way relieve from liability nor limit the liability of Applicant, its officials, officers, employees, agents, volunteers or invitees.
City shall be reimbursed for all costs and expenses, including but not limited to legal fees and costs and court
costs, which the city may be required to pay as a result of any legal challenge related to the city's approval of the
applicant's commercial cannabis business permit. The City may, at its sole discretion, participate at its own
expense in the defense of any such action, but such participation shall not relieve any of the obligations imposed
hereunder.
This Indemnification and Hold Harmless Agreement shall survive the expiration or termination of the Application
and/or Permit.
The undersigned acknowledges that he/she (i) has read and fully understands the content of this Indemnification
and Hold Harmless Agreement; (ii) is aware that this is a contract between the City and Applicant; (iii) has had the
opportunity to consult with his/her attorney, in his/her discretion; (iv) is fully aware of the legal consequences of
signing this document; and (v) is the Applicant or his/her/its authorized signatory.
Signed on this day of 2020.
Applicant Signature City Employee Signature
Print Name and Company Name Print Name
Address Title
Telephone Number Telephone Number
13th November
Tara Lynn Gray, Fresno Metro Black Chamber
1444 Fulton Street Ste 206 Fresno, CA 93721
559-441-7929 x505
3553 Atlantic Avenue, Suite 309, Long Beach, California 90807
c. 916 -955-1996
January 28, 2021
Attn: Ronald Weiner and Elaine J. Trustees
RE: Letter of Intent
1201-1203 Fulton Avenue, Fresno, CA 93721
Assessor’s Parcel Number 466-211-05
Legal Address to be verified and confirmed by buyer and seller
Dear Mr. Weiner and Trustees:
The purpose of this Letter of Intent (LOI) is to set forth the general terms and conditions
by which Fresno Metro Black Chamber of Commerce (Buyer) would purchase or lease
with an option to buy the property described above. Execution and return of this LOI
by the owners in accordance with the instructions described in Section 10 will
document the seller’s interest in pursuing said purchase transaction under the terms
and conditions outlined below. This LOI outlines a framework under which Buyer is
prepared to purchase the Property and must be drafted into a Purchase and Sale
Agreement (PSA) and duly executed by both parties to constitute a binding agreement.
1. Property: Located at Assessor’s Parcel Number 466-211-05 in Fresno County
consisting of approximately 6500 SF GLA on an approximately .074-acre lot.
Buyer’s offer is specifically for the space located at 1201 Fulton and for the 2nd
Floor.
2. Terms: Buyer makes this offer to purchase the property for and close
escrow 120 days upon execution of a purchase and sale agreement. The terms
contained in this LOI are directly associated with a purchase. In the event that a
PSA is not successfully negotiated, the Buyer offers terms to Lease the building
at .50 per sq foot per month for 5 years with an option to buy after 2 years. The
lease with an option to buy is based on a purchase price of and
includes the completion of the improvements currently proposed by the owner.
Additionally, Lessee requests a Right of First Refusal (ROFR) if the building
becomes available for sale during tenancy. Terms of the lease with an option to
buy to be further negotiated in the event that a successful PSA is not negotiated.
3. Initial Deposit: Within five (5) days following the mutual execution of a Purchase
and Sale Agreement, Buyer shall deposit into escrow the sum of which
will remain in escrow and be credited to the Purchase Price. The deposit shall
3553 Atlantic Avenue, Suite 309, Long Beach, California 90807
c. 916 -955-1996
remain refundable to Buyer until Buyer’s written acknowledgement of satisfaction
of the conditions outlined in Paragraphs 4(a)-4(e) below. Upon satisfaction of the
conditions outlined in Paragraphs 4(a)-4(e) below, Buyer shall provide written
acknowledgement to escrow that the deposits are no longer refundable to Buyer.
All deposits shall be applied to the Purchase Price and shall accrue favorable
market rate interest which shall inure to the credit of Buyer.
4. Buyer’s Contingencies: Buyer’s obligation to purchase the property at the close
of escrow shall be subject to the following conditions:
a. Feasibility: Within five (5) days of the mutual execution of a Purchase
and Sale Agreement, Seller shall provide to Buyer all documentation,
with conditions, audited rent rolls with annual expenses, reports, maps,
books and records, lease(s) and any amendments thereto, studies and
information it holds with respect to the Property and shall authorize and
instruct its engineers and outside consultants to share with Buyer such
knowledge or information they have developed with respect to the
Property, if any. Buyer shall have 120 days (Feasibility Period) to
conduct its feasibility and financial study thereof. During the Feasibility
Period, Buyer, at their own expense, may retain engineers,
contractors, soils, environmental, and geological consultants,
architects, and any other advisors the Buyer, in its sole discretion,
deems appropriate to determine if the property is suitable for Buyer. If,
by the end of the Feasibility Period in Buyer’s sole opinion the Property
is not satisfactory, all rights and obligations under the Purchase and
Sale Agreement shall, at the sole election of Buyer, terminate and the
deposits previously made shall be returned to Buyer by escrow. At the
end of the Feasibility Period, if the Buyer proceeds, then the deposit
shall be released to the Seller and become non-refundable. The
released funds shall be applied to the Purchase Price.
b. Financing: Buyer to obtain financing at 80% of the purchase price with
a commercial lender. Buyer will put down 20% of the purchase price.
Alternatively, Buyer would like to explore seller financing with the Seller
as the first lienholder.
c. Title is acceptable to Buyer: Within five (5) days after opening of
escrow, Seller shall cause to be prepared and delivered to Buyer at
Seller’s sole cost, a preliminary title report on the Property, together
with legible copies of all documents referred to therein, including all
colored plotted easements (collectively the PTR), to be provided by
Fidelity National Title. If in Buyer’s sole opinion title is not acceptable,
all rights and obligations under the Purchase and Sale Agreement
shall, at the election of Buyer terminate, and the deposits previously
made shall immediately be returned to Buyer by escrow. If Buyer elects
to proceed with the purchase, at closing, Seller shall provide and pay
for an ALTA policy of Title Insurance with Mechanic’s Lien
Endorsement consistent with the PTR approved by Buyer.
3553 Atlantic Avenue, Suite 309, Long Beach, California 90807
c. 916 -955-1996
d. Delivered Vacant: the property shall be delivered vacant at the close
of escrow with no tenants or occupants and free and clear of all leases
and rental agreements.
e. Environmental: the property shall be delivered free and clear of all
and any environmental considerations including suspect hazardous
chemicals to the satisfaction of the Buyer.
f. Close of Escrow: Buyer and Seller agree that the Close of Escrow
shall occur 120 days from the date that escrow is opened. Escrow may
close sooner if mutually agreed upon by Buyer and Seller. All funds
deposited shall accrue market rate interest in favor of Buyer.
5. Access: Seller hereby grants to Buyer, its agents, assignees, employees, and
nominees the right to enter onto the Property upon 48 hours prior notice at any
time for the purpose of doing or causing to be done any engineering,
environmental surveying, or related work as may be required by Buyer. Said
access shall be during normal business hours.
6. Right to Submit: Buyer reserves the right, at its sole cost and expense and
without incurring any liability to Seller, to submit architectural and other plans to
the appropriate City/Government agencies for approval upon the mutual
execution of the Purchase and Sale Agreement. Seller agrees to cooperate fully
with Buyer in this regard.
7. Escrow and Title: Escrow and title to be with Fidelity National Title upon mutual
execution of the Purchase and Sale Agreement. Escrow shall commence and be
considered “open” on the date that the Escrow Holder receives the Purchase
and Sale Agreement and Escrow Instructions executed by both parties.
8. Closing Costs and Proration: Escrow costs shall be borne equally by Buyer
and Seller, except the Seller shall pay all documentary transfer taxes. Current
non-delinquent real property taxes and assessments shall be prorated between
Buyer and Seller as of the close of escrow based on a three hundred and sixty-
day year.
9. Real Estate Commissions: Buyer acknowledges that Buyer is represented by
the brokerage S L Smith and Associates, Inc. Any commissions due to Seller’s
broker shall be the Seller’s responsibility and the 3% commissions due to the
Buyer’s broker shall be the Buyer’s responsibility. Buyer and Seller shall
indemnify each other to that effect.
10. Expiration: This Letter of Intent shall be null and void if not accepted by Seller
and returned to Buyer by 5:00P.M. Pacific Standard Time on Saturday January,
30, 2021
3553 Atlantic Avenue, Suite 309, Long Beach, California 90807
c. 916 -955-1996
Buyer and Seller agree not to disclose the content of this Letter of Intent or of any
negotiations or information received from the other party regarding the Property to any
unrelated third parties without first obtaining the prior written consent of the other party.
If the basic terms of this letter are acceptable to Seller, Seller shall execute a copy of
this Letter of Intent and return it to Buyer within the timeframe specified herein. The
price and terms of the final LOI shall be drafted on a Purchase and Sale Agreement
(PSA) form and shall be executed within fifteen (15) business days of the execution of
the final LOI.
Sincerely,
______________________________
Tara Gray, President/CEO
AGREED TO AND ACCEPTED:
SELLER:
____________________________________
____________________________________
NAME:
_____________________________________
TITLE:
_____________________________________
DATE:
3553 Atlantic Avenue, Suite 309, Long Beach, California 90807
c. 916 -955-1996
Buyer’s Entry
Seller hereby grants to Buyer, its agents, assignees, employees, and nominees,
the right to enter onto the Property at any time during normal business hours for
the purposes of making inspections and tests and doing any engineering,
environmental surveying, or related work as may be required by Buyer. Buyer shall
give no further notice to Seller.
Following any such entry or work, unless otherwise directed in writing by Seller,
Buyer shall return the property to the condition it was in prior to such entry or work.
All such inspections and tests and any other work conducted or materials furnished
with respect to the Property by or for Buyer shall be paid for by Buyer as and when
due and Buyer shall indemnify, defend, protect and hold harmless Seller and the
Property of and from any and all claims, liabilities, losses, expenses (including
reasonable attorney’s fees), damages, including those for injury to person or
property, arising out of or relating to any such work or materials or the acts or
omissions of Buyer, its agents or employees in connection therewith.
Prior to entry, Buyer shall provide Seller certificates of insurance evidencing that
Buyer, and/or Buyer’s agents, assignees, employees, and nominees, as
applicable, possess liability insurance coverage in an amount not less than
per occurrence and in the aggregate.
This “Buyers Entry Agreement” shall be incorporated into the Purchase and Sale
Agreement and signed at the time of execution.
SELLER:
_______________________________
_______________________________
NAME:
_______________________________
OWNERSHIP ACKNOWLEDGEMENT FORM
FOR COMMERCIAL CANNABIS BUSINESS PERMIT APPLICATION
It is the intent of the City of Fresno to promote equitable ownership and employment opportunities in the cannabis industry to
decrease the disparities in life outcomes for marginalized communities and to provide opportunities for local residents to
compete for cannabis business permits. Therefore, this notice is to clarify the eligibility requirements in order to receive
qualification as a Social Equity Applicant or points for Local Preference by establishing this acknowledgement to provide
additional protections to mitigate against potential predatory practices.
In order to qualify as a social equity applicant, or for the full points relating to the local preference criteria, the business entity
must have ownership that meets the respective eligibility factors and hold at least 51% ownership interest. The social equity
eligibility requirements are identified in FMC section 9-3316(b)(6), while the local preference criteria is identified in FMC 9-
3317(a) and the application evaluation criteria 2.5 (Appendix A). This majority interest can be made up of a single individual that
meets this criteria, or any combination of individuals that hold at least 20% interest individually and meet the definition of an
owner in FMC 9-3304(j). The cannabis social equity permits, and the local preference criteria are intended for the benefit of the
Social Equity or Local Preference Individual Applicants related to business profits, proceeds of the sale of business assets, voting
rights and additional protections. This also requires the Social Equity or Local Preference Owner to receive the Equity Share
percent of the retained earnings and 100 percent of the unencumbered value of each share of stock, member interest or
partnership interest owned in the event of the dissolution of the entity to their equity share, or 100 percent of the value of each
of stock, member interest or partnership interest in the event that the stock, member interest or partnership interest is sold.
Chief among the concepts of equity share, is unconditional ownership which means such individual(s) will receive equal profits,
and distributions or other payments proportionate to their ownership interests. This is intended to ensure true ownership by the
Social Equity or Local Preference Individual Applicant and as such, prohibits the divestment or relinquishment of any part of their
ownership under any circumstance. In addition, the Equity Share is also expanded to address voting rights on fundamental
decisions relating to the business and control of at least the equity share percent of the voting rights on all decisions involving
the operation of the business. Furthermore, it requires the Social Equity or Local Preference Individual owner be the highest
officer position of the business or that another individual is appointed to that position by mutual agreement of the parties. This
requirement is also subject to being audited to assess compliance and the Social Equity or Local Preference Owner can initiate
legal action due to a breach of contract agreement, and the City may suspend and/or revoke a license if any provision in an
operating agreement violates any of the Equity Share or Local Preference requirements. Lastly, all applicants will be required to
incorporate an addendum into their operating agreements that makes any provision ineffective, unenforceable, null and void, if
it is inconsistent with, or in violation of, the Equity Share requirements. As proposed, Social Equity Applicants or Local Preference
Applicants will be required to verify under Section 9-3316(b)(6), 9-3317(a), and Criteria 2.5 of appendix A that they meet the
definition of a Social Equity or Local Preference Owner at the time of applying for a permit or permit renewal. The City shall have
the sole and absolute discretion to determine whether the Applicant qualifies as a Social Equity Applicant and the number of
points for Local Preference.
The undersigned acknowledges that he/she has read and fully understands the content of this Agreement and is
the Applicant or his/her/its authorized signatory.
__________________________________________________ __________________________________________________
Applicant Signature Date Signed
__________________________________________________ __________________________________________________
Print Name Title
__________________________________________________ __________________________________________________
Company Name Address/Telephone
Tara Lynn Gray
Fresno Metro Black Chamber of Commerce
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information and is shared only with the understanding that you will not share its contents or ideas with
third parties without the express written consent of the plan author.
Location Requirements
Triple E Lab Proposed property and location elements
6.1 Description of proposed location
The Triple E Lab proposed location is located at 1201 Fulton Street in the downtown
commercial district. It is a 3,600 square foot building with two floors, built in 1912
and renovated in 1980. Currently the building is blighted and boarded up. It has
historically had a single tenant at the corner location. It has a basement and rear
access for easy pick up and drop off of testing materials. Though it is a one star
commercial rating, the potential exists to bring the building up significantly.
6.2 Photographs
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third parties without the express written consent of the plan author.
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third parties without the express written consent of the plan author.
Triple E Labs
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information and is shared only with the understanding that you will not share its contents or ideas with
third parties without the express written consent of the plan author.
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6.3 Premises
diagram
The rendering of
the planned new
facade is
enclosed. The
building design
and diagram are
pending at this
time.
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6.3.1 Site Diagram
Specifications
Like all labs, cannabis facilities come
with their own set of unique standards
and equipment requirements.
However, unlike many other types of
labs, there is no one standard available
to guide those who design and build
them.
The site will be designed with
cannabis quality control laboratory
equipment and post processing
equipment including the following:
Two walk-in fume hoods, rotovap, TFE skid, and vacuum oven. Photos of the
planned design are included below.
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information and is shared only with the understanding that you will not share its contents or ideas with
third parties without the express written consent of the plan author.
Zoning Inquiry Letter Pending
We have submitted the appropriate zoning inquiry for the property. The official
Zoning Inquiry Application number is P21-00601 in the City's FAASTER system. The
application has been accepted, and is currently with Planner Marisela Martinez for
review and issuance of the zoning inquiry letter.
Triple E Labs
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information and is shared only with the understanding that you will not share its contents or ideas with
third parties without the express written consent of the plan author.
Proof of Capitalization
The most recent bank statement appears on the following page.
Triple E Labs
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information and is shared only with the understanding that you will not share its contents or ideas with
third parties without the express written consent of the plan author.
Triple E Labs
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information and is shared only with the understanding that you will not share its contents or ideas with
third parties without the express written consent of the plan author.
1.4 Credit Line
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information and is shared only with the understanding that you will not share its contents or ideas with
third parties without the express written consent of the plan author.
General Business Plan - Section 1
Overview
1.1 Owner Qualifications
The Fresno Metro Black Chamber of Commerce (FMBCC), established in 2001, is a
twenty-year-old community-based organization that envisions an equitable, open, thriving
market without social, political, or economic barriers for all. Our mission is to engage,
educate, and empower the Black community in the California's Central Valley. As such
FMBCC presents this business plan for the development and opening of Triple E Labs, a
cannabis testing facility.
Triple E Labs (3E), will provide patients, cultivators, producers and dispensaries with important
information about the safety, quality, and potency of their medical/recreational cannabis
products. Triple E Labs (3E) intends to start its testing business from the ground up in 3,000 sq.
ft, well-equipped cannabis laboratory. 3E intends to use a high- pressure liquid chromatography
as the primary testing method.
Main Goals:
To provide unrivaled customer service, and accurate results at an affordable price.
To be fully compliant with all state and local municipalities.
To be on the cutting edge since company’s inception.
Mission:
To adopt “best practices” in cannabis testing.
Main Objectives:
Getting the California Cannabis Testing license.
Net annual income to support operational expenses.
Monthly sales and capacity increasing steadily throughout the first years.
Products & Services
3E intends to provide a comprehensive menu of services to stakeholders in the
medical/recreational Cannabis industry. From Cannabinoid profiling, microbiological screening,
pesticide screening, terpene analysis, infused-product formulation charts and more, 3E will
offer tests and services aimed to guarantee the quality and potency of all cannabis products. 3E
looks to establish long-lasting relationships with its clients through accurate data, quick
turnaround, and exemplary service.
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information and is shared only with the understanding that you will not share its contents or ideas with
third parties without the express written consent of the plan author.
3E Management Team
3E will be a business that will be built on a solid foundation. From the outset, we have decided to
recruit only qualified people to man various job positions in our company. We hope to leverage
on their expertise to build our business brand to be well accepted throughout the region and
state. The core team includes the social equity applicant, James O. Archie; FMBCC Chief
Executive Officer, Tara Lynn Gray; Bruce Heights, Chief Financial Officer; Dr. Cassandra
Little, Workforce Development & Training; and Renita Young, Lab Director. The qualifications
of the core team are demonstrated in the resumes that follow the brief bios.
Social Equity Applicant - James O. Archie
An IT industry veteran with over 40 years in communications, James has hands on experience
with Fiber Optics, network installations, central office installations, transmissions & switching
supervision, termination and testing, outside plant cabling, trenching, remediation, rack and stack
network upgrades, PBX installs, VOIP and paging equipment installations. James served his
country in the armed forces based in Fort Knox, Kentucky and currently serves as the board
president of a niche chamber of commerce in Fresno, California.
Chief Executive Officer - Tara Lynn Gray
In February 2017, the Board of the Fresno Metro Black Chamber of Commerce appointed Tara
Lynn Gray, the first African American woman CEO, to head the Chamber’s day-to-day
operations. Gray came to the Chamber with a history of economic development activities in the
cities of Sacramento and Stockton, and Solano County. Armed with a vision and a mission, Gray
set out to change the Chambers model. She believes that in order to teach Black business owners
and community members how to do business, grow businesses and succeed in entrepreneurship
endeavors, the Chamber must be a business enterprise itself. This philosophy is embodied in the
day-to-day activities of the Chamber and its dogmatic pursuit of business opportunities for its
members through innovative technologies and emerging markets. Gray has a Bachelor of Arts in
Business Management, Saint Mary's College in Moraga, CA and Master of Arts in Christian
Studies, Grand Canyon University, Phoenix, Az.
Chief Financial Officer - Bruce Heights
Bruce Lee Heights born in Springfield Ohio and raised in Sacramento and Fresno California.
My background is in accounting, real estate and mortgage loan origination. I've spent years
solving issues and helping client's businesses run more efficiently and effectively. I do
everything from monthly write up work to individual, partnership, and corporate taxation. I lead
audit teams that perform single audits of non-profits and audits of water districts . I also, broker
both real estate and mortgage loans licensed here in the state of California and Georgia. My goal
is to provide my client with first class service and constant communication. I pride staying with
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cutting edge technology apps and continuing to educate myself in my fields of expertise as the
industry is forever changing.
Laboratory Director - Renita Young
Renita meets the minimum requirements to be a laboratory director of a licensed testing
laboratory under the Act, by holding a Bachelor of Science degree in Chemistry from California
State Polytechnic University, Pomona and a Master of Forensic Sciences from National
University in addition to the requisite practical experience performing analytical scientific testing
in which the testing methods are recognized by a laboratory accrediting body.
Director Workforce Development & Training - Dr. Cassandra Little
Cassandra Little Ph.D. a small business owner of CARE Consulting and an Adjunct Professor
at Fresno State University. She grew up in East Palo Alto California, where she was directly
impacted by the War on Drugs policies. She witnessed her family members, including her
mother, who had a substance abuse disorder, go in and out of jails and prisons. The War on
Drugs not only impacted individuals or families it created a huge void in her community. As a
formerly incarcerated African American woman, she understands the importance of creating a
pathway to employment is essential for system impacted community members. Dr. Little
received her Doctorate in Counseling Educational Psychology from University of Nevada Reno,
in 2003. For 27 years, Cassandra worked in the Child Welfare field as a Licensed Clinical Social
Worker and operated as a CEO of a foster care agency that she founded in Reno Nevada.
Cassandra received her M.A., in Social Work from the University of Nevada Reno and her B.S.
in Sociology-Criminal Justice from California Baptist College in Riverside California.
Organizational Structure
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1.2 Budget
3E will fund its startup costs largely through private investments, savings, and direct public
offering to its members. From a total initial investment of , 3E is expected to generate
nearly $ in gross revenue with net income of nearly $ in year 2, its first full year of operations.
Revenues are expected to grow to nearly $ in year 3 and $ in year 5, with net income of
nearly $ and over $ respectively.
After the first year of operations, it is expected that 3E will be able to trim expenses through
realizing business efficiencies, gaining operational experience and industry knowledge.
Likewise, it is expected as 3E's reputation grows, there will be a significant jump in sales in
years three and four and then level off to about 20% per year through year seven.
The budget worksheets included in the plan include costs for startup and operations inclusive of
testing equipment (High performance liquid chromatography, mass spectrometry, gas
chromatography equipment); security & surveillance; computer & accounting software; SG&A
and capital expenses; real estate and renovations (space improvements, finishing, painting,
kitchen, office space, bathroom, etc.), employee compensation, utilities, and other operating
costs.
3E expects these business activities will have direct and indirect social impacts through job
creation, tax revenue, and business opportunities for FMBCC members.
Included in this section are three budgets; startup budget, operational budget and direct costs
budgets covering the first 5 years. The purpose of the direct costs budget is to demonstrate the
testing business expenses that are rolled up in the startup budget.
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Startup Budget
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1.3 Proof of Capitalization
The most recent bank statement appears on the following page.
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1.4 Pro forma (3 years)
Pro forma financials have been including for the first 5 years of operation including the
following: Profit & Loss Statement, Cash Flows Statement, and Balance Sheet. These statements
appear on the following three pages.
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1.5 Description of hours of operation; opening & closing procedures
The hours of operation and commercial testing activities will be made according to the City of
Fresno Ordinance Sec. 9-339. - Operating Requirements for All Commercial Cannabis Activity
and further modified to meet the specific requirements of the specific license type requirements
for a testing lab.
The City of Fresno Ordinance SEC. 9-3313. - OPERATING REQUIREMENTS FOR A
TESTING LABORATORY is incorporated by reference to the following website address:
https://library.municode.com/ca/fresno/codes/code_of_ordinances?nodeId=MUCOFR_CH9RER
EBUPECO_ART33CAREBUCOCABU_S9-3309OPREALCOCAAC
1.6 Description of daily Operations Specific to License Type
Triple E Labs will adhere to the City of Fresno Ordinance Sec. 9-3313. - Operating
Requirements for a Testing Laboratory as cited below. The Laboratory Director will work to
schedule staff at the appropriate hours of the day to maximize laboratory capacity and revenues.
The City of Fresno Ordinance
SEC. 9-3313. - OPERATING REQUIREMENTS FOR A TESTING LABORATORY is
incorporated by reference to the municipal code website address:
https://library.municode.com/ca/fresno/codes/code_of_ordinances?nodeId=MUCOFR_CH9RER
EBUPECO_ART33CAREBUCOCABU_S9-3313OPRETELA
1.10.1 Criteria for Testing Operations
The Significance of Cannabis Testing
Cannabis testing is by far the smallest segment of the industry when measured by number of
companies. But the work labs perform is critical from a health and safety perspective, as these
companies test for everything from pesticides to potency. Lab-tested cannabis is a requirement in
nearly every state that regulates marijuana businesses, though no federal or industrywide
standards exist.
States that require lab testing do so in an effort to ensure patients and customers are consuming
cannabis that is safe and relatively free of harmful chemicals or contaminants. But each state
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differs in what must be tested. Regardless of what’s required on the regulatory front, the vast
majority of growers, infused product companies and retailers want labs to test for potency and,
primarily, for concentrations of THC and/or CBD.
Aside from providing transparency, cannabis companies understand that providing potency
information can drive purchasing decisions for many consumers and patients. Testing for
residual solvents, and homogeneity can be performed by most labs, though the degree to which
clients are demanding these services varies.
For the past two years, a majority of testing lab survey participants have indicated high- pressure
liquid chromatography is their primary testing method, and that holds true this year as well.
While it is still the most prevalent technique, the portion of companies that utilize high-pressure
liquid chromatography has fallen from 63% last year to 50% this year.
As Triple E Labs becomes a player in the testing market, it will uphold the regulations at both
the State and Local levels to ensure the best level of regulatory compliance and testing
compliance to maximize cannabis use for public health benefits including but not limited to:
ISO/IEC 17025:2017; Good Laboratory Practice (GLP); Document Integrity (SOPs); FDA's 21
CFR Part 11 & Audit Trail.
Testing Standards
Appropriate testing is critical to demonstrate that these products do not contain harmful levels of
contaminants or adulterants and are safe for public consumption.
Specific testing may include, but is not limited to, the following:
• Cannabinoid testing and content (CBC, CBD, CBDa, CBG, CBN, THC, THCa, THCv, etc.)
• Terpene profile
• Pesticides/fungicides/plant growth regulators
• Residual solvents
• Heavy metals
• Microbiological contaminants (mold, insects, bacteria, etc.)
A cultivation facility or dispensary must provide a laboratory, prior to a laboratory taking
samples, with the following:
1) A written request of analysis for each test the laboratory is being requested to conduct; and
2) Notification of whether the batch is being re-sampled because of a failed test and the failed test
results.
A cultivation facility or dispensary must test every batch of usable marijuana, intended for use
by a qualified patient, prior to selling or transferring the usable marijuana for the following:
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a) Pesticides.
b) Water activity and moisture content, unless the cultivation facility or dispensary uses a method of
processing that results in effective sterilization
c) THC and CBD concentration.
d) Heavy Metals.
e) Microbiological contaminants.
A cultivation facility or dispensary must test every process lot of cannabinoid concentrate or
extract for use by a qualified patient prior to selling or transferring the cannabinoid concentrate
or extract for the following:
a) Pesticides.
b) Solvents, unless they did not use any solvent, only used a mechanical extraction process to
separate cannabinoids from the marijuana or used only water, animal fat or vegetable oil as a
solvent to separate the cannabinoids from the marijuana.
c) THC and CBD concentration.
d) Heavy Metals.
e) Microbiological contaminants.
Accreditation
Confidence in the laboratories that perform this testing, and assurance in the test results, is
possible through accreditation to the ISO/IEC 17025 standard. The ISO/IEC 17025 standard is
non-prescriptive and flexible, allowing the organization maximum flexibility in determining
what works best for their business needs.
In addition to the information required by application form, an applicant for a testing laboratory
license shall provide the following information:
• Proof of ISO 17025 accreditation or proof that the applicant is in the process of applying or is
preparing to apply for ISO 17025 accreditation;
• Laboratory-employee qualifications; and
• All required standard operating procedures.
Cannabis testing laboratories may select one of two tracks for A2LA accreditation. The
accreditation tracks both provide independent, third-party accreditation assessments crafted to
serve both the medical cannabis and recreational adult-use markets. These tracks are as follows:
• ISO/IEC 17025 as the primary framework, along with any additional, state-specific requirements
• ISO/IEC 17025 and the additional accreditation requirements derived from the Americans for
Safe Access (ASA) Patient Focused Certification (PFC) Program for testing laboratories
The PFC Laboratory Operations requirements are constructed in accordance with the
Recommendations to Regulators for Cannabis Operations, a guide developed by the Cannabis
Committee for the American Herbal Products Association (AHPA). An assessment to these
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additional requirements is voluntary. They include security, personnel training, sample receipt,
chain of custody, handling and disposal, and data review.
Proficiency Testing
A laboratory will also participate in a proficiency-testing program provided by an ISO 17043
accredited proficiency-test provider at least once every six months.
Testing Methods
We intend to employ High Performance Liquid Chromatography (HPLC) technology to
determine the original composition of cannabinoids present by direct analysis of plant and edible
samples. This technique uniquely determines all of the medicinal components contained within
the products and provides a cannabinoid profile in order to more accurately evaluate potency,
institute material quality assurance and to identify plant phenotype.
Company also is going to utilize GC system to quantify the potency of cannabis samples,
including THC, THCA, CBD, CDBA and CBN components.
MS systems will be used in testing for residual solvents such as pesticides, water, butane, carbon
dioxide, ethanol and other solvents used in cannabis processing.
ICP-MS and AA Spectrometers are critical in testing for heavy metal contaminants such as lead,
mercury, cadmium and arsenic, sometimes found in cultivation.
Testing Equipment
• Mass Spectrometry (MS)
• Gas Chromatography (GC)
• Liquid Chromatography (LC)
• High Performance Liquid Chromatography (HPLC)
• Inductively Coupled Plasma (ICP)
• Atomic Absorption (AA)
Samples
Product Tests Required Sample Size Needed to
Complete all Tests Usable marijuana. 1. Moisture content
2. Cannabinoid analysis
3. Terpene analysis
4. Foreign matter inspection
5. Microbial screening
Up to 12 grams
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6. Mycotoxin screening
7. Heavy metal screening
8. Pesticide residue analysis Extract of marijuana (non-
solvent) like kief, hashish,
bubble hash, infused dairy
butter, or oils or fats derived
from natural sources, includes
CO2
1. Cannabinoid analysis
2. Foreign matter inspection
3. Microbial screening
4. Terpene analysis
7 grams or less
Extract of marijuana (solvent-
based) made using n-butane,
isobutane, propane, heptane, or
other solvents or gases of at
least 99% purity approved by
the NV DPBH, including food
grade ethanol
1. Cannabinoid analysis
2. Terpene analysis
2. Foreign matter inspection
3. Microbial screening
4. Residual solvent test
2 grams or less
Edible marijuana-infused
product
1. Cannabinoid analysis
2. Terpene analysis
3. Microbial screening
1% of batch
Liquid marijuana-infused
product, including, without
limitation, soda or tonic
1. Cannabinoid analysis
2. Terpene analysis
3. Microbial screening
1 unit
Topical marijuana-infused
product
1. Cannabinoid analysis
2. Terpene analysis
1 unit
The laboratory will keep controlled copies of the sampling plans at the laboratory, and the
sampling plans will be available to laboratory personnel. Uncontrolled copies of the sampling
plans will be available to samplers in the field. The laboratory will make the sampling plans
available for inspection if requested.
Sampler Personal Equipment
A sampler will wear the following items during the entire sampling process:
(a) Disposable protective coveralls or disposable lab coat or apron;
(b) Disposable nitrile gloves;
(c) Filtering dust mask;
(d) Safety goggles; and
(e) Hair net.
The sampler will change gloves between sampling different batches.
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1.10.1 (a) Sampling SOP
3E will conduct sampling as a licensed laboratory to be able to issue Certificates of Analysis
(COA) to its customers and clients according to the standards set by the State of California
Bureau of Cannabis Control (www.bcc.ca.gov). Computerized software will be used to track and
maintain SOPs. A screenshot of such software is provided after the operating procedures.
The physical laboratory will include the separate rooms/partitioned areas for the following
activities:
• sample receiving
• sample storage
• record storage
• microbiology analysis
• chemistry analysis
• office space
The following Operating Procedures will be followed.
For a cannabis goods batch that fails regulatory compliance testing:
• A cannabis goods batch that fails any test performed by a licensed testing laboratory
fails regulatory compliance testing and may not be
transported to any retailer for sale.
• If a cannabis goods batch fails regulatory compliance testing, the laboratory may not retest the
batch and must issue a Certificate of Analysis (COA) based on the initial testing.
• Cannabis goods that have received a failing COA due exclusively to label claims may be
relabeled to match the results on the COA.
• A licensed testing laboratory shall not amend any COA after issuance.
• Cannabis goods that fail regulatory compliance testing must be quarantined at the
distribution premises with a clearly identifiable batch number.
• Retesting is not a form of remediation. Any retesting performed without remediation will not
supersede the original test results performed by the licensed testing laboratory.
• A failed cannabis goods batch may be remediated or destroyed if the licensed manufacturer or
licensed microbusiness complies with the following:
- Prior to any remediation, the licensed manufacturer or licensed microbusiness must submit a
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corrective action plan to the California
Department of Public Health (CDPH) at RP.MCSB@cdph.ca.gov.
- CDPH will review and ultimately approve or deny remediation plans.
- Once the cannabis goods have been remediated and returned to the distributor’s premises,
the cannabis goods batch must pass all required regulatory compliance testing before
being transported to a retailer for sale.
REQUIREMENTS FOR CERTIFICATES OF ANALYSIS (COAs)
• All COAs issued by a licensed laboratory must be sent to BCC.Labs@dca.ca.gov within one
business day of completing the analyses of the sample.
• The laboratory shall test each sample for each of the required analytes and shall report the
results of each analysis performed by the laboratory on the COA.
• Once a sample has been collected by the laboratory, the laboratory must test it for each analyte
and must report the results on the
regulatory compliance COA.
- There is no process for the licensee requesting testing to cancel the testing once a sample
has been collected from the distributor’s premises.
• The COA must accurately reflect all testing that is conducted, even if one or more tests were
not requested by the licensee or required by the bureau’s regulations.
• A licensed testing laboratory shall not amend any COA after issuance.
• A unique lot/batch number must be used to identify each cannabis goods batch. The same
batch number may NOT be used for multiple batches.
• The bureau’s regulations do not permit the reporting of any results prior to the completion
of analyses, nor prior to the release of the regulatory compliance COA.
• Laboratories are not permitted to release results as they become available via an online portal
or any other type of notification.
- For example, it is not permitted to allow the requester to access or notify them of results upon
completion of each individual analysis—
cannabinoid, pesticide, microbial testing, etc.
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State of California Testing Standards
Cannabinoids Test Standards
In compliance with California State Law, from the Bureau of Marijuana Control California Code
of Regulations Title 16, Division 42, Section 5307:
1. The laboratory shall test for and report measurements for the following cannabinoids:
1. THC;
2. THCA;
3. CBD;
4. CBDA;
5. CBG; and
6. CBN.
2. For harvest-batch samples, a laboratory shall report, to 3 significant figures, the
concentration in milligrams per gram (mg/g) dry-weight sample of the cannabinoids
listed in subsection (a). The laboratory shall report this information in the certificate of
analysis.
3. For harvest-batch samples, a laboratory shall also calculate the dry-weight percent of
cannabinoids listed in subsection (a) that are detected in the sample in the following way:
1. Dry-weight percent THC = wet-weight percent THC / (1 – percent moisture /
100).
2. Dry-weight percent CBD = wet-weight percent CBD / (1 − percent moisture /
100).
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3. Dry-weight percent THCA = wet-weight percent THCA / (1 − percent moisture /
100).
4. Dry-weight percent CBDA = wet-weight percent CBDA / (1 − percent moisture /
100).
5. Dry-weight percent CBG = wet-weight percent CBG / (1 − percent moisture /
100).
6. Dry-weight percent CBN = wet-weight percent CBN / (1 − percent moisture /
100).
4. For samples from manufactured cannabis batches, a laboratory shall report, to 3
significant figures, the concentration in milligrams per gram (mg/g) of the cannabinoids
listed in subsection (a). The laboratory shall report this information in the certificate of
analysis.
5. A laboratory may test for and provide test results for additional cannabinoids if requested
to do so by the requester of the laboratory testing.
6. For the purposes of cannabinoid potency testing of manufactured cannabis products, the
laboratory shall report that the sample “passed” cannabinoid potency testing if the
concentration of THC does not exceed the labeled potency of THC, plus or minus 15
percent. A cannabis product fails potency testing if the amount or percentage of THC
exceeds the labeled concentration of THC, plus or minus 15 percent.
7. For the purposes of cannabinoid potency testing of manufactured cannabis products, the
laboratory shall report that the sample “passed” cannabinoid potency testing if the
concentration of CBD does not exceed the labeled concentration of CBD, plus or minus
15 percent. A cannabis product fails potency testing if the amount or percentage of CDB
exceeds the labeled concentration of CBD, plus or minus 15 percent.
Residual Solvent Test Standards
In compliance with California State Law, from the Bureau of Marijuana Control California Code
of Regulations Title 16, Division 42, section 5310:
1. A laboratory shall analyze samples of manufactured cannabis batches for residual
solvents and processing chemicals. A laboratory does not need to analyze for residual
solvents and processing chemicals in dried flower, kief, and hashish samples.
2. The laboratory shall analyze the concentration of residual solvents present in each sample
of manufactured cannabis batches in accordance with the table in subsection.
3. For the purposes of residual-solvent testing, the laboratory shall report that the sample
“passed” residual-solvent testing if the concentrations of residual solvents are at or below
the following residual solvents and processing chemicals action levels:
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Chemical Name CAS No. Action Level for
Cannabis Goods
Meant for Inhalation
(ppm)
Action Level for All
Other Cannabis–
Infused Goods (ppm)
1,2-Dichloroethane 107-06-2 2 5
Acetone 67-64-1 750 5000
Acetonitrile 75-05-8 60 410
Benzene 71-43-2 1 2
Butane 106-97-8 800 5000
Chloroform 67-66-3 2 60
Ethanol 64-17-5 1000 5000
Ethyl acetate 141-78-6 400 5000
Ethyl ether 60-29-7 500 5000
Ethylene oxide 75-21-8 5 50
Heptane 142-82-5 500 5000
Hexane 110-54-3 50 290
Isopropyl alcohol 67-63-0 500 5000
Methanol 67-56-1 250 3000
Methylene chloride 75-09-2 125 600
Naphtha 8030-30-6 400 400
Pentane 109-66-0 750 5000
Petroleum ether 8032-32-4 400 400
Propane 74-98-6 2100 5000
Trichloroethylene 79-01-6 25 80
Toluene 108-88-3 150 890
Total xylenes (ortho-,
meta-, para-)
1330-20-7 150 2170
Residual Pesticide Test Standards
In compliance with California State Law, from the Bureau of Marijuana Control California Code
of Regulations Title 16, Division 42, section 5313:
1. A testing laboratory shall test all samples for residual pesticides.
2. Cannabis goods must not contain levels of pesticides above those listed in the below
table.
3. The laboratory shall report the levels detected in parts per million (ppm) to 3 significant
figures in the certificate of analysis. If a sample is found to contain pesticides above the
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allowable amount listed in the tables in subsection (b), the sample “fails” pesticide
testing. If the sample fails pesticide testing, the batch fails laboratory testing and may not
be released for retail sale.
Category 2 Pesticides Edible
Cannabis
Products
(ppm)
Dried
Cannabis
Flowers
(ppm)
All Other
Processed
Cannabis (ppm)
Abamectin 0.02 0.02 0.02
Acephate 0.02 0.02 0.02
Acequinocyl 0.27 0.1 0.02
Acetamiprid 0.01 0.01 0.01
Aldicarb 0.01 0.01 0.01
Azoxystrobin 0.01 0.01 0.01
Bifenazate 1 0.1 0.1
Bifenthrin 0.01 0.01 0.01
Boscalid 0.01 0.01 0.01
Captan 1 0.7 0.05
Carbaryl 0.01 0.01 0.01
Carbofuran 0.01 0.01 0.01
Chlorantraniliprole 0.02 0.02 0.02
Chlordane 0.01 0.01 0.01
Chlorfenapyr 0.01 0.01 0.01
Chlorpyrifos 0.02 0.02 0.02
Clofentezine 1.3 0.1 0.04
Coumaphos 0.01 0.01 0.01
Cyfluthrin 0.01 0.01 0.01
Cypermethrin 1 1 0.5
Daminozide 0.01 0.01 0.01
DDVP (Dichlorvos) 0.02 0.02 0.02
Diazinon 0.01 0.01 0.01
Dimethoate 0.01 0.01 0.01
Dimethomorph 0.01 0.01 0.01
Ethoprop(hos) 0.01 0.01 0.01
Etofenprox 0.01 0.01 0.01
Etoxazole 0.46 0.1 0.05
Fenhexamid 1.7 0.1 0.08
Fenoxycarb 0.01 0.01 0.01
Fenpyroximate 0.5 0.1 0.1
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Fipronil 0.01 0.01 0.01
Flonicamid 0.4 0.1 0.1
Fludioxonil 0.02 0.02 0.02
Hexythiazox 0.25 0.1 0.1
Imazalil 0.01 0.01 0.01
Imidacloprid 0.02 0.02 0.02
Kresoxim-methyl 3.6 0.1 0.02
Malathion 0.01 0.01 0.01
Metalaxyl 0.01 0.01 0.01
Methiocarb 0.01 0.01 0.01
Methomyl 0.01 0.01 0.01
Methyl parathion 0.01 0.01 0.01
Mevinphos 0.01 0.01 0.01
Myclobutanil 0.02 0.02 0.02
Naled 0.01 0.01 0.01
Oxamyl 0.026 0.5 0.2
Paclobutrazol 0.01 0.01 0.01
Pentachloronitrobenzene 0.03 0.1 0.1
Permethrin 2.5 0.5 0.02
Phosmet 0.12 0.1 0.02
Piperonyl butoxide 63 3 3
Prallethrin 0.5 0.1 0.02
Propiconazole 0.02 0.02 0.02
Propoxur 0.02 0.02 0.02
Pyrethrins 0.7 0.5 0.5
Pyridaben 4.4 0.1 0.02
Spinetoram 0.5 0.1 0.04
Spinosad 0.29 0.1 0.02
Spiromesifen 20 0.1 0.1
Spirotetramat 10 0.1 0.1
Spiroxamine 0.01 0.01 0.01
Tebuconazole 0.01 0.01 0.01
Thiacloprid 0.01 0.01 0.01
Thiamethoxam 0.01 0.01 0.01
Trifloxystrobin 25 0.1 0.02
Microbiological Impurities Test Standards
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In compliance with California State Law, from the Bureau of Marijuana Control California Code
of Regulations Title 16, Division 42, section 5316:
1. A testing laboratory shall test all samples for microbiological impurities. For the purposes
of microbiological testing, the laboratory shall report that the sample “passed”
microbiological-impurity testing if the following are not detected:
1. Shiga toxin–producing Escherichia coli: not detected in 1 gram;
2. Salmonella spp.: not detected in 1 gram.
2. The laboratory shall report whether the strains listed in subsection (A) are detected or are
not detected in 1 gram. The laboratory shall report this information in the certificate of
analysis. If the strains are detected, the batch fails laboratory testing and may not be
released for retail sale.
3. A laboratory is also required to test for the pathogenic Aspergillus species A. fumigatus,
A. flavus, A. niger, and A. terreus in all cannabis goods intended for consumption by
inhalation, including but not limited to dried flower, kief, hashish, oil, and waxes.
1. (1) For the purposes of pathogenic Aspergillus-species testing, the laboratory
shall report that the sample “passed” if the concentrations of the following
Aspergillus species are not detected:
1. Aspergillus fumigatus: not detected in 1 gram;
2. Aspergillus flavus: not detected in 1 gram;
3. Aspergillus niger: not detected in 1 gram; and
4. Aspergillus terreus: not detected in 1 gram.
2. If a pathogenic Aspergillus species is detected in a sample under (c)(1), the
sample fails microbiological-impurity testing, and the batch fails laboratory
testing and may not be released for sale. The laboratory shall report the results in
the certificate of analysis.
4. The laboratory may test for and provide test results for additional microorganisms if
requested by the requester of the laboratory testing.
Water Activity and Moisture Content Test Standards
In compliance with California State Law, from the Bureau of Marijuana Control California Code
of Regulations Title 16, Division 42, section 5322:
1. A laboratory shall analyze a dried flower harvest-batch sample to determine its water-
activity level. If the water activity is at or below 0.65 Aw, the sample “passes” water-
activity testing.
2. A laboratory shall analyze solid and semi-solid edible cannabis products to determine its
water-activity level. If the water activity is at or below 0.85 Aw, the sample “passes”
water-activity testing.
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3. The laboratory shall report the water-activity level of the sample in Aw to 2 significant
figures. The laboratory shall report this information in the certificate of analysis.
4. A laboratory shall analyze a dried flower harvest-batch sample to determine its moisture
content. If the moisture content is at 5.0% to 13.0%, the sample “passes” moisture-
content testing.
5. The laboratory shall report the moisture content in percentage to the nearest tenth of one
percent, by weight, of the dry sample. The laboratory shall report this information in the
certificate of analysis.
6. The laboratory may provide additional information on moisture content and water
activity results if the laboratory determines it is important or if requested by the requester
of the laboratory testing.
7. If a harvest-batch sample “fails” water-activity or moisture-content testing, the harvest
batch may be returned to the cultivator or person holding title for further drying and
curing unless prohibited by these regulations. The harvest batch will then need to be
retested for all tests required in this chapter.
Filth and Foreign Material Test Standards
In compliance with California State Law, from the Bureau of Marijuana Control California Code
of Regulations Title 16, Division 42, section 5325:
1. A laboratory shall analyze all samples for filth and foreign material present in the sample.
“Filth and foreign material” includes but is not limited to hair, insects, feces, packaging
contaminants, and manufacturing waste and by-products.
2. The laboratory shall report that the sample “passed” filth and foreign material testing if
the concentration of filth and foreign material is at or below the filth and foreign material
action levels in the following table:
3. The laboratory shall report in the certificate of analysis whether the sample “passed” or
“failed” filth and foreign-material testing. If it fails filth and foreign-material testing, the
batch fails laboratory testing. A harvest batch that fails must be destroyed unless it can be
remediated. Failed manufactured cannabis batches must be destroyed.
Defect Action Level
Mold or foreign material Average of 5% or more by weight
Mammalian excerta Average of 1 mg or more per pound
Heavy Metals Test Standards
In compliance with California State Law, from the Bureau of Marijuana Control California Code
of Regulations Title 16, Division 42, section 5328:
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1. The laboratory shall analyze all samples for concentrations of the following heavy
metals:
1. Arsenic (As);
2. Cadmium (Cd);
3. Lead (Pb); and
4. Mercury (Hg).
2. The laboratory shall report the concentration of each heavy metal listed in subsection (a)
in micrograms per gram (μg/g) in the certificate of analysis. The laboratory shall report
that the sample “passed” heavy-metal testing if the concentrations of heavy metals listed
in subsection below the following heavy metal action levels.
3. The laboratory may test for and may provide test results for additional metals if the
instrumentation detects additional metals in the samples or if requested by the requester
of the laboratory testing.
Heavy Metal Action Level for Edible
Cannabis Products,
Suppositories,
Sublingual Products,
and Other
Manufactured
Products (µg/g)
Action Level for
All Inhaled
Cannabis Goods
(µg/g)
Action Level for
Topical and
Transdermal
Cannabis Goods
(µg/g)
Cadmium 0.5 0.2 5
Lead 0.5 0.5 10
Arsenic 1.5 0.2 3
Mercury 3 0.1 1
Terpenes Test Standards
In compliance with California State Law, from the Bureau of Marijuana Control California Code
of Regulations Title 16, Division 42, section 5331:
1. If the cultivator’s, manufacturer’s, or distributor’s product labeling says that the sample
contains discrete terpenes, the laboratory shall test for those terpenes. The testing
laboratory shall report to one-hundredth of a percent the concentration in percentage in
the certificate of analysis.
2. The laboratory shall also report a terpene measurement for a terpene requested to be
tested for by the requester of the laboratory test.
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Certificate of Analysis
The laboratory shall generate a certificate of analysis for each primary sample of a batch that it
tests and provide the certificate of analysis to the distributor, the licensee who holds title to the
batch, and the bureau within 2 business days of the completion of the analyses.
The certificate of analysis shall, at a minimum, contain the following information:
1. Licensed laboratory’s name, mailing address, and physical address;
2. Sample-identifying information, including matrix type and unique sample identifiers;
3. Sample history, including date collected, date received by laboratory, and date or dates of
sample preparations and analyses;
4. The identity of the test methods used to analyze cannabinoids, residual solvents,
pesticides, microbiological contaminants, mycotoxins, heavy metals, and, if applicable,
terpenes;
5. Test results for sample homogeneity, if applicable; cannabinoids; residual solvents;
pesticides; microbiological contamination; mycotoxins; and, if applicable, terpenes;
6. Test results for moisture content and water activity, and filth and foreign material;
7. The reporting limit for each analyte tested;
8. The total primary sample weight in grams, reported to 3 significant figures;
9. Whether the primary sample and batch “passed” or “failed” laboratory testing; and
10. The licensee for whom the testing was done, including license number, name, and batch
number.
The laboratory shall also report any other claim made by the manufacturer regarding any other
cannabinoids present in the sample.
The laboratory shall validate the accuracy of the information contained in the certificate of
analysis, and the laboratory director shall sign and date the certificate of analysis.
Failure to provide timely and accurate data is grounds for discipline.
A batch may not be retested following a failed testing unless it has gone through a remediation
process. Prior to retesting, the distributor shall provide to the testing laboratory a document
specifying how the product was remediated. This document shall be kept by the laboratory and
be available for inspection by the bureau.
1.10.1 (b) Procedures for Transporting Cannabis Field Samples
Triple E Labs will follow the California Code of Regulations §5709. Laboratory Transportation
of Cannabis Goods Samples as it handles and transports cannabis samples. The regulation is
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incorporated in the business plan by reference to the regulation website url and Triple E further
promises to develop all policies and procedures according to this regulation.
16 CCR § 5709
§ 5709. Laboratory Transportation of Cannabis Goods Samples.
https://govt.westlaw.com/calregs/Document/I4BFC0EA3774743D48994F8E12E0F18EA?viewT
ype=FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextD
ata=(sc.Default)
Triple E Labs will hold any distributors with which it works accountable to the regulations of the
California Cannabis Distributors and will not agree to transport any cannabis on behalf of
distributors as a licensed laboratory.
The regulation is incorporated be reference to the website at the following url:
http://www.calcannabislaw.org/california-cannabis-business-license-compliance-distributor-
transport-only-medicinal-m-type-13
1.10.1 (c) Chain of Custody for Field Samples
Triple E Labs will utilize software for processing, tracking, and archiving testing data. The
software will control and maintain the chain of custody for all samples and tests. Activity date
and time, user, actions performed, custodian, original values, current values, and delta will be
monitored, tracked by the chain of custody function. A screenshot of the chain of custody
software is provided below.
A digital form such as the sample below will be developed for sample chain of custody.
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Good laboratory practice is demonstrated in the chart below and is representative of the 3E plan.
1.10.1(d) QC Procedures
All state and local regulations will be followed in maintaining Quality Control to ensure
comprehensive cannabis tracking, enable control & monitoring, and enhance transparency in the
cannabis industry. To that end, we will utilize software to track and monitor quality control as we
plan in other areas. This will enable us to report to the state and remain compliant as well as
transfer sample and testing data directly to the regulatory software like Metrc, SICPA, BioTrack,
Leaf, and ERPs.
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1.10.1 (e) Lab Director Responsibilities
The Triple E Lab Director will supervise all lab activities according to the license type issued.
Below are the primary Lab Director duties and responsibilities.
• Analyze, supervise and manage all Laboratory Department activities.
• Plan, prepare and supervise laboratory services relating to national standards and
organization’s policies.
• Attain and manage apt and needed accreditation.
• Provide and perform access to laboratory personnel for consultation and determine
operational troubles in timely manner.
• Establish, execute, review and evaluate laboratory procedures and policies and
procedures for operating functions of laboratory.
• Perform analytic, pre and post analytic functions to attain departmental goals and ensure
stable conformance by laboratory staff.
• Perform responsibility of Laboratory Document Control.
• Head responsibility to maintain laboratory records, reports and files.
• Perform activities to fulfill report requirements and record retention as established by
accrediting agencies.
• Support Director with laboratory activities and operation.
• Prepare, implement and evaluate capital budgets and annual operating.
• Analyze and supervise CPT coding and submit lab charges to billing on time.
• Analyze and suggest selected purchase equipment and monitor maintenance and service
agreement.
• Manage laboratory purchase of inventory, storage and supplies usage.
• Manage and resolve administrative and technical problems.
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1.10.1 (f) Location & Procedures for Storing Cannabis Products
In building Triple E Labs, FMBCC will follow the legal and regulatory guidance provided by the
appropriate regulating bodies, many of which are cited in other parts of the business plan. We
will utilize industry standard lab casework and cabinets in configurations that are designed for
the final space selected for the lab. They will furnish the lab space with the proper instruments
and equipment necessary to comply with state laws and environmental regulations, as well as
provide a safe environment for Triple E employees. An example of such industry standard
solutions is OnePointe Solutions which specializes in cannabis testing lab design, furniture, and
casework solutions.
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Social Equity Policy & Local Equity Program (Section 2)
Commitment to a program that considers race, ethnicity, and economic
mobility
2.1 Commitment to a Living Wage
Triple E Labs is committed to providing a minimum of a Living Wage for all employees. A Li ving Wage is defined as
financial compensation that reflects what individuals need to support themselves and their families above the
poverty line, based on the actual costs of living in a specific community. A Living Wage helps with the basic and
essential costs of living and helps to provide an adequate standard of living.
Triple E Labs will use the Living Wage Calculator for Fresno County, California as the basic tool for determining the
minimum Living Wage it needs to pay our employees.
Triple E Labs w ill conduct an annual review of the cost of living in our communities and update the living wage we
pay to our employees when the cost of living changes.
2.2 Employee Benefits
Employee s of Triple E Labs will be eligible to participate in various frin ge benefit plans offered by the company to
full-time employees, including the following: group health insurance--medical, dental and vision, in accordance
with the company's current benefit plan requirements. Employees will be eligible for 2 weeks paid vacation time off
plus holidays and annual sick days. Triple E Labs may change its benefit plans from time to time in accordance with
State and Federal laws. As an equal opportunity employer, Triple E Labs will utilize the EEOC guidelines, and
related state and federal laws.
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2.3 Compensation for Continuing Education
Triple E Labs agrees to pay for Employee’s reasonable, required continuing education. Triple E Labs, shall reimburse
Employee for any and all reasonable deductible expenses paid for these continuing educational benefits, which the
IRS allows Employer to deduct as a legitimate expense that Employee requires in order to remain current and
competent. An estimate of any such expenses shall be submitted to Triple E Labs, CEO for approval in advance of
Emplo yee incurring them.
2.4 Recruiting Individuals Meeting Social Policy Section 9-3316(b)(1) of FMC
Triple E Labs will partner with organizations in its current network of community based organizations like Fresno
Metr o Black C hamber of Commerce in addition to organizations such as VANGST to advertise open positions within
the organization. VANGST applicants will have full background check and their I-9 verified prior to being employed
by Triple E Labs. Triple E Labs will also advertise their open position s on social media and our webpage. The Triple
E Labs will also facilitate job fairs in the community and virtually.
2.5 Locally Managed Enterprise
Triple E Labs is committed to ensuring that the organization remains a locally owned enterprise. The Triple E Labs
is organized with local social equity applicant owner who has 51% equity ownership in the business. The remaining
49% of ownership will be offered to other local individuals and employees.
2.6 Personnel
As outlined in section 1 of the Business Plan, the organizational chart
includes the following structure:
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The Executive Team includes: the social equity applicant, James O. Archie; FMBCC Chief Executive Officer, Tara
Lynn Gray; Bruce Heights, Chief Financial Officer; Dr. Cassandra Little, Workforce Development & Training; and
Renita Young, Lab Director. The qualifications of the core team are demonstrated in the resumes that are inclu ded
in Section of the Business Plan.
The Laboratory team will be headed by Renita Young and she will be responsible for hiring qualified staff members
and technicians for various positions within the laboratory up to and including Lab Technicians (8), w orking within
the lab .
Dr. Cassandra Little will oversee the onboarding, training and recruiting of all personnel.
A Marketing and communications manager will be hired to develop and circulate marketing materials to enhance
community engagement and develop collaborative community partners.
A Sales Manager will be hired to design and develop a sales strategy tha t will grow the organization.
Security systems and personnel will be utilized in every public facing part of the lab and protocols plus equipment
will guard the safety of the lab operations and personnel.
2.7 Labor Peace Agreement
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Labor Peace Agreement Attestation for Applicants
DEPARTMENT OF CANNABIS REGULATION
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LABOR PEACE AGREEMENT ATTESTATION FOR APPLICANTS
Instru ctions: Fresno County SEC. 9-3316 provides that if the state adopts a law requiring a state Cannabis License
Applicant to agree to enter into a labor peace agreement with any bona-fide labor organization who requests such
an agreement, then an Applicant for a City License shall meet that same requirement, with the exception that the
requirement applies to Applicants with 10 or more Employees. Under Regulation No. 3(A)(15), an Applicant shall
attest that it has entered into a labor peace agreement if the Applicant was requested to do so by a bona-fide labor
organization. If a bona-fide labor organization has yet to request a labor peace agreement from the Applicant, then
the Applicant shall attest that it will enter into labor peace Agreement if in the future a bona-fide labor organization
so requests.
A bon a -fide labor organization means a bona-fide union (1) that actually represents employees in California as to
wages, hours, and working conditions, (2) whose officers have been elected by secret ballot or otherwise in a
manner consistent with federal law, and (3) that is free of domination or interference by any employer and has
received no improper assistance or support from any employer. A labor peace agreement means an agreement as
defined in Cal. Bus. & Prof. Code Sec. 260001(x).
Applicant shall complete one of the sections below that corresponds to the current status of its compliance with
the labor peace agreement requirement under Regulation No. 3(A)(15).
Applicant that has entered into a labor peace agreement:
1. On _____________________ (date), _____________________ (Applicant), entered into a labor
peace agreement with __________________ (bona-fide labor organization).
2. The bona -fide labor organization’s c ontact information is as follows:
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_____________________________________ (Name of bona -fide labor organization)
_____________________________________ (Contact person and
title)_____________________________________ (Contact person’s address)
_____________________________________ (Contact person’s
email)_____________________________________ (Contact person’s phone number)
3. Applicant will submit a copy of the page of the labor peace agreement that contains signatures of the union
representative and the Applicant.
Applicant with 10 or more employees that has been contacted by a bona-fide labor organization but that has not
entered into a labor peace agreement:
1. On _____________________ (date), _____________________ (Applicant), was contacted by
__________________ (bona-fide labor organization) with a request to enter into a labor peace
agreement, but Applicant has not agreed to do so.
2. The bona -fide labor organization’s co ntact information is as follows:
_____________________________________ (Name of bona-fide labor organization)
_____________________________________ (Contact person and
title)_____________________________________ (Contact person’s address)
_____________________________________ (Contact person’s email)
_____________________________________ (Contact person’s phone number)
3. Applicant understands it shall not meet the requirements for a City License if it does not enter into a labor
peace agreement if requested to do so by a bona-fide labor organization.
City of Fresno, Department of Cannabis Regulation
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Applicant with 10 or more Employees that has not been contacted by a bona-fide labor organization and has not
entered into a labor peace agreement:
1.
2.
3.
_____________________ (Applicant) has not yet been contacted by a bona-fide labor organization with a
request to enter into a labor peace agreement and it has not entered into a labor peace agreement.
Applicant will enter into a labor peace agreement that meets the requirements for a labor peace agreement.
Applicant will submit a copy of the page of the labor peace agreement that contains signatures of the union
representative and the Applicant upon execution.
Applicant with less than 10 employees that has not entered into a labor peace agreement:
1. _____________________ (Applicant) currently employs less than 10 employees.
2. If Applicant later employs 10 or more employees, it will enter into a labor peace agreement if requested to do
so by a bona-fide labor organization.
3. Applicant will submit a copy of the page of the labor peace agreement that contains signatures of the union
representative and the Applicant upon execution.
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By signing this form and providing supp orting documentation, you are certifying under penalty of perjury that the
information you supply is true and accurate to the best of your knowledge. Submission of false or misleading
information may result in the denial of your application.
____________________________________________________ SIGNATURE OF APPLICANT OR
DULY-AUTHORIZED AGENT
Print Name: _____________________________________
Business Entity/DBA: __________________________________
Application No.: __________________________
Business Premises Address:
__________________________________________________________
2.8.1 Workforce Development Plan
The Triple E Labs is committed to ensuring that at least 30% of the organization’s employees will be local hires. It is
the belief that whatever community Triple E Labs would work in, they would commit to hiring local community
members. The Triple E Labs believes that having local employees working on the project would help to improve the
quality of the work because the local workers would take more pride working on a project in their community. Not
only do will Triple E Labs stress hiring local employees but we actually track every project to see how many local
employees are on the job, helping us to reinforce our commitment to local.
2.8.2 Commitment to Apprenticeships & Continuing Education
The Triple E Labs recognize apprenticeships and continuing education as a vital education and training component
and extremely important part of the program. Apprenticeships pave the way for enhanced career options, and
lifelong learning. This option provides the employee with an opportunity to be upskilled while learning on the job
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and creates a pathway to prosperity which is in alignment with the Fresno Metro Black Chamber of Commerce
mission and one of the foundational reasons for pursuing this opportunity.
2.8.3 Commitment to Living Wage
Triple E Labs is committed to providing a minimum of a Living Wage for all employees. A Living Wage is defined as
financial compensation that reflects what individuals need to support themselves and their families above the
poverty line, based on the actual costs of living in a specific community. A Living Wage helps with the basic and
essential costs of living and helps to provide an adequate standard of living.
Triple E Labs will use the Living Wage Calculator for Fresno County, California as the basic tool for determining the
minimum Living Wage it needs to pay our employees.
Triple E Labs will conduct an annual review of the cost of living in our communities and update the living wage we
pay to our employees when the cost -of-living changes.
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Neighborhood Compatibility Plan
Triple E Labs is committed to neighborhood compatibility.
3.1 Noise Complaints
Triple E Labs is committed to the "Good Neighbor" concept. We are committed to addressing
any and all complaints from community members. All complaints will be documented and
presented to the Operations Manager to be addressed expeditiously. Triple E Labs is committed
to:
1. Provide outside lighting in a manner that illuminates the outside street and sidewalk areas
and adjacent parking as appropriate.
2. Provide adequate and appropriate ventilation to prevent any significant noxious or
offensive odors from escaping the premises.
3. Maintain the premises, adjacent sidewalk and/or alley in good condition at all times.
4. Prohibit patrons from double-parking directly outside the premises.
5. Prohibit loitering in or around the premises.
6. Prohibit littering in or around the premises.
7. Prohibit the consumption of cannabis products around the premises.
8. Post notices on the premises that:
1. Direct patrons to leave the establishment and neighborhood peaceful and in an
orderly fashion.
2. Direct patrons to not litter or block driveways.
3. Advise individuals of the prohibition on loitering.
4. Advise individuals that smoking of cannabis is prohibited in public places.
9. Ensure notices are clear, well-lit, prominently displayed and maintained at all public
entrances to and exits from the establishment.
10. Secure the premises within 50 feet of any public entrance and exit.
3.2 Security Standard Operating Procedures
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Policy: Daily Opening Inspection
It is the responsibility of the Director of Security to adopt and implement the Opening Inspection
policies and procedures. Security Personnel and a manager will perform or oversee a daily
inspection to ensure compliance with the rules set forth by the Bureau and all applicable state
and local laws, regulations, ordinances, and other requirements. The manager will remain a safe
distance away from the Facility’s entrance while Security Personnel enters and conducts a walk-
through of the Facility to be certain it is safe to enter. The development of a corrective action,
delegation of duties, and the mandated expedience of such corrective actions will be determined
by the appropriate manager.
Policy: Surveillance and Monitoring
The Director of Security will install security cameras to monitor and record all areas of the
Facility including all entrances and exits into and out of the exterior of the Facility, recording
both indoor and outdoor vantage points. Policy Citation: 16-42-5044(e)(5). The Distribution
Facility will be equipped with Closed Circuit Television (CCTV) cameras, that may be
supplemented with fixed and pan-tilt-zoom (PTZ) cameras. CCTV cameras can be monitored in
real-time within the Security Operating Center and at remote monitoring stations. Video
surveillance footage will be kept for a minimum of 90 days, located within the Security Room.
Policy Citation: 16-42-5044(i). All outdoor lighting used for security purposes will be shielded
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and downward facing. The video surveillance system and all surveillance system capabilities and
features described in this SOP will operate 24 hours per day, 7 days per week, at 15 frames per
second. Policy Citation: 16-42-5044(g).
Purpose: This document describes the specifications and features of the video surveillance
system installed at Triple E Lab’s Facility, as well as the policies applicable to video surveillance
system operation, maintenance, and required reporting.
Scope: Distribution, Security
Employee Responsible: Director of Security
Definitions: Access Control Program – PC-based software and hardware system to monitor and
control access to secured areas of the Facility. Facility – COMPANY’s Licensed Distribution
Facility. Security Room – Central hub for security personnel. Houses all camera monitors, the
Access Control Program, Employee Badge Access Program, Visitor Management System and
other essential security programs. Also serves as Incident Command Center during the course of
an emergency.
Resources: Alarm system, security cameras
Policy: Security Personnel Training
In addition to new employee and annual training, Security Personnel will also be required to
complete additional training components. Security personnel responsibility in creating a safe
environment: Badge Access Policy; Employee Access Credential Policy; and Prevention of loss,
theft and diversion.
Purpose: This document provides an overview of the topics covered during company orientation,
new employee training, and annual training courses in security-related matters.
Scope: Distribution, Security
Employee Responsible: Human Resources Manager and Security Manager
Definitions:
Security Personnel – As directed and assigned; responsible for the monitoring and patrolling of
the retail Facility, including enforcing shoplifting procedures, as well as other security duties. In
some locations and/or in certain circumstances, security personnel may be trained to check-in
consumers. All security personnel hired or contracted for by Triple E Labs will comply with
Chapters 11.4 and 11.5 of Division 3 of the Business and Professions Code. Access Control
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Program – PC- based software and hardware system to monitor and control access to secured
areas of the Facility. Facility – Triple E Labs’s Licensed Distribution Facility. Security Room –
Central hub for security personnel. Houses all camera monitors, the Access Control Program,
Employee Badge Access Program, Visitor Management System and other essential security
programs. Also serves as Incident Command Center during the course of an emergency.
Resources: N/A
Policy: Incident Response Drill
Triple E Labs will carry out incident response drills at least quarterly.
Purpose: The purpose of this SOP is to identify any problems with incident response procedures.
Scope: Distribution, Security
Employee Responsible: Security Manager
Definitions: N/A
Resources: Incident Log
Physical Security Plan
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3.3 Odor Mitigation Practices
Policy: Odor Mitigation
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The Ventilation System should be inspected on a weekly basis. Light cleaning and maintenance
will be performed at least monthly, or as necessary, when indicated by the weekly inspection.
Heavy cleaning should be completed at least twice per year by a professional HVAC provider.
The Maintenance Manager performs a visual sanitation inspection after light cleaning and
maintenance is completed by assigned distribution personnel. It is the responsibility of the
Maintenance Manager to adopt, implement, and monitor the enforcement of Ventilation System
Cleaning and Maintenance SOP and to document the findings and any corrective actions in the
Facility Maintenance Log.
Purpose: The written Ventilation System Cleaning and Maintenance SOP describes the
procedures that will be followed when an employee engages in Odor Mitigation, Ventilation
System Cleaning and Maintenance.
Scope: Cultivation, Distribution, Non-Volatile Manufacturing
Employee Responsible: Maintenance Manager
Definitions:
Light Cleaning – A process that occurs when an inspection demonstrates dirt that can be
removed using a bristle brush or low-pressure air and a HEPA filtered vacuum cleaner to remove
airborne dirt before it enters the occupied space. Light cleaning can be performed by
maintenance personnel at the end of a business day since it creates no to minimal noise, odors
and airborne hazardous materials. Heavy Cleaning – Cleaning activities that involve the use of
larger industrial cleaning equipment and should be conducted by a professional HVAC provider
during non-operational hours when the Facility is not being used.
Resources: HEPA filtered vacuum cleaner, low-pressure air gun, flashlight, approved sanitizing
agent, absorbent washcloth or other approved cleaning rag
3.4 Potential sources of odor
Triple E Labs is aware of the challenges with identifying potential sources of odors. We are
committed to collaborating with experts who will assist Triple E Labs with using products that
will cause the least amount of odor in the community. Triple E Labs will participate in an
extensive odor mitigation planning that will include the design of our facility and the instillation
of our HVAC system.
3.5 Odor Control techniques
Odor Control
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1. Once weekly, ensure all ventilation systems are properly balanced to ensure minimum
movement of odors from one area to another and minimum fresh air requirements are met
for all rooms.
2. Once weekly, perform maintenance on all UV and insect filters in accordance with
manufacturers’ recommendations.
3. Once weekly, check all air intake openings corrosion-resistant screens, louvers, or grilles
for cleanliness and desired functionality.
4. Once weekly, clean intake and exhaust vents in rooms.
5. Once weekly, examine duct work behind supply and return vents for accumulated dust
and or mold.
6. Once weekly, clean the coils by using a low-pressure air gun to blow air through the coil
and collect debris using the HEPA vacuum cleaner.
7. Once weekly, clean the drip pan and condensate the drain line.
8. Once weekly, clean and inspect the dampers and mechanical connections by using a
damp cloth containing water and an approved detergent to remove dirt and dust from
accessible surfaces. Use a low-pressure air gun to dislodge debris while holding the
HEPA exhaust hose downwind to collect the dirt removed.
9. Once weekly, check that the fresh air intake is not blocked and no standing water or mold
is accumulating near the intake.
10. Once a week, clean or replace the filters by using the HEPA filtered vacuum to clean the
surface of the filters, and removing the filter and inspecting it with a flashlight or other
light source. When no light is visible, replace the filter. When light is visible, do not
replace the filter unless the date of replacement listed in the Facility Maintenance Log has
passed. When replacing a filter, mark the date the filter was replaced on the filter itself
and in the Facility Maintenance Log.
3.6 Proposed Staff Odor Training
Triple E Labs will facilitate a rigorous staff training program to ensure that all staff are
sufficiently trained in all aspects of the business operations, particularly product handling and
odor control. Staff training will be comprehensive and, specifically, for odor management will
include understanding of the odor management system, basic maintenance and product handling
to reduce odor output. Triple E Labs will require all employees to undergo a course in
"Cannabis Odor Control" in which they will learn the following:
• How different odor control tools, equipment and products work
• Safety concerns related to odor control
• Mastering effective odor controls strategies
• Odor system maintenance
• Maintaining records for the Odor Management System
• Strategies to actively reduce odor
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• Reporting issues to management
3.7 Waste Management
Policy:
It is the responsibility of Triple E Labs to properly evaluate waste to determine if it should be
designated a hazardous waste. At no time during the 72 hour holding period may the cannabis be
handled, moved, or rendered into cannabis waste. Cannabis waste will NOT be sold. All
cannabis waste will be rendered unusable and unrecognizable and no product will be disposed of
in its packaging. Policy Citation: 17-01-40290(c). Cannabis waste will NOT be disposed of in an
unsecured waste receptacle, whether in the control of Triple E Labs or not.
Purpose: This document describes responsibilities that shall be implemented by all members of
the manufacturing department as a condition of employment regarding the quarantine and
destruction of cannabis and cannabis products. The purpose of this document is to ensure all
employees follow the Waste Management policies and procedures.
Scope: Manufacturing, QC
Employee Responsible: Director of Manufacturing
Definitions: N/A
Resources: Scale, Designated Cannabis Waste Holding Area, Desired Personal Protective
Equipment, Computer
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Community Benefits and Investment Plan
Triple E Labs is committed investing in the local
community.
7.1 Social Responsibility
The harms of marijuana have been devas tating, particularly for BIPOC people who
have suffered dramatic rates of arrest, criminalization, mass incarceration, heavy-
handed policing, seizure of property with little or no due process, and large-scale
deportations. Given this history, Triple E Labs acknowledge s t hat we have some
responsibility to support repairing the harms of that prohibition.
Repairing the harms of prohibition for Triple E Labs will entail:
1) ensuring that the harm is not continuing;
2) supporting the development of an accurate historical record of the harms caused
by marijuana prohibition, including how it has oppressed BIPOC communities; and
3) supporting initiatives that create a remedy for past harms.
Triple E Labs will seek measures that will further repair the harms of prohibition
inc lude, among others: resisting attempts to legislatively or administratively
exclude people with marijuana-related arrests or convictions from working in or
otherwise accessing the sector or from participating in home grow or social
cannabis clubs; promotin g automatic expungement of records for people with
marijuana convictions; investing in the communities that have been most impacted
by prohibition; and making it possible for communities that have been most
impacted by prohibition to participate in the new industry, e.g., by removing
barriers to entry and promoting racial equity. Triple E Labs will develop policy and
intentionally promote and participate in hiring formerly incarcerated community
members. All hiring practices will be inclusive and equitable .
Community Investment
Triple E Labs will develop a structured plan that will afford community members
and employees an opportunity to become stockholders in the organization. Our
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program will provide ongoing educational workshops and trainings that will
address and update policy and legal information regarding Cannabis legislation.
Triple E Labs will develop an executive research committee with its main goal being
to address the past legislation on cannabis impact on society, including income
inequalit y, diversity, and the environment. We understand that the biggest social
justice and community issue includes racial equity and reparations, overturning
cannabis incarceration and convictions, environmental impact on cultivation, and
continuing the fight to end the broader war on drugs.
7.1.1 Community Expungement clinics and outreach services
Triple E Labs will partner with a reentry Attorney to develop an extensive legal
department that will partner with community legal aid agencies to provide ongoing
expungement clinics and assist with completing legal paperwork that will eliminate
barriers to employment and housing. Triple E Labs legal team will provide free
ongoing legal advice and services to community members.
7.1.2 Environmentally sustainability
Triple E Labs recognize their role in minimizing negative environmental impacts
and shall identify material environmental risks, impacts and opportunities for their
operations, and develop goals, policies, programs and metrics to continually
improve results in the following Impact Areas:
1. Greenhouse Gas Emissions (GHG) management systems that measure and
minimize volume and intensity of emissions.
2. Water management, including improvements in consumption, recycling and
quality.
3. Packaging materials and/ or waste reduction strategies to reduce
consumption of raw materials
and related environmental impacts.
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4. Agricultural practices to reduce human and environmental health impacts,
including soil and pest management.
7.1.3 Utilization of vacant buildings in blighted areas of the city
Triple E Labs is committed to researching and utilizing vacant buildings in blighted
areas in the community. Triple E Labs is investigating the EPA Brownfield Program
that is focused on empowering communities and stakeholders, like ourselves to
work together to prevent, assess, safely clean up, and sustainably reuse
brownfields.
7.2. Public Health Outreach & Education
Educating community members on the safe and responsible consumption of
marijuana is essential to the success of the Triple E Labs organization. We have
accumulated a vast body of knowledge, and will educate our employees and
community members based on our research and experience foundation
supplemented by available medical and scientific empirical data. We believe
education is the most important piece of every community engagement. We plan to
accomplish this through education pamphlets, private consultations, workshops,
and advocacy.
Triple E Labs will create several educational pamphlets and handouts which are
available to every community member. We will outline basic guidelines for safe
consumption, rules on where consumption is legal, possession limits, the
importance of not driving while impaired, and how best to keep marijuana out of
the hands of children and away from pets. We will provide ongoing education to
underage youth regarding the safety and legal issues surrounding cannabis. We will
partner with and sponsor events for Students. We will actively participate in local
and national legislation to further cannabis education.