Seed-to-Sale Tracking Standard Operating Procedure
Comprehensive protocol for cannabis inventory tracking compliance across METRC, BioTrackTHC, and state-specific systems
Critical Compliance Requirements
- • All plant movements must be recorded within 24 hours in state tracking system
- • Inventory discrepancies exceeding 3% require immediate regulatory notification
- • Daily reconciliation between physical inventory and tracking system mandatory
- • Backup documentation required for all system entries (photos, weights, batch IDs)
- • System downtime procedures must be documented and approved by state authority
1Tracking System Overview
State-Mandated Systems
METRC (Marijuana Enforcement Tracking Reporting Compliance)
Used in: CA, CO, MI, MA, OR, NV, AK, MD, ME, MT, OH, OK
- • RFID tag-based tracking (plant and package tags)
- • API integration available for licensed software
- • Real-time inventory synchronization required
- • Manifest generation for all transfers
BioTrackTHC
Used in: WA, IL, NM, HI, ND
- • Barcode-based inventory tracking
- • Web portal and mobile app access
- • Batch-level tracking for cultivation
- • Integrated lab result reporting
System Access & Credentials
All employees with inventory responsibilities must have individual login credentials. Shared logins are prohibited and constitute a compliance violation in most jurisdictions.
- Maintain current employee roster with system access levels
- Revoke access within 24 hours of employee termination
- Document all credential changes in personnel files
- Implement two-factor authentication where available
2Plant Tracking Protocol
Immature Plant Phase (Clone/Seedling)
Initial Entry Requirements
- Record source (mother plant ID, seed lot number, or vendor)
- Propagation date and method (clone, seed)
- Strain/cultivar name and genetic lineage
- Growing medium and container size
- Assigned batch ID (group tracking permitted in most states)
Batch Tracking Limits
Most states allow batch tracking for immature plants (typically up to 100 plants per batch). Document batch creation date, strain, and initial count. Update batch count within 24 hours of any plant destruction or transfer.
Vegetative & Flowering Phase (Individual Tracking)
Tag Assignment Protocol
- METRC: Affix RFID plant tag to main stem or container within 24 hours of transition to vegetative phase
- BioTrackTHC: Print and attach barcode label to plant container
- Verify tag scan/read functionality before finalizing in system
- Document tag ID, plant strain, and transition date
- Photograph tagged plant for backup records
Phase Change Documentation
Record all phase transitions (immature → vegetative → flowering) within 24 hours:
- Date and time of phase change
- Plant height and health status
- Growing location (room/zone ID)
- Responsible employee ID
Plant Destruction & Waste
All plant destruction must be recorded in the tracking system before physical disposal. Most states require waste to be rendered unusable and unrecognizable.
- Document reason for destruction (male plant, disease, pest infestation, quality failure)
- Record wet weight before rendering
- Mix with non-cannabis waste (50% minimum in most states) — coffee grounds, soil, grease
- Photograph waste mixture before disposal
- Obtain waste manifest signature from authorized employee
- Retain disposal records for minimum 7 years
3Harvest & Processing Tracking
Harvest Documentation
Required Data Points
- Harvest date and time
- Plant tag IDs included in harvest batch
- Wet weight (total and per-plant if required by state)
- Assigned harvest batch ID
- Drying location and method
- Responsible employee(s)
Weight Loss Documentation
Most states expect 70-80% weight loss from wet to dry. Deviations exceeding 10% may trigger compliance review. Document environmental conditions (temperature, humidity) during drying period.
Package Creation & Labeling
Package Tag Assignment
- Create package in tracking system before physical packaging
- Assign RFID/barcode package tag
- Record source harvest batch ID(s)
- Document net weight (to 0.01g precision)
- Specify product type (flower, trim, shake, pre-roll, etc.)
- Enter strain name and cannabinoid profile (if tested)
Package Adjustments
Any weight adjustment to an existing package requires system documentation:
- Reason for adjustment (sampling, testing, repackaging)
- New net weight
- Adjustment date and employee ID
- Destination of removed material (waste, testing, new package)
4Transfer Manifests & Transportation
Manifest Creation Requirements
All transfers between licensed facilities require a state-generated manifest. Manifests must be created in the tracking system before product leaves the originating facility.
Manifest Data Elements
- Originating facility license number and address
- Destination facility license number and address
- Departure date/time and estimated arrival date/time
- Transporter information (name, license, vehicle details)
- Package tag IDs and quantities
- Product types and total weights
- Route information (if required by state)
Receiving Protocol
Acceptance Checklist
- Verify manifest number matches physical paperwork
- Scan/count all package tags listed on manifest
- Inspect packages for damage or tampering
- Weigh packages and compare to manifest weights (±3% tolerance typical)
- Accept or reject transfer in tracking system within 24 hours
- Document any discrepancies with photos and written notes
Discrepancy Reporting
Discrepancies exceeding state tolerance (typically 3% weight variance or missing packages) must be reported to the regulatory authority within 24 hours. Retain all documentation and contact originating facility immediately.
5Daily Inventory Reconciliation
Reconciliation Procedure
Daily reconciliation between physical inventory and tracking system records is mandatory in most jurisdictions. Assign a dedicated employee to perform reconciliation at the same time each day.
Daily Checklist
- Generate inventory report from tracking system (plants, packages, waste)
- Physically count all plants in each growth phase
- Scan all package tags and verify weights for high-value inventory
- Compare physical counts to system records
- Investigate and document any discrepancies
- Update system records if errors identified
- Sign and date reconciliation log
Acceptable Variance Thresholds
Most states allow minor variances without immediate reporting:
- Plant count: 0% variance (must match exactly)
- Package weight: ±3% variance (moisture loss, scale calibration)
- Waste: ±5% variance (material adherence, moisture)
Variances exceeding thresholds require regulatory notification within 24 hours.
6System Downtime & Backup Procedures
Manual Documentation Protocol
When the tracking system is unavailable, all inventory activities must be documented manually using pre-approved backup forms. Most states require regulatory notification if downtime exceeds 4 hours.
- Use pre-printed backup forms (approved by state authority)
- Record all data points required by tracking system
- Photograph all activities (plant movements, harvests, transfers)
- Store backup documentation in secure, designated location
- Enter all manual records into system within 24 hours of restoration
- Retain backup forms for minimum 7 years
Downtime Notification
If system downtime exceeds state threshold (typically 4-8 hours), notify regulatory authority via email or phone. Include estimated restoration time and confirmation that manual backup procedures are in effect.
7Audit Preparation & Record Retention
Required Documentation
Maintain organized records for all tracking system activities. Most states require 7-year retention for all inventory documentation.
- Daily reconciliation logs (signed and dated)
- Transfer manifests (originating and receiving copies)
- Waste disposal records and photos
- System downtime backup forms
- Discrepancy investigation reports
- Employee training records for tracking system use
- Tag inventory logs (unused tags, damaged tags)
- System access logs and credential changes
Common Audit Findings
Avoid these frequent compliance violations:
- Late system entries (exceeding 24-hour requirement)
- Missing or illegible package tags
- Inventory discrepancies without investigation documentation
- Shared employee login credentials
- Incomplete waste disposal records
- Transfer manifest discrepancies not reported
- Missing backup documentation for system downtime
Document Information
Last Updated: January 2025
Version: 3.2
Reviewed By: Cannabis Regulatory Compliance Team
This SOP is a general template. Consult your state's specific regulations and legal counsel to ensure full compliance. State requirements vary significantly — verify all procedures with your regulatory authority.