Application Addendum:
On-Site Consumption Plan
The Lounge at Mercy
7950 Redwood Drive, Suites #15 & #16
Cotati, CA 94931
APN # 144-060-006
Table of Contents
Table of Contents 2
Introduction 3
Project Description 3
Owner Qualifications 4
Operating Plan for The Lounge at Mercy Wellness 5
Safe Consumption 9
Safe Transport 10
Noise 10
Odor Mitigation Plan 10
Security Measures 11
Staffing 12
Green Waste Management 14
Sanitization 14
Facility Cleanliness 15
Compliance Inspections 15
Events 15
Modified Opening Plan 16
Community Benefits 16
Safety Plan 16
Attachment A:
Site and Floor Plans 17
Attachment B:
Safe Consumption Policy 20
Policy and Purpose 21
Consumption Education 21
Consumption by Inhalation 21
Consumption of Joints (aka PreRoll) 22
Consumption by Vaping 23
Consumption of Concentrates 23
Consumption of Tinctures 23
Topical Application 23
Consumption of Edibles 23
Consumption of Beverages 24
Cannabis and Driving 24
Customer Guidance and Assessing Impairment 25
Customer Responsibility 26
Work Cited 27
Attachment C: Safety Plan prepared by E.S.P. Alarms Inc 28 2 Introduction
Thank you for considering our application amendment to become one of the first microbusinesses in the State of California to offer a complete farm to taste experience. Mercy Wellness of Cotati and its owner Brandon Levine is a pioneer in the cannabis industry. We feel very fortunate that the City of Cotati is progressive and has entrusted Mercy Wellness to operate a dispensing facility for over 11 years.
With the passing of Prop 64, cannabis became legal statewide in 2018. The voters spoke, they want cannabis and Mercy Wellness is here to give them what they need in a safe and professional manner.
While the recreational cannabis industry has been in existence for over four years, Mercy Wellness believes that there are still many opportunities to improve where, when, and how cannabis is sold as well as consumed.
We believe that adding an On-Site Consumption Lounge is an opportunity for the City of Cotati to be at the forefront of innovation and a destination for tourists for years to come. We hope this document reflects the amount of time, energy and resources invested in this process. We are very grateful for your consideration and hope to meet the high standards of the Planning Commission and City Council.
Mercy Wellness’ goal is to fill the demand for a wellness and education-focused cannabis retail experience for locals and tourists alike. We feel that we’re in an ideal location to add an On-Site Consumption Lounge as the current use is a micro-brewery. We plan to develop and focus on the customer experience that mirrors similar to wineries and other micro-breweries.
Project Description
Mercy Wellness of Cotati is a licensed cannabis microbusiness facility with permits to cultivate, manufacture, and distribute cannabis, as well as conduct retail sales with delivery in the City of Cotati.
We are a company run by cannabis professionals who seek to add a fully operational on-site consumption lounge to our facility.
Our business operates within an existing 40,485-sf commercial building known as Gravenstein Business Center located at 7950 Redwood Drive, Cotati, California. Currently, the dispensary portion of our facility consists of Suites 6, 7, 8,9, 23 and 24 for a total of approximately 8,241 square feet, in which 2,300 square feet of this area is dedicated to the public retail dispensing area.
The cultivation portion consists of Suites 10, 11, 12, 21, and 22 for a total of approximately 5,750 square feet. This facility is not open to the public and no retail sales transactions will take place. These cultivation activities occur in sealed rooms equipped with odor control and air purification systems, as will the entire premise. The cannabis that is cultivated in this facility supplies the Adult-Use market in 3 our adjacent retail dispensary as well as other Retail Dispensaries through licensed Distributors throughout California.
The manufacturing use consists of Suites 25, 26, 27, 28 and 29 for a total of approximately 5,550 square feet. This facility will be manufacturing Adult-Use and Medicinal cannabis. Cannabis will enter the facility as biomass (cannabis leaves) or partially refined oil predesignated for Adult-Use or Medicinal depending on the license of the cultivator.
The distribution use consists of Suites 14, 15, 18, 19, and 20 for a total of approximately 4,961 square feet. This facility distributes Adult-Use and Medicinal cannabis, which is securely transported from licensed cultivation facilities or other distributors for the purpose of distribution, testing and tax collection. This stand-alone distribution acts as a fulfillment center to Mercy Wellness and other licensed retail dispensaries.
The proposed on-site consumption lounge consists of Suites 15 and 16 for a total of 4,566 square feet.
Cannabis products will be delivered by an employee from the retail location to customers for consumption in The Lounge at Mercy. The mission for The Lounge at Mercy is to provide education and experience using clean cannabis products in an above-board professional facility. For more information regarding the building layout and uses, please refer to Attachment A: The Lounge at Mercy Wellness Floor Plan & Site Plan.
We strongly believe in bringing quality cannabis products to our local community and providing educational experiences for customers who are new to cannabis use. Our multifaceted facility is meant to show transparency of the cannabis production process to our consumers so they can trust the quality and care that goes into our products. To build on these principles, we seek to open and operate an on-site consumption lounge on our premises. On-site consumption lounges are the future of the cannabis industry, and allow customers to try new products in a safe, comfortable environment. We want to be at the forefront of this next step in the cannabis sector, and help facilitate an even more positive cannabis environment in the City of Cotati.
Owner Qualifications
Operations are overseen by Brandon Levine as the Executive Director. Brandon has successfully been the Managing Director of Mercy Wellness in Cotati for the past 11-years. His most recent contribution to the cannabis community was serving as a board member of the Cannabis Advisory Group (CAG) where his years of operating experience gave insight to the County of Sonoma and the Board of Supervisors to build and reform commercial cannabis licensing.
The experience and knowledge of the commercial cannabis community also placed Brandon on the Sonoma County Marijuana Technical Advisory Committee (MTAC), also known as the Marijuana Task Force, which includes representatives of nearly every county agency. The MTAC included several 4 working groups such as Agriculture and the Environment, Enforcement and Land Use, Taxation and Revenue, Economic Development and Jobs and Health and Human Services. Together these groups explored many facets of the cannabis industry and its impacts in the community to develop the ordinance that regulates the industry in Sonoma County.
In addition to MTAC, Brandon was a board member of the California Growers Association (CGA). This statewide cannabis lobbying organization was formed in 2015 to protect and promote growers and independent businesses within California’s cannabis industry. CGA works actively on the frontline of monumental policy decisions being made at the state level.
Brandon was also a board member of the Sonoma County Growers Alliance (SCGA) which educates, collaborates and advocates for patient, cultivator and community rights and responsibilities. SCGA works cooperatively with all individuals, businesses and regulatory bodies to ensure that reasonable environmental, social and economic standards are set in place, helping cultivators within the community to participate and thrive responsibly.
In early 2023, SCGA was re-formed as Sonoma County Cannabis Alliance (SCCA). SCCA is a grassroots nonprofit group organized to educate, collaborate and advocate around operator and community rights and responsibilities in the cannabis space. They work cooperatively with individuals, businesses, and regulatory bodies to educate our members and the community and to ensure that reasonable environmental, social and economic standards are set in place, helping cannabis operators within the community to participate and succeed in the regulated cannabis marketplace.
SCCA also brings together industry leaders from a variety of fields and sectors of the supply chain to educate and activate operators and community members. This is where Brandon along with our independent security firm, ESP Pros has mentored many local cannabis operators from other retailers to cultivation, distribution and manufacturing facilities on safety, security. In addition to educating the industry on best practices, Brandon is always making recommendations on how to safely secure a cannabis business.
Operating Plan for The Lounge at Mercy Wellness
Hours of Operation
The operating hours for The Lounge at Mercy Wellness shall be limited to Monday through Sunday, 9:00 a.m. to 10:00 p.m. Monday through Sunday or as further limited by the City of Cotati code
17.42.200. After approval is received The Lounge at Mercy will begin operations on a limited number of days and hours, such as Friday-Sunday, 12 pm - 8pm, etc.
Consumption Operations
The Lounge at Mercy premise Suites #15 and 16 is definite and distinct from where the retail, distribution, manufacturing and cultivation activities occur and will be accessed through a separate 5 entrance. The Lounge at Mercy will not be visible to the public or by any persons under 21-years of age.
Mercy Wellness will only deliver cannabis products to an individual at least 21 years of age and in an amount reasonable for on-site consumption and consistent with personal possession and use limits allowed by the state. Common consumption methods will be used such as smoking, vaping, or ingestion of edible, beverage or application of topical products. There will be no on-site sales of alcohol or tobacco, and no on-site consumption of alcohol or tobacco products by patrons or employees. The Lounge at Mercy will sell merchandise such as apparel and various smoking apparatuses. There will also be various pipes, bongs, volcanos and electronic dab rigs available to rent. The Lounge at Mercy will also hold educational seminars, and host industry and community events.
The Lounge at Mercy will have several indoor areas dedicated for cannabis consumption, as well as an enclosed outdoor patio that are all shown in the proposed Site Plan. The on-site cannabis consumption lounge will be limited to consumption of cannabis by smoking, vaping, topical application, and ingestion and will comply with Chapter 9.31: Smoking and Secondhand Smoke of the Cotati Municipal Code. Smoking, vaping, application of topicals, or ingestion of cannabis, or cannabis products will not be visible from any public place or non age-restricted area.
The Lounge at Mercy will be well-ventilated and partitioned off from access to all other areas of the retail establishment as well as other uses under the approved microbusiness premises. Enclosed smoking areas will be separately ventilated, with sufficient negative pressure, air exchange, odor control/filtration, self-closing sealed doors, and other operational and physical measures to ensure that the general public or other persons outside of the enclosed smoking area are not exposed to secondhand smoke or associated odors. Employee exposure, if any, shall be consistent with State law. In addition, an odor absorbing ventilation and exhaust system will be installed so that odor generated inside the business is not detected outside the property or lease area boundaries, or anywhere on adjacent property, or public rights-of-way, or within any other unit located within the same building as the on-site consumption lounge.
The Lounge at Mercy Wellness will not prepare and serve food for any period of time that state law prohibits non-cannabis food and beverage from being prepared and sold on-site. The Lounge at Mercy understands deviations from a consumption area application related to the preparation and sale of non-cannabis food and beverages are permitted, subject to confirmation by the City of Cotati. If regulations were to change and laws are updated, The Lounge at Mercy will seek permission from the City of Cotati and provide plans for preparing and serving food, as well as nonalcoholic beverages that will complement the cannabis that is being consumed.
At that point The Lounge at Mercy will also obtain a County Health Food Facility Operating Permit issued by the Sonoma County Department of Health Services and abide by all application requirements, inspections and any current or future regulations. The on-site consumption lounge will also comply with all applicable provisions of the California Retail Food Code (Chapter 1 (commencing with Section 113700) of Part 7 of Division 104 of the Health and Safety Code) when preparing and selling 6 non-cannabis food and beverage products. There would then also be designated staff that will only take and serve food and nonalcoholic drink orders. Employees that deliver and serve cannabis will not be taking and delivering food to customers.
Mercy Wellness will clearly post a sign to the exterior entrance to Suite #16 that no person under the age of 21 shall be allowed in the on-site consumption lounge. All persons entering the site, including those representing a regulatory agency, shall present a photo identification verifying that they are 21 years of age or older. The exterior and interior entrances will also have clear and legible posted notice indicating that smoking and vaping of cannabis is prohibited on-site or in the vicinity of the site except in the designated permitted area(s).
The Lounge at Mercy provides a lobby, “waiting area” at the entrance to receive members. This is the only entrance and is controlled by on-site security personnel by way of a secured locked door, a buzz-in electronic/mechanical entry system, and electronic surveillance cameras. The waiting area is controlled by a lounge employee qualified during all hours of operation. Depending on the type of customer any and all individuals will have to present:
If Adult-Use: Valid government issued photo ID whose date of birth is at least 21 years prior to the date of entry.
If Medicinal: Valid California photo ID whose date of birth is at least 21 years prior to the date of entry and a valid doctor’s recommendation which must be a formal letter, written on a doctor’s letterhead, listing the doctor’s medical license information as well as the date the recommendation expires. A recommendation containing these elements written by a doctor in the State of California will allow a patient to gain access to the dispensary after they have been approved and buzzed in through the security system.
The Lounge at Mercy employee will verify all recommendations are valid by way of online verifications, contacting the doctor’s office by telephone or work with a Mercy Customer Service Representative CSR in the Retail premise using the Treez POS System. Depending upon the doctor, verifications can happen instantly or may take up to a week. The dispensary, prior to dispensing medical cannabis, always obtains verification from the recommended Physician that he or she is a qualified patient. Records are maintained on-site digitally and physically secured and are allowed to be verified by the City as needed and at least every 21 months by the qualifying patient’s physician or Doctor of Osteopathy. The Mercy Wellness Micro-Business campus does not have a physician on site.
The Lounge at Mercy will utilize Patronscan, a state-of-the-art technology system that analyzes over 6,000 data points to determine an ID's authenticity. Patronscan verifies over 4,500 IDs from around the world, including all driver's licenses and passports with near-zero false positives. This terminal will mark the screen red (see photo on right below) when troublemakers scan their ID including details on 7 why they've been flagged. Patronscan’s leading ID verification technology catches most fake IDs in seconds. Their proprietary algorithms go beyond simple ID authentication to look for pixel-level discrepancies present in the modern counterfeit. This software can also flag potential trouble from 50,000+ individuals known for assaults, chargebacks, drugs and property damage and reduces incidents by as much as 97% by spotting these individuals before it becomes a problem. The Lounge at Mercy will easily be able to keep track of banned customers from the on-site consumption lounge and from our retail locations.
The Lounge at Mercy employees will provide the customer with a list of rules and regulations. This membership agreement must be signed agreeing to the governing cannabis use and consumption within the City of Cotati as well as recommendations on sensible cannabis etiquette. The membership agreement also states that no outside products are allowed and they will only consume products provided by our retail facility in The Lounge at Mercy. Customers also have to agree not to redistribute cannabis obtained from the consumption lounge or use in a manner that violates local City and State laws. Lastly customers will agree to consume our products in the designated consumption areas and not in public spaces outside of our facility. If a customer fails to comply, Mercy Wellness reserves the right to revoke their membership.
The Lounge at Mercy will utilize a reservation system so that there is the ability to limit the number of occupants and have a timed experience. This will provide analytics that we can use to improve our processes and procedures. Cannabis consumption and effect varies by person to person, therefore the number one priority is safety. If a customer is new to consumption, or looking to try different types of cannabis products, a lounge employee is there to educate them on use.
When the membership agreement is signed and the customer receives proper education, they are allowed to enter the consumption lounge. The customer will be escorted to one of a variety of inside or outside seating to choose from. Customers will view a few types of menus featuring different cannabis products, food and non-alcoholic beverages. Mercy Wellness plans to have a cannabis-sommelier to help 8 guide customers through their selection while providing education on consumption, dosing and onset.
Then customers make their selections based upon their needs.
The cannabis-sommelier will assist the customer in placing their cannabis product order through Mercy Wellness’ POS system Treez using a Microsoft Surface Pro, iPad, or their personal device. The customer will then check-out their cart using the delivery method and can even pay upfront using a card. All payments for the purchase of any cannabis products will run through Treez and settled in the Retail premise.
The order is received by the fulfillment center in Mercy’s Retail premise. The customer will be verified before cannabis product orders will be processed. The Fulfillment Team will hand-off to the Delivery Team who will enter the on-site consumption lounge and locate and verify the customer before finalizing the transaction. All transactions will be recorded in Treez POS, and is reconciled in METRC.
The entire lifecycle of the order will be recorded using an advanced security system. Cannabis products will not be stored in The Lounge at Mercy unless they are sold to a customer.
The on-site consumption lounge will only deliver cannabis to an individual in an amount reasonable for on-site consumption. Cannabis and cannabis products purchased on-site may be removed from their packaging and consumed onsite. Cannabis and cannabis products not fully consumed on-site may be resealed in their original packaging, placed in opaque packaging, and taken off site by the consumer.
The Lounge at Mercy will not sell live plants or seeds. The Lounge at Mercy will only provide cannabis to an individual in an amount consistent with personal possession and use limits allowed by the State of California.
The Lounge at Mercy will provide law enforcement and all neighbors within 100-feet of the business with the name and phone number of an on-site community relations employee to notify if there are operational problems with the establishment. The City of Cotati, Cotati Police Chief and/or its Officers, Adobe Fire District Fire Department Staff or other agents or employees of the City requesting admission for the purpose of determining compliance with these standards will be given unrestricted access. In addition, Mercy will attend regular meetings if needed with the City of Cotati Police Department, Adobe Fire District and the City of Cotati’s Public Safety Department staff to review public safety issues should any arise associated with the operations.
Safe Consumption
When it comes to the on-site consumption lounge and the patrons who will utilize it, safety is Mercy’s number one priority. We will cut off service to inebriated patrons and will provide transportation through a rideshare service if necessary. In order to further our vision of cannabis education and commercial transparency, we have drafted a Safe Consumption Policy, which will be made available to all of our patrons.
9 This policy will also double as part of the employee training and customer education programs for the various products the on-site consumption lounge sells, including potency of the products, absorption time, and effects of the products. Employees will also diligently educate all customers in an effort to ensure responsible consumption when they sign their membership agreement. The Lounge at Mercy is also working on developing software that can track the consumption through a customer profile to help with usage and sampling propensities.
Safe Transport
Mercy Wellness has also put together a rideshare program. We have partnered with Uber and will be providing free transportation to those that we may feel are unsafe to drive. Mercy Wellness wants to make it easy for drivers to make the right choice to never drive impaired. We will also encourage through education that rideshare apps offer a convenient transportation option that helps reduce the risk of driving under the influence, especially among younger drivers. We will promote and incentivize patrons to have a rideshare (Uber, Lyft, etc) pick them up and bring them to and from The Lounge at Mercy.
Noise
The structure housing the on-site consumption lounge will have adequate soundproofing so that interior and exterior noise shall comply with Chapter 9.100: Nuisance Abatement from the Cotati Municipal Code. In addition, Mercy Wellness will enforce appropriate patron conduct and make an announcement at closing requesting customers respect the residents of the adjacent residential neighborhoods by being quiet when leaving. Mercy will also post signage clearly visible within the consumption area and on-site parking area(s), requesting patrons to respect residents of adjacent residential neighborhoods by being quiet when leaving.
Odor Mitigation Plan
A combination of engineering and administrative controls is proposed to effectively mitigate cannabis smoke and odors. Engineering controls include carbon filtration via a dedicated environmental exhaust fan; and negatively pressurizing odor sources. Carbon filtration is commonly accepted throughout the cannabis industry as the current best engineering control technology for mitigating odors in facilities generating marijuana smoke and odors with exhaust air/filter intake points located in areas of the facility where smoke and odor-generating activities take place. As such, the engineering control strategy will effectively mitigate smoke and odors within the facility.
Design Considerations: Carbon filtration smoke and odor removal effectiveness depends on three criteria:
10 1. Exhaust air contact time
2. Filter cleanliness
3. Negative room pressurization
Contact time is a function of air velocity through the filter and should be designed to maintain a minimum contact time of 0.2 seconds or as specified by the manufacturer. Filter cleanliness can be quantified by monitoring system pressure drop across the filter and should not exceed a manufacturer’s published performance rating for a given filter. Areas of high smoke and odor concentration are typically negatively pressurized to allow for the control of odors through carbon filter(s).
System Design: The following summarizes the administrative and engineering controls proposed to mitigate cannabis odors:
1. Administrative Controls
a. Standard operating procedures will require routine monitoring of carbon filter differential static pressure.
b. Filter replacement will be required any time monitoring yields acceptable pressure monitoring results.
c. Monitoring results and filter replacement dates will be documented in an odor control log available to a building inspector in the event of a compliant or routine inspection.
2. Engineering Controls
a. Carbon filter(s) and environmental exhaust fan(s) will be specified to maintain an acceptable contact time.
b. Carbon filter(s) exhaust air inlet(s) will be located in storage room(s), creating a negative pressure in this space.
c. Intermittently operated environmental exhaust fans (break room, restroom, etc) will not be filtered.
d. Exhaust fan make-up air will be via mandatory ventilation air at space conditioning equipment.
e. Exhaust fan and space conditioning equipment shall be required to operate continuously during occupied hours.
f. System testing and balancing will be required of the installing contractor. g. Contractor shall provide a test and balance report to the owner inducing: initial system pressure drop; outdoor air rates at space conditioning equipment; and environmental exhaust rates.
h. Installing contractor shall provide written monitoring instructions and provide operational training to the owner upon placing the system in service.
Security Measures
In order to minimize environmental impacts and preserve the safety of the surrounding community, 11 safeguards have been implemented as an integral part of this project. All reasonable measures have been incorporated into the security plan that assures employee and property safety and uninterrupted uses of adjacent business spaces. At each entrance and exit to the facility, camera coverage will record customer facial features with sufficient clarity to determine identity.
All areas used for commercial cannabis activities have locking doors, with commercial-grade non-residential locks, to prevent free access. Only staff and persons with bonafide business are permitted in the restricted access areas. All other visitors remain in the designated waiting area until qualified or turned away.
The Lounge at Mercy installed a variety of security devices to ensure that only authorized personnel have access to any location where cannabis is stored, so that employees are safe and secure inside. All doors are equipped with locks and alarms that will sound if they are opened without code and key or if they are damaged. The security system is run and operated by an outside agency.
Security lighting is one of the most effective ways to prevent crime in or around a cannabis business.
There is sufficient exterior lighting surrounding the entire building and property that is monitored by Mercy Wellness in order to ensure that all lighting is functioning properly. The interior of the building has dedicated security lights that are on 24/7.
Mercy Wellness contracts with a 3rd party Security Company, ESP Pros. For more information regarding security at our facility, please refer to Attachment C: Safety & Security Plan.
Staffing
No person under the age of twenty-one (21) is employed at Mercy Wellness. The Lounge at Mercy will maintain a current register of the names and contact information of all employees. Mercy will ensure that each person engaged in the operations has the education, training and experience or any combination thereof, to enable that person to perform all assigned functions.
In order to hire a good workforce, Mercy Wellness will conduct background checks on every associate and employee. All current employees already have background searches that were conducted by the California Department of Justice and verified by local law enforcement. As a condition of employment, any and all future employees must submit fingerprints to an approved Live Scan vendor and pass an electronic background check completed by the DOJ and FBI before they can be hired.
Mercy anticipates hiring individuals from the surrounding community and will market its hiring campaigns in order to accomplish this. Currently the positions to be recruited will be for hostess greeters, canna-concierges and canna-sommeliers, food and beverage servers, product runners, cooks, bussers, dishwashers and security personnel.
12 Staff for Mercy Wellness will include one General Manager and up to twenty-five (25) full-time/part-time employees. Starting wages for any new employee begins at-least $18.00/hour. The Lounge at Mercy employees will arrive and leave daily for a work shift from 8:30 am to 10:30 pm, 7 days a week. There will be at minimum four employees working each day, working four 10-hour shifts or five 8-hour shifts, depending on the position. Shifts are created to ensure that each employee receives required lunches and breaks. The Lounge at Mercy will have a dedicated manager responsible for supervising employees at all times during business hours. A manager will be on-site seven days per week during work shifts and will be on-call for any after hour emergencies.
No person shall be allowed onto the premises unless they are an employee, customer, vendor or contractor of the retail facility, a primary caregiver, and/or a qualified patient or an employee of an agency having jurisdiction monitoring or investigating the terms of regulatory compliance. In addition, and in strict accordance with California Health and Safety Code Section 11362.5 et seq., no person under the age of twenty- one (21) shall be allowed on a nonmedical cannabis retail site pursuant to California Business and Professions Code section 26140.
Mercy Wellness authorizes the Police Chief to implement an employee permit system, whereby any employee or volunteer of a commercial cannabis business must obtain a work permit from the City of Cotati. At a minimum, this work permit will be visibly displayed at all times by the employee or volunteer when he or she is working and contains a recent photograph of the individual.
All newly hired employees will receive training on the detailed operations and education on cannabis, with an emphasis on safe consumption. Weekly employee and staff training will be held, covering all security and emergency procedures, compliance with state and local regulations, and also to address any training deficiencies. Mercy Wellness will also maintain records of any training provided to personnel for the performance of all assigned functions. Personnel training includes instructions regarding regulatory inspection preparedness and law-enforcement interaction as well as state and local laws, regulations and policies. These records will be available to the Chief of Police, designee, or any other City official authorized to enforce the Cotati Municipal Code for purposes of determining compliance.
All employees will be thoroughly trained in procedures to ensure a consistent, quality experience for the customers. It is important to both the medicinal and adult-use cannabis retail customers and the industry in California that employees are highly educated in the therapeutic benefits of cannabis.
Employees will not be allowed to work without completing the necessary company-mandated training.
We strongly encourage all employees to maintain studies in developing retail practices and to conduct background research on cannabis in order to fully immerse themselves in this industry.
Policies are implemented to protect personnel in all operations and provide personnel with adequate safety training, accident reporting and investigation policies as well as fire prevention and response plans. An emergency contact list is visibly posted and maintained which includes operation manager, 13 emergency responders, poison control and fire department contacts.
Occupational Safety: Mercy Wellness will comply with all applicable federal, state, and local laws and regulations governing California Agricultural Employers, which may include: federal and state wage and hour laws, CAL/OSHA, OSHA and the California Agricultural Labor Relations Act.
Green Waste Management
Mercy Wellness has implemented and maintains a waste management plan. All waste including cannabis waste, is disposed of in accordance with applicable laws. All cannabis products consumed in The Lounge at Mercy have been sold to an end-user via retail delivery, there are no requirements for the state’s track-and-trace compliance software, METRC. The Lounge at Mercy will dispose of cannabis waste in a secured waste receptacle in a secured area on the licensed premises. “Secured waste receptacle” or “secured area” means that physical access to the receptacle or area is restricted to the licensee, employees of the licensee, the local agency, waste hauler franchised or contracted by the local agency, or private waste hauler permitted by the local agency only.
Public access to the designated receptacle and area are prohibited. Cannabis waste is stored in a secure area of the facility until picked up by our contracted waste hauler or self transport/self-haul.
No cannabis product is disposed of in its packaging. Cannabis products in packaging designated for disposal will be removed from the package prior to disposal. All flower/flower waste will be disposed of by mixing cannabis with sand until unrecognizable. Vape cartridges will be rendered unrecognizable and unusable as cannabis or a cannabis product at the time of disposal by the contracted disposal company.
Again, Cannabis products are consumed by customers after the purchase is made, therefore no cannabis waste from the consumption lounge will be entered into the track and trace system. The Lounge at Mercy will however maintain records of the business name, address, contact person, and contact phone number of the entity hauling the cannabis green waste. We will also obtain and maintain documentation from the entity hauling the waste that evidences subscription to the waste collection service.
Sanitization
When it comes to apparatuses, it’s important to only use sanitation methods and systems specifically developed for use in food-contact environments. Isopropyl alcohol wipes will be used on mouth pieces and surfaces. Even though we will not be preparing food on-site, glass pipes, bongs and dab rigs will need to be sanitized in between every use. One of the most important pieces of equipment will be a commercial glassware washing machine that will be used to clean and sanitize any apparatus. The commercial glassware washing machine is designed to meet regulatory requirements 14 for sanitary and design that are approved for food contact. The Lounge at Mercy will ensure apparatus does not pose a risk of contaminant introduction to the product, and that the apparatus is cleanable.
Other equipment and utensils may also be installed to allow for effective cleaning and maintenance such as application of UV light. Written procedures for cleaning and sanitizing equipment and utensils will be maintained and include the detailed, written procedure for cleaning, sanitizing, and maintaining (including calibrating) equipment and utensils. A schedule for cleaning, sanitizing, and maintenance. A procedure, including a log, for documentation of the date and time of maintenance, cleaning, and sanitizing of equipment and utensils. In addition, a detailed, written procedure for storage of cleaned and sanitized equipment to protect it from contamination.
Facility Cleanliness
General office trash and recycling is stored in an existing locked and enclosed disposal area. All refuse is behind a secured fencing out of the view of the public. Recycling is securely removed from the premises by Recology’s Waste Zero Program.
Our team clears the trash and litter that is found on sidewalks adjoining the premises plus 10-feet beyond property lines along the street as well as parking lots under the control of The Lounge at Mercy as needed. Graffiti shall be removed from the premise and parking lots within 72-hours of its found application.
Each employee is assigned daily tasks related to cleaning. A mandatory check-list is signed off every shift by management to ensure that the on-site consumption lounge, bathrooms, breakroom, security and reception areas are cleaned and maintained to the highest quality. In addition, a Compliance Director checks weekly that these tasks are signed off daily.
Compliance Inspections
Mercy Wellness of Cotati and The Lounge at Mercy will allow access to all areas of the premise in its entirety, and shall be subject to compliance inspections by the City, County or other governing agencies.
Any inspection shall be conducted during regular business hours, with at least 24-hours’ notice unless public health or safety requires otherwise.
Events
The Lounge at Mercy will have ticketed events on various nights such as senior education; comedy shows; movie nights; major sporting events such as World Series, Super Bowl and March Madness; game nights and bingo; paint and puff and small musical acts. Mercy will also work with brand partners 15 to host their corporate events for private parties. On most days there will be ambient music playing in the background.
Modified Opening Plan
If approved, The Lounge at Mercy will open and operate the on-site consumption lounge under a phased approach. At first there will be limited terms such as open only 2 days/week to the public (potentially Saturdays and Sundays). Events may be limited to private parties. Mercy Wellness of Cotati feels this is in the best interest of protecting our community, patrons and our employees. We only have one opportunity to make the first impression and we want it to feel right and our focus to be on cannabis education and safe consumption.
Community Benefits
Since inception in 2010, Mercy Wellness mission is to serve the community. We feel this project will fall in line with the City’s Vision for Cotati. We believe that adding an on-site consumption lounge will reinforce both the quality and vitality of the community. In addition, this new business will promote existing businesses in the surrounding area and encourage new businesses to our community. The Lounge at Mercy will also be a tax generator that will help balance the city budget and add to appropriate reserves. Lastly, Mercy will add additional security presence and monitoring for the Gravenstein Business Center to protect the health and well-being of the community so that we provide a safe and secure environment.
Safety Plan
Mercy Wellness of Cotati has previously submitted a Safety Plan under the original Microbusiness License Application process to the City of Cotati. We currently have a comprehensive Injury Illness Prevention Program (IIPP). There are written procedures for Employee Accidents which include situations where an employee does not wish to seek medical care. The Employee Handbook also contains Worker’s Compensation Policy and what to do if there is an emergency and when to dial 911.
We will keep documents for all incidents and related expenses, serious injuries, first aid response, and chemical related medical emergencies. Additional staff training will cover OSHA requirements, workplace violence and will include action plans in event of fire, earthquake, weather disturbances or terrorist/robbery events. Medical emergency training will be conducted which includes CPR and defibrillators. Emergency exits will be clearly marked as well as the evacuation routes. Further instruction will include use of fire extinguishers and criteria for whether employees should attempt to extinguish a fire themselves.
16 Attachment A:
Site and Floor Plans
17 18
19 Attachment B:
Safe Consumption Policy
20 Policy and Purpose
The purpose of this document is to outline the ways that we at Mercy Wellness of Cotati and The Lounge at Mercy plan to implement safe and responsible consumption at our on-site cannabis consumption lounge and through delivery from our dispensary. On-site consumption lounges are the next step forward in the progress of the regulated cannabis industry. As jurisdictions permit regulated commercial cannabis dispensaries there is an empty space left in the market: safe spaces to consume cannabis.
We want to bring a safe consumption space to the City of Cotati community, where people can responsibly enjoy this regulated market and economically uplift our community. With seven U.S. states already legalizing regulated on-site consumption lounges, and with the City of Cotati permitting them, we will be supporting Cotati’s vision for regulation versus prohibition, and as a leader for other California jurisdictions to follow.
Consumption Education
One of the most important aspects of an on-site cannabis consumption lounge is making sure customers are consuming responsibly. Not every patron is going to be a long-time cannabis user, so it’s important that customers are provided all the information and education they need to make responsible decisions for themselves and those in their group. So, how do you responsibly consume cannabis? With cannabis, it isn’t always a cut-and-dry scenario of what is a responsible dose and what is too much.
Experts typically advise cannabis users to subscribe to the “Start low, go slow” method. This means starting with a small amount, and slowly increasing your serving size over several days or weeks. It also means starting with a low-THC product and gradually working up to more potent products with higher THC.
Every person is different, and what could be considered a “small” amount or a “low” THC product varies from individual to individual. For oral cannabis products, there is not yet an agreed-upon standard dose of THC. Although a proposal has been made to standardize oral dosing at 5 mg of THC, more cautious cannabis operators recommend that their customers start with 2.5 mg. Individuals more sensitive to the effects of oral ingestion of cannabis may experience unpleasant effects at doses of 5 mg, and studies have shown that women can also be more sensitive to the effects than men.
Consumption by Inhalation
Smoking is the oldest form of consuming cannabis and continues to be the most popular method even today. Cannabis flower is the most sold cannabis product. Smoking that flower in joints, pipes, or bongs 21 are some of the most popular ways to consume weed. After you take a drag off a joint or a pull off a bong, inhaled smoke travels from your mouth into your lungs. The inside of your lungs are lined with millions of air sacs called alveoli, and combined, they have a huge surface area.
Compounds in cannabis smoke, such as THC, enter your bloodstream via the air sacs in your lungs, traveling first to your brain, and then the rest of your body. This happens within seconds, and the cannabis consumer will likely feel the effects of smoking within minutes. Smoking methods include:
Rolling (joints or prerolls), pipes (including bubblers and one-hitters like chillums and dugouts) and bongs. Each has its pros and cons and provides a different experience.
Joints are arguably the most classic way to smoke flower. Portable and versatile, these rolls can be consumed almost anywhere with the flick of a match. It used to be that you or someone you knew had to have the skills to roll one, but not anymore with the advent of pre-rolls.
Pipes are probably the most common smoking device because they are small, portable, convenient, and easy to use. Just break up some flower, pack a bowl, put a flame to it, and inhale. They are available in different materials and come in many shapes and sizes, and price points. Pipe glass blowing itself has evolved into an art form, while other pipes are prized for their functionality.
Bongs also come in a variety of styles and designs, and usually increase in sophistication from pipes because they incorporate water and need a chamber for it. The addition of water cools the smoke, making hits smoother and cleaner, but it’s uncertain whether it acts as an effective filter for harmful substances.
The benefit of smoking flower is that you're able to taste the flavor. It is the purest, most basic way of consuming cannabis—it hasn’t been altered or turned into dabs, edibles, or other products and allows you to taste the flavor of a strain. Growers have different growing practices as well, which can come out in the flavor of flower. You can enjoy all the different varieties of strains and the different flavors and effects each has to offer when smoking flower. Other cannabis products could be a mix of many strains.
Consumption of Joints (aka PreRoll)
A pre-roll is, simply, a pre-rolled joint, typically with a crutch. Joints are cheap, discreet, disposable, and easily shared among friends. They require neither the financial investment of a bong nor the time commitment of an edible. But unless you’ve got nimble fingers or hours to spend practicing, it can be tough to learn how to twist one up.
Using shake, trim, or ground down nugs, the filling material is usually loaded into pre-rolled paper cones by the tens or even hundreds. A machine shakes the joints to help settle the mixture and remove air pockets. With a twist of the tip, the pre-roll’s ready to go. 22 Consumption by Vaping
Vaping delivers a different experience than smoking a joint, but it’s not easy to quantify that difference.
Recently, though, scientists have looked into the question and found that vaping actually packs a more powerful punch than the traditional joint. People who vaporized cannabis flower experienced more pronounced effects than those who smoked the same dose. Effects increased along with the dose administered, suggesting that vaporized flower should be approached with a more conservative dosing strategy than smoked flower, especially for infrequent consumers.
Consumption of Concentrates
Concentrates are another method cannabis users sometimes use. It refers to the act of heating cannabis on a hot surface and inhaling the smoke (vapors). This dose of cannabis is made by extracting THC and other cannabinoids. Heat is applied which vaporizes the cannabis concentrate. This oil is heated on a hot surface and inhaled through a specific type of water pipe known as a dab rig.
Consumption of Tinctures
Cannabis tinctures are alcohol-based cannabis extracts—essentially, cannabis-infused alcohol. In fact, tinctures were the main form of cannabis medicine until the United States enacted cannabis prohibition.
They’re a great entry point for both recreational and medical consumers looking to ease into smokeless consumption methods.
Topical Application
Topicals are cannabis-infused lotions, balms, and oils that are absorbed through the skin for localized relief of pain, soreness, and inflammation. Because they’re non-intoxicating, topicals are often chosen by patients who want the therapeutic benefits of marijuana without the cerebral euphoria associated with other delivery methods. Other transdermal innovations are fast arriving in the cannabis market, including long-lasting patches for patients and recreational consumers alike.
Consumption of Edibles
Mercy Wellness of Cotati and The Lounge at Mercy will always recommend that any customer starts with 1 mg to 2.5 mg of THC. This dosage is generally considered best practice for new users of cannabis edibles, beverages, and tinctures. Customers can always take more, but there is no way to reverse THC’s 23 effects after digesting an edible. Please see the table below which outlines acceptable uses for cannabis consumers.
According to a recent Leafly article, effects of cannabis edible doses vary from person to person. Leafly explains which effects are most often a result of certain doses, as well as which doses would work best for which type of cannabis users based on experience or physiological conditions. For example, the dosage range between 2.5 and 15 milligrams can be a good choice for people who are either social butterflies or people who have a hard time sleeping. This is due to the fact that a dosage range between
2.5 and 15 milligrams tends to produce strong physical symptom relief as well as a feeling of euphoria.
Providing a guide to our consumption lounge users similar to this will help customers gauge what kind of products to consume, with the general warning that this is not a blanket guide for all users.
An important bit of information to remember when considering cannabis dosing is that it is highly unlikely that a person would consume so much cannabis that major or fatal health complications occur as a result of drug dosing. However, consuming too much cannabis may cause decreased motor function, dizziness, anxiety, nausea, or minor hallucinations, but temporary discomfort and disorientation is the worst case scenario. In these cases a calm environment, a healthy amount of water, and some sugary foods will help the body process the overabundance of THC out of the system within a couple of hours.
Consumption of Beverages
Cannabis beverages start to kick in the moment they touch your tongue. When you take cannabis as a water-soluble liquid, THC absorbs into your bloodstream through the tissue of your mouth, esophagus, and stomach. First-timer could have 2.5 mg and feel great while a more experienced user might opt for 5-10 mg. Since it's a microdose, consumers can feel the buzz wear off a bit before they decide to grab another drink.
Cannabis and Driving
Driving under the influence of any substance can be a major risk, and cannabis is no different. Finding ways to keep consumers from driving while impaired is an important aspect of any consumption lounge’s business model.
Research into the effects of cannabis have concluded that the drug negatively affects a number of skills required for safe driving, including slowing your reaction time, impairing coordination, difficulty with decision-making, and distorted perception. Additionally, the risk of impaired driving associated with cannabis in combination with alcohol appears to be greater than that for either by itself.
The direct link between whether cannabis use increases the risk of car crashes is unclear, though. This is in part because an accurate roadside test for drug levels in the body doesn’t exist, combined with the fact 24 that cannabis can stay in a user’s system for days or weeks after consumption. However, because of its impairing effects, cannabis consumers must wait a sufficient time period before driving. Mercy Wellness of Cotati and The Lounge at Mercy will enforce this rule. This is a critical control point for any consumption lounge operator. Despite this obvious health and safety challenge, there are many ways that we will provide safe means for our customers to travel.
Initially, we require consumption lounge patrons to sign a release of liability form prior to consumption of any product. This form can include comprehensive warnings including how the cannabis plant is not regulated by the Food and Drug Administration, and how customers should not operate a motor vehicle or machinery for a designated period after consumption. This form will set a precedent for the customer to take personal responsibility to keep themselves safe and have a plan for their consumption practices.
We plan to develop this form once our consumption lounge is operational.
As an important component to our customer’s safety, we will also have transportation options in place for customers to use in case they become too impaired to drive. As a precursor to a customer’s arrival, we will encourage them to come with friends and designate a driver; use a ridesharing service; hire a cab; or take public transit as their means of travel, thereby eliminating the need for any of the patrons to drive. No matter what, we will remain diligent in the conduct and state of our customers, and we will be ready to help customers who need assistance with transportation from The Lounge at Mercy itself if they appear to be inebriated.
Customer Guidance and Assessing Impairment
Customers utilizing the space will have continuous access to and oversight by our experienced, knowledgeable staff at The Lounge at Mercy. Customer service representatives in cannabis retail facilities are extensively trained on the use, effects, and dosing on cannabis products in support of their retail responsibilities. One of the most important parts of cannabis customer service is guiding cannabis users of all experience levels to identify and use cannabis products to maximum benefit and safety. In the absence of a consumption lounge, this guidance is given in store with the hopes that customers are able to properly self-administer once they reach their private residence. A consumption lounge may prove to be the optimal location for new users to try unfamiliar products, as they can be visually observed and supported throughout the experience.
A critical component in ensuring the safety of our lounge is the ability of our staff to recognize when someone has become impaired. Staff will be trained on recognizing if a customer has become impaired, and reserves the right to stop serving anyone in The Lounge at Mercy at any time, for any reason. Our team will be developing this training for staff based on the guidelines for how to deal with overly-intoxicated patrons provided by the California Department of Alcohol Beverage Control. Because the existence of cannabis consumption lounges is so new, there are not comprehensive protocols for how to deal with patrons that are too impaired. Therefore we have adapted our lounge’s protocols to match that of the California Department of Alcohol Beverage Control’s Responsible Beverage Service (RBS) 25 certification. Many of the same methods for impairment can be found within this educational program for bartenders. It’s the goal of Mercy Wellness of Cotati and The Lounge at Mercy to create our own Responsible Consumption Service (RCS) certification for our budtenders and all lounge employees.
Staff training will prioritize the management of consumption by customers, including encouraging food along with cannabis consumption, keeping track of the pace or amount of cannabis consumed by patrons, and slowing down service if a patron seems to be heading toward impairment. Staff will be trained on how to spot impaired customers by assessing reactions, inhibitions, change in physical appearance, coordination, and judgment. If a patron is deemed too impaired and service must cease, our staff will immediately alert a supervisor and arrangements will be made to make sure the customer is safely transported home. Any incidents involving impaired customers will be thoroughly documented, and staff training will emphasize de-escalation and assistance.
While we will be implementing this impairment assessment training upon initial opening of the consumption lounge, we will continue to adapt our strategies in terms of impairment assessment and our process as time goes on.
Customer Responsibility
No matter what, it’s important for each patron for Mercy Wellness on-site cannabis consumption lounge to know themselves and their limits. Providing advice and educational tools to new or inexperienced cannabis users is vital in guaranteeing a safe, enjoyable experience for everyone involved. Each individual patron is responsible for their own well-being and their own choices. As operators of a consumption lounge, we will take every possible measure to equip those customers with the information they need to have a safe experience, but it’s up to them to use that information for their own benefit. 26 Work Cited
● Bhaskar, Arun et al. “Consensus recommendations on dosing and administration of medical cannabis to treat chronic pain: results of a modified Delphi process.” National Library of Medicine, https://pubmed.ncbi.nlm.nih.gov/34215346/. July 2021. ● World Health Organization, Expert Committee on Drug; Dependence Pre-Review Delta-9-tetrahydrocannabinol Section 3: Toxicology, 2018 ● “Cannabis and Driving.” California NORML, https://www.canorml.org/cannabis-and-driving/. 29 December 2017.
● “Embracing Cannabis Consumption Lounges.” CannaCon,
https://cannacon.org/consumption-lounge-updates/. 4 May 2021 ● Freeman, Tom P. “'Standard THC units': a proposal to standardize dose across all cannabis products and methods of administration.” National Library of Medicine, https://pubmed.ncbi.nlm.nih.gov/31606008/. July 2020.
● Fogel, Jessice S. et al. “Sex differences in the subjective effects of oral Δ9-THC in cannabis users.” National Library of Medicine, https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4947027/. 15 January 2016.
● “Intoxication.” California Department of Alcoholic Beverage Control, https://www.abc.ca.gov/education/licensee-education/intoxication/. ● “Cannabis 101” Leafly https://www.leafly.com/news/cannabis-101 ● “How to Smoke Weed” Leafly https://www.leafly.com/learn/consume/smoke ● “Which Is More Potent, Vaping Cannabis or Smoking a Joint?” Leafly https://www.leafly.com/news/health/which-is-more-potent-vaping-cannabis-or-smoking-a-joint ● “What is the difference between smoking, vaping and ingesting cannabis? Legaline.CA https://www.legalline.ca/legal-answers/what-is-the-difference-between-smoking-vaping-and-cons uming-cannabis/
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