HomeMy WebLinkAboutItem 03 Review Ordinance Adopting Regulations for Medical Marijuana Dispensaries AGENDA ITEM SUMMARY Meeting Date: 7/14/2014
Meeting Type: Work Session
Staff Contact/Dept.: Lauren King, CAO Jim Donovan, DPW
Staff Phone No: 541-726-3660
Estimated Time: 20 Minutes S P R I N G F I E L D
C I T Y C O U N C I L
Council Goals: Enhance Public Safety
ITEM TITLE: REVIEW ORDINANCE ADOPTING REGULATIONS FOR MEDICAL
MARIJUANA DISPENSARIES
ACTION REQUESTED: Staff requests Council direction on final draft revisions to municipal and land use codes prior to initiation of adoption procedures at their next Regular Session.
ISSUE STATEMENT: Under SB 1531 (2014) local governments may impose “reasonable regulations” on dispensaries. Staff is presenting several potential regulations that seek to meet
Council’s priorities of preventing the distribution of marijuana to minors and
ensuring that medical marijuana dispensaries are adequately regulated by the city.
ATTACHMENTS: Attachment 1 – Council Briefing Memorandum
Attachment 2 – Draft Changes to the Springfield Municipal Code
Attachment 3 – Draft Changes to the Springfield Development Code Attachment 4 – Maps reflecting the proposed locational restrictions Attachment 5 – Medical Marijuana Industry Meeting Handout
DISCUSSION/
FINANCIAL IMPACT:
In April, staff and the City Attorney’s Office sought guidance from Council as to
whether the city should adopt a moratorium on medical marijuana facilities while deliberating and adopting any necessary adjustments to the City Code. Council
elected not to adopt a moratorium but requested that staff return with potential
regulations that protect children and allow the city to better regulate the new use.
The following regulations are proposed:
• Prohibit non-cardholders and minors from the premises
• Prohibit dispensaries from locating within 1,000 feet of parks, daycare facilities and residential zones
• Require usable marijuana includes labels documenting quantities of THC
• Add Medicinal Marijuana Dispensaries as a “use” under the SDC
• Limits the hours of operation
• Prohibit dispensaries from giving away free marijuana as a promotion
• Require dispensaries to obtain a business license and all employees to undergo a background check
On June 27, 2014, staff met with representatives from the local medical marijuana industry to discuss the suggested regulations. Staff sought the industry
representatives’ feedback on each area of regulation. In general, the representatives found the proposed concepts reasonable in nature; specific feedback from the
representatives on potential regulations is included in the Council Briefing Memo.
The proposed regulations include changes to the Municipal Code and the Development Code. Under Oregon’s land use law and Springfield’s Code, changes
to the Development Code require 35 day notice to DLCD and review by the
Planning Commission. Council can adopt the changes to the Springfield
Municipal Code on July 21. Council can request that staff initiate the
changes to the Development Code at the earliest convenience.
M E M O R A N D U M City of Springfield
Date: 7/14/2014
To: Gino Grimaldi COUNCIL
From: Lauren King
Jim Donovan
BRIEFING
Subject: Regulating Medical Marijuana Dispensaries MEMORANDUM
ISSUE: Shall the City adopt regulations that allow for the regulation of medical marijuana dispensaries for the purposes of protecting the public health and safety?
COUNCIL GOALS/
MANDATE:
Enhance Public Safety
BACKGROUND:
Oregon House Bill 3460 (2013) authorized the Oregon Health Authority (OHA) to
establish and regulate a medical marijuana facility (dispensary) registration system.
Under that law, registered medical marijuana dispensaries were authorized to sell
medical marijuana beginning March 1, 2014. To better clarify a local government’s ability to regulate the facilities, the Oregon Legislature passed Senate Bill 1531 (2014).
SB 1531 provided that cities may only impose “reasonable regulations” on the hours of
operation; limitations on where the facility may locate in the authorized zones; and
reasonable conditions on the manner in which a facility may dispense medical
marijuana.
In April, staff and the City Attorney’s Office sought guidance from Council as to
whether the city should adopt a moratorium on medical marijuana facilities while
deliberating and adopting any necessary adjustments to the City Code. Council elected
not to adopt a moratorium but requested that staff return with potential regulations that protect children and allow the city to better regulate the new use.
This Council Briefing Memorandum is prepared at Council’s request. The briefing
memo presents potential regulations based on Council priorities.
On June 27, 2014, staff met with representatives from the local medical marijuana
industry. Staff reached out to five industry representatives from the growing, testing and
dispensary sectors of the business community. Brenda Young, owner of Wikit Weedery
in Springfield, and Callie Cooper, Executive Director of Cannabis Research Institute attended the meeting. Staff presented the industry representatives with the attached
handout (Attachment 5) and sought their feedback on each of the potential regulations.
In general, the representatives were generally receptive of the proposed regulations.
Feedback as it relates to specific potential regulations is included below.
1. Protect Children In August of 2013, the United States Department of Justice
issued the “Cole Memo” providing federal guidance regarding marijuana
enforcement. The memo outlines enforcement priorities and states that
Attachment 1, Page 1 of 5
MEMORANDUM 7/10/2014 Page 2
“[p]reventing the distribution of marijuana to minors” is particularly important to
the federal government. The City Council agrees with this priority and is
seeking to enact local measures to ensure that minors do not have access to
marijuana unless that minor is a patient and accompanied by an adult or legal guardian. Accordingly, the following local regulations are recommended:
a. No Minors on Premises. Under the OHA regulations, a minor may not be
“present in any area of a registered [dispensary] where usable marijuana or
immature plants are present, even if the minor is a patient or an employee.”
However, OHA regulations do not prohibit minors or non-card holders from entering into a dispensary and waiting in a waiting room, lobby, or other area
of the dispensary where there is no “usable marijuana or immature plants.”
Potential Municipal Code Regulation: Have to be a cardholder to be on the
premises and no minors on the premises unless they are accompanied by
legal parent or guardian for the sole purpose for procuring the minor’s medicine. Feedback from Industry: Industry representatives supported a total ban of minors because any minor has to have an adult guardian responsible
for procuring their medication.
b. Locational restrictions to protect children. OHA regulations prohibit a dispensary from locating at the same address as a grow site; within 1,000 feet of an elementary, secondary or career school; within 1,000 feet of another
dispensary. Potential Development Code Regulation: Prohibit dispensary
from locating within 1,000 feet of public parks; state licensed commercial
pre-schools and daycares; and residential zones. Feedback from Industry: At the time of our meeting with the industry, the attached map (Attachment 4)
was not yet finalized. Without the availability of the map, the industry
representatives felt that the residential restrictions could largely prohibit
medical marijuana from most commercial areas of the city. Suggestions
included considering a 100 foot setback from parks and not including the additional locational buffers from residential areas.
c. Labeling Requirements. Under the OHA regulations, prior to transferring
usable marijuana a dispensary must affix a label that includes: (a) The
amount of THC and CBD in the usable marijuana; (b) If pre-packaged, the
weight or volume of the packaged usable marijuana in metric units; (c) The amount of usable marijuana in a finished product in metric units; (d) Potency information; and (e) Who performed the testing. Additionally, all edible
marijuana must include a warning label that states: “WARNING:
MEDICINAL PRODUCT — KEEP OUT OF REACH OF CHILDREN” in
bold capital letters, in a font size that is larger than the type-size of the other printing on the label such that it is easy to read and prominently displayed on the product. Potential Development Code Regulation: Adopt the same
language into the Springfield Municipal Code to allow local code
enforcement has the ability to ensure and regulate that this information is
included in the packaging. It is worth noting that, this may be difficult for the city to enforce and lack of enforcement may open potential liability for the city.
2. Land Use As stated above, OHA regulations prohibit a dispensary from
locating at the same address as a grow site; within 1,000 feet of an elementary, secondary or career school; within 1,000 feet of another dispensary. This regulation, however, is not included in the Springfield Development Code and,
Attachment 1, Page 2 of 5
MEMORANDUM 7/10/2014 Page 3
thus, the city is unable to identify and regulate changes of use without the
addition of the new use in the Development Code. Potential Development Code
Regulation: Dispensaries should be added to the list of permitted uses in general
commercial, and mixed use zones where the primary is not residential, subject to buffer zones discussed above. Listing and definition of the use allows normal processing and enforcement of appropriate planning and building approvals.
Feedback from the Industry: The industry representatives’ concerns regarding
buffers are identified above. The industry representatives were amenable to
adding a marijuana industry category and permitted uses to applicable zoning overlay districts consistent with other listed uses in the city. 3. Sign Code OHA has no regulations relating to the Sign Code. Under the Oregon
Constitution, all expression is equal and equally protected. Any law that focuses
on the content of speech or writing and is written in terms that are directed to the substance of any subject are “on their face” unconstitutional. Accordingly, the city cannot enact restrictions on signs or promotional advertising that is specific
to medical marijuana.
a. Re-enforce Sign Code Regulations. Although not necessarily new or
additional regulation, by restating in the medical marijuana section of the code that the sign code applies to these businesses, it will re-enforce
the requirements for the businesses. These requirements include the
requirement to obtain a permit and prohibit use of logos that are not that
of the business. Potential Development Code Regulation: All marijuana
businesses are subject to the requirements of the Springfield Sign Code. Feedback from the Industry: The industry representatives had no concerns with this regulation.
4. Miscellaneous Operational Regulations. In accordance with Senate Bill 1531
(2014), the city may impose “reasonable regulations” on the hours of operation; limitations on where the facility may locate in the authorized zones; and reasonable conditions on the manner in which a facility may dispense medical
marijuana. The following are recommended measures to regulate the hours of
operation and the manner in which medical marijuana is dispensed.
a. Hours of Operation. Potential Municipal Code Regulation: No sales,
delivery or other operations upon the premises between 7:00 pm and 8:00
am. Feedback from the Industry: The industry representatives felt these
time limitations were too restrictive and would limit the ability for some
customers to acquire their marijuana. Industry representatives suggested
that most patients would be better served by allowing operating hours of
7:00 am to 9:00 pm.
b. Giveaways. Potential Municipal Code Regulation: Dispensaries may not
distribute to any consumers marijuana or marijuana-infused products free
of charge. Staff feels that sales incentives and samples are inappropriate
under medical marijuana provisions. It is worth noting that this may be
difficult to enforce. Feedback from the Industry: Many of the
dispensaries in Oregon and other states give out “free” products or
provide their customers with promotional giveaways through “rewards
programs.”
Attachment 1, Page 3 of 5
MEMORANDUM 7/10/2014 Page 4
c. Business License. By requiring a business license, the city can ensure
that all new medical marijuana dispensaries register with the city.
Potential Municipal Code Regulation: Dispensaries must obtain a
business license and register with the city. This ensures that the city is
aware of all certified dispensaries operating in the city and that they
comply with local buffer requirements. Feedback from Industry: The
industry representatives had no concerns with this regulation but
suggested that any business license fee was not so high as to prohibit
smaller, “mom and pop” businesses from opening in Springfield. The
representatives in attendance acknowledged other cities and states having
licenses in the range of 500 to 1000 dollars and were amenable to this
range. Staff suggests that licenses be reviewed annually with a fee of
$500.
d. Background Check. OHA requires that the owner of a dispensary
undergo a background check and not have been convicted of certain
crimes. There are no similar requirements under the OHA for employees
or volunteers of a dispensary. Potential Municipal Code Regulation:
Employees, volunteers and agents of a dispensary must undergo a
background check at the time the dispensary applies for a business
license with the city. The background check would be required and
verified with annual licenses and preclude employees from having certain
felony convictions. License fees would cover the cost of background
checks. Feedback from Industry: The industry representatives have no
concern with this potential regulation.
e. Display of State license. Potential Municipal Code Regulation:
Dispensaries must display their OHA license in a manner visible and
readable, at or near the entrance to the facility. This ensures that staff is
aware that the dispensary is lawfully licensed under the OHA regulations.
f. No Consumption of Marijuana Premises. The OHA regulations require
that no consumption, ingestion, inhalation, or topical application of
usable marijuana is permitted on the premises. There is an exception for
employees. Only an employee of a registered dispensary, who is a
patient, may consume usable marijuana during their work shift as
necessary for his/her medical condition, in a closed room, alone if
smoking, not visible to the public or to patients. Potential Municipal
Code Regulation: Restate the OHA requirement, including the exemption
for an employee of the dispensary who is a patient.
Attachment 1, Page 4 of 5
MEMORANDUM 7/10/2014 Page 5
RECOMMENDED ACTION:
This packet of regulations includes recommended changes to the Springfield Municipal
Code and the Springfield Development Code. Council may adopt the changes to the
Municipal Code as an emergency on July 21, 2014. Under Oregon’s land use law, the changes to the Development Code requires that the City notify DLCD 35 days prior to
the public hearing for new code changes. Public notice of the code changes is required
and any changes should first be considered by the Planning Commission. Following the
Planning Commission’s recommendation, City Council can then consider the code
amendments to zoning districts upon their return from summer break.
We recommend Council adopt the changes to the Municipal Code and direct staff to
initiate the process for changing the Development Code.
Attachment 1, Page 5 of 5
DRAFT MUNICIPAL CODE CHANGES
7.600 Statement of Purpose.
To protect the public health and safety from unlawful use and sale of marijuana. All medical marijuana
dispensaries shall be registered in accordance with ORS Chapter 475 and the applicable Oregon
Administrative Regulations (OAR). Registration by the Oregon Health Authority is not a guarantee that a
dispensary is permitted to operate under applicable local municipal regulations. All dispensaries shall
comply with the regulations set forth in the Springfield Municipal Code and the Springfield Development
Code.
These regulations set forth by the Springfield Municipal Code provide reasonable regulations that
supplement the Oregon Health Authority’s Medical Marijuana Program. These regulations are intended
to address solely the issue of selling or dispensing medical marijuana. These regulations do not address
and shall not be applied to any recreational or other use of marijuana that does not relate to the authorized
use under Oregon’s existing Medical Marijuana Act.
7.601 Definitions.
The following words and phrases as used in sections 7.600 to 7.603 mean:
Marijuana. As defined under ORS 475.005.
Dispensary. A medical marijuana facility registered by the Oregon Health Authority under ORS 475.314.
Cardholders. Persons authorized under Oregon’s Medical Marijuana Program to buy and transfer medical
marijuana. This includes patients, designated primary caregivers, person responsible for a medical
marijuana facility, and person responsible for a medical marijuana grow site.
License. A license issued pursuant to Springfield Municipal Code Sections 7.000 to 7.006.
7.602 License Required.
(1) No person shall establish, maintain or operate a dispensary within the city unless a license for that
use is obtained from the city. Every place or building where a dispensary is carried on, whether for profit
or not, shall be deemed a dispensary subject to the provisions of sections 7.600 to 7.603. Each licensee
shall meet the requirements set forth in sections 7.000 to 7.006.
(2) No license will be issued without proof of registration to operate a dispensary issued by the State
of Oregon.
(3) The City may deny a license if any owner, manager, operator, employee, agent, or volunteer:
a. Has been convicted for the manufacture or delivery of a controlled substance in Schedule
I or Schedule II within five years from the date the application for a license was received
by the City; or
Attachment 2, Page 1 of 3
b. Has been Convicted more than once for the manufacture or delivery of a controlled
substance in Schedule I or Schedule II; or
c. Is prohibited by a court from participating in the Oregon Medical Marijuana Program
(OMMP).
(4) Application for a license must include the information necessary for background checks of a
criminal record of the any owner, manager, operator, employee, agent, or volunteer. The City of
Springfield will conduct all necessary background checks.
(5) No license shall be issued until after a background check of the criminal record by the police
department of the applicant and all individuals employed or volunteering with the dispensary.
(6) Once the dispensary is licensed, the licensee must notify the city and submit necessary
information for background checks of a criminal record of any new owner, manager, operator, employee,
agent, or volunteer.
(7) Each licensee shall be required to pay the applicable license fee as set by Resolution of the
Common Council.
(8) The requirements of sections 7.600 to 7.603 shall apply to the owners, managers, operators,
employees, agents, and volunteers of the licensee’s business.
(9) The Licenses authorized by the city shall be displayed in the window such that it is clearly visible
from the nearest public right-of-way. The sign shall be no less than 8 inches by 11 inches in size.
7.603 Operational Requirements.
(1) Dispensaries must be located in accordance with ORS 475.314 and the Springfield Development
Code.
(2) Only cardholders shall be permitted on the premises of a dispensary.
a. No minors shall be permitted on the premises.
(3) Labeling.
a. Prior to transferring usable marijuana, a label shall be affixed to the usable marijuana that
includes but is not limited to:
i. The amount of THC and CBD in the usable marijuana;
ii. If pre-packaged, the weight or volume of the packaged usable marijuana in
metric units;
iii. The amount of usable marijuana in a finished product in metric units;
iv. Potency information; and
v. Who performed the testing.
b. If the registered facility transfers usable marijuana in a form that is edible, a warning
label shall be affixed on the outside of the packaging that includes the following:
“WARNING: MEDICINAL PRODUCT — KEEP OUT OF REACH OF CHILDREN”
in bold capital letters, in a font size that is larger than the type-size of the other printing
on the label such that it is easy to read and prominently displayed on the product.
Attachment 2, Page 2 of 3
(4) Sign Code. All dispensaries shall be subject to the requirements of Sections 8.200 through 8.268,
the Springfield Sign Code.
(5) Hours of Operation. No sale or other distribution of marijuana shall occur upon the premises or
via delivery between 7:00 pm and 8:00 am.
(6) Giveaways. Dispensaries shall not distribute to consumers marijuana or marijuana-infused
products free of charge.
(7) Consumption on Premises Prohibited. Consumption, ingestion, inhalation, or topical application
of usable marijuana anywhere on the premises of the dispensary shall be prohibited; except as allowed
under OAR 333-008-1200.
Attachment 2, Page 3 of 3
Page 1 of 3
PROPOSED SPRINGFIELD DEVELOPMENT CODE (SDC) AMENDMENTS TO ALLOW
MEDICAL MARIJUANA DISPENSARIES IN CERTAIN ZONING DISTRICTS
Proposed text us underlined and highlighted in yellow.
Commentary. The following zoning districts are those cited in ORS 475.314 where medical marijuana
dispensaries can be permitted in Springfield. Medical marijuana dispensaries are proposed to be
permitted as a “Special Use” because they must comply with certain licensing requirements as specified
in Chapter 7 of the Springfield Municipal Code; and specific locational prohibitions as proposed below.
Section 3.2-300 Commercial Zoning Districts
3.2-310 Schedule of Use Categories
Commentary. The Neighborhood Commercial (NC) Zoning District, while listed under “Commercial
Districts”, is discussed under the Metro Plan Residential Designation where “neighborhood commercial
services” are allowed as auxiliary uses. The SDC limits the NC Zoning District to not more than 3 acres in
size. Medical marijuana dispensaries are proposed to be prohibited in the NC Zoning because the
locational restrictions proposed in Subsection 4.7-177 below cannot be met.
Commercial Districts
Categories/Uses NC CC MRC GO
Marijuana Uses (Section 4.7.177)
Medical Marijuana Dispensaries N S S S
Section 3.2-400 Industrial Zoning Districts
3.2-410 Schedule of Use Categories
Industrial Districts
Use Categories/Uses LMI HI SHI
Marijuana Uses (Section 4.7.177)
Medical Marijuana Dispensaries S S S
3.2-415 Schedule of Campus Industrial Use Categories
Use Category/Uses CI District
Marijuana Uses (Section 4.7.177)
Medical Marijuana Dispensaries S
Attachment 3, Page 1 of 3
Page 2 of 3
Section 3.2-600 Mixed Use Zoning Districts
3.2-610 Schedule of Use Categories
Districts
Categories/Uses MUC MUE MUR
Marijuana Uses (Section 4.7.177)
Medical Marijuana Dispensaries S S N
Commentary. SDC 4.7-100 contains “special use” standards for a number of permitted uses in various
zoning districts. The proposed Subsection provides specific standards for permitting a medical marijuana
dispensary in any allowable zoning district.
Section 4.7.177 Medical Marijuana Dispensaries
A. Medical marijuana dispensaries shall be:
1. Registered in accordance with ORS 475.314;
2. Licensed and regulated as specified in Chapter 7 of the Springfield Municipal Code; and
3. Permitted in Commercial, Industrial and Mixed Use zoning districts as specified in
Subsections 3.2-310, 3.2-410, 3.2-415, and 3.2-610 of this Code.
B. Where permitted by this Code, medical marijuana dispensaries shall not be located:
1. At the same address as a registered marijuana grow site;
2. Within 1,000 feet of the real property comprising a public or private elementary,
secondary or career school attended primarily by minors (“within 1,000 feet” means a
straight line measurement in a radius extending for 1,000 feet or less in every direction
from any point on the boundary line of the real property comprising an existing public or
private elementary, secondary or career school primarily attended by minors);
3. Within 1,000 feet of another medical marijuana facility (“within 1,000 feet” means a
straight line measurement in a radius extending for 1,000 feet or less in every direction
from any point on the boundary line of the real property compromising a registered
facility); and
Commentary. This standard is not listed in ORS 475.314; the intent is to provide additional protection of
children.
4. Within 1,000 feet of parks, pre-schools and registered day care facilities and residential
zoning districts.
Attachment 3, Page 2 of 3
Page 3 of 3
C. Planning Review.
1. When the proposed dispensary is a change of use in an existing building, Minimum
Development Standards (MDS) as specified in Section 5.15-100 will apply.
2. When the facility is proposed in a new building, Site Plan Review standards as specified
in Section 5.17-100 will apply.
3. MDS or Site Plan Review approval by the Director will require, in addition to any other
conditions of approval, a copy of the Oregon Health Authority registration approval and
a copy of the Springfield medical marijuana facility business license. These documents
shall be required prior to occupancy.
Commentary. The proposed definition of “medical marijuana facility” is the same as the definition in
Chapter 5 of the Springfield Municipal Code.
Section 6.110 Meaning of Specific Words and Terms
Medical Marijuana Dispensary.
A. Marijuana as defined under ORS 475.005.
B. Dispensary. A Medical marijuana facility registered by the Oregon Health Authority under ORS
475.314.
Attachment 3, Page 3 of 3
Attachment 4-a, Page 1 of 1
Attachment 4-b, Page 1 of 1
Attachment 4-c, Page 1 of 1
Potential Medical Marijuana Dispensary Regulations
Discussion With Industry Representatives
1. Protect Children
a. No Minors on Premises. OHA regulations do not prohibit minors and/or
non-card holders from entering into a dispensary (however, minors are
prohibited from entering “secured area” where marijuana is displayed).
Potential Municipal Code Regulation: Have to be a cardholder to be on the
premises and no minors on the premises unless they are accompanied by
legal parent or guardian for the sole purpose for procuring the minor’s
medicine.
b. Locational restrictions. OHA regulations prohibit a dispensary from
locating at the same address as a grow site; within 1,000 feet of an
elementary, secondary or career school; within 1,000 feet of another
dispensary. Potential Development Code Regulation: Prohibit dispensary
from locating within 1,000 feet of parks; pre-school and registered daycare;
and residential zones.
2. Sign Code. Oregon Health Authority has no regulations relating to the Sign
Code.
a. Re-enforce Sign Code Regulations. Potential Development Code
Regulation: All marijuana businesses are subject to the requirements of
the Springfield Sign Code.
i. Although not new regulations, by making it explicit that the sign
code applies to the dispensaries will re-enforce the requirements
for the businesses such as the requirement to obtain a permit and
prohibit use of logos that are not that of the business.
3. Land Use. OHA regulations prohibit a dispensary from locating at the same
address as a grow site; within 1,000 feet of an elementary, secondary or career
school; within 1,000 feet of another dispensary. Potential Development Code
Regulation: Dispensaries should be added to the list of permitted uses in
commercial, and mixed use zones, subject to buffer zones discussed above.
Listing and definition of the use allows normal processing and enforcement of
appropriate planning and building approvals.
Attachment 5, Page 1 of 2
4. Miscellaneous—Examples of regulations adopted by other jurisdictions.
a. Hours of Operation. Potential Municipal Code Regulation: no sale or
other distribution of marijuana upon the premises or via delivery between
7:00 pm and 8:00 am.
b. Giveaways. Potential Municipal Code Regulation: Dispensaries may not
distribute to consumer marijuana or marijuana-infused products free of
charge.
c. Business License. Potential Municipal Code Regulation: Dispensaries
must obtain a business license and register with the City. This ensures
that the City is aware of all dispensaries operating in the City.
d. Display of State license. Potential Municipal Code Regulation:
Dispensaries must display their OHA license. This ensures that staff is
aware that the dispensary is lawfully licensed under the OHA regulations.
e. No Consumption of Marijuana Premises. The OHA regulations require
that no consumption, ingestion, inhalation, or topical application of usable
marijuana is permitted on the premises. There is an exception for
employees. Potential Municipal Code Regulation: Restate the OHA
requirement.
f. Background Checks- The OHA regulations require background checks
for the Person Responsible for the Facility. Potential Municipal Code
Regulation: All employees shall undergo background checks.
Attachment 5, Page 2 of 2