The State of Ohio Division of Cannabis Control’s (“DCC”) recently adopted rule on employee training and qualification requirements takes effect on January 1, 2026. This new rule contained little details on how operators are expected to comply.¹ Fortunately, the DCC recently released guidance and new, publicly available resources on its website to fill that gap. Combined, they provide practical steps operators can take before January 1.

Training Documentation and Inspection Readiness

Before discussing content and license‑type nuances, operators should note DCC’s emphasis on proof of training. Training records must be retained for two years pursuant to Ohio Administrative Code² and will be reviewed during Certificate of Operation and renewal inspections. The guidance makes clear that training documentation will become a standard component of compliance audits, meaning operators should expect inspectors to request and review these records as part of routine regulatory oversight.

To that end, all licensees must maintain an Employee Training Record Form that identifies (1) the trainer and their qualifications, (2) the materials used, (3) the employees trained, (4) training dates, and (5) any certificates of completion. The form adds additional clarity by specifying the precise training elements each category of licensee is expected to document. Although the guidance itself establishes baseline training expectations, the form reveals how the DCC intends to verify compliance during inspections. Because inspectors will rely on this form to confirm whether each employee received the appropriate training, operators should pay close attention to the training elements applicable to their license type.

The guidance also clarifies that each licensee must ensure that training materials are reviewed at least once per calendar year and updated as necessary. Additionally, each licensee must ensure that all employees regularly receive training, which includes any updates to training materials.

License Specific Clarifications & Training Resources

Under the new rule, foundational training for employees across all license types must include instruction on Metrc, Ohio’s seed-to-sale tracking system, and accurate documentation of all cannabis maintained at the licensed premises. The DCC recently clarified that employees who access Metrc must complete the New Business Training program before using the system and encourages employees to take additional “business journey” courses tailored to their facility type. These trainings are available on demand through the Metrc Learn platform.

For dispensaries, the DCC guidance closely tracks the rule but also directs operators to key compliance resources (e.g., qualifying conditions, the OARRS-PMP eCourse, and the Foundational Training page). The DCC does not mandate a specific format or adopt an approval process for training materials. Instead, dispensaries may develop internal materials or utilize third-party options, provided the materials are accurate and updated as regulations evolve.

For cultivators and processors, the new rule requires either a 30 hour Occupational Safety and Health Administration (OSHA) General Industry course for at least one safety leader or an approved third party OSHA safety consultant who provides regular trainings and safety audits. The DCC guidance clarifies that the approval pathway for consultants requires contacting the Cannabis Service Center (CSC) via the CSC Portal or by emailing DCC at DCCCompliance@com.ohio.gov with a prescribed subject line: “[DCC License Number] - [Licensee Business Name] - OSHA Approval Request.”

The new rule also requires processors to ensure that at least one highly-trained employee is available during all operating hours when cannabis products are prepared or packaged. This individual must be a Certified Food Protection Manager through a provider accepted by the Ohio Department of Health (ODH) or through a nationally recognized accrediting agency approved by the Division. If a processor wants to use a provider that is not on the ODH-approved list, the processor must request approval from the Division. Again, the request should be submitted through the CSC Licensee Portal or by emailing DCCCompliance@com.ohio.gov. The subject line must follow the prescribed format: “[DCC License Number] - [Licensee Business Name] - Food Protection Provider Request.”

Developing Training Materials: Flexibility Without Pre-Approval

The DCC guidance next provides that “[u]nless specific training content or materials is otherwise prescribed, licensees may independently develop content where appropriate or work with a qualified third-party.” The DCC does not require pre-approval of training materials.

Such flexibility places heightened responsibility on operators. Employers must ensure that training content is complete, accurate, and reflective of current rules and procedures. They must also maintain systems to track revisions, retrain employees when updates occur, and produce documentation upon request. The absence of pre-approval simplifies administrative procedures but expands the operator’s obligation to maintain strict internal compliance.

Looking Ahead to 2026 Compliance

With the January 1, 2026, effective date approaching, operators need to act now and into 2026 to ensure their training programs and documentation processes are fully compliant. Employee Training Guidance and updated resources on DCC’s website provide some operational clarity that the new rule lacks. Operators, either through their own operations and human resources professional, with qualified consultants or their legal advisors, should ensure that existing onboarding processes, confidentiality protocols, dispensing procedures, and recordkeeping practices align with the DCC’s expectations.

Contact Ice Miller if you have questions about the DCC’s new rule and guidance.

^{[1] OAC § 1301:18-3-10.
[2] OAC § 1301:18-3-14(B)(6).}

This publication is intended for general information purposes only and does not and is not intended to constitute legal advice. The reader should consult with legal counsel to determine how laws or decisions discussed herein apply to the reader's specific circumstances.