Oce of the Government Records Ombudsman
GRAMA Claim of Business Confidentiality
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GRAMA Claim of Business Confidentiality
The following is a concise statement supporting the claim of business confidentiality related to
Columbia Care UT LLC’s (“Applicant”) submission for medical cannabis processing
establishment application:
The information contained on pages 1 and 5 contain non-public individual and business
information that is protected as trade secret and contains specific employee name and contact
information. Applicant derives independent economic value from its business location, ownership
structure, expected opening date, and operational hours to the extent that information is not readily
ascertainable. Our competitors can derive economic value from its disclosure. Applicant has taken
reasonably efforts to maintain the secrecy of such information.
Processing Establishment Property Information
The information contained on pages 6 through 14 contain non-public property and facility
information that is protected as trade secret. Applicant derives independent economic value from
its facility layout, blueprint descriptions, and description summaries for highly competitive
application submissions. It has hired experts and expended considerable resources to design a
state-of-the-art facility. Our competitors can derive economic value from its disclosure and
competitive advantages from the disclosure of such information that is not publicly available.
Applicant has taken reasonably efforts to maintain the secrecy of such information. In addition,
keeping Applicant’s facility diagrams confidential is vital for ensuring a secure facility. Disclosure
could compromise the safety of the facility, its contents, and the employees working within the
facility.
Operating Plan
The information contained on pages 15 through 40 strike at the heart of trade secret information
and describe our facility’s operating plan. Applicant derives independent economic value from its
product types, product type descriptions, extraction methods and processes, equipment used,
applicable security procedures and protocols, storage plans, recall practices, destruction methods,
transportation strategies, and the formulas patterns, compilations, programs, devices, methods,
techniques, and processes associated with the operating plan. Its description and summaries are
kept confidential and are only available to internal personnel that need to know the information.
Any such disclosure may be used in a highly competitive application submissions by competitors
not only in Utah but other jurisdictions as well. Applicant has hired experts and expended
considerable resources to develop its operating plan. Applicant has taken reasonably efforts to
maintain the secrecy of such information. In addition, keeping Applicant’s security information
confidential is vital for ensuring a secure facility. Disclosure could compromise the safety of the
facility, its contents, and the employees working within the facility.
Appendixes
Applicant’s Ownership structure, performance bond, manufactured food status, business license,
and municipal permit constitute trade secret information. The descriptions constitute methods and
techniques related to the application procedures that our competitors could use upon disclosure to
submit similarly situated applications without expending the time and resources necessary to create
the same content. Applicant derives economic value from such documents and has taken
reasonably necessary efforts to maintain its secrecy. Further, the ownership issue contains personal
information not readily available to the public.
GRAMA Claim of Business Confidentiality
This concise statement constitutes a trade secret. As with other portions of the application
descriptions, Applicant derives economic benefit from these statements. If disclosed, competitors
could bypass the time and training expended and expertise necessary to detail trade secret and
confidential information by copying such descriptions. Applicant has limited access to such
descriptions and has not made them readily available to the public.
Utah Department of
Agriculture & Food
350 North Redwood Rd
P.O. Box 146500
Salt Lake City, UT 84114
MEDICAL CANNABIS
PROCESSING
ESTABLISHMENT
APPLICATION CHECKLIST
Website: www.ag.utah.gov
Phone: 801-982-2200
Email: cannabis@utah.gov
The Application submitted by a Cannabis Processing Facility and approved by the Establishment Board will
be considered the business’s operation plan. UDAF Inspectors will use the operation plan for regulatory
purposes. Ensure all information is complete, current, and accurate.
The information provided by the applicant for a Medical Cannabis Production Establishment must fit within the
following Guidelines:
a) Maximum 50 pages
b) Information provided must be clear and concise; do not repeat information
c) Ensure each section speaks to the requested information; and are in the same order as application
d) Everything in the application is contained in a single PDF document.
Utah Department of
Agriculture & Food
350 North Redwood Rd
P.O. Box 146500
Salt Lake City, UT 84114
MEDICAL CANNABIS
PROCESSING
ESTABLISHMENT
APPLICATION
Medical Cannabis Program
Application Number: ___________
(office use only)
Medical Cannabis Processor Facility is multi-tiered:
(a) A tier 1 processor license allows the licensee to process, manufacture, dry, cure, package, and label cannabis and
cannabis products for sale or transfer to another cannabis processing facility, a medical cannabis pharmacy, or the
state central fill medical cannabis pharmacy. A tier 1 processing license is $100,000 per year.
(b) A tier 2 processor license allows the licensee to package and label cannabis and cannabis products for sale or
transfer to another cannabis processing facility or a medical cannabis pharmacy. A tier 2 processing license is $35,000 per
year.
All Facilities must pay a non-refundable application fee of $1,250.00 before the application is reviewed. Call
UDAF’s number 801.982.2200 and ask for accounting to make the payment.
Prior to approving an application, the department may contact any applicant and request additional supporting documentation or information.
The department may conduct face-to-face interviews with an applicant if needed.
The department shall inspect the premises to determine if the applicant complies with state laws, administrative rules and best practice
standards.
Ownership Information
1. Ownership Entity: ______________________________________________________________
__________________
Entity Type: Individual Partnership Corporation Limited Liability Company
2. DBA: (assumed name of business) _____ _________________________________________________________________
3. Processing Facility Address:
STREET CITY STATE ZIP
4. Mailing Address:
________________________ ___________
(IF DIFFERENT) STREET CITY STATE ZIP
5. Business Phone: _______ Fax: ____________ _______ Other/office: _ _______________________
6. Facility Manager Contact: ___________ _______ Phone number:______ ____________ Email:______ ________ _________
7. Contact Person for Inspections: _ ___ Phone number:__ _______ Email:
Columbia Care UT LLC
TBD N/A
N/A
8. Contact Person for Sampling / Results: _ __ Phone number: __ Email:
9. Additional Contact: ______________________ Phone number:________ __________ Email:________ ________
10. Other industrial hemp and/or medical cannabis licenses currently or previously held by applicant/entity/principals:
Ownership Information
An owner is a person who, if the company is privately held, has a financial or voting interest of 2% or greater in the cannabis
production establishment; or if the entity is publicly traded has more than a 2% financial interest in the company; or is an individual
who has the power to direct or cause the management or control of a facility, in other words is a general manager of daily
operations.
List all Owners and their positions in the Company.
Legal Name (First & Last)
Role in the Company’s Finances and
Decisions
DATE OF
BIRTH
mm/dd/yy
FINGERPRINTS SUBMIITTED
Y/N
11. The applicant understands that as an applicant and potential licensee you are REQUIRED to know the current
statutory law, administrative rules and Departmental policies and comply in full? Yes No
12. Criminal History Background Documents must be submitted for all owners. Background Forms should NOT be part
of the application. Go to https://medicalcannabis.utah.gov/production/processors/ for background check
information.
13. Descriptions of the credentials and experience of each officer, director, and owner and prospective employee who
have a financial or voting interest of 2% or greater in the proposed cannabis production establishment; or the power
to direct or cause the management or control of a proposed cannabis production establishment
a) A description of any investigation or adverse action taken by any licensing jurisdiction, government agency,
law enforcement agency, or court in any state for any violation or detrimental conduct in relation to any of the
applicant’s cannabis-related operations or businesses.
Processing Facility Information
14. Application for: Tier 1 Tier 2
15. Projected Opening Day: Days/hours of operation:
Processing Establishment Property Information
16. Submit for Company’s Current Cannabis Processing Facility a Blueprint with:
a) the square footage of the areas where cannabis is extracted;
b) the square footage of the area(s) where cannabis products are manufactured;
c) location of all extraction machinery/ stationary equipment;
d) the square footage of the areas used for storage and what type of product is stored there (i.e crude oil,
untested products, final tested product) ;
Dispensary License: CCUT Pharmacy LLC
In Progress
In Progress
*See Appendix A attached
e) the areas where cannabis is to be dried, trimmed, and cured (if applicable);
f) the square footage of the areas where cannabis is to be packaged;
g) the location of the toilet facilities and hand washing facilities;
h) the location of a break room;
i) the location of lobby or area where non-agents can access.
j) the location of the areas to be used for loading and unloading of cannabis products for transportation; and
k) the location of all cameras and external lights.
17. Proximity: Confirm the proposed location is 1000 feet or more by pedestrian travel to a “community location” and is
600 feet or more by pedestrian travel to any district zoned as primarily residential. YES NO
Operating Plan
18. List all product types that will be produced in the upcoming year. (i.e Vapes, Salves, Flower)
19. List all extraction methods used at the facility. Include all solvents, chemicals, and equipment used.
20. Is the facility doing CBD to THC conversion? If yes, outline the facility’s methods.
21. Provide all written emergency procedures for Fire, Chemical Spills, and other Emergencies. This information plus the
Material Safety Data Sheet (MSDS) must be easily accessed by all employees.
22. Submit the facility’s most up-to-date security plan. Security plans shall include:
a) description of security alarm system;
b) person(s) notified of potential security breaches and alerts;
c) video storage device location: local or cloud storage
d) procedures to provide UDAF inspectors immediate access to current and archived video footage when requested.
e) any additional security measure in place that exceed the security requirements outlined in R68-28-6
23. Provide the facility’s storage protocols, both short and long-term, to ensure all cannabis is stored in a manner that is
sanitary and preserves the integrity of the cannabis in accordance to R68-28-9.
24. Provide the processing facility’s written plan and procedures to handle potential recalls in accordance to R68-28-14.
Include:
a) The name(s) of persons designated as recall coordinator (R68-28-14(2a);
b) the contact information for how to reach staff member(s);
c) how will affected parties be notified;
d) a written procedure with specifics of what to do in case of a product recall.
25. Submit procedures on how the facility will dispose of Product that fails quality assurance testing. A destruction plan
must be written for every product type produced at the processing facility, and must be in compliance with federal
and state laws laid out in Utah Code 4-41a-405 and Rule R68-27-15 Cannabis Waste Disposal.
26. Detail the procedures the facility has employed to meet the transport and transfer requirements of Utah Rule R68-28-
13. Include the make and model of every vehicle the company will use to transport Cannabis Material.
Compliance
27. Submit proof of a $50,000 performance bond. (See Appendix B)
28. The facility understands all scales must be certified, as outlined in Utah Administrative Rule 68-28-4 (8). Visit https://
ag.utah.gov/businesses/regulatory-services/weights-measures/ for more information.
29. Submit proof of registration as a Manufactured Food Establishment with UDAF’s Regulatory Services. (See Appendix C)
30. Submit a current local business license or permit from the city/municipality. (See Appendices D & E)
31. The Facility is responsible for ensuring all employees have background checks and are registered in the Electronic
Verification System (EVS). The company is also responsible for collecting agent cards and notifying the Department
when an agent leaves their facility. Failure to comply will result in a citation and a fine to the company.
AGREE
LICENSE AGREEMENT
Applicant understands the requirements for licensure are based on current statute and rule and are subject to change.
Applicant agrees as a condition of licensing that he has read and will abide by the provisions of Utah Code 4-41a and all rules
promulgated thereunder and all directives of the Utah Department of Agriculture and Food. The applicant also understands
that failure to adhere to or maintain the qualifications of their license, may result in suspension or revocation of the license
and/or forfeiture of the performance bond or any other remedies allowed by law.
Applicant agrees to immediately notify the department of any change in ownership or financial interest of the facility; the
facility's name, change in location, change in testing methods, equipment, remodeling, expansion, reduction or physical, non-
cosmetic alteration of the facility, change in written operating procedures, or change in any information submitted in this
application.
The undersigned acknowledges that representatives of the Utah Department of Agriculture and Food may inspect the records
and facility of a cannabis production establishment at any time during business hours to determine and ensure the cannabis
production establishment is in compliance with the law. Failure to provide the department or the department's authorized
agents immediate access to records and facilities during business hours in accordance with this section may result in a civil
monetary penalty; license or registration suspension or revocation; or an immediate cessation of operations under a cease and
desist order issued by the department.
Disclaimer:
Applicant acknowledges and understands that cultivating, possessing, using, distributing and/or selling marijuana is
prohibited by federal law, notwithstanding Utah law or any authorizations in the Agent or this Registration to the contrary.
Nothing in this Application is intended to provide any guidance or assistance in violating or complying with existing federal
laws regulating marijuana cultivation, distribution, or use. Similarly, compliance with state law or the terms of this
Registration, or possession of the registration card does not confer immunity from enforcement of federal law or federal
enforcement practices. Further, nothing in this Application or the Registration Card shall be construed as advice with regard
to compliance with applicable federal, state, or local tax laws or any regulatory consequences of engaging in any business in
this industry.
The undersigned acknowledges that he/she has read and understands the statements herein and the execution thereof is done
voluntarily and by the authorization of the applicant entity.
The undersigned hereby makes application to the Utah Department of Agriculture and Food and certifies that the information
contained hereinP and attached here is true and correct.
If selected for a license, applicant agrees to pay the required license fee ($100,000 Tier 1 or $35,000 Tier 2) within 30 days of
being notified of licensure decision.
_____ ________________________
___________________________
Applicant/Owner of business Title/Position
__________________________________________ ___________________
Applicant Signature Date
4/12/2021
President, Columbia Care UT LLC
Columbia Care UT LLC
2021 Renewal Application
Columbia Care UT LLC
TIER ONE MEDICAL CANNABIS PROCESSING
2021 RENEWAL APPLICATION
April 14, 2021
Submitted by:
President, Columbia Care UT LLC
Columbia Care UT LLC
2021 Renewal Application
Processing Establishment Property Information
16. Current Cannabis Processing Facility Blueprints with:
a) The square footage of the areas where cannabis is extracted;
b) The square footage of the areas where cannabis products are manufactured;
c) Location of all extraction machinery/stationary equipment;
d) The square footage of the areas used for storage and what type of products is
stored there (i.e. crude oil, untested products, final tested products);
e) The areas where cannabis is to be dried, trimmed, and cured (if applicable);
f) The square footage of the areas where cannabis is to be packaged;
g) The location of the toilet facilities and hand washing facilities;
h) The location of the break room;
i) The location of lobby or area where non-agents can access;
j) 10.The location of the areas to be used for loading and unloading of cannabis
products for transportation; and
k) The location of all cameras and external lights
Columbia Care UT LLC has provided current Cannabis Processing Facility Blueprints, demonstrating compliance
with U.A.C. R68-28-4
Attachment B provides blueprints for Columbia Care UT LLC’s proposed equipment needs, including all
extraction machinery and stationary equipment.
17. Proximity
Columbia Care UT LLC confirms that the proposed location is 1,000 feet or more by pedestrian travel to a
“community location” and is 600 feet or more by pedestrian travel to any district zoned as primary residential.
Attachment A
t © 2021 KLUB
NOTE: SCALES DEPICTED ON THIS DRAWING ARE NOT CORRECT UNLESS PLOTTED SHEET SIZE IS 30 X 42 INCHES.
4/1/2021 6:25:55 PM BIM 360://1350 - Columbia Care - Centerville UT Manufacturing Facility/1350 - Arch-Struc.rvt
Attachment B
Attachment C
Attachment D
Columbia Care UT LLC
2021 Renewal Application
Operating Plan
Product Types and Extraction Methods
18. List all product types that will be produced in the upcoming year:
Columbia Care UT LLC will produce approved derivatives of products limited to the forms and
routes of administration allowed by the Department in compliance with Utah Code
26-61a-102(32)
In compliance with U.A.C. R68-28-10,
•
Columbia Care UT LLC
2021 Renewal Application
19. List all extraction methods used at the facility. Include all solvents, chemicals, and
equipment used:
n order to extract the
cannabinoids from the plant material and pursuant to U.A.C. R68-28-5(2),
will be at least 99% purity in compliance with U.A.C. R68-28-5(3).
in compliance with U.A.C. R68-28-5(4) and
R68-28-5(5), is:
• Safe for its intended use;
• Commercially manufactured, and
• Built to codes of recognized and generally accepted good engineer practices such as:
o The American Society of Mechanical Engineers (ASME);
o American National Standards Institute (ANSI);
o Underwriters Laboratories (UL); or
o The American Society for Testing and Materials (ASTM).
Columbia Care UT LLC
2021 Renewal Application
Columbia Care UT LLC will ensure that all processing agents
l have direct access to all applicable Material Safety Data Sheets (MSDS)
in compliance with U.A.C R68-28-5(10).
In compliance with U.A.C. R68-28-5(11),
Columbia Care UT LLC will ensure that parts per million of one gram of finished extract will not
exceed residual solvent levels set forth in U.A.C. R68-29-6.
in approved Medicinal Dosage Forms specified in Utah Code 26-61a-
102(32).
.
Columbia Care UT LLC
2021 Renewal Application
samples are taken and independent laboratory testing,
per U.A.C R68-29-3(2), is completed.
Columbia Care UT LLC
2021 Renewal Application
waste protocols, and in
compliance with U.A.C. R68-28-15 and R68-27-12
in compliance with U.A.C. R68-29-3(2).
Columbia Care UT LLC shall dispose
of the entire batch or lot from which the sample was taken in compliance with U.A.C. R68-29-3(7).
Columbia Care UT LLC
2021 Renewal Application
o
in compliance with U.A.C. R68-
28-5 during the extraction of medical cannabis. This includes:
•
20. Is the facility doing CBD to THC conversion? If yes, outline the facility’s methods:
Columbia Care UT LLC
2021 Renewal Application
Security
21. Provide all written emergency procedures for Fire, Chemical Spills, and other
Emergencies. This information plus the Material Safety Data Sheet (MSDS) must be
easily accessed by all employees.
Columbia Care UT LLC
2021 Renewal Application
o
Columbia Care UT LLC
2021 Renewal Application
Columbia Care UT LLC
2021 Renewal Application
Columbia Care UT LLC
2021 Renewal Application
Columbia Care UT LLC
2021 Renewal Application
Columbia Care UT LLC
2021 Renewal Application
Columbia Care UT LLC
2021 Renewal Application
.
Columbia Care UT LLC
2021 Renewal Application
22. Most up-to-date security plan including:
a) Description of security alarm system
b) Person(s) notified of potential security breaches and alerts
c) Video Storage Device location: local or cloud storage
d) Procedures to provide UDAF inspectors immediate access to current and archived video
footage when requested
e) Any additional security measure in place that exceed the requirements outlined in R68-
28-6
s. In compliance with U.A.C R68-28-6(1),
Columbia Care UT LLC
2021 Renewal Application
strict adherence to the visitor policies set forth by U.A.C. R68-28-6.
Columbia Care UT LLC
2021 Renewal Application
Acceptable forms of identifications must contain a name, photograph and date of birth
and be a valid form of photo identification (ID) including any of the following United States federal
or state-issued photo ID as defined in Utah Code 26-61a-102(44):
• A driver license;
• A United States passport;
• A United States passport card; or
• A United States military identification card
The badge must be visible at all times in compliance with U.A.C. R68-28-6(9).
The visitor shall always be physically escorted by a medical cannabis processing facility agent
authorized in compliance with U.A.C R68-28-6(10).
As required by U.A.C. R68-28-6(11), the Visitor Log shall include:
• Visitors full name
• Visitor Identification Badge Number issued
• Date of arrival
• Time of arrival
• Time of departure
• Purpose of the visit
Per U.A. C. R68-28-6(12) and (13),
.
will exceed U.A.C. R68-28-6(4).
Columbia Care UT LLC
2021 Renewal Application
•
at least 640 x 470 pixels in compliance with U.A.C. R68-28-6(2)(a),
the
requirements set forth in U.A.C. R68-28-6(2).
requirement set forth in U.A.C. R68-28-6(2)(b),
Columbia Care UT LLC
2021 Renewal Application
in compliance with U.A.C R68-28-6(8).
Columbia Care UT LLC
2021 Renewal Application
23. Storage Plan
Provide the facility’s storage protocols, both short and long-term, to
ensure all cannabis is stored in a manner that is sanitary and preserves the
integrity of the cannabis in accordance to R68-28-9
In compliance with U.A.C. R68-28-9 and R68-28-15, Columbia Care UT LLC will implement
s.
disposed of in accordance with U.A.C.
R68-28-15 and R68-27-12.
In accordance with U.A.C. R68-28-9, these containers
will be stored on shelving that is a minimum of six inches off of the ground.
Columbia Care UT LLC
2021 Renewal Application
.
Columbia Care UT LLC will enforce standard operating procedures in compliance with U.A.C. R68-
28-9,
Columbia Care UT LLC
2021 Renewal Application
24. Recall Plan
Provide the medical cannabis processing facility’s written plans and procedures to
handle potential recalls in accordance to R68-28-14. Include:
a) The name(s) of persons designated as recall coordinator (R68-28-14(2))
b) The contact information for how to reach staff member(s)
c) How will affected parties be notified
d) A written procedure with specifics of what to do in case of a product recall
In compliance with U.A.C. R68-28-14, in the event the Utah Department issues a public notice
regarding a product recall,
Columbia Care UT LLC
2021 Renewal Application
25. Destruction and Disposal of Cannabis
Submit procedures on how the facility will dispose of Product that fails quality
assurance testing. A destruction plan must be written for every product type produced
at the processing facility, and must be in compliance with federal and state laws laid
out in Utah Code 4-41a-405 and Rule R68-27-15 Cannabis Waste Disposal
In compliance with Utah Code 4-41a-405, Columbia Care UT LLC’s processing facility
Columbia Care UT LLC
2021 Renewal Application
in compliance with U.A.C R68-27-12 prior to final disposal.
Columbia Care UT LLC
2021 Renewal Application
26. Transportation Plan
Detail the Procedures the cannabis facility has employed to meet the transport and
transfer requirements of Utah Administrative Code R68-28-13, Transportation.
Include the make and model of every vehicle the company will use to transport
Cannabis Material
Columbia Care UT LLC’s transportation and delivery procedures will operate in compliance with
U.A.C R68-28-13.
all requirements set forth in U.A.C R68-28-13 are being met and adhered to.
Columbia Care UT LLC
2021 Renewal Application
•
Columbia Care UT LLC
2021 Renewal Application
In compliance with U.A.C R68-28-13, a printed transport manifest shall accompany every transport
of medical cannabis product.
Columbia Care UT LLC
2021 Renewal Application
Appendix A: Ownership
Utah Department of Agriculture and Food
PO Box 146500
Salt Lake City, UT 84114-6500
Appendix B: Performance Bond
Columbia Care UT LLC
2021 Renewal Application
Appendix C: Manufactured Food Establishment
Appendix D: Current Business License
Appendix E: Permit from City/Municipality
