Review
Investigation
Procedures

Background

The Master Instructor Program is Green CulturED’s voluntary training initiative focused on hazard awareness and compliance in the cannabis industry. The Program is designed to promote workplace safety and operational compliance by educating cannabis industry workers about workplace hazards, regulatory responsibilities, and compliance measures. It provides learners with critical information about safety regulations and teaches them about their rights, employer responsibilities, and how to maintain compliance with cannabis industry standards, including identifying, preventing, and addressing job-related hazards.

Master Instructors authorized through Green CulturED’s Master Instructor Program and any organization acting on behalf of the trainer (or certified partner) must conduct training classes following:

1. The current Master Instructor Program Requirements
2. Cannabis-specific training procedures, such as Responsible Vendor Training (RVT)
3. Other compliance guidance issued by Green CulturED

It is the responsibility of every Master Instructor and certified partner to adhere to the current Program Requirements, cannabis-specific procedures, and other issued guidance. Failure to comply may necessitate corrective action, up to and including the revocation of authorization to conduct or provide training under the Master Instructor Program.

As outlined below, Green CulturED may take corrective action, including probation, suspension, or revocation of a Master Instructor’s (or certified partner’s) authority to conduct training and issue learner certifications for failure to comply with Program Requirements, cannabis-specific procedures, or other issued guidance. Green CulturED may also publish the names of trainers and certified partners subject to suspension or revocation on its public Trainer Compliance Watch List.

Fact-Finding

The Chief Training Officer (CTO) for Green CulturED shall review instances where a Master Instructor (or certified partner) may not comply with current Program Requirements, cannabis-specific procedures, or issued guidance. The CTO shall seek and collect all available information and may request additional documentation from certified partners, learners, or other parties. During this process, the CTO may, at their discretion, contact the Master Instructor or certified partner under investigation to gather additional insights. All relevant information will be retained in an investigative file.

The CTO may contact industry regulators or compliance officers for assistance in the investigation and may assign staff to investigate allegations of misconduct, forwarding findings to the CTO for further review.

The CTO, in consultation with Green CulturED’s executive leadership, may exercise discretion to suspend the Master Instructor’s (or certified partner’s) authority to conduct training and issue certifications during the investigation. If suspension occurs, Green CulturED may include the trainer’s name on the Trainer Compliance Watch List.

Notification of Alleged Noncompliance

The CTO shall notify the Master Instructor (or certified partner) of any allegations regarding noncompliance with the Program Requirements, cannabis-specific procedures, or issued guidance. The notification shall:

1. Name the Master Instructor (or certified partner)
2. Provide a detailed description of the facts and circumstances supporting the allegations
3. Inform the Master Instructor (or certified partner) of the response due date
4. Advise that a Decision by Default may result if a timely response is not filed

Master Instructor Response

The Master Instructor (or certified partner) shall have an opportunity to respond to the Notification of Alleged Noncompliance. The response must include any arguments or evidence the Master Instructor or certified partner believes address the allegations raised in the notification. To be considered timely, Green CulturED must receive the response within fifteen (15) calendar days from the date the notification is received by the Master Instructor (or certified partner).

Decision by Default

If the Master Instructor (or certified partner) fails to respond to the Notification of Alleged Noncompliance within the required timeframe, Green CulturED may issue a Decision by Default. This will result in an indefinite suspension until the Master Instructor or certified partner responds to the notification. Additionally, the trainer’s name will be added to the Trainer Compliance Watch List with a “suspension” status, and the certified partner’s name may be removed from the list of authorized Green CulturED providers. Alternatively, Green CulturED may opt to issue an Initial Decision based on the investigation and available information.

Voluntary Termination

If at any point before the conclusion of an investigation, or after the issuance of a Decision by Default, a Master Instructor chooses to voluntarily terminate their authorized status instead of responding to the Notification of Alleged Noncompliance, they may do so in writing. This written statement must unequivocally state that the Master Instructor agrees not to seek reauthorization in the future. The Master Instructor must also surrender any Green CulturED-issued Master Instructor certifications or credentials when submitting their written statement. Voluntary termination is considered a permanent revocation, and the Master Instructor’s name will be placed on Green CulturED’s Trainer Compliance Watch List with a status of “revocation.”

If, after voluntary termination, the Master Instructor seeks or attempts to seek reauthorization in the future, Green CulturED will reopen the investigation and may pursue additional corrective action, up to and including permanent revocation and debarment from future participation in the Master Instructor Program.

Initial Decision

After the investigation, Green CulturED’s Chief Training Officer (CTO) shall issue an Initial Decision and will consider all available and relevant material in the investigative file, as well as any arguments and/or evidence submitted by the Master Instructor (or certified partner), when rendering the Initial Decision. The Initial Decision shall include a statement of findings and conclusions, impose appropriate corrective actions, and inform the Master Instructor or certified partner of the right to appeal the Initial Decision to Green CulturED’s executive leadership.

Appeal

The Master Instructor (or certified partner) may appeal the Initial Decision to Green CulturED’s executive leadership. The appeal must include specific reasons why the Initial Decision should be modified or reversed. To be considered timely, the appeal must be received by Green CulturED within fifteen (15) calendar days from the date the Initial Decision was received by the Master Instructor or certified partner.

Final Decision

Green CulturED’s executive leadership shall issue a Final Decision after the time for filing a timely appeal has expired. The leadership team shall review an appeal (if submitted) and may consult with relevant Green CulturED staff during the review but shall exercise independent judgment when rendering the Final Decision. The Final Decision shall consider all available and relevant material in the investigative file, as well as any arguments and/or evidence submitted by the Master Instructor (or certified partner). The Final Decision shall affirm, modify, or reverse the Initial Decision, and/or remand the case for further investigation. The Final Decision shall state that no further review will be available within Green CulturED.

Corrective Action/Effect of Probation, Suspension, or Revocation

A Final Decision may subject a Master Instructor (or certified partner) to corrective actions, including, but not limited to, probation, suspension, or revocation of their Master Instructor authorization. In the event of suspension or revocation, the Master Instructor’s (or certified partner’s) name will be placed on Green CulturED’s Trainer Compliance Watch List. Green CulturED will notify its certified partners of the status of Master Instructors and organizations under probation, suspension, or revocation.

Probation

Except in cases of willfulness or where public health, interest, or safety requires immediate action, before any suspension or revocation of a Master Instructor’s (or certified partner’s) authorization, Green CulturED may allow the opportunity to demonstrate or achieve compliance with Program Requirements, cannabis-specific procedures, and other guidance through a probationary period.

During probation, the Master Instructor (or certified partner) may continue to offer and teach classes through the Master Instructor Program and issue learner certifications, provided they comply with the terms of the probation, which may include but are not limited to:

• Advance notification of all planned Green CulturED training programs
• Submission of advance copies of all promotional materials (including hard copy, electronic, and website) related to the Master Instructor’s training
• Submission of additional class documentation or detailed records for each class conducted, as requested by Green CulturED

Probation ends after the period stated in the Final Decision. Master Instructors (or certified partners) are not required to request reinstatement after their probation.

Suspension

If the Final Decision suspends the Master Instructor (or certified partner) may not conduct any Green CulturED training programs during the suspension period. The Final Decision may require the Master Instructor (or certified partner) to request reinstatement after the suspension period. Following reinstatement, the Master Instructor (or certified partner) may be placed on probationary status and subject to appropriate probationary terms.

Revocation

If the Final Decision imposes revocation, the Master Instructor (or certified partner) is permanently barred from conducting or offering any training through Green CulturED. Individuals or organizations whose authorization has been revoked are not eligible for reinstatement.

Reinstatement

Master Instructors and certified partners under suspension may request reinstatement following the end of the prescribed suspension period. Additional terms, including a probationary period, may apply to reinstatement as outlined in the Final Decision.

Trainer Compliance Watch List

Green CulturED publishes the Trainer Compliance Watch List, which includes individuals whose authority to conduct training programs has been suspended or revoked due to failure to comply with Program Requirements, cannabis-specific procedures, or other issued guidance. Certified partners whose authority to conduct training has been suspended or revoked will be removed from Green CulturED’s list of authorized providers.

Review of Procedures

Green CulturED will revise these procedures as warranted to maintain the quality and compliance of its Master Instructor Program.