ELB Works

The Client

A cannabis and hemp beverage brand operating across multiple regulated state markets in the United States, selling through state-licensed cannabis dispensaries and authorized hemp retail locations.

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The Challenge

The client engaged ELB Works to build a compliance framework for a new customer rewards program — a merchandise rewards program designed to launch simultaneously across two distinct commercial channels: cannabis sales through state-licensed dispensaries, and hemp product sales through retail locations.

The program needed to operate consistently across six states, each with its own regulatory framework governing cannabis advertising, marketing, and promotions. The core compliance question was whether a points-based rewards program — where consumers earn points on qualifying purchases and redeem them for branded merchandise — could be structured to operate lawfully across a multi-state, dual-channel program without triggering “free cannabis” prohibitions, unauthorized advertising restrictions, or other state-specific marketing violations.

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The Approach

ELB Works conducted a primary-source regulatory review across all six states, building a compliance framework from the ground up.

State-Specific Advertising & Promotions Analysis
Reviewed primary statutory and regulatory sources in California (DCC regulations), Arizona (A.R.S. and A.A.C.), and Nevada (NRS and NCCR) to map the exact boundaries of permissible promotional mechanics. Developed a four-tier risk evaluation scale to communicate compliance risk clearly and consistently to the client across all deliverables. Built a state-by-state compliance matrix covering free product prohibitions, loyalty programs, discounts, branded merchandise, and QR-code cash rebate programs.

Dual-Channel Program Structure
Identified that the program needed to operate across two distinct channel types — single channel cannabis only states and dual channel cannabis and hemp retail states — and developed channel-specific definitions for Qualifying Purchases, Retail Locations, and State Licensed Cannabis/Marijuana Facilities that could be housed in a single terms document with carve-outs by channel type, rather than maintaining separate documents per channel.

Terms & Conditions Review
Reviewed the full program membership terms against cannabis advertising and promotions regulations across all six states. Identified and resolved compliance gaps including: free cannabis redemption risk, undefined reward types, overconsumption messaging in program copy, FTC disclosure requirements for product reviews, and unauthorized use of “free” language throughout. Developed revised Key Program Definitions and recommended language for all flagged sections.

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The Outcome

ELB Works delivered:

• State-Specific Promotions & Loyalty Compliance Guidance — A comprehensive guidance document covering CA, AZ, and NV with a four-tier risk evaluation scale, state-by-state analysis of promotional mechanics, and recommended program guardrails.
• Reviewed and Annotated Membership Terms & Conditions — A single terms document with channel-specific carve-outs in the Key Program Definitions section, replacing a planned two-document structure with a more maintainable single-document approach
• Pre-Launch Compliance Checklist — A general framework checklist applicable across all program states as an ongoing operational reference

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Key Highlights

• Six-state scope across two regulatory frameworks — state cannabis law and federal hemp law
• Dual-channel structure resolved through a single terms document with channel-specific definitions, avoiding the operational complexity of maintaining separate documents per channel type
• All guidance grounded in primary statutory and regulatory sources, with secondary sources flagged where unverified
• Scope discipline maintained throughout — tax, data privacy, consumer protection, and contract drafting items identified and referred to appropriate specialist counsel, keeping the engagement within cannabis compliance boundaries

The Client

A cannabis beverage brand operating through state-licensed dispensaries in Arizona.

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The Challenge

With less than a week before HB2179 took effect on June 30, 2026 — significantly amending Arizona’s cannabis advertising statute — the client came to ELB Works concerned that their entire library of marketing and promotional assets would need to be overhauled to include warning language and license numbers before the deadline. The prospect of retroactively updating every asset across all active placements in a matter of days was creating significant operational anxiety.

The question ELB Works was brought in to answer: which assets actually need to be updated, and by when?

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The Approach

Rather than working from a list of assets and applying the new rules to each one, ELB Works started at the foundation — the statutory definition of advertising itself.

Step 1: Define What Advertising Actually Is

A.R.S. § 36-2850 defines advertising as “any public communication in any medium that offers or solicits a commercial transaction involving the sale, purchase or delivery of marijuana or marijuana products.”

Two operative elements in this definition do significant work:

• “Public communication” — communications inside a licensed dispensary, where entry is age-verified and restricted to 21+ consumers, have a credible argument that they are not “public” in the statutory sense
• “Offers or solicits a commercial transaction” — a digital menu listing or in-store product display provides product information at a location where the consumer has already decided to purchase; it is not soliciting a transaction

Step 2: Apply the Definition to the Client’s Asset Library

Working from this definition, ELB Works categorized the client’s assets into two groups:

Assets that do not meet the definition of advertising — and therefore do not require warning language or a license number under HB2179

Assets that meet the definition of advertising — and do require warning language and a license number

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The Outcome

The analysis revealed that the majority of the client’s active assets — being in-store materials and digital menu placements — did not meet the statutory definition of advertising and were therefore not subject to HB2179’s warning language and license number requirements. The client did not need to overhaul their full asset library before the June 30 deadline.

The immediate compliance action required was limited to out-of-store and digital advertising assets, a significantly smaller and more manageable scope than the client had feared going into the engagement.

ELB Works delivered:

• Arizona Advertising Asset Classification Framework — A clear two-column reference document distinguishing assets that meet and do not meet the statutory definition of advertising under A.R.S. § 36-2850, with the statutory basis for each determination documented
• HB2179 Compliance Summary — Plain-language guidance on what changed, what it means for the client’s asset library, and what actually needs to be updated before the effective date

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Key Highlights

• Time-sensitive engagement completed within days of a statutory effective date
• The most important finding was definitional, not operational — the statutory definition of advertising excluded the majority of the client’s active assets from the new requirements entirely
• All analysis grounded in primary sources — A.R.S. § 36-2850, A.R.S. § 36-2859 as amended by HB2179, and the enrolled bill text
• Outcome: the client avoided a costly, time-pressured asset overhaul by understanding precisely what the law actually requires — and what it does not

The Client

A cannabis beverage brand with active dispensary distribution across California, Arizona, and Nevada, seeking to launch two consumer incentive programs as part of a broader loyalty and promotions strategy.

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The Challenge

The client came to ELB Works with two promotional program concepts they wanted to launch simultaneously across three regulated state markets:

Scenario 1 — Post-Purchase Cash Rebate: A QR-code-based program where consumers purchase the client’s product at full retail price at the dispensary, scan a QR code on the packaging, upload proof of purchase, and receive a cash rebate directly to PayPal or Venmo — funded by the brand through a third-party facilitator, with no retailer involvement in the rebate.

Scenario 2 — Merchandise Rewards Program: A points-based program where consumers earn points on qualifying purchases and redeem them for branded merchandise or cash, administered by the brand through a third-party facilitator.

The central compliance question was the same for both: did either program trigger the “free cannabis” prohibition in California, Arizona, and Nevada? And if not, what structural guardrails were needed to keep them compliant across all three states?

A secondary structural question arose when the client began considering running both programs simultaneously — did stacking the two programs on the same transaction create a combined compliance exposure neither program carried alone?

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The Approach

ELB Works conducted a primary-source regulatory review across California (DCC regulations, CCR Title 4), Arizona (A.R.S. and A.A.C.), and Nevada (NRS and NCCR), building the analysis from the ground up rather than relying on secondary summaries.

Developed a Four-Tier Risk Evaluation Scale

To communicate compliance risk clearly and consistently across both scenarios and all three states, ELB Works developed a proprietary four-tier risk scale:

• 🚫 Prohibited — Explicitly prohibited by regulation. Do not do it.
• 🚩 High Risk — Likely to trigger a Child Appeal, False/Misleading, or similar violation
• ⚠️ Low Risk — Permitted but verify the operational structure (location/audience restrictions, program design)
• 🔎 Generally Permitted — Requires standard compliance checks (age-gating, no youth appeal, etc.)

Specific regulatory requirements were called out separately with a ⚖️ notation, distinguishing binding regulatory obligations from program design recommendations.

Analyzed Each Scenario Against the Free Cannabis Prohibition

For Scenario 1, the post-purchase cash rebate structure — where the consumer pays full retail price and receives cash back through a third-party facilitator — was analyzed against the free cannabis prohibition language in all three states. Because the cannabis purchase occurs at full price before any rebate is issued, and because the cash is fungible rather than tied to a future cannabis purchase, the program was assessed as 🔎 Generally Permitted across CA, AZ, and NV, with the structural guardrail that the rebate value in any single transaction must not equal or exceed the consumer’s originating purchase amount. A 50% cap was recommended as a conservative compliance buffer.

For Scenario 2, the merchandise rewards program carried more structural complexity. The compliance risk was not in the earn mechanic but in the redemption options — specifically, what the points could be redeemed for. ELB Works identified three redemption paths and rated them individually:

• 🔎 Branded merchandise — clearly compliant; merchandise is not cannabis
• 🔎 Cash to PayPal or Venmo — compliant; cash is fungible and not tied to a cannabis purchase
• 🚩 Gift card redeemable only at the dispensary — High Risk; likely to be interpreted as free or discounted cannabis regardless of the dollar amount

The program overall was assessed as ⚠️ Low Risk pending confirmation that the gift card redemption option would not be implemented.

Identified and Addressed the Stacking Risk

A key finding ELB Works raised proactively: running both programs on the same transaction created a combined rebate value exposure that neither program carried individually. If a consumer could receive a cash rebate under Scenario 1 and earn points toward a cash or merchandise redemption under Scenario 2 on the same purchase, the aggregate value of both programs could approach or exceed the “free cannabis” threshold.

The recommendation was a clean no-stacking rule: Scenario 1 and Scenario 2 should not apply to the same purchase transaction. A consumer either receives a direct cash rebate or earns points — not both. This was identified as the cleanest compliance position and the easiest to administer and audit.

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The Outcome

ELB Works delivered a structured compliance guidance document covering both scenarios across all three states, including:

• A three-state overview matrix rating each scenario by state and channel
• Scenario-by-scenario compliance analysis with primary regulatory citations
• Specific guardrails for each scenario including hard stops, program design recommendations, and regulatory requirements
• The no-stacking recommendation with rationale
• A companion Pre-Launch Compliance Checklist as an ongoing operational reference for the client’s marketing and program teams

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Key Highlights

• Three-state, two-scenario analysis completed in a single engagement, giving the client a unified compliance framework before launch rather than piecemeal state-by-state guidance
• The four-tier risk scale was purpose-built for this engagement and has since become a standard ELB Works communication tool across cannabis compliance deliverables
• Primary-source verification throughout — secondary sources flagged and discarded where unverified, including one widely-cited third-party compliance summary that contained materially inaccurate Arizona regulatory claims
• The most important compliance finding was structural, not prohibitive: neither program was prohibited, but the redemption mechanic and stacking question required deliberate design choices to keep both programs on the right side of the free cannabis prohibition across all three states
• Tax and flow-of-funds structure referred to tax counsel throughout — scope maintained clearly within cannabis compliance

The Client

A cannabis beverage brand operating across California, Arizona, and Nevada, with a marketing team actively developing creative campaigns, social media content, event activations, and promotional materials across all three markets.

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The Challenge

The client’s marketing team needed a single, practical reference document that could guide day-to-day advertising and marketing decisions across three states — each with its own regulatory framework, enforcement posture, and specific content restrictions. The challenge was not just identifying what was prohibited, but giving the team a usable framework for navigating the gray areas that make up the majority of real-world marketing decisions in cannabis.

The client needed guidance that was:

• Grounded in primary regulatory sources across all three states
• Structured so a non-lawyer marketing professional could apply it
• Specific enough to address real creative decisions — imagery choices, language selection, platform selection, event activations, and audience targeting
• Scalable across channels, from social media and digital advertising to out-of-home, events, and branded merchandise

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The Approach

ELB Works built the guidance document in two layers — a general framework applicable across all three states, followed by state-specific callouts where the rules diverged meaningfully.

Layer 1: The General Framework

Rather than starting with a list of rules, ELB Works began with the foundational question the marketing team needed to answer before anything else: what is advertising, and what isn’t?

The document established a clear distinction between communications that meet the regulatory definition of advertising — and therefore carry the full weight of state advertising restrictions — and those that don’t, including packaging and labeling, earned media, building signage, and in-store decor. A separate category was developed for branded merchandise, which occupies its own regulatory space across all three states and carries a different set of rules than advertising proper.

From this foundation, the guidance built out a comprehensive framework across the major categories of marketing activity:

• Age Verification — the threshold requirement underlying every channel and communication type, with specific guidance on email and SMS opt-ins, DMs and chatbots, websites, and in-person interactions
• Design Imagery — detailed state-by-state tables covering fruit imagery, cartoons, balloons, mascots, anthropomorphic imagery, candy references, bright colors, and packaging that imitates children’s brands, with specific visual examples drawn from the client’s own creative assets
• Health Claims — a framework distinguishing explicit claims from implied claims, with a plain-language “tips and tricks” section covering how to pivot language toward terpene attribution, probability language (“may,” “can,” “might”), and intent-vs.-outcome framing
• Product and Consumption Imagery — state-by-state tables covering packaging shots, edible product images, pre-rolls, cannabis leaf/bud imagery, and liquid/splash imagery, plus specific guidance on how to navigate people in imagery without triggering consumption prohibitions
• Free Samples — the B2C prohibition across all three states, with California’s licensed trade sample program identified as a specific exception requiring separate operational compliance
• Location and Placement — the 1,000-foot buffer rules, physical signage placement bans (transit, airports, highways, vehicles), and the local control overlay that requires city and county ordinance review in addition to state compliance
• Digital Audience Composition — the 73.6%/71.6%/70% adult audience thresholds by state, documentation requirements, platform-specific risk ratings (TikTok 🚩, Snapchat 🚩, Instagram/Facebook 🔎), and how to obtain and maintain the required evidence
• Sweepstakes and Raffles — state-by-state table distinguishing what’s permitted, with cannabis as a prize uniformly prohibited across all three states
• Warning Language — exact required language, formatting requirements, and placement obligations by state, including Arizona’s 10% minimum advertising area requirement and California’s vape-specific disposal language
• Documentation — state-specific record-keeping obligations, including Nevada’s five-year retention requirement for audience composition documentation

Layer 2: State-Specific Callouts

Throughout each section, state-specific callouts flagged where the three states diverged from each other — including Arizona’s potency advertising prohibition, Nevada’s lab co-branding restriction, California’s tech platform rules, California’s events framework for non-retail licensees, and Arizona’s advertising platform authorization structure.

The Risk Evaluation Scale

Every guidance item was rated using a four-tier risk scale developed for the engagement, allowing the marketing team to quickly assess the compliance posture of any creative decision without needing to read the underlying regulatory text.

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The Outcome

ELB Works delivered a comprehensive 67-slide advertising compliance guidance deck covering the full scope of cannabis marketing activity across California, Arizona, and Nevada — structured as a practical working reference for a non-lawyer marketing team, with state-by-state comparison tables, visual examples, plain-language interpretations, and real creative asset examples analyzed against the regulatory framework.

The document was designed to function as both a day-to-day decision tool for the marketing team and a foundation document that legal counsel could review and build upon — with primary regulatory citations embedded throughout and plain-language interpretations clearly identified as interpretive aids rather than enforceable guidance.

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Key Highlights

• Three-state scope with a unified general framework reducing the need for the marketing team to navigate three separate regulatory documents
• Visual and practical format — imagery examples, comparison tables, and real asset analysis made the guidance actionable for non-lawyers
• Two-layer structure (general framework + state callouts) allowed the team to understand the baseline rule once and then check for state-specific exceptions, rather than learning three separate frameworks from scratch
• Design imagery section went beyond the standard prohibition list to address real creative decisions — including a specific analysis of whether the client’s brand mascot constituted a prohibited cartoon or mascot under state law
• Health claims section provided a practical language substitution framework, not just a list of prohibited words
• Local control section flagged the significant gap between state compliance and city/county zoning compliance — a frequently overlooked risk for event activations and out-of-home placements

The Context

As Director of Regulatory Administration at Ascend Wellness Holdings, I led a joint initiative with the Director of Marketing to standardize packaging and labeling across the Ozone brand — Ascend’s flagship consumer line — sold across multiple product categories including flower, edibles, and concentrates in five regulated state markets: New Jersey, Illinois, Pennsylvania, Ohio, and Michigan.

The Challenge

Ozone had grown organically across state markets, resulting in a fragmented packaging landscape. Each state had its own compliance-driven design variations, resulting in inconsistent brand presentation, duplicative packaging SKUs, and significant unnecessary cost across the supply chain.

The compliance challenge was significant: each of the five states had its own labeling requirements governing what information must appear on primary packaging, what could appear on secondary or on-site labels, and how required elements — warning statements, THC content, net weight, license numbers — had to be displayed across different product categories.

The goal was ambitious: standardize Ozone’s packaging design and color scheme across the entire product line and all five states, without creating a single compliance violation in any market.

The Approach

This was a joint initiative between the regulatory compliance and marketing teams — unusual in cannabis, where the two fucntions often operate in silos.

Step 1: Catalog the Existing Packaging Landscape
Before any standardization could happen, we documented the full scope of existing packaging — every product category, every state, every SKU — to understand what existed in market, what was compliant, and where the inconsistencies lived.

Step 2: Map State-by-State Labeling Requirements
I conducted a primary-source regulatory review across all five states to establish what each required on primary packaging versus what could be moved to on-site or secondary labels. This distinction became the foundation of the standardization strategy — by identifying what was mandatory on the main label versus what was flexible, we could build a single compliant design that worked everywhere.

Step 3: Develop a Unified Design & Compliance Framework
Working with the Director of Marketing and graphic designer, we developed a single design system and color scheme for Ozone that could carry compliant labeling across all five states and all product categories. The labeling architecture separated:

• Primary label — fixed elements required in all states
• On-site label — state-specific required elements applied at the facility level, allowing the same base packaging to be used across markets

Step 4: Implement Across the Full Product Line
Rolled out the new standardized packaging and labeling system across the entire Ozone product line — flower, edibles, concentrates, and beyond — ensuring every SKU in every state launched compliantly under the new design system.

The Outcome

The Ozone brand emerged from this project with a unified, professional visual identity that held up compliantly across five regulated state markets and multiple product categories. The on-site label architecture significantly reduced the number of unique packaging SKUs required across the supply chain, directly reducing packaging costs across all markets.

I delivered:

• State-by-State Labeling Requirements Matrix — primary-source documentation of mandatory label elements across NJ, IL, PA, OH, and MI for each product category
• Primary vs. On-Site Label Architecture — a clear framework defining what must be on the main label versus what can be applied on-site, enabling a single base package design to work across all five states
• Compliant Unified Design System — developed in collaboration with the Director of Marketing, a single Ozone design and color scheme applied consistently across the full product line
• Full Product Line Rollout — implementation across all Ozone SKUs in all five markets

Key Highlights

• Five-state scope across multiple product categories — flower, edibles, concentrates, and more
• Joint compliance and marketing engagement — rare in cannabis and a model for how the two functions can collaborate effectively
• The on-site label architecture was the key insight — it unlocked a single base package design that works compliantly in all markets, directly reducing packaging complexity and cost
• All labeling requirements grounded in primary statutory and regulatory sources for each state

The Context

As Director of Regulatory Administration at Ascend Wellness Holdings, a publicly traded multi-state cannabis operator, I worked closely with a large commercialization and marketing department spanning C-level executives, brand managers, and entry-level designers across multiple regulated state markets.

The Challenge

The VP of Compliance was getting pushback from the leadership team about the volume of assets being routed through compliance review. I identified the underlying issue: the marketing team didn’t have the foundational knowledge to make good compliance decisions. They were routing everything through compliance because they didn’t know what to look for. The right fix wasn’t a faster review process — it was building the capability so the team could do more of their own reviews with confidence. I pitched the training program to the VP of Compliance and was given the green light to build it.

The Approach

Rather than creating a simple checklist or a policy document nobody would read, I built a training program designed to fundamentally change how the marketing team thought about compliance — and give them the tools to conduct more of their own reviews with confidence.

Curriculum Design
I developed a comprehensive training curriculum covering the foundational compliance concepts every marketing and commercialization team member needed to understand — from C-suite executives to entry-level designers. The program was built to be accessible across all levels without oversimplifying the regulatory complexity underneath.

Core topics included:

• What legally constitutes advertising under state cannabis regulations — and what doesn’t
• Age verification requirements across digital, in-person, and SMS/email channels
• Design restrictions: what imagery, colors, and visual elements are prohibited or restricted and why
• State-by-state variation: how requirements differ across markets and how to navigate those differences
• A risk evaluation framework for independently assessing whether a piece of creative was compliant, risky, or prohibited

Delivery
I delivered the program across two live sessions to the full commercialization and marketing department. The response was strong enough that the CMO requested a second, more specialized training program following the first.

The Outcome

The training fundamentally shifted how the marketing team operated. Teams that had previously routed every asset through compliance developed the knowledge and confidence to conduct their own preliminary compliance reviews — catching issues earlier in the creative process and reducing the compliance team’s review load significantly.

I delivered:

• A comprehensive training curriculum covering advertising law, age verification, design restrictions, and state-by-state regulatory variation
• A four-tier risk evaluation framework giving the marketing team a consistent, repeatable method for assessing compliance risk independently
• State-specific reference materials for each regulated market, grounded in primary statutory and regulatory sources
• Two live training sessions delivered to the full commercialization and marketing department, with a follow-on specialized program commissioned by the CMO

Key Highlights

• Program spanned all levels of the marketing organization — from C-suite to entry-level designers
• The four-tier risk framework (Prohibited / High Risk / Risk / Navigate Carefully) became an internal reference tool used beyond the training itself
• The most significant outcome was behavioral, not documentary — the marketing team became more compliance-capable, reducing bottlenecks and catching issues earlier in the creative process
• Commissioned for a second program by the CMO following the success of the first

The Context

As Director of Regulatory Administration at Ascend Wellness Holdings, I led the design and implementation of a company-wide compliance issue tracking system across the full regulatory compliance department — including the corporate compliance team and state-focused teams operating onsite in facilities and retail locations across multiple markets.

The Challenge

The compliance department had no centralized system for tracking issues, violations, deadlines, or regulatory actions across the organization. The corporate team — comprising the VP of Compliance, a technical writer, and myself — needed visibility into what was happening at the state level, and the state directors and their onsite staff needed a consistent, structured way to log and escalate issues as they arose.

Without a shared system, issue tracking was fragmented — relying on email threads, spreadsheets, and individual judgment about what needed to be escalated and when. The VP of Compliance needed a solution that would bring consistency, accountability, and real-time visibility across the entire department.

The Approach

I led the full build inside Monday.com, working directly with the VP of Compliance to design a system that would actually work for a distributed team operating across corporate and facility-level environments.

System Design
Working with the VP of Compliance, I developed the issue categorization framework — defining the types of issues the system needed to capture, how they should be classified, and what information was required at the point of entry. This included:

• Issue type categories covering regulatory violations, advertising and labeling flags, licensing matters, and operational compliance issues
• Status and escalation workflows defining how issues moved from identification through resolution
• Ownership and accountability fields ensuring every issue had a named owner and a tracked deadline

Build & Configuration
I built the full Monday.com board architecture from the ground up — columns, automations, status workflows, and permissions — configured for both corporate team members and state-level directors and staff. The system needed to be simple enough for onsite facility staff to use consistently while giving the corporate team the visibility and reporting capability they needed.

Dashboard & Reporting
Developed dashboards and reporting views giving the VP of Compliance real-time visibility into issue volume, status, and trends across all state markets — turning fragmented issue data into a management tool.

Rollout
Developed and delivered the rollout process to the full compliance team — training state directors and their staff on how to use the system consistently, and establishing the norms and expectations for issue logging and escalation.

The Outcome

The compliance department moved from fragmented, informal issue tracking to a centralized, structured system with consistent categorization, clear ownership, and real-time reporting visibility across all markets and teams.

I delivered:

• Full Monday.com issue tracking system — designed, built, and configured for a distributed compliance team operating across corporate and facility environments
• Issue categorization framework — developed in collaboration with the VP of Compliance, defining how issues are classified, owned, and escalated
• Executive dashboards and reporting views — giving department leadership real-time visibility into issue volume, status, and trends
• Team rollout and training — process documentation and training delivered to state directors and onsite staff across all markets

Key Highlights

• Built end-to-end — from categorization framework design through system build, dashboard development, and team rollout
• Designed for a distributed team spanning corporate and facility-level environments with different technical comfort levels and different visibility needs
• Turned fragmented issue tracking into a management tool — giving leadership real-time visibility across all state markets for the first time
• Collaborative design process with the VP of Compliance ensured the system reflected real departmental needs, not just technical capability

The Context

As Director of Operations at Holistic Industries, and drawing directly on my concurrent work as COO of Undone Chocolate — a health-focused chocolate company I was scaling from startup to 200+ retail locations including Whole Foods — I partnered with Holistic’s CEO and CSO to develop, legalize, and launch a raw cacao medical cannabis ingestible product in Washington, DC.

The product that resulted was not simply the first of its kind. It was the product that reopened a category that DC regulators had shut down entirely.

The Challenge

The DC regulatory agency had previously shut down the ingestibles category following a wave of non-compliant products — weed-infused rice crispy treats and similar items where potency was unknown, packaging was indistinguishable from conventional food products, and there was nothing genuinely medical about how the products were positioned or branded. Regulators had seen enough. The category was closed.

The challenge wasn’t launching an ingestible product. It was demonstrating to regulators that an ingestible product could be done right — and earning back the category in the process.

The Approach

Building a Genuinely Medical Product
The foundation of the compliance argument was the product itself. Working with Holistic’s CEO and CSO, I helped develop a raw cacao cannabis ingestible that was designed from the ground up to be positioned and branded as a medical product — not a novelty food item. Precise potency, professional packaging, medical framing, and a clear patient-facing purpose. Everything the prior products had lacked.

Working Directly with DC Regulators
Rather than submitting a product and hoping for approval, I worked directly with DC regulators to help shape the rules that would govern the re-opening of the ingestibles category. This meant engaging the agency not just as a license applicant but as a participant in building the framework — providing a compliant model they could point to as the standard for what a medical ingestible should look like.

Leveraging CPG Expertise
My background scaling Undone Chocolate through rigorous food safety, USDA Organic Certification, and Whole Foods-level retail standards was directly relevant here. I understood what professional food production looked like, what documentation regulators needed, and how to position a product credibly in a regulated consumer environment. That expertise translated directly into the cannabis context — and gave the product a level of operational and compliance credibility that the bad actors had never had.

The Outcome

The product launched as the first medically-positioned cannabis ingestible in Washington, DC under the new compliant framework — the product that demonstrated to regulators that the category could be reopened responsibly.

To be precise about the claim: this was not the first ingestible ever sold in DC. Products had existed before — they were the reason the category was shut down. This was the first medically-positioned ingestible launched under a compliant framework, and the engagement that helped define what that framework looked like.

Key outcomes:

• Category reopening — worked directly with DC regulators to shape the rules governing ingestibles, helping to re-open a category that had been shut down due to bad actors
• First medically-positioned ingestible launched in DC under the new compliant framework
• Product development — developed a raw cacao medical cannabis product built from the ground up to meet medical positioning and regulatory standards
• Regulatory engagement — engaged DC regulators not just as an applicant but as a participant in building the compliance framework for the category

Key Highlights

• The most important distinction: this wasn’t just a product launch — it was a category reopening, achieved by demonstrating to regulators that a compliant, medically-positioned ingestible was possible
• The product succeeded where prior products had failed because it was designed to be medical, not just compliant — positioning, branding, and patient framing were as important as the regulatory paperwork
• Cross-industry expertise was the differentiator — food safety, retail standards, and CPG operational credibility from Undone Chocolate translated directly into a more credible regulatory engagement
• Working directly with regulators to shape the framework, not just submit to it, was the approach that made the difference

The Context

Through a subcontracting relationship with CannaAdvisors, I served as the primary writer and operational strategist on competitive cannabis license applications across Illinois, West Virginia, and New Jersey — spanning cultivation, manufacturing, and retail license types across multiple applicants. Working alongside a lead advisor who managed the client relationships, I was responsible for the written work product — narrative development, operational plans, and compliance documentation — across all engagements.

The Challenge

Cannabis license applications in competitive markets are won and lost on two things: compliance and story. Most applicants nail one or the other. Operational plans that are technically compliant often read like they were written by a lawyer and would never actually work in year one. Narratives that are compelling often lack the regulatory grounding that evaluators require.

The applicants I worked with needed both — operational plans that were compliant on paper and genuinely executable in practice, and narratives that gave evaluators a reason to choose them over the competition.

The Approach

Finding and Telling the Right Stories
The most important work happened before a single page was written. I worked with each applicant to identify the right people — heads of cultivation, manufacturing leads, operational experts — and then built their narratives from the ground up. Who are these people, what have they built, why are they the right team to bring this license to life in this community? Evaluators read hundreds of applications. The ones that win give them a reason to believe in the people behind the plan.

Operational Plans That Actually Work
Most operational plans submitted in competitive licensing processes are written to satisfy a checklist. They hit the compliance requirements but describe operations that would be unworkable in practice. I wrote operational plans designed to do both — satisfy the regulatory requirements and reflect how the business would actually run in its first year. That distinction matters to experienced evaluators, and it matters even more to the applicant who has to execute against the plan once the license is awarded.

The West Virginia Application — Start to Finish in Under Two Weeks
The most demanding engagement in this body of work was a West Virginia application completed from start to finish in under two weeks. The final submission ran over 100 pages — covering cultivation, manufacturing, and retail operations, narrative sections, compliance documentation, and operational plans — all researched, written, reviewed, and submitted within a 14-day window. It required simultaneous management of multiple workstreams, rapid regulatory research into a newly structured state program, and precise coordination with the applicant team under significant time pressure.

The Outcome

Across Illinois, West Virginia, and New Jersey, I supported applicants through the full application process — from team identification and narrative development through operational plan writing and final submission.

Key outcomes:

• Multi-state scope across IL, WV, and NJ covering cultivation, manufacturing, and retail license types
• Operational plans written to be both regulatorily compliant and genuinely executable in year one — a distinction that separates winning applications from also-rans
• Narrative development grounded in the real stories of the people behind each application — heads of cultivation, manufacturing leads, and operational teams
• West Virginia application completed start to finish in under two weeks — 100+ pages, multiple license types, submitted on deadline

Key Highlights

• The most valuable insight: compliance and narrative are not separate tasks — the strongest applications weave them together
• Operational plans written to be executed, not just submitted — reflecting what the business would actually look like in year one
• The WV engagement remains one of the most compressed, high-stakes deliverables in this body of work — 100+ pages in under two weeks, on deadline
• Engaged as a subcontractor through CannaAdvisors — responsible for all written work product while the lead advisor managed client relationships. Work grouped under ELB Works LLC consulting practice.

The Context

As Director of Operations at Holistic Industries, I was deployed to California during the medical-to-adult-use transition under MAUCRSA to assess, remediate, and prepare a newly acquired dispensary for state inspection. The facility included a retail dispensary with detached manufacturing and cultivation operations.

Holistic had acquired the facility just weeks before new regulations were set to take effect and a state inspection was scheduled. I was sent to evaluate the situation and get it inspection-ready over a three-week engagement — while the CEO focused on hiring the permanent facility director who would run the operation going forward.

The Challenge

When I arrived, the facility was not going to pass inspection. The issues were fundamental and widespread:

• No labeling — product throughout the facility was unlabeled and untracked
• No inventory protocols — there was no system governing how product moved through the facility or was accounted for
• Improper storage — cannabis was being cured in brown paper bags stored in the office
• Non-compliant transportation — because manufacturing and cultivation were in detached buildings, product was being transported between facilities in a way that exposed it publicly, which was not permissible under the new regulatory framework
• Non-compliant product — a significant volume of product on hand had come from various sources and could not be brought into compliance; it needed to be properly destroyed

The facility needed to close for remediation and reopen inspection-ready within approximately 48 hours — part of a three-week engagement to fully assess, remediate, and prepare the facility for state inspection.

The Approach

Rapid Assessment
On arrival I conducted a full assessment of the facility across all three operations — retail, manufacturing, and cultivation — to understand the full scope of what needed to be addressed before inspection.

Three-Week Remediation
I worked with existing staff to execute a remediation plan across all identified gaps simultaneously:

• Labeling and inventory — established labeling protocols and inventory tracking systems across all product and all three facility areas
• Storage — proper cannabis curing and storage protocols implemented to replace the brown bag office storage
• Non-compliant product destruction — identified all product that could not be brought into compliance and executed proper destruction protocols
• Transportation solution — developed a cart-based solution for transporting product between the detached buildings that kept product covered and out of public view, satisfying the regulatory requirement without requiring facility renovation

Closure, Final Remediation & Inspection
After three weeks of remediation work, the facility closed for approximately 48 hours for the final push. It reopened inspection-ready. The state inspection was conducted — and the facility passed.

Handover
With the inspection complete, I had one day to train and hand over to the incoming facility director the CEO had hired — walking her through every system, protocol, and procedure that had been established during the engagement before she took over operations.

The Outcome

Over three weeks, a facility that was not going to pass state inspection under California’s new adult-use regulatory framework was fully assessed and remediated. The facility closed for approximately 48 hours for the final remediation push, reopened, and passed state inspection on schedule.

Key outcomes:

• Full facility remediation across retail, manufacturing, and cultivation over three weeks
• State inspection passed on schedule
• Systems established from scratch — labeling, inventory protocols, storage standards, and compliant inter-facility transportation all implemented where none existed before
• Non-compliant product destroyed — proper destruction protocols executed for all product that could not be brought into compliance
• Successful handover — one-day training and transition to incoming facility director following inspection

Key Highlights

• The most significant constraint was the regulatory deadline — three weeks to take a facility from non-compliant to inspection-ready
• The transportation solution was the most creative problem to solve — a cart-based approach that kept product covered during inter-facility movement, satisfying regulatory requirements without requiring structural changes
• Worked exclusively with existing staff — no outside team, no additional resources — while the CEO focused on longer-term hiring
• The facility passed inspection. That was the only outcome that mattered.

Great detail — the shared kitchen thread is particularly compelling because your work had ripple effects beyond just your own products. Here it is:

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USDA Organic Certification — Undone Chocolate · Washington, DC · 2015–2016

The Context

As COO of Undone Chocolate, a health-focused chocolate company I was scaling from startup to 200+ retail locations including Whole Foods, I led the company through USDA Organic Certification for five products — three chocolate bars and two drinking chocolates. The certification was a strategic business decision: a premium product needed to justify a premium price point, and organic certification would open doors to a more specific, values-aligned customer base.

I had no prior experience with the USDA Organic certification process. I built the knowledge and led the engagement from scratch.

The Challenge

The certification process itself was straightforward in concept but demanding in execution — particularly because Undone Chocolate operated out of a shared commercial kitchen space, not a dedicated production facility. Shared kitchen environments create significant complexity for organic certification: every item in the space has to be clearly separated and labeled, and the audit requires demonstrating that your organic products cannot be contaminated by non-organic ingredients or processes happening in the same space.

The shared kitchen was the biggest obstacle — but it also became an unexpected opportunity.

The Approach

Learning and Executing the Certification Process
With no prior experience in USDA Organic certification, I researched the requirements, completed the full application, and managed the process end to end. The supply chain was relatively straightforward — Undone Chocolate’s ingredients were already well-documented and sourced from suppliers who could provide the necessary organic documentation.

Preparing for the Audit
The audit was the most demanding part of the engagement. Operating in a shared kitchen meant that every Undone Chocolate item — ingredients, packaging, equipment, and finished products — had to be clearly separated and labeled in a way that satisfied the auditor that no cross-contamination with non-organic materials was possible. I developed the organizational and labeling protocols that made that demonstration credible.

A Ripple Effect for the Kitchen
Because Undone Chocolate was the first business in the shared kitchen to pursue organic certification, the work we did to prepare for the audit laid the groundwork for the kitchen itself to pursue organic certification — making it easier for every other business operating in the space to do the same. A compliance engagement that started as a business decision for one company ended up lowering the barrier for an entire shared production community.

The Outcome

USDA Organic Certification was achieved for all five products — three chocolate bars and two drinking chocolates — within approximately six months of beginning the process.

Key outcomes:

• Five products certified — three chocolate bars and two drinking chocolates — all within approximately six months
• Price premium justified — organic certification supported a premium price point appropriate for a health-focused, Whole Foods-level product
• Customer base sharpened — certification appealed to a more specific, values-aligned customer base that the product was already positioned to serve
• Shared kitchen certification pathway opened — Undone Chocolate’s certification laid the groundwork for the kitchen itself to pursue organic certification, benefiting every other business in the space

Key Highlights

• Built the knowledge and led the process from scratch — no prior USDA Organic certification experience
• The shared kitchen environment was the most significant obstacle — requiring meticulous separation, labeling, and organizational protocols to satisfy the auditor
• The ripple effect was unplanned but significant — becoming the first certified business in a shared kitchen space created a pathway for the entire community
• Organic certification was not just a compliance achievement — it was a strategic business decision that directly supported revenue and customer acquisition goals