Cannabis manufacturing,
licensed right.

Manufacturing license work breaks cleanly into four operational areas. These are our named responsibilities — not coordination tasks. Where we own, we draft, file, certify, and close out. Where you own, we coordinate but the process-chemistry and capital decisions are yours.

Escalation path

When work crosses into privileged legal analysis — product-liability structuring, IP disputes over extraction methods, enforcement appeals, administrative hearings at OAH — we coordinate with your counsel or introduce one from our retained network. The engagement letter names this boundary. We do not practice law.

How we draw the boundary with you

You own: process chemistry, equipment selection, formulation, brand and SKU decisions, capital structure. We own: the four areas above. Where a decision is yours but we have a clear recommendation — file Type 6 now and add Type N in year two rather than stretching the process into a single scope, or select a Type S shared-facility rather than stand up your own room — we document the recommendation with rationale so the decision is informed.

What’s explicitly out of scope

Process engineering itself (equipment design, extraction-method selection), product development, formulation IP, brand strategy, and any litigation work are not within this engagement. Those are specialist fields with their own practitioners.

Most manufacturing engagements feel opaque because firms guard their process. The work below is the opposite — exactly what happens, in what order, and which deliverable lands at each milestone. Type 7 volatile-solvent operations extend the closed-loop / fire / air phase; Type 6, N, P, and S engagements compress it.

The playbook

• Week 1–2 — License-type selection. We map your actual process equipment, solvents, and finished-form intent against Type 6 non-volatile, Type 7 volatile, Type N infusion-only, Type P packaging-only, and Type S shared-use facility under CCR 17200-series. Volatile vs. non-volatile is the highest-stakes decision because Type 6-to-Type 7 is a re-application, not a modification. Output: license-type strategy memo with decision tree, CCR 17200-series requirement matrix, and full year-one cost picture. Capital plan, premises plan, and SOP plan all flow from this single decision.
• Week 3–6 — PQP/MMP/BPR + SOPs + premises. The documentation triangle gets built first because everything else cites it. Product Quality Plan per product identifying adulteration, misbranding, and test-failure hazards; Master Manufacturing Protocol per formulation with ingredients, equipment, parameters, and acceptance criteria; Batch Production Record format per batch binding CCR 17408 COA, METRC tag, yield reconciliation, and QC release. The Form DCC-LIC-019 SOP library covers receiving, manufacturing, packaging, allergen control, sanitation, recall, and CCR 15048 destruction. The CCR 15006 premises diagram is drafted to match the room the inspector will walk — quarantine, extraction or infusion rooms, packaging, finished goods, limited-access zones, and allergen segregation lanes.
• Week 6–8 — Closed-loop, fire, and air (Type 7). Three agency tracks run in parallel rather than serially. A licensed Professional Engineer certifies the closed-loop extraction system to CCR 17205–17207, confirming solvent containment, recovery, and recirculation. The local fire authority reviews solvent storage, classified electrical areas, fire suppression, and ventilation against the California Fire Code, California Building Code, and California Mechanical Code. The local air district — SCAQMD, BAAQMD, or the relevant district — opens the process-emissions permit application. Type 6, N, P, and S engagements skip this milestone entirely.
• Week 8–10 — Local authorization & CEQA. Local authorization under BPC 26055 is the gate the state cannot open without. We confirm the conditional use permit or ministerial pathway, document the local lead agency's CEQA determination under Public Resources Code 21000 et seq. (Notice of Exemption, Mitigated Negative Declaration, or full EIR), and collect Form 9206 landowner consent supporting CCR 15007 evidence of legal right to occupy. The local business license is sequenced so it lands inside the state submission window. Where the lease predates the cannabis use, a cannabis-use addendum acknowledging federal Schedule I status is built and executed.
• Week 10–12 — Portal submission & pre-submission QA. A line-by-line pre-submission quality review runs against the DCC manufacturing checklist and the live DCC compliance-action record. Form 9101 disclosures are reconciled against the cap table and operating agreement; the Form 9205 LPA attestation is confirmed at the post-July-2024 ten-employee threshold; the Form 8113 surety bond at the $5,000 minimum payable to the State of California is on file. Manufacturing applicants file through the MLS portal with individual Owner profiles built directly in MLS. Submission confirmation, application reference number, and weekly status tracking begin the same day.
• Week 12+ — Deficiency response & pre-licensure inspection. Every DCC notice is answered inside the CCR 15002(d) ten-business-day window with documented response and corrected materials. The CCR 15011 pre-licensure inspection is staged so the premises matches the diagram exactly; for Type 7, the room is walked with the inspector against the closed-loop certification, the fire marshal sign-off, and the air-district permit. On issuance we activate METRC through the state-administered Franwell portal, tag inventory inside the activation window, and hand off a 60-day post-licensure compliance calendar. Issuance becomes the start of operations, not an emergency.

Duration and rhythm

From kickoff to portal submission is typically 10–14 weeks for Type 6, N, P, and S engagements; Type 7 extends to 14–20 weeks because the engineer-of-record, fire authority, and air-district tracks add real serialization risk. From submission to issuance is another 60 business days at the DCC's target pace, extended by Live Scan returns, deficiency stacking, pre-licensure inspection scheduling, or CEQA iteration with the local lead agency. End-to-end realistic timelines run 6–14 months from first scoping through to issuance for Type 7; 4–9 months for Type 6, N, P, and S. The 60-day post-licensure handoff bridges issuance to first batch.

Who you work with each phase

One named licensing coordinator owns the engagement end-to-end — the same person on every status call, every DCC notice, every submission. Specialist contributors come in at the milestones their work demands: a CCR 15006 diagram drafter at week 3–6, a Live Scan logistics coordinator at week 2–4, a PQP/MMP/BPR documentation lead at week 3–6, and the engineer-of-record / fire / air coordinator at week 6–8 for Type 7. Where the matter touches counsel territory — equity dispute among Owners, undisclosed interest discovered late, an extraction-method IP claim, an enforcement matter already issued — we coordinate with your retained counsel on a single record rather than running parallel.

When we finish this manufacturing engagement, you have a defined set of documents, certifications, and agency clearances in hand. These are not summary memos. They are filed SOPs, issued certifications, completed inspections, and a tracked record defensible against DCC pre-licensure inspection, fire marshal audit, and institutional diligence.

The ten outputs, in detail

• License-type strategy memo. Written analysis mapping your actual process to Type 6 non-volatile, Type 7 volatile, Type N infusion-only, Type P packaging-only, or Type S shared-use under CCR 17200–17210. Includes the decision tree — is the extraction volatile, is the infusion post-extraction, is the packaging room physically separated, is the equipment shared with other tenants — and a cost-benefit analysis of each scope including Type-6-to-Type-7 re-application risk. Typical length: 6–10 pages with the year-one cost picture and a 24-month modification roadmap.
• Master SOP library. Form DCC-LIC-019 SOPs covering receiving and quarantine, manufacturing operations, packaging and labeling, cleaning and sanitation, allergen control (FDA Big 9 including sesame under the FASTER Act), change control, recall and withdrawal, destruction under CCR 15048, and personnel hygiene and training. Each SOP is written to your equipment, room layout, and SKU mix — not a template — and tied to a written procedure, a training log, and a CCR 15037 retention plan. Typical package runs 80–160 pages depending on license type and SKU breadth.
• PQP/MMP/BPR documentation triangle. A Product Quality Plan per product identifying adulteration, misbranding, and laboratory-test-failure hazards (structurally similar to a HACCP plan); a Master Manufacturing Protocol per formulation with ingredient amounts, equipment, parameters, and acceptance criteria; and a Batch Production Record format per batch binding the CCR 17408 Certificate of Analysis, the METRC package tag, in-process controls, yield reconciliation, and QC release on a single auditable document. DCC inspectors open the BPR first — this is the executed evidence of compliance.
• Type 7 closed-loop certification. Engineer-of-record selection and coordination, certification letter conforming to CCR 17205-17207, and the certification documentation bundled into the premises package. For Type 6 non-volatile, a scope letter confirming why closed-loop certification does not apply.
• Fire marshal prep package. Solvent storage plan, classified-area determination, fire suppression specification, ventilation calculations, electrical classification, and the pre-submittal meeting coordinated with the local fire prevention bureau. For Type 7, this is often the true critical-path item.
• Air-quality permit (Type 7). Local air district permit application with process-emissions inventory, control-device specification, and monitoring plan. Coordinated with SCAQMD, BAAQMD, or the relevant district depending on jurisdiction.
• CCR 15006 premises diagram. Scaled diagram with process flow, limited-access areas, quarantine, extraction or infusion rooms, packaging, finished goods storage, and sanitation flow. Drafted to DCC's measurement and labeling standard so pre-licensure inspection does not return a deficiency.
• Owner & FIH disclosures. Form 9101 for every Owner (BPC 26001(al)), FIH disclosures under CCR 15004, LiveScan for every disclosed person, cap-table reconciliation against the operating agreement and any side-letters. PSI and Cal/OSHA credentialing where applicable.
• DCC portal submission. Full application filed through MLS for manufacturing applicants with individual Owner profiles built directly in the portal, fee payment processed, application reference number logged, and a weekly status dashboard active from submission day. Every DCC deficiency notice is answered inside the CCR 15002(d) ten-business-day window with a documented response and corrected materials. The CCR 15011 pre-licensure inspection is coordinated and the premises is staged to match the diagram — for Type 7, the room is walked with the inspector against the closed-loop certification and fire authority sign-off.
• Quality manual foundation. A QMS built 21 CFR Part 111-adjacent and ISO 22000-compatible — change control, CAPA, deviation management, supplier qualification, and stability where shelf-life is claimed. Passes DCC inspection today; passes institutional diligence on the next capital raise.

Format and delivery

Every SOP, MMP, and batch record is delivered as an editable source (Word or Pages) and as a controlled PDF with revision history. Document control follows a numbered, versioned convention. All records retained for 7 years per CCR 15037.

Defensibility anchor

Every recommendation cites a specific regulation. CCR 17200-17210 for manufacturing operations. CCR 17205-17207 for closed-loop. CCR 17408 for testing. BPC 26131 for product safety. CCR 15037 for retention. CCR 15048 for waste. California Fire Code and the local air district rule. 21 CFR Part 111 as the QMS anchor. If DCC, fire marshal, PSI, the air district, or a future diligence team asks “why did you do it this way?” the citation is in the document.

What’s not included

Process engineering, equipment design, formulation development, product IP, brand strategy, and any privileged legal analysis (product-liability structuring, enforcement appeals, administrative litigation) are explicitly outside this scope. Where those are needed, we coordinate with retained counsel or introduce the appropriate specialist from our network.

Deliverables are what we produce. Outcomes are what those deliverables enable — the specific operational results that follow from the work being done right the first time. Below are the ten outcomes a manufacturing-license engagement is designed to produce, each tied to a regulation, a form, or a specific agency clearance.

Ten outcomes, in detail

• License type matched to the actual process. Type 6 for non-volatile (CO2, mechanical, ice-water, rosin, kief), Type 7 for volatile closed-loop (butane, propane, ethanol above the volatile threshold), Type N for infusion-only, Type P for packaging-only, Type S for shared-use facility tenants — selected against the equipment list and finished-form intent under CCR 17200-series. No over-buying Type 7 scope when Type 6 fits; no under-scoping that forces a CCR 15020 material-change filing in month six.
• Closed-loop extraction certified before DCC issues (Type 7). A licensed Professional Engineer's CCR 17205–17207 certification on file, with the certification documentation bundled into the premises package and stored on-site for inspector review. Material modifications are flagged for re-certification before they go live, not after.
• Fire authority sign-off in hand (Type 7). Solvent storage, classified electrical areas, fire suppression, and ventilation reviewed and approved against the California Fire Code, California Building Code, and California Mechanical Code. The fire authority's pre-installation review and post-installation acceptance are both completed before DCC issues.
• Air-district permit issued (Type 7). Local air-district permit — SCAQMD, BAAQMD, or the relevant district — with process-emissions inventory, control-device specification, and monitoring plan in force on day one. The permit binds operations; it is not an afterthought.
• PQP/MMP/BPR documentation triangle live. A Product Quality Plan per product, a Master Manufacturing Protocol per formulation, and a Batch Production Record format per batch — built to the DCC checklists and ready for the first batch on day one. Inspectors find executed BPRs, signed contemporaneously, with QC release recorded.
• Allergen control program operational. The FDA Big 9 framework including sesame under the FASTER Act documented in the PQP, segregation enforced in receiving and storage, production scheduled to minimize cross-contact, and FDA-compliant Contains statements built into the label set. Cross-contact is the most common allergen failure — closed at the source.
• SOPs that survive an actual inspection. Form DCC-LIC-019 written to your equipment, your room layout, your staffing, and your SKU mix — not a template. Inspectors who request SOPs and find generic templates issue Notices to Comply at minimum; site-written SOPs hold up.
• Premises diagram that matches the building. CCR 15006 scaled diagram with quarantine, extraction or infusion rooms, packaging, finished goods, limited-access zones, allergen segregation, and process flow shown on a single drawing — ready to compare against the physical site at pre-licensure inspection. Mismatch is the most-cited finding on first inspection; eliminated at the source.
• Ownership and FIH disclosure that survives diligence. Form 9101 for every Owner under BPC 26001(al) and CCR 15003 with LiveScan completed; every Financial Interest Holder under CCR 15004 documented including profit-share landlords and revenue-share consultants; Form 9205 LPA aligned to the post-July-2024 ten-employee threshold; Form 8113 surety bond at the $5,000 minimum on file.
• METRC-ready, calendar handed off, batch-record archive on day one. METRC activated through the state-administered Franwell portal; CDTFA seller's-permit verified; a 60-day post-licensure compliance calendar populated with the first material-change checkpoints, allergen-program audit, and renewal-window date 60 days before expiration. CCR 15037 seven-year retention archive opened with the first BPR.

How we measure

Outcomes are measured at three checkpoints: completeness on submission (the DCC manufacturing checklist scored 100% before filing), velocity through review (deficiency notices logged and resolved inside the CCR 15002(d) ten-business-day window without exception), and operational readiness on issuance (the 60-day post-licensure calendar populated with named owners and dated milestones, METRC activation scheduled, and the first BPR template loaded). Every measurement is on the record so a buyer's diligence two years later sees the work, not just the result.

Post-engagement review

30 days after issuance we run a 60-minute post-engagement review covering the deliverables in production, the first batch records executed, allergen-program adherence, METRC transactions reconciled, the closed-loop certification cadence (for Type 7), the air-district permit conditions, and the upcoming renewal window 60 days before expiration. Where the engagement continues into the Ongoing Compliance Retainer, this becomes the kickoff for the steady-state cadence; where it does not, the calendar and the document vault transfer to your team with a one-page handoff brief.

When DCC asks why we recommended something, we cite the regulation. When the fire authority asks what a specification is based on, we cite the code. When an inspector eighteen months later asks what a procedure is based on, we cite the CCR section. The specificity is the difference between advice and defensible compliance — and it is what survives a deficiency response, an embargo, a recall, and a buyer's diligence.

Manufacturing operates inside four overlapping authorities: the Business & Professions Code (MAUCRSA), CCR Title 4 Division 19 (DCC's operational regulations), local building / fire / air rules, and federal-adjacent standards (FDA GMPs and the FDA Big 9 allergen framework). Every form, every SOP, every line on the BPR resolves to one of those four.

Business & Professions Code (statute)

• BPC 26050 — License classifications. Defines the DCC license subtypes including Type 6 non-volatile, Type 7 volatile, Type N infusion, Type P packaging, and Type S shared-use manufacturing. Picking the wrong type is a re-application, not a modification.
• BPC 26055 — Local authorization. DCC may not issue a manufacturing license without evidence of local authorization at the proposed premises. The most common reason an application stalls.
• BPC 26131 — Product safety standards. Imports food-and-supplement-style product safety obligations into cannabis manufacturing. Anchors the GMP framework that DCC's CCR 17200-series builds on.

California Code of Regulations Title 4 Division 19 (DCC operational rules)

• CCR 15003–15004 — Owners and Financial Interest Holders. Defines who must be disclosed as an Owner versus a Financial Interest Holder. Misclassification is a serious violation discovered late.
• CCR 15006 — Premises diagram. Sets the scale, labeling, and content standards. For a manufacturer the diagram must show extraction or infusion rooms, packaging, finished goods, limited-access areas, and process flow. Inspectors compare to the physical site at every visit.
• CCR 15037 — Recordkeeping retention. Seven-year retention floor for every master batch record, executed BPR, deviation log, COA, and SOP version. The retention obligation outlives most operating leases.
• CCR 15048 — Waste management. Cannabis waste must be rendered unusable and unrecognizable before disposal, logged in METRC, and routed through a licensed hauler or self-hauled to an authorized facility.
• CCR 17200–17210 — Manufacturing core. The operational rulebook for cannabis manufacturers: GMPs, facility and equipment standards, personnel procedures, adulteration prevention, and the PQP/MMP/BPR documentation framework.
• CCR 17205–17207 — Closed-loop extraction. Volatile-solvent extraction must use a closed-loop system certified by a licensed Professional Engineer. Material modifications trigger re-certification before the change goes live.
• CCR 17408 — Certificate of Analysis format. Every batch released to a distributor must carry a lab COA in the CCR 17408 format. A non-conforming COA is a release-failure finding even if the product tests within spec.

DCC Forms (the operational documents)

• Form 9101 — Commercial Cannabis Owner Submittal. One per Owner under BPC 26001(al) and CCR 15003. Manufacturing applicants build individual MLS profiles directly in the portal.
• Form DCC-LIC-019 — Consolidated SOPs. The single SOP package covering receiving, manufacturing, packaging, sanitation, allergen control, recall, and destruction. Required on file before operations begin.
• Form 9205 — Labor Peace Agreement Notarized Statement. Required at 10 employees or more (lowered from 20 in July 2024). Either the notarized attestation to enter into an LPA or the executed signature page.
• Form 9206 — Landowner Approval Consent. Landlord's written consent to the cannabis manufacturing use, supporting the CCR 15007 evidence of legal right to occupy.
• Form 8113 — Commercial Cannabis Licensee Bond. Surety bond of $5,000 minimum per premises payable to the State of California. Required for every DCC licensee, not distribution-only.

Federal-adjacent & local code

• 21 CFR Part 111 — FDA Current Good Manufacturing Practices. Federal GMP framework for dietary supplement manufacturing — the anchor DCC's CCR 17200-series adapts and the standard institutional diligence grades against.
• FDA Big 9 allergens (FASTER Act, sesame effective Jan 1, 2023). Major food allergens that must be identified, controlled, and disclosed. DCC's allergen guidance follows this framework; labels must include FDA-compliant Contains statements.
• California Fire Code, California Building Code, California Mechanical Code. Govern Type 7 facilities for solvent storage, classified electrical areas, fire suppression, ventilation, and Group H occupancy classification. The local fire authority enforces.
• NFPA 30 — Flammable and Combustible Liquids Code. National standard incorporated by reference into the California Fire Code for solvent quantities, container types, and storage configurations.
• ISO 22000 — Food safety management. Not required by DCC. Increasingly expected by institutional investors, multi-state acquirers, and large retail buyers; the QMS we build is structured to be compatible from day one.

How the authorities interact

BPC 26055 and the local cannabis ordinance form the gatekeeper layer — without local authorization, no DCC review proceeds. CCR Title 4 Division 19 then governs the operational packet itself, with each DCC form (9101, 8113, 9205, 9206, DCC-LIC-019) attached to a specific CCR section it satisfies. CCR 17200-series adapts the federal 21 CFR Part 111 GMP framework into California-specific manufacturing rules and creates the PQP/MMP/BPR documentation triangle. For Type 7, the California Fire Code, California Building Code, California Mechanical Code, and the local air-district rule sit alongside CCR 17205–17207 — all four must align before DCC will issue. CCR 17408 governs the release standard at the back end; CCR 15037 governs the seven-year retention floor that follows the operation through diligence and audit. If any one layer falls out of sync — local approval lapses, closed-loop certification stales, allergen labeling misses sesame, the Form 9205 LPA is not refreshed at the ten-employee crossing — the operation moves backward. The packet's job is to keep all four layers aligned through issuance and beyond.

• Type 6 vs Type 7? Type 6 covers non-volatile methods — mechanical separation, ice-water hash, rosin presses, kief screening, and CO2 extraction. Type 7 covers volatile-solvent extraction with butane, propane, hexane, or ethanol above the volatile threshold under CCR 17205–17207. Type 7 requires a closed-loop system certified by a licensed Professional Engineer, local fire authority sign-off on solvent storage and ventilation against the California Fire Code, and typically a local air-district permit. Switching from Type 6 to Type 7 after issuance is a re-application, not a modification.
• Type N vs Type P vs Type S? Type N is infusion-only using already-extracted concentrate purchased from another licensee, with no extraction performed on-site. Type P is packaging-only — repackaging or first-packaging finished cannabis goods made by other licensees. Type S is the shared-use facility tenant model: multiple Type S licensees share equipment in a registered host facility (commonly Type 6 or Type N) on a time-share basis, each maintaining their own PQP, MMP, and BPR for their products under CCR 17200-series. Type S is often the right entry point for small brands and equity-program operators.
• Closed-loop certification? Required for every Type 7 volatile-solvent operation under CCR 17205–17207. A licensed Professional Engineer certifies the system at installation, confirming solvent containment, recovery, and recirculation rather than venting. The certification documentation must be on-site and provided during inspections, and material modifications trigger re-certification before the change goes live. The fire authority separately approves solvent storage, classified electrical areas, fire suppression, and ventilation against the California Fire Code, California Building Code, and California Mechanical Code.
• What is the PQP/MMP/BPR documentation triangle? DCC's central documentation framework. The Product Quality Plan (PQP) is product-specific and identifies, prevents, monitors, and remediates risks that could cause adulteration, misbranding, or test failure — structurally similar to a HACCP plan. The Master Manufacturing Protocol (MMP) is per formulation and codifies the written instructions, ingredient amounts, equipment, parameters, and QC checks that mitigate the PQP-identified hazards. The Batch Production Record (BPR) is per actual batch and captures contemporaneous values, deviations, yield reconciliation, and documented QC release.
• Allergens in cannabis edibles? DCC's allergen guidance follows the FDA Big 9: milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soybeans, and sesame — sesame added January 1, 2023 under the FASTER Act. The control program identifies allergens in incoming components, segregates them in storage, schedules production to minimize cross-contact, validates cleaning between allergen runs, and labels with a FDA-compliant Contains statement. Cross-contact is the most common allergen failure — a nut-free SKU contaminated by shared equipment without validated cleaning. The program is documented in the PQP and the Form DCC-LIC-019 SOP set.
• Vape cartridge manufacturing — what is different? Cannabis vape cartridges fall under AB 1894 vape labeling and traceability rules in addition to standard manufacturing requirements: unique identifiers binding the cartridge to the manufacturer and the batch, integrated-vaporizer rules where the device is sold filled, and the same CCR 17408 COA discipline at release. Cartridge manufacturers also follow the standard PQP/MMP/BPR triangle, with the MMP specifying fill weights, hardware lots, and post-fill leak testing. We build the documentation set to AB 1894 from day one.
• Failed lab test — can we remediate? Remediation is permitted for some failure types but requires DCC pre-approval. The manufacturer emails remediation@cannabis.ca.gov before any remediation action with the proposed protocol; only after written approval may the remediation proceed and a re-test be ordered. Attempting remediation without pre-approval is a separate violation on top of the original failure. The remediation pathway, COA chain of custody, and re-test mechanics live in the SOP library so the team executes correctly under time pressure.
• Do I need ISO 22000? Not required by DCC. The QMS we build is anchored to 21 CFR Part 111 GMPs and the FDA allergen framework, with ISO 22000 as a compatible overlay that institutional investors, multi-state acquirers, and large retail buyers grade against. Building the foundation as Part 111-adjacent and ISO 22000-compatible from day one means the next diligence event does not trigger a rebuild. Where you intend to pursue formal ISO 22000 certification, the documentation set is already structured for the certifying body's audit.
• How much does Type 7 cost to launch? Typical year-one figures for a Type 7 manufacturer in a mid-size California jurisdiction land in the $350K–$2.5M+ range. The closed-loop system itself runs $40K–$200K depending on throughput and configuration; engineer-of-record certification, fire authority review, and the local air-district permit add another $25K–$115K combined. Tenant improvements for sanitation, classified electrical, ventilation, and security drive the bulk of the variance. The DCC application fee plus first-year annual license fee runs $3,000–$85,000 depending on revenue tier under CCR 15014.
• What happens after the license is issued? On issuance you activate METRC through the state-administered Franwell portal and tag inventory inside the activation window. You maintain CCR 15037 seven-year recordkeeping (every BPR, MMP version, deviation, and COA), report regulatory changes under CCR 15020 within 14 business days, file CDTFA returns, manage the closed-loop re-certification cadence for Type 7, audit allergen control, and renew the license 60 days before expiration. We hand off a complete 60-day post-licensure compliance calendar; the engagement can continue via our Ongoing Compliance Retainer.