Kim Anzarut, Founder & CEO of Allay Consulting LLC – Interview Series

Considering how strict the regulations for cannabis companies in legal states often are, the importance of proper, thorough compliance can’t be overstated. Even more than that, a growing number of cannabis production facilities and testing labs are now seeking the incredibly stringent ISO and cGMP certifications, two certificates that come with equally strict requirements. To find out more about the processes for obtaining these certifications, which certainly aren’t easy to acquire, mycannabis.com had the pleasure of speaking with Kim Anzarut, Founder/CEO of Allay Consulting LLC.

While attending Metropolitan State University of Denver, what were the most useful or otherwise essential courses in your Bachelor’s in Nutrition Sciences program that you took and why?

I’ve always been fascinated by nutrition, and I genuinely loved organic chemistry because it helped me understand the world at a fundamental level. But the most influential course I took, in terms of shaping my career, was food safety science. The professor who taught that class ultimately connected me to the opportunity that became my first role in Denver as a Public Health Investigator, and the rest is history.

What were the first roles you held while working at the Denver Department of Public Health and Environment? What were some notable venues you visited as part of your role as Public Health Inspector?

I began my career as a Public Health Investigator, working primarily in wholesale food operations and restaurants. During that time, I inspected a wide range of facilities across the Denver metro area, from the Denver Stampede to Broncos Stadium, to Korean markets, and nearly everything in between. That experience gave me a deep understanding of food safety, operational challenges, and regulatory enforcement across diverse environments.

When did your role there shift into working with the cannabis industry? When you first started visiting facilities during the first few months of the Colorado industry’s life, what were the most common issues you observed regarding sanitation and cleanliness?

In 2014, when Colorado passed its adult-use cannabis law, the medical market still had no meaningful health or safety oversight, it was truly the wild west. I approached the department director with a proposal to become the cannabis specialist for the agency, and they approved it. That decision shifted my role entirely. The early years were challenging. Cultivation facilities commonly struggled with significant pest and mold issues. I remember inspecting grows where the floors were literally carpeted with mold and algae was climbing the walls, spider mite problems that made the plants look like cotton candy, and huge issues with pesticide usage.

Dispensaries often sold home-baked edibles with no labeling, no potency testing, and no ingredient lists. It was a completely different landscape compared to today’s regulated environment. Manufacturing facilities had no quality-management systems or cGMP principles in place at all, which led to frequent recalls. During my 3.5 years in that role, I organized so many disposals and recalls that people in the industry started calling me the “Weed Whacker.”

How was the ASTM Committee D37 on Cannabis formed, and why was it necessary that such a committee be formed to begin with? How has the committee helped cannabis businesses operate more compliantly and ensure that cleanliness is being prioritized?

ASTM Committee D37 on Cannabis was formed in 2017 because the industry had no consistent standards for safety, cleanliness, testing, or quality. Every state was doing something different, labs were using different methods, and operators had no clear guidance. A standards body was badly needed.

ASTM already had a strong history of creating science-based, voluntary consensus standards for other regulated industries, so forming D37 gave cannabis a way to catch up.

What sectors of the industry are represented through the membership and the objectives of the committee?

The committee brought together regulators, scientists, and industry professionals to create a common framework for things like sanitation, lab practices, packaging, and cGMP principles. These standards have helped cannabis businesses understand what compliant, well-run operations should look like.

They give facilities a roadmap for prioritizing cleanliness and safety, especially in states where regulations are vague. Serving as Vice Chair of the cGMP Subcommittee allowed me to help build some of that foundation, which continues to guide operators as the industry moves toward more formal oversight. The hope moving forward is that the federal government adopts these standards eventually as they have in other industries like aerospace and concrete.

How did your professional experiences with ASTM International, the DDPHE, and other organizations influence your decision to found Allay Consulting?

I had an “aha” moment while working at DDPHE. I was in a hearing with an operator who had accumulated fines and was genuinely struggling to understand the regulations. As a regulator, my job was only to determine whether someone was in compliance, not to help them fix the problem. That was incredibly hard for me, because I’m a natural problem-solver and I wanted to help them succeed. My supervisor reminded me that we couldn’t give advice for liability reasons and that the operator needed to hire a consultant. When I went online afterward to look for consultants who specialized in cannabis public health or consumer safety, I discovered that none existed. That’s when I realized there was a real need in the industry that wasn’t being met. I knew I could make a bigger positive impact as a consultant than I could as a regulator, so I decided to start my own firm.

I launched Allay Consulting in 2017 (the same year ASTM D37 was formed) and became one of the committee’s first members. I’ve been working to raise the bar for safety, compliance, and quality in the industry ever since.

As someone who used to work in cannabis manufacturing and lab testing myself, I’m aware of how difficult the ISO and cGMP certifications in particular are to obtain and how stringent the requirements are. How does Allay Consulting help cannabis businesses eventually obtain those important but very strict certifications?

Achieving ISO, GACP, or cGMP certification is a major undertaking for any cannabis business, because these standards require not only strong documentation, but also consistent, repeatable systems and a real culture of quality. At Allay Consulting, we break that process down into manageable phases so operators aren’t overwhelmed.

We always start with a full gap analysis to understand where a facility currently stands compared to the certification requirements. From there, we build a customized roadmap that includes developing or revising SOPs, implementing quality-management systems, establishing proper documentation and recordkeeping practices, and ensuring that equipment, sanitation, and production workflows meet the appropriate standards.

A huge part of the work is training. Certification isn’t just about having the right documents, it’s about having a team that understands and follows them consistently. We train staff at every level so that quality isn’t something that lives in a binder; it becomes part of daily operations.

We also conduct mock audits so businesses know exactly what to expect during certification. By the time an external auditor walks through the door, the facility has already corrected issues, implemented preventive systems, and feels confident in their ability to demonstrate compliance.

The goal is to help businesses build sustainable systems, not just pass an audit. With the right structure, support, and education, operators who once thought certification was out of reach are often surprised by how attainable it becomes.

From a state compliance standpoint, what are the most frequent issues that your clients with Allay Consulting run into? Do those issues sometimes change based on the state your clients are located in?

From a state compliance standpoint, the most common issues we see tend to fall into a few predictable categories, regardless of where a client is located. Documentation is the number one challenge across the board. Many operators struggle with maintaining complete and accurate records, whether that’s batch production records, sanitation logs, training documentation, or inventory reconciliation. Regulators place a huge emphasis on documentation because it’s the only way to verify whether a facility is truly operating as required.

Another frequent issue is labeling and packaging issues. States change their labeling rules often, and the details can be very specific. It’s easy for operators to miss small requirements around potency statements, warning labels, allergen declarations, or font size, and even minor errors can lead to product holds or recalls. Plus every state is completely different so MSO’s have even bigger challenges for this.

The types of issues do shift depending on the state. Each market has its own regulatory quirks. For example, some states are stricter about microbial testing, while others focus heavily on pesticide compliance or extraction safety. Newer markets tend to struggle with basic operational readiness, while more mature states often run into issues related to evolving standards and more rigorous inspections.

Overall, while the specifics vary by jurisdiction, the core challenges, documentation, training, quality systems, and labeling, tend to be universal. The difference lies in how each state prioritizes and enforces those areas, which is why a tailored compliance approach is so important.

When it comes to successful and compliant cannabis businesses, what are some common factors you’ve seen throughout their operations? How can cannabis companies do their best to remain as compliant as possible at all times?

The most successful and compliant cannabis businesses all share a few core characteristics, regardless of their size or market. The first is a strong culture of compliance that starts at the top. When leadership values compliance and understands why it matters, that attitude carries through every level of the organization. Teams that see compliance as a daily practice, not a last-minute scramble before an inspection, tend to run smoother, safer, and more efficient operations.

Another common factor is robust documentation and well-designed SOPs. The companies that consistently stay compliant not only have clear procedures, but actively follow them and update them as regulations change. Their documentation tells the true story of how the facility operates, they are specific to the operation, and employees are trained to use those systems instead of working around them.

Successful operators also invest in continuous training. They don’t treat training as a one-time onboarding task. They treat it as an ongoing process that builds competency, strengthens safety, and prepares staff for regulatory expectations. When employees understand why procedures exist, compliance becomes much more natural.

Finally, the strongest companies embrace regular third-party audits. They don’t wait for regulators to point out gaps. Instead, they invite feedback, identify weaknesses early, and implement corrective actions before issues escalate. This proactive approach does more to protect a license than nearly any other strategy.

To stay compliant at all times, cannabis companies should focus on a few key practices: document everything, train consistently, update SOPs as regulations evolve, and bring in third party auditors regularly for objective insight. Compliance isn’t a milestone, it’s a system that needs constant attention and refinement. The companies that understand this are the ones that stay ahead of regulators and build the strongest, most sustainable operations.

If cannabis is federally rescheduled to Schedule III, how do you predict that would change various state regulations? Do you think a federal rescheduling would change any ISO or GMP regulations in the future?

I don’t have a crystal ball unfortunately, and a lot of what happens with Schedule III will depend on how the federal agencies choose to interpret and implement it. Technically, if THC is rescheduled to Schedule III, it falls into the same category as many pharmaceuticals, like codeine. Under that model, you’d expect full FDA oversight: cGMP 211 requirements, clinical trials to support safety and efficacy, and formal FDA approval before products could be sold through pharmacies. Most of the cannabis companies operating today are not set up for that level of pharmaceutical compliance nor have the time or funds for trials and approvals.

That said, I don’t believe the intention is to shut down the entire existing industry and hand everything over to pharmaceutical companies, or at least I hope not. Regulators are going to have to figure out how to layer federal oversight on top of an industry that already exists at the state level. My best guess is that we’ll see a hybrid model. States may retain control over adult-use programs, while the federal government increases expectations around manufacturing and quality systems, potentially requiring things like cGMP, GACP, and OSHA for cultivation and production facilities.

That’s what many of my clients are preparing for now. A world where federal expectations look more like food, supplement, or pharma standards, even if the details aren’t fully written yet. The truth is, there’s no way to know exactly how it will play out until we see how it all pans out.

One clear upside, if Schedule III moves forward, would be access to basic infrastructure the industry has struggled without. FDIC-insured banking, relief from 280E tax burdens, and a more normalized financial environment. So while there are still a lot of unknowns, I’m cautiously optimistic that with stronger standards and better financial tools, the industry could end up on more stable ground in the long run. The changes will be hard for many in the industry, but Allay will be there to support the industry when the time comes. This is why I started the company.

Thank you for joining us, Kim! For more information on Allay Consulting, please visit its website.