PLCB Recordkeeping Rules & Best Practices

2/17/2020
Let’s just cut to the chase here. Nobody (well, maybe an elite few) likes to talk about recordkeeping, paperwork, regulatory rules for documentation, etc. It’s boring and tedious but can actually get you in a lot of trouble if it’s not done right. Recordkeeping is totally necessary. We’d be lost without it; in any industry - but especially in the highly regulated alcohol industry. And that’s a good thing, when you think about it. You want your business, your employees, your patrons, and the public to stay safe, so you have to keep track of things like receipts, invoices, inventory, and perhaps most importantly, legally mandated training records. Let’s take a look at why accurate recordkeeping is so important to governing bodies, the public, and you.

Why Do We Keep Records?
Recordkeeping exists for a reason - and has for thousands of years (tens of thousands, if you count ancient cave art). As people gathered into tribes, clans, and kingdoms, rules became necessary. “Government” was sometimes just the village elders’ council agreements, or King’s edicts, later turning into actual legislation by appointed or elected representative officials. The earliest modern example of systematized recordkeeping in Western Civilization is the Domesday Book. The book was commissioned in 1085 by William I, also known as “William the Bastard” before he conquered Britain at the Battle of Hastings in 1066, where after he was known as “William the Conqueror”. The undertaking of the Domesday Book was an extremely thorough and very efficient inventory of England’s land and assets - including census information, shires (i.e. counties), towns, villages, buildings, livestock, businesses, and any existing taxation methods and amounts. It was the first known effort of its kind in England, and it took a complete inventory of the kingdom. This recordkeeping effort was massive, a method consisting of royal emissaries dispatched to different parts of the country to record the information in Latin and English, compile it all, and bring it back to the King. So why are we talking about this? Because it’s the first known example of systematic and efficient recordkeeping. American law has its roots in English Common Law (read our blog “Dram Shop Laws & Liability in Pennsylvania” for more on this). So, for a second, let’s pretend that recordkeeping isn’t just a dusty file box of slips of scrap paper and outdated documents. Let’s remember that without the keeping of records, we don’t know who we are, what we’re doing (or have done), and maybe most importantly, WHY we’re doing it?

The Codification of Commodities (i.e. Alcohol Regulations)
Anything of value is usually monitored in some fashion. Since alcohol is a taxable commodity and a controlled substance, there’s naturally going to be rules and regulations on serving and selling (and brewing, distilling, distributing, etc.) The How, When, Where, Who, and Why of it all. You already know that. Our question is, how are we - as a society and an economy - keeping track of this important information? We know recordkeeping rules for alcohol in Pennsylvania are set forth in the Pennsylvania Liquor Code and governed by the Pennsylvania Liquor Control Board (PLCB), the Bureau of Liquor Control Enforcement (BLCE) and the Office of the Administrative Law Judge (ALJ) (read our blog “Undercover Compliance Checks - PLCB Rules & BCLE Enforcement Tactics” for more on the separation of responsibilities between these agencies.) The PLCB has the responsibility of actually maintaining the records of BCLE cases and ALJ decisions, including keeping an up-to-date searchable database of license records. It’s ultimately up to the PLCB who gets, keeps, or loses an alcohol license, and they document those factors. And that’s exactly why we’re talking about this. They’re keeping their records straight - are you?

RAMP Training Recordkeeping Rules
Let’s be clear here - there are different recordkeeping rules for different kinds of liquor licenses (e.g. a Limited Winery (LK) license), and for different functions or activities within a premise (e.g. Small Games of Chance). Recordkeeping for different aspects of your business will depend on what TYPE of establishment you own or manage, and what you DO there. But for ALL license types, the PLCB states “From a risk management perspective, your first line of defense should be RAMP training for ALL your employees”. That’s official advice and it’s VERY valid. So, for now, let’s focus on the most commonly needed training - Server/Seller. Read our blogs “PLCB Compliance Means Risk Management For Your Business” and “Selling to Minors in Pennsylvania - PLCB Guidelines & Consequences” for just some of the multitude of reasons (civil, criminal, and just plain profitable) why you should train ANY and ALL staff who classify as “alcohol personnel''. The PLCB has methods of documentation and recordkeeping that try to assist the licensee or approved manager in this, such as the Alcohol Service Staff Roster, a.k.a. the “RAMP Roster”, which is nice because it’s already in a PLCB-approved format. And since 2016 the PLCB itself has modernized with its online resource portal PLCB+. So, what’s the big deal about the records? Is it really all that important, and what do we even need to record? Here’s a breakdown of some of the information you actually need to maintain compliance with your Server/Seller training records. Keep in mind, if you have a surprise inspection by the authorities, like an undercover compliance check, or (knock on wood) you accidently serve an intoxicated guest or a minor? You’ll wish you had this information at the tips of your fingers. And you can!

1. WHO - Name; First & Last. The employee who’s training, including any other identifiers, like employee ID, SSN, or PLCB-Approved Manager.
2. WHAT - What training or certification was taken or needs to be? (e.g. Server/Seller, or perhaps this employee has been (or will be) promoted and needs Owner/Manager training?)
3. WHERE - Where is the employee located? (Store #, District, Division)
4. WHEN - When did the employee complete training? When does the training expire?
5. WHY - Is this a new-hire employee, training for the first time or a renewal?
6. HOW - Did the employee Pass or Fail? What was the test score?
Conclusion
Per the PLCB, the training records for each staff member must be kept for the duration of their employment. But where do you keep them? If you have turnover (like everyone in the industry), you might find yourself shuffling papers; looking for certificates, new-hire orientation acknowledgments, and just kind of wondering about training and renewal dates. “Are ALL of your required employees current? If not - who isn’t? And for that matter, who won’t be current tomorrow, or next week?” Only ONE employee puts your business out of compliance and puts your license and livelihood at risk. Wouldn’t it just be easier if that information was accessible at the click of a button? Read our blog “Is Online or Classroom Training Better for Your RAMP Server/Sellers?” to answer some of those questions. Partnering with an expert training provider who has your back will take a lot off of your shoulders. Take a page from William I and the Domesday Book - create and maintain a systematic inventory, assessment, and knowledge base that accurately tells you about your establishments’ compliance and risk management status. Your Business is your Kingdom - and no one can rule it like you can.
If you have any questions at all concerning RAMP Certification or RAMP Server/Seller Training, we’re here to make your life (and your business) worry-free. We’re currently offering a FREE 15-minute telephone consultation with our Compliance Expert, in which you can talk about anything and everything RAMP-related and get solid business advice. No Strings Attached. You can grab this opportunity just by clicking here and reserving a calendar spot, or fill out the form below to have us call you directly. Either way is fine - and it’s up to you!
   

RAMPtraining.com is the largest and most widely used online RAMP Server/Seller training provider in the Commonwealth of Pennsylvania, with over 75,000 people trained. Our team collectively has over 25 years of regulatory compliance training experience and 95% of our users pass the RAMP course on the first attempt. We’re experts in the industry and we’re here to help you and your business succeed.

Contact Us for Your FREE RAMP Compliance Consultation Sources:
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