This article was originally published in The Pennsylvania Observer / Pennsylvania Beverage Media in June 2023. A pdf version can be found here.
The PA State Police Bureau of Liquor Control Enforcement (BLCE) has become aggressive with licensees who violate a conditional licensing agreement (CLA) where compliance with the PLCB’s Responsible Alcohol Management Program (RAMP) is mandated. Licensees who have entered into a conditional licensing agreement with the PLCB must maintain and renew the RAMP certification every two years. Failure to timely renew or obtain the RAMP certification is a violation of that conditional licensing agreement for which the PA State Police BLCE will issue a citation against the licensee.
All of the PLCB conditional licensing agreements contain a provision which provides that a licensee’s failure to comply with or “adhere” to the agreement could result in either a citation being issued by the State Police BLCE for the violation of the conditional licensing agreement and/or the liquor license not being renewed by the PLCB.
A violation of a PLCB conditional licensing agreement regarding RAMP compliance is a serious matter which can be easily avoided. Licensees should have a check system in their computers to alert the licensee when the RAMP certification has to be renewed. Also, licensees should assign a reliable employee to maintain a dual system to alert the licensee as to the renewal of the RAMP certification. The PLCB will also send letters to licensees alerting them of the RAMP requirement and the dates for compliance.
Once cited by the PA State Police BLCE for failing to maintain RAMP, a licensee must correct the error and become RAMP certified as quickly as possible. At least it will demonstrate that the licensee took quick corrective action once it realized the error in not renewing the RAMP certification in a timely manner.
Furthermore, per the CLA, the PLCB also could object to the renewal of the license for the licensee’s failure to comply with the CLA even though a licensee became RAMP compliant and was cited by the PA State Police and paid any fines imposed relative to the citation case.
Licensees should make certain that they are in full compliance with all of the other conditions of the CLA. Licensees who fail to comply with all of the conditions of their CLA often fail to comply with other provisions of their CLA, for example, having periodic meetings with the local police or maintaining security cameras.
Licensees should consult with an attorney as to the RAMP requirements.
