In this guide, we break down a Facility Security Plan that covers everything from advanced access control and #38excludeGlossary surveillance to critical maintenance protocols and computerized systems that keep your facility safe, efficient, and compliant.
Dive in to discover how your cannabis facility can transform into a fortress of safety and compliance. Access control to licensed premises and their #39excludeGlossary areas is one key component of your mission of complete and comprehensive security of the premises.
To achieve thorough access control, cannabis operations will install a commercially viable, #40excludeGlossary security alarm system and video surveillance system to prevent and detect diversion, theft, or loss of cannabis and cannabis products, or unauthorized access to the premises.
For doors into #41excludeGlossary areas and all entries and exits into the licensed premises, facilities will use Underwriter’s Lab (UL) approved locks and lock cylinders, which are #42excludeGlossary, #43excludeGlossary, and #44excludeGlossary.
All facility windows will be of reinforced glass and will be tinted, in addition to being monitored by the facility’s central alarm system.
Employee proximity cards, access codes, physical keys, and other access hardware credentials will be distributed on a limited and individual basis to #45excludeGlossary essential personnel.
The security management team will ensure the facility’s access control system at the premises allows for programming or uploading individual user permissions and allowed entry times, as well as #46excludeGlossary information including personnel photos.
Access to the premises will be limited to personnel and authorized visitors including authorized government officials when necessary to perform their official duties.
This will also ensure that the access control system monitors and records:
- The identity of all personnel or visitors entering and exiting the premises.
- All keycard entry and exit activity, including dates and times.
- Lengths of time in specific areas.
- Any unauthorized attempts to access.
All records relating to access control must be maintained in business records on the premises at all times for seven years.
These records are to be made available to the local law enforcement government agencies, or regulatory authorities upon request.
These tasks will be performed at all times when a visitor is seeking access to a #47excludeGlossary area within the facility.
Entry into #48excludeGlossary areas is only possible by the use of a valid keycard with the appropriate permissions.
Anyone not employed or contracting with your cannabis operations that are granted access to a #49excludeGlossary area will be escorted by an authorized employee at all times while within the #50excludeGlossary area.
Only employees with assigned permissions to the limited access area may escort the visitor(s). Acceptable forms of #51excludeGlossary ID include:
- A document issued by a federal, local, or municipal government, or a political subdivision or agency thereof, such as a valid motor vehicle operator’s license, that contains the name, #52excludeGlossary (DOB), physical description, and picture of the person.
- A valid identification card issued to a member of the Armed Forces that includes a date of birth and a picture of the person.
- A valid passport issued by recognized government jurisdiction or by a foreign government.
Access to limited access areas within the facility is restricted to employees who have been granted appropriate access permissions; however, #53excludeGlossary individuals who have a legitimate reason for entering the limited access area may be granted limited and supervised access on a #54excludeGlossary basis. Visitors may include:
- Laboratory Agents
- Contractor, Vendor, or Service Provider (authorized to be on the licensed premises)
- Another Licensee or Licensee’s Agent(s)
- Government Officials
Your cannabis operations and employees will report to the regulators and local authorities any discovered plan or act by a visitor to:
- Commit theft, burglary, underage sales, diversion of cannabis or cannabis products, or other crimes related to the operations.
- Compromise the integrity of the #55excludeGlossary tracking system.
- Do something that results in serious bodily injury to anyone or something that otherwise creates a material risk to public health and safety.
You must protect the health of medical patients, adult consumers, and staff throughout all aspects of operations.
It is your responsibility to ensure that the cannabis operation is conducted in a sanitary manner to not create contamination and pose a health risk to adult consumers and medical patients.
Cleaning and sanitation procedures will apply to work performed by contractors or temporary employees as well as work performed by #56excludeGlossary employees during the ordinary course of operations.
Building maintenance will ensure the interior and exterior of the facility are maintained in a sanitary condition to ensure the safety of employees and authorized visitors and to prevent the deterioration and contamination of cannabis products and cannabis materials.
Additionally, it is the responsibility to document the findings and any corrective actions regarding facility maintenance and cleaning in the facility maintenance log.
Always use waste receptacles constructed of a material that is smooth, #57excludeGlossary, and easily cleanable.
The number, size, and location of waste receptacles at the facility will encourage their use and not result in overfilling.
They will be emptied at least once each working day, unless unused, and will be maintained in a clean and sanitary condition.
Always use receptacles with a solid #58excludeGlossary cover unless sanitary conditions can be maintained without the use of a cover.
Furthermore, the grounds of the facility will be equipped with draining areas to prevent pooled or standing water.
Routine sanitation and maintenance practices include:
- Maintaining a regular schedule for cleaning and maintenance activities.
- Removing trash and maintaining waste treatment, sewage, and disposal systems.
- Maintaining cracks, window and door frames, drain areas, and floor joints with sealant or screens to limit pest movement.
- Eradicating any weeds or pest habitats surrounding the facility.
- Controlling airborne contamination as needed where cannabis products or contact surfaces are exposed.
- Inspecting the facility for mold and having a mold expert address any mold found in the facility immediately.
- Check that any pipes within twenty (20) feet (ft) (6.1 meters) of the building are #59excludeGlossary and not leaking.
- Cutting grass and weeds to minimize harborage areas for pests.
- Removing any food or water supply outside of the facility could attract and support a pest population.
- If pests are found on the facility, including roads and parking lots, capture and remove them or contact your pest control service provider to capture and remove the pests.
- Checking that all dumpsters are closed to exclude pests so close any open dumpsters.
All sanitizing agents used to clean equipment, floors, counters, walls, and ceilings at the facility will be:
- Registered with the Environmental Protection Agency (EPA) or equivalent government agency.
- Stored and disposed of in a manner that protects against contamination of cannabis products and cannabis materials.
- Stored and disposed of in a manner that follows any applicable local or federal law, rule, regulation, or ordinance.
All floors, walls, and ceilings in the facility will be smooth and constructed in a manner that they can be adequately cleaned and kept clean, and in good repair.
Fixtures, ducts, and pipes will not pose a source of drip or condensate that may contaminate cannabis products, contact surfaces, or packaging material.
Additionally, the premises will have a janitorial facility to be used for the cleaning of mops or similar wet floor cleaning tools and the disposal of mop water and similar liquid waste.
The Security Manager will develop best practices to mitigate and prevent loss, theft, and diversion.
Loss, theft, and diversion prevention measures will be updated as often as necessary.
There will be areas provided where personnel may store, but to access personal items will be separate from operational areas and will establish procedures for the investigation of suspicious activities.
Help prevent loss, theft, or diversion of cannabis and cannabis products by:
- Keeping each unique identifier with its respective cannabis or cannabis products.
- Track all cannabis and cannabis products at each step of the process into the #60excludeGlossary system.
- Supervising tasks or processes with high potential for diversion, including the loading and unloading of cannabis operation vehicles.
There will be #61excludeGlossary (24) hours per day, seven (7) days per week of video monitoring of the premises, including but not limited to:
- Areas where cannabis and cannabis products are weighed, packaged, stored, quarantined, loaded and unloaded for transportation, prepared, and moved within the premises.
- #62excludeGlossary Areas
If there is evidence of suspected theft or diversion, it will report the suspected theft or diversion to management and law enforcement promptly which is typically defined in cannabis regulations. The notice will include, in writing:
There will always be a video surveillance recording system to prevent unauthorized entrance into #63excludeGlossary areas and to prevent the diversion of cannabis and cannabis products.
The surveillance system and its capabilities and features will operate continuously #64excludeGlossary (24) hours per day, seven (7) days per week.
Security will ensure that cameras are not installed in bathrooms or any other area where a legitimate expectation of privacy exists, they will verify that:
- The surveillance equipment is properly functioning and maintained so that the playback quality is suitable for viewing and the surveillance equipment is capturing the identity of all individuals and activities in the monitored areas.
- All surveillance cameras are free of debris or obstruction due to cannabis goods and other materials.
- The surveillance system or equipment has the capabilities to produce a color still photograph from any camera image, live or recorded.
- The current date and time are displayed on recordings and do not significantly obstruct the recorded images.
Camera coverage is required for:
- #65excludeGlossary Areas
- Security Rooms
- Areas containing #66excludeGlossary storage devices, which shall contain at least one camera to record the access points to such an area.
- Twenty (20) feet (ft) (6.1 meters) of the interior and exterior of all entrances and exits to the premises.
- Areas where cannabis or cannabis products are weighed, packed, stored, quarantined, loaded, and unloaded for transportation, prepared or moved within the premises.
The surveillance equipment used to monitor licensed premises will typically have:
Security will ensure that camera locations, the direction of coverage, and camera numbers are accurately depicted on the premise’s diagram and numbered on the physical camera and premise diagram.
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