Legalizing Marijuana for Medicinal Use in Kentucky

Legalizing Marijuana for Medicinal Use in Kentucky

Kentucky politicians are and have been optimistic about the legal status of marijuana within their state. “State Rep. Jason Nemes of Louisville predicts medical marijuana will be legal in Kentucky within the next year. The Louisville Republican has co-sponsored a bill that he believes addresses most of the past concerns about medical marijuana…’Fundamentally, we’re going to have, I believe, medical marijuana in Kentucky within the next year,’ said Nemes. ‘I strongly believe that.’”  [1]

Mr. Nemes was a little off on his prediction. We are fast approaching the one-year mark from when Mr. Nemes made this prediction. Kentucky has moved closer, and many are sure the legislation will pass in the upcoming session. The community of Louisville has agreed that possession of small quantities of marijuana shouldn’t be a priority for law enforcement. [2]

Jason Nemes is co-sponsor of House Bill 136, legislation to legalize and regulate marijuana for medicinal use in Kentucky. In March of 2019, the House Judiciary Committee approved this bill almost unanimously [3].

This bill proposes that a new organization be formed within the powers of state government to regulate the medicinal marijuana industry, ‘The Department for Alcoholic Beverage and Cannabis Control’. While there is no legislation to review as of yet, it would appear that their requirements and guidelines for facilities will mirror those of Michigan and Illinois. Why not mirror your midwestern neighbors if their system is working efficiently?

KL Security is able to help at all levels of the supply chain:

Reinforced Vault Rooms & Custom Vaults of All Sizes

Smart Cash Management Safes & CashControl Software

  • Ideal for Retail Dispensaries in Kentucky, Growers & Cash Businesses

Bulletproof Glass, Doors and Retail Dispensary Design & Build

Security Cameras, Recorders and Software for Surveillance and Cash in Transit

 

[1] Lawmaker says medical marijuana will be legal in Ky. ‘within the next year’. (2018, August 24). Retrieved from: https://www.wdrb.com/news/lawmaker-says-medical-marijuana-will-be-legal-in-ky-within/article_62e82cd3-ef4a-5491-a7de-f5dd13a6ac82.html

[2] Costello, Darcy. (2019, June 19) “Louisville is moving closer to telling police not to prioritize marijuana possession”. Louisville Courier Journal. Retrieved from: https://www.courier-journal.com/story/news/politics/metro-government/2019/06/19/louisville-moves-closer-effectively-decriminalizing-pot/1499214001/

[3] Cheves, John. (2019, March 6) Medical marijuana approved by Kentucky House panel. More legislative hurdles remain. Lexington Herald Leader. Retrieved from: https://www.kentucky.com/news/politics-government/article227177759.html

 

Helpful Links:
Code of Federal Regulations: Title 21

https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?fr=205.50

 

Kentucky House Bill 136

https://apps.legislature.ky.gov/record/19rs/hb136.html

 

When you’re ready to begin the process of securing your facility, the consultants at KL Security are available to assist. Well versed in government regulations and recent legal mandates, we are prepared to ensure your business will pass requirements.

TOLL FREE 1-866-867-0306

contact@klsecurity.com

Information has been gathered from sources deemed reliable but not guaranteed and is subject to change without notice. All license information and security measures taken directly from the Code of Federal Regulations: 21CFR205.50

Image source: http://thesource.com/2018/10/30/weed-marijuana-2018-midterm-elections/

The EPA ‘Final Rule’: Amendment to P075 Safes and Cabinets for Regulated Materials

The ‘Final Rule’, by its title, sounds rather ominous. When the government institutes regulatory changes, it is often to the lament of affected agencies. This time: not so much. The Final Rule regarding Management Standards for Hazardous Waste Pharmaceuticals is actually overall beneficial to facilities as well as the environment. One of the key focuses of the amendment is how facilities handle expired or unused pharmaceuticals and the compliant storage of hazardous waste pharmaceuticals.

Hazmat Storage Lockers & Buildings Specifically designed for hazardous material storage and dispensing from 55-gallon drums containing flammable or combustible liquids.

Historically, the most common way of disposing pharmaceuticals has been flushing (pouring down the drain), “Until this final rule, drain disposal has been an allowable disposal method for hazardous waste pharmaceuticals under RCRA…” 84 FR 5816. It was previously thought that this had no impact on our water sources, but the opposite has been scientifically proven. There have been multiple studies performed on the effect of flushing on wildlife, “A study by Karen Kidd et al., in the 22 May 2007 issue of Proceedings of the National Academy of Sciences, showed the collapse of a population of fish in an isolated lake spiked with relatively high levels of the synthetic estrogen 17α-ethinylestradiol.” Lubick, Naomi. “Drugs in the environment: do pharmaceutical take-back programs make a difference?.” Environmental health perspectives vol. 118,5 (2010): A210-4. doi:10.1289/ehp.118-a210 

 

List of Potentially Affected Facilities:
Drug Wholesalers
Supermarkets and Other Grocery (except convenience) Stores.
Pharmacies and Drug Stores.
Warehouse Clubs and Supercenters.
Veterinary Services.
Physicians’ Offices.
Dentists’ Offices.
Other Health Practitioners (e.g., chiropractors).
Outpatient Care Centers.
Other Ambulatory Health Care Services.
Hospitals.
Nursing Care Facilities (e.g., assisted living facilities, nursing homes).
Continuing Care Retirement Communities (e.g., assisted living facilities with on-site nursing facilities).
Reverse Distributors.

 

The scientific community has not yet definitively linked the flushing of pharmaceuticals to adverse effects on humans. If these chemicals are being introduced into our drinking water and having profound effects on the wildlife within the drinking water, it is only logical to assume that humans would incur negative consequences as well. Now that an issue has been identified, we must address it: “One way to prevent additional impact to our waters is the cessation or reduction of pharmaceutical drugs disposed of via sewers,” C.G. Daughton, I.S. Ruhoy, Environmental footprint of pharmaceuticals: The significance of factors beyond direct excretion to sewers, Environ. Toxicol. Chem., 28 (2009), pp. 2495-2521, 10.1897/08-382.1.

Another beneficial facet of this amendment is the new guideline on how Nicotine products will be handled. Traditionally, smoking cessation products containing Nicotine qualified as hazardous waste and had to be disposed of as such. Not anymore; from now on, these products are categorized as nonhazardous pharmaceutical waste.

Lastly, this new rule affects how expired medicines are returned. An outdated drug may be returned to a reverse distributor. This is common practice; after August 21, 2019, a drug becomes eligible for return the day it expires or ‘outdates’ (assuming it meets other mitigating factors: “original manufacturer packaging; undispensed; and unexpired or less than a year past expiration” SMITH, CHARLOTTE A. “Countdown to New Drug Waste Rule: EPA’s New Disposal Regulations to Require Operational Changes.” Health Facilities Management, vol. 32, no. 6, July 2019, p. 52. EBSCOhost, search.ebscohost.com/login.aspx?direct=true&db=f5h&AN=137427558&site=eds-live.

The exact dates for when regulations roll out may be affected by state guidelines, so a facility must always be sure to cross-check federal regulations with state level regulations. These changes will take some time for facilities to adjust, but are anticipated to be overall cost-saving. Less training will be needed for staff with the list of hazardous products lessened by the release of Nicotine products for hazardous disposal. Distribution centers may qualify for different (less expensive) licensing options with the removal of Nicotine products from the list. Waste management practices will be more streamlined by the removal of flushing as an option for disposal.

After expiration and before disposal, facilities must still adhere to government regulations of containment.

Schedules I and II

May suffice with safe or steel cabinet:

Safe or cabinet must have following specifications: 30 man-minutes against surreptitious entry, 10 man-minutes against forced entry, 20 man-hours against lock manipulation, and 20 man-hours against radiological techniques.  These includes TL-15 Rated EPA Safes and some agencies may be approved for GSA Approved Class 5 rated containers.

Or if quantities require a vault:

Walls, floors, and ceiling are constructed of at least 8 inches of reinforced concrete or other substantial masonry, reinforced vertically and horizontally with ½ inch steel rods tied 6inches on center, or the structural equivalent to such reinforced walls, floors, and ceilings. Modular vault structures of a UL Class 1 rating are equivalent to 12″ inch poured concrete w/ 4 layers of re-bar per ASTM specifications.

Vault includes Choice of Class 1 Door or ArmorStor ™ Class 5 Equivalency Rated Door.

Following specifications: 30 man minutes against surreptitious entry, 10 man-minutes against forced entry, 20 man-hours against lock manipulation, and 20 man-hours against radiological techniques

One of the following: Electrical lacing of the walls, floor, and ceilings; sensitive ultrasonic equipment within the vault; a sensitive sound accumulator system; or such other device designed to detect illegal entry as may be approved by administration

Schedules III, IV and V

Subject to the same storage security regulations as schedules I and II

May utilize a building used specifically for storage of controlled substances providing the building:

Has an electrical alarm system

Perimeter security during working and non-working hours

Etc.

May store drugs in a cage within a building on the premises

Cage must have walls of no less than No. 10 gauge steel fabric mounted on steel posts

Posts are at least one inch in diameter, set in concrete or installed with lag bolts that are pinned or brazed, and placed no more than ten feet apart with 1 and 1 ½ inch reinforcements every sixty inches

Etc.

Helpful Links:
Code of Federal Regulations: Title 21

https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?fr=205.50

EPA: Final Rule

https://www.epa.gov/hwgenerators/final-rule-management-standards-hazardous-waste-pharmaceuticals-and-amendment-p075

Federal Register

https://www.federalregister.gov/documents/2019/02/22/2019-01298/management-standards-for-hazardous-waste-pharmaceuticals-and-amendment-to-the-p075-listing-for

When you’re ready to begin the process of securing your facility, the consultants at KL Security are available to assist. Well versed in government regulations and recent legal mandates, we are prepared to ensure your business will pass requirements.

TOLL FREE 1-866-867-0306

contact@klsecurity.com

Information has been gathered from sources deemed reliable but not guaranteed and is subject to change without notice. All license information and security measures taken directly from the Code of Federal Regulations: 21CFR205.50 and 84 FR 5816.

 

503A & 503B Facility Security Requirements

Outsourcing Facilities and Security

An outsourcing facility combines pharmaceutical drugs to tailor meet the needs of an individual; a person may be allergic to a component of a medication or may need a solid drug transformed to liquid form for consumption. This compounding of drugs must be done by a pharmacist, physician, or under supervision of a pharmacist. The individual drugs are FDA approved, but the new combination of two drugs is not. There are two categories of facilities: 503A and 503B.

Facilities that fall under the 503A category are pharmacies licensed for operation under Federal and State Codes. Facilities that fall under the 503B category are pharmacies, or often manufacturers, that have applied for 503B licensing through the FDA.  The 503B status gives a facility the license to compound drugs on a larger scale, save money by producing compounded drugs in bulk, and the ability to relay these savings on to a consumer.

Applying for status as a 503B facility is voluntary, but affords benefits. The facility may be able to qualify certain compounded drugs for FDA approval exemptions, but must still conform to current good manufacturing practice requirements and FDA regulations.

Regulations for security requirements of outsourcing facilities can be found within the Code of Federal Regulations.  21CFR13.01.72 outlines the specific guidelines of storage for each schedule of drug. Listed are a few key notes of interest taken directly from legislature:

Schedules I and II

  • May suffice with safe or steel cabinet:
  • Safe or cabinet must have following specifications: 30 man-minutes against surreptitious entry, 10 man-minutes against forced entry, 20 man-hours against lock manipulation, and 20 man-hours against radiological techniques.
Modular Reinforced Vaults of UL Class 1 Rating Equivalent to 12 Inches reinforced Concrete

Or if quantities require a vault:

Walls, floors, and ceiling are constructed of at least 8 inches of reinforced concrete or other substantial masonry, reinforced vertically and horizontally with ½ inch steel rods tied 6inches on center, or the structural equivalent to such reinforced walls, floors, and ceilings.

Following specifications: 30 man minutes against surreptitious entry, 10 man-minutes against forced entry, 20 man-hours against lock manipulation, and 20 man-hours against radiological techniques

One of the following: Electrical lacing of the walls, floor, and ceilings; sensitive ultrasonic equipment within the vault; a sensitive sound accumulator system; or such other device designed to detect illegal entry as may be approved by administration

Schedules III, IV and V

  • Subject to the same storage security regulations as schedues I and II
  • May utilize a building used specifically for storage of controlled substances providing the building:
  • Has an electrical alarm system
  • Perimeter security during working and non-working hours
  • Etc.
  • May store drugs in a DEA approved cage within a building on the premises
  • Cage must have walls of no less than No. 10 gauge steel fabric mounted on steel posts
  • Posts are at least one inch in diameter, set in concrete or installed with lag bolts that are pinned or brazed, and placed no more than ten feet apart with 1 and 1 ½ inch reinforcements every sixty inches

Etc.

Helpful Links:

https://www.fda.gov/drugs/human-drug-compounding/compounding-and-fda-questions-and-answers

https://www.fda.gov/drugs/human-drug-compounding/regulatory-policy-information

https://www.fda.gov/drugs/human-drug-compounding/regulatory-policy-information

https://www.klsecurity.com/index.php/products/vaults-and-doors/dea-approved.html

When you’re ready to begin the process of securing your facility, the consultants at KL Security are available to assist. Well versed in government regulations and recent legal mandates, we are prepared to ensure your business will pass requirements.

TOLL FREE 1-866-867-0306

contact@klsecurity.com

Information has been gathered from sources deemed reliable but not guaranteed and is subject to change without notice. All license information and security measures taken directly from the Code of Federal Regulations: 21CFR13.01.72

Recycling Reefer: Proper Disposal of Cannabis Product in Massachusetts

There is no doubt that opening a marijuana business is complicated. Even taking out the trash has stringent requirements. Any marijuana refuse has to be secured, documented, and disposed of properly. Mass Ann Laws ch. 94G, § 4 (a ½) (xxviii) gives the Cannabis Control Commission power to regulate the disposal requirements for marijuana establishments. It also encourages the Commission to promote recycling within the industry. 

To properly recycle cannabis plant parts, they must be ground and mixed with other organic materials: food waste, soil, mulch, other plant waste. This will render the product unusable and ready for compost. If the facility does not have the physical space to compost the material on-site, the cannabis compost material may be sent to a facility approved to handle such materials, 935 CMR 502.105.

The department of Environmental Protection within the state of Massachusetts mandates that records be kept of any hazardous wastes created, stored, treated, disposed, or transferred for disposal, Mass Ann Laws ch. 21 C, § 6 and Mass Ann Laws ch. 111F, § 16. The Cannabis Control Commission of Massachusetts provides links to all disposal options and waste service providers on their website: https://mass-cannabis-control.com.

Secure Transport and In Transit Tracking of Plants and Product for the Cannabis Industry are also available

The marijuana industry is highly regulated at every level. It’s no surprise that waste management would be any different. It is also feasible that out of all processes to be overlooked within the planning of a Cannabis facility would be that of waste management, “…one of the top five cannabis cultivation violations for 2018 was cannabis waste management.” Commendatore, Cristina. “The Complicated World of Cannabis Waste Generation (Part One).” Waste 360, July 2019, https://www.waste360.com/legislation-regulation/complicated-world-cannabis-waste-generation-part-one

KL Security offers solutions to these rigorous regulations in the form of reinforced vault rooms, TL Rated DEA Approved safes, electronic data management storage and video surveillance solutions. Record keeping will undoubtedly be most efficiently be done electronically, and must be stored in a safe location to ensure access by local officials at a moment’s notice.

Electronic Records Management for Illinois Marijuana Dispensaries

 

 

 

 

Illinois legislature requires dispensaries in Illinois to maintain security measures to protect both people and product.  One of the requirements for dispensary security is 24/7 video surveillance. Cameras must be rolling at all times and record footage of all entries & exits, parking lots, exterior of building, all vaults, safes, storage areas , and anywhere cannabis is handled in any fashion (sales, disposal, preparation, retail areas, storage, etc.) These cameras must be of substantial quality with the ability for law enforcement to identify vehicle license plates and use facial recognition. These records must be maintained for a minimum of 90 days, and available for review at any time.

All security system equipment and recordings shall be maintained in good working order, in a secure location so as to prevent theft, loss, destruction, or alterations.
Cannabis Regulation and Tax Act., 2019 Bill Text IL H.B. 1438

As if this wasn’t an already massive amount of data to store, dispensaries must also electronically maintain records of the following items for a minimum of three years (even in the event the dispensary closes):

(1)  Operating procedures;

(2)  Inventory records, policies, and procedures;

(3)  Security records;

(4)  Audit records;

(5)  Staff training plans and completion documentation;

(6)  Staffing plan; and

(7)  Business records, including but not limited to:

  • (i)  Assets and liabilities;
  • (ii)  Monetary transactions;
  • (iii)  Written or electronic accounts, including bank statements, journals, ledgers, and supporting documents, agreements, checks, invoices, receipts, and vouchers; and
  • (iv)  Any other financial accounts reasonably related to the dispensary operations.

Cannabis Regulation and Tax Act., 2019 Bill Text IL H.B. 1438

These are all just the requirements set in place by the state of Illinois. It is important to also check the local ordinances to review any additional local guidelines, “…it is crucial to understand compliance within the state or states where an organization operates.” Smallwood, Robert F. Managing Electronic Records: Methods, Best Practices, and Technologies, John Wiley & Sons, Incorporated, 2013.

ioSafe data storage products are the best brand manufacturer of virtual cloud data to physical endpoint files and complete systems that process, store and archive data and electronic records for Illinois Dispensary and retail marijuana shops.

Effective electronic record management is vital to the efficient operation of any modern business; “An investment in ERM (Electronic Record Management) is an investment in business process automation and yields document control, document integrity, and security benefits.” Smallwood, Robert F. Managing Electronic Records: Methods, Best Practices, and Technologies, John Wiley & Sons, Incorporated, 2013.

When you’re ready to begin the process of securing your business (cannabis or otherwise), the consultants at KL Security are available to assist. Well versed in government regulations and recent legal mandates, we are prepared to ensure your business will pass requirements.

TOLL FREE 1-866-867-0306

contact@klsecurity.com

DEA Rules, security requirements and regulations per the Code of Federal Regulations 21CFR1301.72https://www.klsecurity.com/products/medical-marijuana-dea-storage.html

 

Information has been gathered from sources deemed reliable but not guaranteed and is subject to change without notice. All license information and security measures taken directly from legislation: Cannabis Regulation and Tax Act., 2019 Bill Text IL H.B. 1438

 

 

Maneuvering Marijuana in Michigan: Secure Transporters

Secure transporters move marijuana product and cash obtained from medical cannabis and/or recreational marijuana transactions across the state for a fee.  Think about it as a business owner: you are operating a new business, and your product was very recently illegal. The black market will continue to operate for some time until the State of Michigan has a system in place to protect these assets. As such, there is a mandated 3rd party transport law for all medical cannabis and recreational marijuana moving from Growers, Processors, Licensed Micro business, storage and retail dispensaries.

“In Colorado, which legalized recreational use in 2014, the illegal black market is now a larger problem than before legalization…” Walsh, Dustin. (4/8/2019) Legal pot vs. black market a balance. Crain’s Detroit Business, Vol. 35 Issue 14, p1-1, 1p.  

Bearing this in mind, the conveyance of product from grower to seller must be protected. 

The state of Michigan will begin accepting applications for select secure transport licenses beginning December 6, 2019. If an individual or entity is thinking of applying for any licensure, it would be in his/her best interest to start assembling documents now. To be eligible as a secure transporter, the license applicant will need to meet several qualifications taken from: Mich. Comp. Laws Serv. SS 333.27505 (LexisNexis 2018) and Mich. Comp. Laws Serv. SS 27959 (LexisNexis 2018):

  • No ownership/interest in another marijuana business
  • May not be a registered patient or caregiver of medicinal marijuana
  • Resident of Michigan
  • May not hold title to marijuana 
Growers, Processor and Provisioning Centers and Secure Transportation of Marijuana and Cannabis The role of secure transporter within the Michigan Medical cannabis and recreational marijuana chain is integral. A grower may not move their product legally (to other growers and/or dispensaries) without using the services of a secure transporter. MCL 333.27503 (4) (LexisNexis, Lexis Advance through Public Act 47 from the 2019 Legislative Session): 

 

 

 

 

 

 

Secure Transporter Requirements: 

  • Drivers must have chauffeur’s license issued by Michigan
  • Employees handling marijuana or cash from transactions may not have a felony conviction within the past five years, been released from incarceration in the past five years, or a hold a  misdemeanor conviction involving substance abuse in the past five years. 
  • Each transporting vehicle must be operated by a minimum 2-person crew. The vehicle is never to be left unattended while marijuana product is in custody.
  • Route plans and manifests must be kept within the vehicle, and available to present to law enforcement at all times. This data must also be logged into the statewide monitoring system. 
  • Marijuana must be contained within sealed containers, and not accessible while the vehicle is in motion. 
  • A vehicle operating as a secure transporter may not display any visual markings or indicate in any way that it is transporting marijuana. 

In Michigan, security requirements vary by municipality and County.  It is imperative one checks the local code for a potential business to correctly implement the adequate standard. It is of the utmost importance that businesses/operators are complying with regulations as these establishments are available for inspection at any time.

DEA Rules, security requirements and regulations per the Code of Federal Regulations 21CFR1301.72 https://www.klsecurity.com/products/medical-marijuana-dea-storage.html

For the latest updates, the Michigan Marijuana Regulatory Agency (MRA) is in the process of implementing the security and regulatory framework for the entire state, Michigan County and Townships. Information has been gathered from sources deemed reliable but not guaranteed and is subject to change without notice.

All license information and security measures taken directly from legislation: Michigan Regulation and Taxation of Marihuana Act. “REGULATION AND TAXATION OF MARIHUANA ACT”. , 2017 Bill Text MI S.B. 1243 SEC. 501

 

LINKS TO FORMS & LEGISLATION:

MICHIGAN MARIJUANA REGULATORY AGENCY

https://www.michigan.gov/lara/0,4601,7-154-89334_79571_90056—,00.html

MICHIGAN REGULATION AND TAXATION OF MARIHUANA ACT

https://www.legislature.mi.gov/(S(wwmtk0j1m4jeg10at2zbsucs))/mileg.aspx?page=getObject&objectName=mcl-Initiated-Law-1-of-2018

 

Secure your Stash: Licensing and Security in Michigan’s Medical Cannabis & Recreational Marijuana Market

Due to the legalization of marijuana on a medical and recreational level, Michigan is ripe with financial opportunities. There are many different levels of operation an entrepreneur may engage. To cultivate, sell, or transfer marijuana to establishments, one would need a Michigan Grower’s license. There are three classes of license for growers: Class A – 500 marijuana plants; Class B – 1,000 plants; Class C – 1,500 plants. Remember, cannabis still may be subject to DEA Rules, security requirements and regulations per the Code of Federal Regulations 21CFR1301.72

Within the pot hierarchy, there is a step directly below growers: microbusiness. Michigan Microbusiness license holders may cultivate up to 150 marijuana plants, process/package marijuana, and may sell/transfer to those 21 & over but cannot sell to other marijuana businesses. (Think: start up with little capital.)

Next in the cannabis chain, we will find the processor and the retailer. These are separate licenses and have different limitations/functions. The processor may purchase marijuana from a grower, extract resin, or create a marijuana infused product for sale (edibles, etc.), and/or transfer said product to another processor or provisioning center. The retailer may acquire marijuana from establishments and sell to other establishments or individuals.

The chart below demonstrates which cannabis license holder can engage with another:

The state of Michigan will begin accepting applications for select licenses beginning December 6, 2019. If an individual is thinking of applying for any licensure, it would be in his/her best interest to start assembling documents now. The forms and applications are not yet available, but It’s safe to assume the document checklist will resemble those for medicinal facilities. The MMFL prequalification requires over 40 documents alone.  This information can be found on the state of Michigan’s website: https://www.michigan.gov/lara/0,4601,7-154-89334_79571_87302—,00.html

In Michigan, security requirements vary by municipality.  It is imperative one checks the local code for a potential business to correctly implement the adequate standard. It is of the utmost importance that recreational businesses/operators are complying with regulations as these establishments are available for inspection at any time. Performing a realistic evaluation of the expected size of business (as well as future growth) should be done at the introductory phase. For example: a microbusiness may suffice with several small TL-15 Rated safes bolted to the floor or a dispensary may require a modular vault and vault door to house the quantity of inventory.

In summation, asset protection should always be at the forefront of a business owner’s mind. Replacing valuable product or having to cease business to meet government regulations is costly, inconvenient, and stressful.  The cannabis and marijuana industry is sure to be highly competitive and a highly sought-after revenue stream. KL Security has experienced consultants ready to help, and offers security solutions for dispensaries, growers and retails that meet compliance for security.

KL Security is able to help at all levels of the supply chain:

Full line of cash management safes for retail point of sale

Cannabis Inventory Management

Growers, Greenhouses, or Cultivations Farms and Land

  • Safe and Vault Systems
Modular Vaults systems that meet DEA 21CFR1301.72 for Dispensaries are designed for DEA Approved Storage at Growers, Retail and Cultivation Farms

For the latest updates, the Michigan Marijuana Regulatory Agency (MRA) is in the process of implementing the security and regulatory framework for the entire state, Michigan County and Townships. Information has been gathered from sources deemed reliable but not guaranteed and is subject to change without notice.

All license information and security measures taken directly from legislation: Michigan Regulation and Taxation of Marihuana Act. “REGULATION AND TAXATION OF MARIHUANA ACT”. , 2017 Bill Text MI S.B. 1243 SEC. 501

 

LINKS TO FORMS & LEGISLATION:

MICHIGAN MARIJUANA REGULATORY AGENCY

https://www.michigan.gov/lara/0,4601,7-154-89334_79571_90056—,00.html

MICHIGAN REGULATION AND TAXATION OF MARIHUANA ACT

https://www.legislature.mi.gov/(S(wwmtk0j1m4jeg10at2zbsucs))/mileg.aspx?page=getObject&objectName=mcl-Initiated-Law-1-of-2018

 

 

 

 

 

ATF Offices in the United States, Contact Information for Storage Requirements

Contact Information for ATF Offices in the United States

Alabama & Tennessee

Head Office: Brentwood, Tennessee

Phone: (615) 565-1400

Fax: (615) 565-1401

NashDiv@atf.gov

 

Alaska, Washington, Oregon, Idaho, Hawaii, and Guam

Head Office: Seattle, Washington

Phone: (206) 204-3205

Fax: (206) 204-3252

SeattleDiv@atf.gov

 

Arizona and New Mexico

Head Office: Phoenix, Arizona

Office of Criminal Enforcement Phone: (602) 776-5400

Office of Industry Operation Phone: (602) 776-5480

Fax: (602) 776-5429

PhoenixDiv@atf.gov

 

Arkansas, Louisiana, and Mississippi

Head Office: Metairie, Louisiana

Phone: (504) 841-7000

Fax: (504) 841-7039

NewOrleansDiv@atf.gov

California (northern) and Nevada

Head Office: Dublin, California

Phone: (925) 557-2800

Fax: (925) 557-2805

SanFranciscoDiv@atf.gov

 

California (Los Angeles)

Head Office: Glendale, California

Phone: (818) 265-2500

Fax: (818) 265-2501

LosAngelesDivision@atf.gov

 

Colorado, Montana, Utah, and Wyoming

Head Office: Denver, Colorado

Phone: (303) 575-7600

Fax: (303) 575-7601

DenverDiv@atf.gov

 

Connecticut, Rhode Island, Vermont, New Hampshire, Maine, and Massachusetts

Head Office: Boston, Massachusetts

Phone: (617) 557-1200

Fax: (617) 557-1201

 

Delaware and Maryland

Head Office: Baltimore, Maryland

Phone: (443) 965-2000

Fax: (443) 965-2001

BaltimoreDiv@atf.gov

 

Florida (Miami)

Head Office: Miami, Florida

Phone: (305) 597-4800

Fax: (305) 597-4801

MiamiDiv@atf.gov

 

Florida (Tampa)

Head Office: Tampa, Florida

Phone: (813) 202-7300

Fax: (813) 202-7301

TampaDiv@atf.gov

 

Georgia

Head Office: Atlanta, Georgia

Phone: (404) 417-2600

Fax: (404) 417-2601

AtlantaDiv@atf.gov

 

Illinois

Head Office: Chicago, Illinois

Phone: (312) 846-7200

Fax: (312) 846-7201

ChicagoDiv@atf.gov

 

Indiana and Ohio

Head Office: Columbus, Ohio

Phone: (614) 827-8400

Fax: (614) 827-8401

ColumbusDiv@atf.gov

 

Iowa, Kansas, Missouri, and Nebraska

Head Office: Kansas City, Missouri

Phone: (816) 559-0700

Fax: (816) 559-0701

Kansascitydiv@atf.gov

 

Kentucky and West Virginia

Head Office: Louisville, Kentucky

Phone: (502) 753-3400

Fax: (502) 753-3401

LouisDiv@atf.gov

 

Michigan

Head Office: Detroit, Michigan

Phone: (313) 202-3400

Fax: (313) 202-3445

DetroitDiv@atf.gov

 

Minnesota, North Dakota, South Dakota, and Wisconsin

Head Office: St. Paul, Minnesota

Phone: (651) 726-0200

Fax: (651) 726-0201

StPaulDiv@atf.gov

 

New Jersey

Head Office: Woodland Park, New Jersey

Phone: (973) 413-1179

Fax: (973) 413-1190

 

New York

Head Office: New York, New York

Phone: (646) 335-9000

Fax: (646) 335-9001

NYDiv@atf.gov

 

North Carolina and South Carolina

Head Office: Charlotte, North Carolina

Phone: (704) 716-1800

Fax: (704) 716-1801

CharlotteDiv@atf.gov

 

Oklahoma and Texas (northern)

Head Office: Dallas, Texas

Phone: (469) 227-4300

Fax: (469) 227-4330

DallasDivision@atf.gov

 

Pennsylvania

Head Office: Philadelphia, Pennsylvania

Phone: (215) 446-7800

Fax: (215) 446-7811

PhilDiv@atf.gov

 

Texas (southern)

Head Office: Houston, Texas

Phone: (281) 716-8200

Fax: (281) 716-8219

HoustonDiv@atf.gov

 

Virginia and District of Columbia

Head Office: Washington, DC

Phone: (202) 648-8010

Fax: (202) 648-8001

WashDiv@atf.gov

List of Explosive Materials per ATF Federal Law & Storage

Department of Justice: Bureau of Alcohol, Tobacco, Firearms, and Explosives:

2017 Annual List of Explosive Materials

 

Source: Federal Register, Vol. 82 No. 248 December 28, 2017 https://www.gpo.gov

 

In accordance with Federal law, the Department of Justice must publish and revise at least annually in the Federal Register a list of explosives determined to be explosive materials.

This list covers explosives, blasting agents and detonators, all of which are defined as “explosive materials.” Each material listed, as well as all mixtures containing any of these materials, constitute ‘‘explosive materials’’ under 18 U.S.C. 841(c). This list contains the 2017 Annual List of Explosive Materials, which remains unchanged from the 2016 Annual List of Explosives.

Note: While the list is comprehensive, it is not all-inclusive. The fact that an explosive material is not on this list doesn’t mean that it is not within the coverage of the law if it otherwise meets the statutory definition in 18 U.S.C. 841.

Materials constituting blasting agents are marked in italics.

Explosive materials are listed alphabetically and followed by their common names (where applicable), chemical names, and/or synonyms in brackets.

 

A

Acetylides of heavy metals.

Aluminum containing polymeric propellant.

Aluminum ophorite explosive.

Amatex.

Amatol.

Ammonal.

Ammonium nitrate explosive mixtures (cap sensitive).

Ammonium nitrate explosive mixtures (non-cap sensitive).

Ammonium perchlorate having particle size less than 15 microns.

Ammonium perchlorate explosive mixtures (excluding ammonium perchlorate composite propellant (APCP)).

Ammonium picrate [picrate of ammonia, Explosive D].

Ammonium salt lattice with isomorphously substituted inorganic salts.

NFO [ammonium nitrate-fuel oil]. Aromatic nitro-compound explosive mixtures.

Azide explosives.

B

Baranol.

Baratol.

BEAF [1, 2-bis (2, 2-difluoro-2- nitroacetoxyethane)].

Black powder.

Black powder based explosive mixtures.

Black powder substitutes.

Blasting agents, nitro-carbo-nitrates, including non-cap sensitive slurry and water gel explosives.

Blasting caps.

Blasting gelatin.

Blasting powder.

BTNEC [bis (trinitroethyl) carbonate].

BTNEN [bis (trinitroethyl) nitramine].

BTTN [1,2,4 butanetriol trinitrate].

Bulk salutes.

Butyl tetryl.

 

C

Calcium nitrate explosive mixture.

Cellulose hexanitrate explosive mixture.

Chlorate explosive mixtures.

Composition A and variations.

Composition B and variations.

Composition C and variations.

Copper acetylide.

Cyanuric triazide.

Cyclonite [RDX].

Cyclotetramethylenetetranitramine [HMX].

Cyclotol.

Cyclotrimethylenetrinitramine [RDX].

 

D

DATB [diaminotrinitrobenzene].

DDNP [diazodinitrophenol].

DEGDN [diethyleneglycol dinitrate].

Detonating cord.

Detonators.

Dimethylol dimethyl methane dinitrate composition.

Dinitroethyleneurea.

Dinitroglycerine [glycerol dinitrate].

Dinitrophenol.

Dinitrophenolates.

Dinitrophenyl hydrazine.

Dinitroresorcinol.

Dinitrotoluene-sodium nitrate explosive mixtures.

DIPAM [dipicramide; diaminohexanitrobiphenyl].

Dipicryl sulfone.

Dipicrylamine.

Display fireworks.

DNPA [2,2-dinitropropyl acrylate].

DNPD [dinitropentano nitrile].

Dynamite.

 

E

 

EDDN [ethylene diamine dinitrate].

EDNA [ethylenedinitramine].

Ednatol.

EDNP [ethyl 4,4-dinitropentanoate].

EGDN [ethylene glycol dinitrate].

Erythritol tetranitrate explosives.

Esters of nitro-substituted alcohols.

Ethyl-tetryl.

Explosive conitrates.

Explosive gelatins.

Explosive liquids.

Explosive mixtures containing oxygen-releasing inorganic salts and hydrocarbons.

Explosive mixtures containing oxygen-releasing inorganic salts and nitro bodies.

Explosive mixtures containing oxygen-releasing inorganic salts and water insoluble fuels.

Explosive mixtures containing oxygen-releasing inorganic salts and water soluble fuels.

Explosive mixtures containing sensitized nitromethane.

Explosive mixtures containing tetranitromethane (nitroform).

Explosive nitro compounds of aromatic hydrocarbons.

Explosive organic nitrate mixtures.

Explosive powders.

 

F

 

Flash powder.

Fulminate of mercury.

Fulminate of silver.

Fulminating gold.

Fulminating mercury.

Fulminating platinum.

Fulminating silver.

 

G

 

Gelatinized nitrocellulose.

Gem-dinitro aliphatic explosive mixtures.

Guanyl nitrosamino guanyl tetrazene.

Guanyl nitrosamino guanylidene hydrazine.

Guncotton.

 

H

 

Heavy metal azides.

Hexanite.

Hexanitrodiphenylamine.

Hexanitrostilbene.

Hexogen [RDX].

Hexogene or octogene and a nitrated Nmethylaniline.

Hexolites.

HMTD [hexamethylenetriperoxidediamine].

HMX [cyclo-1,3,5,7-tetramethylene 2,4,6,8- tetranitramine; Octogen].

Hydrazinium nitrate/hydrazine/aluminum explosive system.

Hydrazoic acid.

 

I

 

Igniter cord.

Igniters.

Initiating tube systems.

 

K

 

KDNBF [potassium dinitrobenzo-furoxane].

 

L

 

Lead azide.

Lead mannite.

Lead mononitroresorcinate.

Lead picrate.

Lead salts, explosive.

Lead styphnate [styphnate of lead, lead trinitroresorcinate].

Liquid nitrated polyol and trimethylolethane.

Liquid oxygen explosives.

 

M

 

Magnesium ophorite explosives.

Mannitol hexanitrate.

MDNP [methyl 4,4-dinitropentanoate].

MEAN [monoethanolamine nitrate].

Mercuric fulminate.

Mercury oxalate.

Mercury tartrate.

Metriol trinitrate.

Minol-2 [40% TNT, 40% ammonium nitrate, 20% aluminum].

MMAN [monomethylamine nitrate]; methylamine nitrate.

Mononitrotoluene-nitroglycerin mixture.

Monopropellants.

 

N

 

NIBTN [nitroisobutametriol trinitrate].

Nitrate explosive mixtures.

Nitrate sensitized with gelled nitroparaffin.

Nitrated carbohydrate explosive.

Nitrated glucoside explosive.

Nitrated polyhydric alcohol explosives.

Nitric acid and a nitro aromatic compound explosive.

Nitric acid and carboxylic fuel explosive.

Nitric acid explosive mixtures.

Nitro aromatic explosive mixtures.

Nitro compounds of furane explosive mixtures.

Nitrocellulose explosive.

Nitroderivative of urea explosive mixture.

Nitrogelatin explosive.

Nitrogen trichloride.

Nitrogen tri-iodide.

Nitroglycerine [NG, RNG, nitro, glyceryl trinitrate, trinitroglycerine].

Nitroglycide.

Nitroglycol [ethylene glycol dinitrate, EGDN].

Nitroguanidine explosives.

Nitronium perchlorate propellant mixtures.

Nitroparaffins Explosive Grade and ammonium nitrate mixtures.

Nitrostarch.

Nitro-substituted carboxylic acids.

Nitrourea.

 

O

 

Octogen [HMX].

Octol [75 percent HMX, 25 percent TNT].

Organic amine nitrates.

Organic nitramines.

 

P

 

PBX [plastic bonded explosives].

Pellet powder.

Penthrinite composition.

Pentolite.

Perchlorate explosive mixtures.

Peroxide based explosive mixtures.

PETN [nitropentaerythrite, pentaerythrite tetranitrate, pentaerythritol tetranitrate].

Picramic acid and its salts.

Picramide.

Picrate explosives.

Picrate of potassium explosive mixtures.

Picratol.

Picric acid (manufactured as an explosive).

Picryl chloride.

Picryl fluoride.

PLX [95% nitromethane, 5% ethylenediamine].

Polynitro aliphatic compounds.

Polyolpolynitrate-nitrocellulose explosive gels.

Potassium chlorate and lead sulfocyanate explosive.

Potassium nitrate explosive mixtures.

Potassium nitroaminotetrazole.

Pyrotechnic compositions.

Pyrotechnic fuses.

PYX [2,6-bis(picrylamino)] 3,5- dinitropyridine.

 

R

 

RDX [cyclonite, hexogen, T4, cyclo-1,3,5,- trimethylene-2,4,6,-trinitramine; hexahydro-1,3,5-trinitro-S-triazine].

 

 

S

 

Safety fuse.

Salts of organic amino sulfonic acid explosive mixture.

Salutes (bulk).

Silver acetylide.

Silver azide.

Silver fulminate.

Silver oxalate explosive mixtures.

Silver styphnate.

Silver tartrate explosive mixtures.

Silver tetrazene.

Slurried explosive mixtures of water, inorganic oxidizing salt, gelling agent, fuel, and sensitizer (cap sensitive).

Smokeless powder.

Sodatol.

Sodium amatol.

Sodium azide explosive mixture.

Sodium dinitro-ortho-cresolate.

Sodium nitrate explosive mixtures.

Sodium nitrate-potassium nitrate explosive mixture.

Sodium picramate.

Squibs.

Styphnic acid explosives.

 

T

 

Tacot [tetranitro-2,3,5,6-dibenzo-1,3a,4,6a tetrazapentalene].

TATB [triaminotrinitrobenzene].

TATP [triacetonetriperoxide].

TEGDN [triethylene glycol dinitrate].

Tetranitrocarbazole.

Tetrazene [tetracene, tetrazine, 1(5- tetrazolyl)-4-guanyl tetrazene hydrate].

Tetrazole explosives.

Tetryl [2,4,6 tetranitro-N-methylaniline].

Tetrytol.

Thickened inorganic oxidizer salt slurried explosive mixture.

TMETN [trimethylolethane trinitrate].

TNEF [trinitroethyl formal].

TNEOC [trinitroethylorthocarbonate].

TNEOF [trinitroethylorthoformate].

TNT [trinitrotoluene, trotyl, trilite, triton].

Torpex.

Tridite.

Trimethylol ethyl methane trinitrate composition.

Trimethylolthane trinitrate-nitrocellulose.

Trimonite.

Trinitroanisole.

Trinitrobenzene.

Trinitrobenzoic acid.

Trinitrocresol.

Trinitro-meta-cresol.

Trinitronaphthalene.

Trinitrophenetol.

Trinitrophloroglucinol.

Trinitroresorcinol.

Tritonal.

 

U

Urea nitrate.

W

Water-bearing explosives having salts of oxidizing acids and nitrogen bases, sulfates, or sulfamates (cap sensitive).

Water-in-oil emulsion explosive compositions.

X

Xanthomonas hydrophilic colloid explosive mixture.

Storage Requirements for NYSED Regent Exams

The New York State Education Department (NYSED) requires secure

High Security TRTL-30 Safes for Storage Requirements for NYSED Regent Exams

examination materials to be stored in locked Regents boxes. In turn, locked Regent boxes must be stored in a NYSED-approved safe or walk-in vault that meets all of the listed specifications below.

Newly constructed vaults, modified existing vaults, or recently purchased safes must be inspected by a NYSED representative and approved by the department before secure materials can be stored.

Safes must meet or exceed Underwriters Laboratories (UL) TRTL-30 Safe performance standards for burglary resistance and must have:

  • Steel door at least 1 ½” thick
  • Steel walls at least 1” thick
  • 750 lbs. minimum weight
  • Built-in combination lock
  • Sufficient capacity to store the locked Regents boxes or the school’s largest examination request (minimum acceptable unobstructed inside dimensions of 11”H x 20”W x 27D” to store one Regents box)

Walk-In Vaults must meet all of the following criteria:

  • Poured concrete floor
  • No windows or access panels
  • Walls of reinforced cement block or concrete sealed to a poured concrete floor below with structural floor or roof deck above
  • Metal door in a metal frame with interior or welded-pin hinges
  • Built-in dead-latch (deadbolt) with combination or key lock that allows exiting at all times

T K.L. Security we offer a full range of TRTL-30 rated safes for NYSED Regents Exam storage and can customize the interiors to meet your exact needs and requiremetns.

 

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