Five Things You Need to Know
Before Starting Security Planning & Programming

Be sure to avoid costly mistakes by downloading this free guide first!

Pesticides & Cannabis | PSA

The safe cultivation of marijuana for consumption is a murky pool to wade through. Marijuana is illegal at the federal level, and thus the EPA is unable to issue guidelines or regulations regarding pesticides and fertilizers that are safe to use.

It would be assumed that marijuana farmers would utilize pesticides deemed safe for food crops. This would be a logical association, but we are forgetting that these pesticides were deemed safe for ingestion, not inhalation.

“…nobody is smoking zinnias, so the safety hasn’t been established for those uses.” – Janna Beckerman, professor of botany and plant pathology at Purdue University [1]

If you were to google ‘pesticides and marijuana’, you would find a plethora of articles and websites. The information is endless, but it’s hard to verify and substantiate.

The disconnect of federal government and the legalization of marijuana is not only inconvenient, but dangerous.

Consumers living in states where marijuana is legal are purchasing and using the plant under the assurance and assumption that it’s safe. It’s legal so it must be regulated…right?

“…the federal government still considers cannabis an illegal drug, the EPA has not approved any pesticides for use on the plant, nor has the agency provided any indication of the level of residues on cannabis products—if any—that could be considered safe…” [2]

Many states have compiled their own lists of pesticides that are safe to use, but without the ‘green light’ from federal government the funding and extensive studies have yet to be performed. For example: Colorado has a list and even offers a sign-up function to be notified of modifications to the list:

https://www.colorado.gov/pacific/agplants/pesticide-use-cannabis-production-information.

 

The documentation of pesticide use is addressed through the states that have legalized marijuana for sale. Marijuana must be tracked from seed to sale, and stringent records must be kept. This will only assist the process of validating and approving pesticides when they finally do go legal nationwide.

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.

 

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.

 

Sources & Links

 

[1] Schiller, Melissa. (2019, January 9). Cannabis Business Times. Purdue Researchers Tackle Cannabis Industry’s Pesticide Problem. Retrieved from:

https://www.cannabisbusinesstimes.com/article/purdue-researchers-cannabis-pesticide-problem/

[2]

https://ehp.niehs.nih.gov/doi/full/10.1289/EHP5265

EPA Pesticide Worker Safety

https://www.epa.gov/pesticide-worker-safety/requirements-pesticide-storage

National Pesticide Information Center

http://npic.orst.edu/health/storage.html

 

How High-End Dispensaries & Large-Scale Growers Drive Profits & Gain Competitive Advantages

Integrating Security Requirements, Video Surveillance & Data

As competition in the cannabis and marijuana markets increases, the keys to long term success for any cannabusiness point to operational efficiency, quality assurance, customer service, regulatory compliance and market penetration. With proper planning, the consultants and advisors at KL Security are setting the new standards for cannabis facility design and security by integrating security standards, data and video that results in greater business success.

Track product at your cultivation facility – RFID combined with video can tell you the last time a plant or cannabis product was seen

Top 4 Challenges a Cannabusiness faces to meet state-mandated requirements for surveillance:

  • – Camera types and placements
  • – Resolution and frame rates
  • – Retention periods and off-site storage
  • – RFID tag verification

 

How Video & Data Help Cannabusinesses at any level:

 In Cultivation Facilities

  • Tracking automation and a visual record of each plant’s location
  • How a plant may have been removed or misplaced and who was involved
  • Reveal where more staff training is required (improve operations & success)
  • Seamlessly share video and RFID data evidence with law enforcement

    Reduce your security risk, keep drivers safe, and maintain regulatory compliance for your state or municipality
  • Combined with access control systems, modular vaults, restricted access areas and storage rooms or cages, automated reports with video snapshots can show operators when shifts aren’t starting as scheduled, or find out why one product is taking longer to dry in one cultivation facility compared to the rest

Cannabis In Transit & Secure Transportation Services

  • View marijuana inventory as it’s loaded at the cultivation facility, as it is being transported, and as it is being unloaded at the retail dispensary locations
  • Integrate video with vehicle data, such as a GPS location or speed, to see information on the transport route from start to finish. This can provide proof that a vehicle has not accidentally crossed into a U.S. state where cannabis sale is still illegal

 At the Retail Dispensary

  • Video integrated with POS data can help dispensary operators cut losses by setting up alerts triggered by suspect transactions, such as voids over a set amount
  • Run searches across multiple dispensary locations simultaneously
  • Using video and analytics like people counting, queue length or dwell time, operators can see how long customers waited in line, of they spent more time in front of a certain promotional display, or if they left the dispensary without making a purchase

    Gather valuable metrics on operations and customer service

 

 

Tracking and Security of Cannabis Plants and Products through the Supply Chain to Retail Dispensary

 

How Business Analytics become Competitive Advantages

With a full view of the retail dispensary, it’s easier for companies to discover  customer trends that can be turned into higher profits, repeat business and brand loyalty.

Key Performance Indicators (KPIs)

  • See how many customers are in your store at any given time.
  • Determine conversion rates of walk-in traffic.
  • Identify the average number of people waiting in a line or queue, and average amount of time they waited.
  • Learn how long people dwell in a particular area of your dispensary such as display counters or in-store online order systems.
  • Establish KPIs, based on factors like:

— Which store turns more shoppers into buyers if you have multiple retail dispensaries

— The time or day that most people are waiting in line, and for how long (to measure customer service and implement staffing changes). Such as happy hours, Friday afternoon or evening, payday, start of the weekend and other key times of the week.

— The success of a particular end-cap or promotion that may be in effect through advertising campaigns or POS integrations with Weedmaps, Leafly, Wikileaf, Baker, springbig and others.

  • Export business analytics data to an Excel file to incorporate into your own charts and reports or CRM systems.

 

To learn more about standards for cannabis facility design and security, call 866-867-0306 today

 

 

 

Dispensary Security Cameras, State Compliance & Green Bits POS Integration

March Networks Cameras can integrate with Green Bits POS and other flavors of retail dispensary POS systems.

When it comes to marijuana dispensary security cameras and video surveillance requirements, every state has its own set of rules & regulations that must be met. Retail marijuana rules are stringent and a robust security plan and integration across platforms results in the best in class compliance, loss prevention and seed-to-sale tracking.

Dispensary Challenges

Video surveillance cameras & recorders to be fully compliant with state laws for monitoring, video retention requirements and any ingress/egress recording requirements for “no blind spots.” Additionally, the ability to review Green Bits POS transactions to ensure loss prevention.

  • Be Fully Compliant with State Marijuana Laws for Retail
  • Green Bits POS Integration, a leader in Cannabis Retail, for improved Loss Prevention
  • RFID Tracking of Cannabis Flower, Edibles, Shatter, Concentrates and CBD Products

Solutions

Retail Cannabis POS & Marijuana Dispensary POS Software Integration with video surveillance is a best choice when considering state laws for compliance requirements.

Full end-to-end security with March Networks dispensary camera systems based on square footage of the retail dispensary floor and back of house secure vault room.

  • High Capacity Recorder for 40+ Days of Video Data Retention
  • Multiple High-Resolution HD Cameras at ingress/egress, secured & limited access areas and parking lots for employee and customer safety.
  • SearchLight RFID Tracking for monitoring of all cannabis and marijuana products
  • Green Bits POS integration to cross reference all cash deposits and transactions
  • Door traffic counting system to measure walk in traffic to sales conversion rates with Green Bits POS

 

We can assist you with the complete security plan for your retail dispensary, growing facility, cultivation, processing or manufacturing of cannabis flowers and products. Robust security systems from March Networks are the best in class when you compare the pros and cons, prices and benefits for security cameras, surveillance and POS integration for the retail marijuana dispensary.

Dispensary POS Software | Retail Cannabis POS & Marijuana Dispensary POS Software Integration with video surveillance of entry and exit doors, the product floor and in some states face recognition capabilities.

Marijuana Regulatory Agencies by State

List of Marijuana Regulatory Agencies by State

July 26, 2019

Alaska: Recreational & Medicinal

Marijuana Control Office

Anchorage
Mailing/Physical Address

550 W 7th AVE, STE 1600
Anchorage, AK 99501

Phone: (907) 269-0350

https://www.commerce.alaska.gov/web/amco

Arizona: Medicinal

Arizona Department of Health Services
150 North 18th Avenue
Phoenix, Arizona 85007

(602) 542-1025
Fax: (602) 542-0883

https://azdhs.gov/licensing/medical-marijuana/index.php

 

Arkansas: Medicinal

Arkansas Medical Marijuana Commission

4815 W. Markham

Little Rock, AR 72205-3867
1-800-462-0599

https://www.mmc.arkansas.gov/

 

California: Recreational & Medicinal

Bureau of Cannabis Control
Address:

2920 Kilgore Road
Rancho Cordova, CA 95670

Mailing Address:
PO Box 419106
Rancho Cordova, CA 95741-9106

Phone: (833) 768-5880

bcc@dca.ca.gov

https://bcc.ca.gov/

 

Colorado: Recreational & Medicinal

Department of Revenue: Marijuana Enforcement
1707 Cole Blvd., Suite 300
Lakewood, CO  80401
303-866-3330

https://www.colorado.gov/pacific/enforcement/marijuanaenforcement

 

Connecticut: Medicinal

Department of Consumer Protection: Medical Marijuana Program

450 Columbus Blvd.
Suite 901
Hartford CT 06103
860-713-6100

https://portal.ct.gov/DCP/Medical-Marijuana-Program/Medical-Marijuana-Program

 

Delaware: Medicinal

Department of Public Health: Medical Marijuana Program

258 Chapman Rd, Newark, DE 19702

(302) 283-7100

https://dhss.delaware.gov/dhss/dph/hsp/medmarhome.html

 

Florida: Medicinal

Department of Health
Office of Medical Marijuana Use
4052 Bald Cypress Way, Bin M-01
Tallahassee, FL 32399

800-808-9580

MedicalMarijuanaUse@flhealth.gov

 

Hawaii: Recreational

Department of Health

Medical Cannabis Program

1250 Punchbowl Street
Honolulu, Hawaii 96813
(808) 586-4400
Fax: (808) 586-4444

https://health.hawaii.gov/medicalcannabis/

 

Illinois: Recreational & Medicinal

Illinois Cannabis Programs

Chicago:

100 West Randolph, 9th Floor

Chicago, IL 60601
Springfield

320 West Washington, 3rd Floor

Springfield, IL 62786

1 (888) 473-4858

https://www.idfpr.com/ILCannabis.asp

 

Louisiana: Medicinal

Department of Agriculture & Forestry: Medical Marijuana Program

5825 Florida Blvd
Baton Rouge, LA 70806

1.866.927.2476

http://www.ldaf.state.la.us/medical-marijuana/

 

Maryland: Medicinal

Maryland Medical Cannabis Commission

849 International Drive, 4th Floor

Linthicum, MD 21090

1-844-421-2571

https://mmcc.maryland.gov/Pages/law.aspx

 

Massachusetts: Recreational & Medicinal

Cannabis Control Commission

101 Federal St, 13th floor

Boston, MA 02110

617-701-8400
CannabisCommission@State.MA.US

 

Michigan: Recreational & Medicinal

Ottawa Building
611 W. Ottawa
P.O. Box 30004
Lansing, MI 48909

517-335-9700

https://www.michigan.gov/lara/0,4601,7-154-89334_79571—,00.html

 

Minnesota: Medicinal

Department of Health

P.O. Box 64975
St. Paul, MN 55164-0975

888-345-0823

https://www.health.state.mn.us/people/cannabis/index.html

 

Montana: Medicinal

Montana Medical Marijuana Program

PO Box 202926
Helena MT 59620
(406) 444-0596
(406) 444-4110 (Fax)
mtmarijuanaprogram@mt.gov

https://dphhs.mt.gov/marijuana

 

Nevada: Recreational & Medicinal

Department of Taxation

Grant Sawyer Office Building

555 E. Washington Ave, Suite 1300

Las Vegas, NV 89101

(702) 486-2300 (Phone)

(702) 486-2373 (Fax)

marijuana@tax.state.nv.us.

http://marijuana.nv.gov/

 

New Hampshire: Medicinal & Decriminalized (not legal for recreational sale)

New Hampshire Department of Health and Human Services
129 Pleasant Street

Concord, NH 03301-3852
(603) 271-9333

https://www.dhhs.nh.gov/oos/tcp/

 

New Jersey: Medicinal

Medical Marijuana Program

Department of Health
P. O. Box 360
Trenton, NJ 08625-0360

https://www.nj.gov/health/medicalmarijuana/program-rules/

 

New Mexico: Medicinal

Mailing Address
Department of Health
Medical Cannabis Program
PO Box 26110
Santa Fe, NM, 87502-6110
medical.cannabis@state.nm.us

Physical Address
Medical Cannabis Program
1474 Rodeo Rd., Suite 200
Santa Fe, NM 87505

505-827-2321 (Phone)
505-476-3025 (Fax)

https://nmhealth.org/about/mcp/svcs/info/

 

New York: Medicinal

Department of Health

Medical Marijuana Program

90 Church St

New York, NY 10007

844-863-9312

mmp@health.ny.gov

https://www.health.ny.gov/regulations/medical_marijuana/regulations.htm

 

North Dakota: Medicinal & Decriminalized (not legal for recreational sale)

Department of Health

Division of Medical Marijuana

600 East Boulevard Ave., Dept. 301
Bismarck, ND 58505-0200

701.328.1311

Fax 701.328.1333

medmarijuana@nd.gov

https://www.ndhealth.gov/mm/

 

Ohio: Medicinal

Ohio Medical Marijuana Control Program

Department of Commerce77 South High Street, 23rd Floor
Columbus, OH 43215-6123

614-466-3636

https://www.medicalmarijuana.ohio.gov/

 

Oklahoma: Medicinal

Oklahoma Medical Marijuana Authority
PO Box 262266
Oklahoma City, OK 73125-2600

http://omma.ok.gov/rules-regulations

 

Oregon: Medicinal & Recreational

Recreational Marijuana Program

https://www.oregon.gov/olcc/marijuana/Pages/default.aspx

Oregon Medical Marijuana Program (OMMP)
PO Box 14450
Portland, OR 97293-0450

971-673-1234

ommp.info@dhsoha.state.or.us

https://www.oregon.gov/oha/ph/DiseasesConditions/ChronicDisease/MedicalMarijuanaProgram/Pages/index.aspx

 

Pennsylvania: Medicinal

Pennsylvania Medical Marijuana Program

625 Forster Street
Harrisburg, PA 17120

717-787-8015

RA-DHMedMarijuana@pa.gov

https://www.health.pa.gov/topics/programs/Medical%20Marijuana/Pages/Medical%20Marijuana.aspx

 

Vermont: Medicinal & Recreational

Vermont Marijuana Registry
45 State Drive
Waterbury,  VT  05671-1300
Tel: (802) 241-5115
Fax: (802) 241-5230
DPS.MJRegistry@vermont.gov

https://medicalmarijuana.vermont.gov/

 

Washington: Recreational & Medicinal

Washington State Liquor and Cannabis Board

1025 Union Avenue SE
Olympia, WA 98504

(360) 664-1600

https://lcb.wa.gov/

 

West Virginia

Bureau for Publlic Health

Office of Medical Cannabis
Room 702
350 Capitol Street
Charleston, WV 25301
Phone:(304) 558-2971
Fax:(304) 558-1035

https://dhhr.wv.gov/bph/Pages/Medical-Cannabis-Program.aspx

 

 

 

Marijuana Business Licensing in Illinois

On January 1, 2020, marijuana will be legal for adult use in Illinois. While residents and neighbors of Illinois may be counting the days, dispensaries and growers are trying to plan for demand.

“…55 existing stores will have to meet the demands of a 13 million-person state with a massive tourist population.” [1]

The current medical cannabis structure serves roughly 70,000 residents. Even if only a quarter of the population decides to partake in the newly legal activity, that’s an additional 3.18 million people. That number doesn’t consider tourists (and/or neighbors to Illinois).

“…our tourism industry welcomes more than 110 million visitors per year, who spend billions of dollars annually.” – Illinois Office of Tourism [2]

What does this mean for entrepreneurs looking to open their own marijuana growing, cultivation, processing or Illinois dispensary business?

Businesses currently operating under a medical marijuana license are going to be able to remain in operation and sell recreationally. These existing businesses are also granted an additional location under their current license.

Applications for new dispensaries are due no later than January 1, 2020. Illinois has until May 1, 2020 to either approve or deny an application. The license awarded from this round is conditional or a pre-license. An establishment must then pass inspection and pay all fees to receive their final licensing to sell marijuana product.

“Non-Social Equity Applicants will pay a $5,000 application fee. Should they be awarded a license, the fee for an Adult Use Dispensing Organization License is $60,000 for a two-year license. Social Equity Applicants will pay a $2,500 application fee. Should they be awarded a license, the fee for an Adult Use Dispensing Organization License is $30,000 for a two-year license.” [3]

Applicants should begin collaborating with industry consultants now to ensure construction of the dispensary occurs quickly and efficiently. Detailed plans for every facet of the business are required within the conditional application, and must be adhered to during implementation. This is where industry experts come into play.

KL Security has successfully developed and implemented security measures for multiple marijuana dispensaries and secure cannabis facilities in multiple states. Our security experts are knowledgeable and eager to assist your business in developing a one of a kind plan to best suit your needs.

ArmorStor™ MJ7840D Controlled Substance Vault Door with Day Gate   Our Vault Doors are manufactured to meet GSA Approved Class 5 Ratings and in their native form are used by the US Government for the storage of Classified Information as well as items such as weapons, ammunition, narcotics, etc.  The sale of the standard doors is restricted however, to only the US Government and Military.  GSA now allows us to market the exact same door, without the GSA Approved Label, to the private sector. 

   

Restricted Access Approved Vaults

Prevent diversion, theft or loss of medical marijuana at a dispensary with UL Class 1 rated vaults. Our modular vaults are a fraction of the cost of a poured concrete vault and are fully scalable to your business growth. These vaults are in place in multiple states for DEA or pharmacy board approved applications.

Access Control & Entry Doors

BR Glass for retail dispensary locations and safety, we have you covered.

Locking entry door barriers for secure rooms and limited access for key employees that can be monitored with video surveillance to meet any potential codes for cannabis dispensaries and retail marijuana locations.

 

 

 

TOLL FREE 1-866-867-0306 OR contact@klsecurity.com

 

SOURCES

[1] Krane, Kris. (2019, June 25). Forbes Magazine. Illinois Legalization Is Historic, But Good Luck Finding Cannabis To Buy. Retrieved from:

https://www.forbes.com/sites/kriskrane/2019/06/25/illinois-legalization-is-historic-but-good-luck-finding-cannabis-to-buy/#4d59bb65e253

[2] https://www2.illinois.gov/dceo/AboutDCEO/Pages/Tourism.aspx

[3] https://www.idfpr.com/FAQ/AUC/FAQ%20-%20Adult%20use%20license%20for%20new%20dispensing%20organizations_.pdf

DEA Rules, security requirements and regulations per the Code of Federal Regulations 21CFR1301.72

Information has been gathered from sources deemed reliable but not guaranteed and is subject to change without notice.

All license information found at the website for the Illinois Department of Financial and Professional Regulation: https://www.idfpr.com/profs/adultusecan.asp

 

 

The Oklahoma Obstacle: Cash Management and Marijuana Sales

“Oklahoma is the fastest-growing medical marijuana market in the average number of daily patient increases, and MMJ patients represent 4.1% of the state’s total population – one of the highest rates in the nation.” [1]

Image taken from: https://mjbizdaily.com/medical-marijuana-market-growth-with-oklahoma-and-florida-leading/ 

Who would have thought? Oklahoma is the fastest growing market for medical marijuana sales. Their legislation, whether consciously or not, is set up to do primarily just this. The barriers to entry for cannabis businesses are fairly easy and obtainable (as far as marijuana establishment regulations go). The license application is a mere $2,500 for medical marijuana dispensaries, commercial growers, and processors (Okl. Title 63, Ch. 15, Medical Marijuana). This should make it possible for smaller mom and pop retail dispensary, grower or cash in transit (Oklahoma legislation also dictates that a separate ‘transportation’ license must be obtained to “to transport marijuana from an Oklahoma licensed medical marijuana retailer, licensed growing Facility, or licensed processor Facility to an Oklahoma licensed medical marijuana retailer, licensed growing Facility, or licensed processing Facility.” Okla Stat tit. 63, 424) establishments to do business in the marketplace.  Also, there’s no list of required medical conditions for patients to suffer from prior to obtaining their medical license; it would appear that if an Oklahoman ‘patient’ applies for a medical marijuana license for use, they will probably be approved.  

 

This is all great news for Oklahoman entrepreneurs planning to set up shop and open legal cannabis establishments. Millions of dollars will be pouring in to these establishments from card carrying patients, but these patients will be paying in cash. Marijuana is still considered an illegal drug as per Federal law. Most credit card companies will not allow transactions at marijuana establishments, Visa has explicitly stated they will not permit any transactions involving marijuana on their credit network [2]. This means Oklahoman businesses are going to be faced with the challenge of handling mass amounts of cash.  

Canna Cash Smart Safes The SecureCash smart safes are a state-of-the-art solution designed specifically for cannabis dispensary cash management. Focused on simplicity and security, the unit is ideal for cannabis point-of-sale and under-counter installations. Retail businesses experience up to 55% savings in time spent on cash counting, tills & daily cash deposits with Smart Cash Safes

The marijuana industry is estimated at nearly $9 billion in sales, and “…expected to grow to $50 billion in just a few years…” [3] most of those sales being completed in cash. The amount of cash exchanging hands presents abundant opportunities for security issues. A standard old-fashioned till is not going to suffice in a successful Oklahoma cannabis dispensary. 

In addition to security concerns, business owners must adhere to state regulations. The state of Oklahoma requires all marijuana establishments to keep business records (including those pertaining to cash transactions) for seven years for auditing purposes (2018 OK Regulation Text 19159). Cash management software will be the easiest way to meet this requirement. 

 

Cash Management Software for Retail Cash Management Safes  Dispensary

Cash levels can be monitored in real time and end-of-day accounting is performed automatically without the need for employees to manually count cash. Retailers can even monitor the amount of cash collected by CIT across a chain of stores. CashControl’s reporting tools help optimize performance and ensure that in-store security routines are being followed. In addition, technicians can use the application to remotely maintain, update and service SafeCash Retail machines, which means increased uptime and a more reliable closed cash handling process. 

 

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 for DEA federal guidelines for Vaults, Safes and retail cash management.

 

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 Oklahoma legislation: OAC 310:681 & Okl. Title 63, Ch. 15, Medical Marijuana & Okla Stat tit. 63, 424.

Sources: 

[1] Cowee, Maggie. (2019, August 13). Marijuana Business Daily. Medical marijuana markets expanding at varying rates, with Oklahoma, Florida setting the pace.

Retrieved from: https://mjbizdaily.com/medical-marijuana-market-growth-with-oklahoma-and-florida-leading/

[2] Sommer, Constance & Mims Caitlin. (2019, June 18) Paying with cards at marijuana dispensaries? It’s complicated.

Retrieved from: https://www.creditcards.com/credit-card-news/marijuana-dispensaries-pay-with-credit-cards.php

[3] Murphy, Kevin. (2018, September 6). Forbes. Legal Marijuana: The $9 Billion Industry That Most Banks Won’t Touch.  Retrieved from: https://www.forbes.com/sites/kevinmurphy/2018/09/06/legal-marijuana-the-9-billion-industry-that-most-banks-wont-touch/#6a3d49013c68

Helpful Links:
Code of Federal Regulations: Title 21

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

OMMA: Oklahoma Medical Marijuana Authority

http://omma.ok.gov/

Legislation: 

http://omma.ok.gov/rules-regulations

 

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.