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

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

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

As a premier partner of Total Harvest Coverage (THC360) we help leading cannabis entrepreneurs and businesses with security plans and integration to stay compliant.

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 recreational cannabis. These existing businesses are also granted an additional location under their current license.

 

Security Plans & Architectural Planning

Success in the cannabis market depends on a solid business plan & security plan that is designed to maintain compliance, meet regulatory standards and optimize business operations. Leading cannabis companies utilize the Total Harvest Coverage method to plan, grow and scale their business security.


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, learn more about Security Plans and cannabis facility design 

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 [email protected]

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 Source 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.  

SSPOS Smart Safe point-of-sale-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. 

When properly implemented, a cannabis security plan utilizing SSPOS and intelligent video surveillance can help drive revenue and create opportunities for a cannabis dispensary to become more profitable. As a premier partner of Total Harvest Coverage, we help cannabis growers, processors, transportation and dispensaries with integrated security that maintains compliance.

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. 

Setting the Standards for Cannabis Facility Design Security & Operational Protocols

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

[email protected]

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

UPDATE:

February 13, 2020–In August 2019, State Representative Jason Nemes was optimistic about the potential success of a bill he co-sponsored. This bill, House Bill 136, would legalize marijuana for medicinal use in Kentucky.

 

Yesterday (Wednesday, February 12, 2020), HB 136 passed the House Judiciary Committee 17-1. The bill now moves on to the House of Representatives, where Nemes expects it to pass.

 

“We won the battle in the House committee,” Nemes said. “It’s almost, pretty much over in the House of Representatives. Now we’ve got to let our senators understand where you are and educate them on the bill.”  – Jason Nemes1

 

Sources & Helpful Links

  1. Desroches, Daniel. February 12, 2020. Medical Marijuana bill clears KY House panel, gains momentum heading into House vote. Lexington Heard Leader. Retrieved from: https://www.kentucky.com/news/politics-government/article240232736.html

Kentucky House Bill 136

https://apps.legislature.ky.gov/record/20rs/hb136.html

___________________________________

August 16, 2019 –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]

as a premier partner of Total Harvest Coverage, we help businesses with security plans, architectural planning and programming and design of compliant solutions for cannabis facilities.

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?

A recent story posted by High Times, indicates that even though cannabis remains illegal in Kentucky, the state has the highest per capita rate of plants destroyed by the DEA. Approximately 80 percent of voters in the State of Kentucky favor reform or legalization of cannabis and marijuana plants and products. Kentucky house bill HB 136 would provide for improved access for medicinal marijuana. Security plans and requirements have yet to be released or published as of this article.

In other news, Hempwood and hemp processing facilities are up and running in Murray, Kentucky

 

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

Deter Diversion & Theft with Security Planning and Cannabis Facility Design Standards

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

[email protected]

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

[email protected]

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

[email protected]

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

as a partner of the Total Harvest Coverage network, we assist cannabis facilities with designs, plans and deployment of compliant solutions to help them become more successful.

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.

For more information on cannabis security plans and facility design, architectural programming and more, call 1-866-867-0306

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.
Offering solutions for Business Continuity & Disaster Recovery planning of records management as part of your cannabis security plan and design.

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.

 

Effective electronic record management is vital to the efficient operation of any modern business; “An investment in ERM (Electronic Record Management) is an

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.

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.  With sufficient cannabis security planning and programming your facility will be ready for license and compliance

TOLL FREE 1-866-867-0306

[email protected]

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. 

    Implementing Total Harvest Coverage to maintain compliance with state laws and regulatory requirements is key to the best security planning and protocols that deter diversion and theft.

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.

Learn more about Marihuana facility design standards, security compliance and planning

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

THC360’s approach to integrated security plans, compliance with state laws and maximize business revenues is part of the leading cannabis companies success and growth plans. As a premier partner of Total Harvest Coverage, we believe in designing best in class plans for your cannabis facility or transportation fleet.

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

[email protected]

 

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

Head Office: Seattle, Washington

Phone: (206) 204-3205

Fax: (206) 204-3252

[email protected]

 

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

[email protected]

 

Arkansas, Louisiana, and Mississippi

Head Office: Metairie, Louisiana

Phone: (504) 841-7000

Fax: (504) 841-7039

[email protected]

California (northern) and Nevada

Head Office: Dublin, California

Phone: (925) 557-2800

Fax: (925) 557-2805

[email protected]

 

California (Los Angeles)

Head Office: Glendale, California

Phone: (818) 265-2500

Fax: (818) 265-2501

[email protected]

 

Colorado, Montana, Utah, and Wyoming

Head Office: Denver, Colorado

Phone: (303) 575-7600

Fax: (303) 575-7601

[email protected]

 

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

[email protected]

 

Florida (Miami)

Head Office: Miami, Florida

Phone: (305) 597-4800

Fax: (305) 597-4801

[email protected]

 

Florida (Tampa)

Head Office: Tampa, Florida

Phone: (813) 202-7300

Fax: (813) 202-7301

[email protected]

 

Georgia

Head Office: Atlanta, Georgia

Phone: (404) 417-2600

Fax: (404) 417-2601

[email protected]

 

Illinois

Head Office: Chicago, Illinois

Phone: (312) 846-7200

Fax: (312) 846-7201

[email protected]

 

Indiana and Ohio

Head Office: Columbus, Ohio

Phone: (614) 827-8400

Fax: (614) 827-8401

[email protected]

 

Iowa, Kansas, Missouri, and Nebraska

Head Office: Kansas City, Missouri

Phone: (816) 559-0700

Fax: (816) 559-0701

[email protected]

 

Kentucky and West Virginia

Head Office: Louisville, Kentucky

Phone: (502) 753-3400

Fax: (502) 753-3401

[email protected]

 

Michigan

Head Office: Detroit, Michigan

Phone: (313) 202-3400

Fax: (313) 202-3445

[email protected]

 

Minnesota, North Dakota, South Dakota, and Wisconsin

Head Office: St. Paul, Minnesota

Phone: (651) 726-0200

Fax: (651) 726-0201

[email protected]

 

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

[email protected]

 

North Carolina and South Carolina

Head Office: Charlotte, North Carolina

Phone: (704) 716-1800

Fax: (704) 716-1801

[email protected]

 

Oklahoma and Texas (northern)

Head Office: Dallas, Texas

Phone: (469) 227-4300

Fax: (469) 227-4330

[email protected]

 

Pennsylvania

Head Office: Philadelphia, Pennsylvania

Phone: (215) 446-7800

Fax: (215) 446-7811

[email protected]

 

Texas (southern)

Head Office: Houston, Texas

Phone: (281) 716-8200

Fax: (281) 716-8219

[email protected]

 

Virginia and District of Columbia

Head Office: Washington, DC

Phone: (202) 648-8010

Fax: (202) 648-8001

[email protected]