Missouri Security Measures for Medicinal Marijuana Facilities

Planning for Medical Marijuana & Potential Recreational Cannabis Requirements

Security is a facet of consideration of any new business, especially those within the cannabis industry. Marijuana is currently purchased almost exclusively with cash, and has a high resale market value through illegal means. For these reasons, significant safeguards must be established to protect product and profit.

Key Considerations for Missouri Cannabis Facilities & Retail Dispensaries

  • Develop Protocols to Deter Diversion & Crime
  • Maintain Compliance with reporting sales, diversion & evidence for law enforcement
  • CPTED (crime prevention through environmental design)
  • Exterior Security Protocols
  • Interior Security Protocols
  • Plans for Security Cameras, Intelligent Video Surveillance
  • Prevention of Theft of Product & Cash
  • And many more.

This would lead an entrepreneur to infer that state regulations regarding security provisions for marijuana facilities would be explicit and detailed, but the contrary is true for Missouri. The legislation is vague in regards to physical security, and there is no detailed protocol for construction or building security requirements. It could be inferred that this is due to the illegal status of the product at the federal level. If (when) cannabis is legalized at a national level, states would need to revise legislation, guidelines, forms, administrative materials, protocols for diversion, etc. to meet these federal demands upon implementation. If a state does not address these provisions specifically, the legislation will be easier to amend when the time comes.

Facilities shall install and maintain security equipment designed to prevent unauthorized entrance into limited access areas and to prevent diversion and inversion of medical marijuana: 2019 MO Regulation Text 25597

Within the facility application, a business must describe verbally what measures to be implemented. At the schematic planning and architectural programming phases, this plan is vital to long term business success. Attachments/visuals are not accepted. The assistance of a security expert is incredibly beneficial within the preparation of this portion of the application. The cannabis facility security plan developed within the application MUST be adhered to after the issuance of a license (unless otherwise authorized by the Missouri Department of Health and Senior Services). Veering from the original plan would cause numerous delays and potentially incur fines and or financial consequences.

Luckily, there are industry experts that have experience with securing product on par with federal regulations. If stringent guidelines are imposed at the point of planning, the likelihood of changes needed afterwards is much lower. By using federal guidelines in place for the storage and handling of highly regulated products, a business owner can rest assured that they will meet or exceed federal guidelines when they are established.

4 Factors to Success for Marijuana Business in Missouri

  1. Proper Planning – Business Strategy & Security Plans / Safety Plans
  2. Maintain Compliance with State Laws & Regulations
  3. Optimize Business Operations for growing revenue
  4. Continual Improvement

Consulting and Planning for Missouri Cannabis Facilities

At KL Security we utilize the Total Harvest Coverage™ methodology for security plans as well as cannabis business operation improvements. With successful projects in facilities in multiple states we help leaders in the cannabis industry drive revenue and stay compliant with state laws.

  •             Developing Protocols for Business Operations
  •             Integration of Video Surveillance, SSPOS and Cannabis Software
  •             Cash Management Process
  •             Monitoring and tracking of plants, products and closing the loop at point of sale
  •             Schematic Design & Development from Architectural Planning through Construction

We work with leading architects, interior designers and construction management firms to ensure projects are completed from start to finish. With an established track record of completed facility designs, we set the standard for growing, cultivation and retail dispensary for medical and recreational marijuana plans, layouts and project management.

 

Information has been gathered from sources deemed reliable but not guaranteed and is subject to change without notice. Legislation referenced within this article: 19 CSR 30-95.040

 

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

 

 

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/

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

 

 

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