The State of Maryland will soon usher in regulatory changes designed to boost security at marijuana businesses while reducing implementation headaches and costs.
The sweeping changes to cannabis security arrive on September 1 as the state clarifies off-site video archiving requirements. The revised regulations no longer require licensees to store video surveillance recordings at both the licensed premises and at an off-site location. Now licensees can choose whether to store video on-site or off-site.
Previously, state regulators interpreted the law for off-site archiving of video footage “to mean simultaneously recorded,” states Tim Sutton, a senior security consultant and cannabis security practice leader at Guidepost Solutions.
Sutton, who has 30 years of security experience and is a noted subject matter expert in the cannabis industry, explains licensees originally needed to record video on-site and off-site and keep it for 30 days. “Businesses could not record video on-site then pipe it over, it had to be simultaneous. That meant companies needed a dual server and storage. You had to spend the money twice,” Sutton says. “Cameras cost money too, but when you’re recording a sizeable amount of video, your server has to have some power and your storage takes up some space.”
Meeting this requirement added $20,000 to $40,000 to a project, according to Sutton. The security consultant recalls meeting this requirement in a large cultivation center by adding a steel container on a concrete pad 50 yards from the main building. “We piped fiber underneath to connect the two,” he says. “It cost us a fortune, but that’s what the law required.”
On another project, Sutton met the dual storage mandate by simultaneously storing video on-site and in the cloud through RTLS. “This solution would not work with a cultivation center, however, because you’re looking at too much bandwidth,” he says.
Other Regulatory Shifts
Maryland’s regulatory changes also mandate keeping video surveillance footage for 90 days instead of 30 as of September 1. Licensees also must make video surveillance recordings available upon request to the Maryland Medical Cannabis Commission (MMCC) or law enforcement within 48 hours.
The laws going into effect also set new surveillance coverage requirements for growers, processors, and dispensaries.
Growers: Maintain video surveillance at the entrance to and within each area where the business trims, packages and stores medical cannabis.
Processors: Maintain video surveillance at the entrance to and within each area where the business processes, packages, and stores medical cannabis.
Dispensaries: Maintain video surveillance at the entrance to and within each area where the company packages, stores or dispenses medical cannabis.
Maryland law requires a high-quality HD video system capable of capturing facial details. The state expects security cameras that record by motion detection to ensure cameras record and store any movement within range.
“There law lacks specifics about frame rate or resolution, but both resolution and frame rate affects the usefulness of an image from a camera,” Sutton says.
The regulations get specific about camera placement, areas to cover, continuous recording, recording on motion, etc. The law demands capturing activity at every entry and exit and installing surveillance cameras in areas where the business packages, tests, processes, stores, and dispenses medical marijuana.
“There must be camera coverage in any area that has a green leaf in it,” Sutton says. “Any room that contains plant material must have coverage at the entrance and inside. The law states the cameras must ‘record all activity in images of high quality and high resolution capable of clearly revealing facial detail.’”
Sutton adds, “What I do is use up to a 5-megapixel camera inside an entrance and right outside the entrance. This camera captures a good enough image to identify someone as they enter. If you can identify them at the front door, you can find them anywhere else in the building any time you want [on the other security cameras]. It doesn’t mean you have poor quality video everywhere else, but it means you’re not spending a ton of money making every camera super high resolution.”
However, area lighting, angle of incidence, and the camera’s ability to react to lighting and backlighting also factor into camera selection, he says. These capabilities impact the quality of facial details. For example, with a backlit subject, his face may be too dark to clearly identify. If you place cameras too high up, a baseball cap will block facial features.
Cannabis operators must carefully consider camera placement, adds Sutton, who notes that if a camera records a room from a single corner, it may not see the entire room. The room may need cameras in two corners. A vault may need a camera in every corner and a 360-degree camera in the middle. “You want to cover the entire space,” he says.
Licensees must operate the surveillance camera system 24-hours a day, 365 days a year without interruption, with accurate date and time stamps. Sutton recommends a network time server to ensure the system stays operational during power outages.
“Maryland requires a date and time stamp on every recorded frame,” he says. “Many systems affix the date time stamp to the video as part of the metadata. It’s not on the video itself, and it’s only viewable when you play it on a proprietary player. If you play it on Windows Media Player, it will not show the date time stamp.”
To meet Maryland’s requirement, Sutton says, “you must turn on the date and time stamp feature on each camera, which will display the date and time on the camera itself and on every frame as it records. That poses a problem because when you have 150 cameras, you can easily have 150 different times unless you have a network time server and sync the cameras up with that.”
The state limits video security system access to the property owner and trusted staff members and requires law enforcement and MMCC access upon request.
Sound the Alarm
Maryland requires an alarm system for the building and a separate alarm system in video storage areas. It also requires panic alarms throughout the facility.
“The alarm system in the video storage area must be a separate and unique alarm system from the building,” Sutton says. “The state also puts this requirement on the cabinet or room that holds medical cannabis. This means you need two systems and they should be from two different vendors just like a jewelry store.”
The law requires backup power to keep alarm systems operational for 48 hours during a power outage. Facilities require smoke and fire alarms at all perimeter entry points and portals. Maryland requires operators to protect perimeter portals, which Sutton says involves using motion sensors in rooms with perimeter walls and glass break sensors for every perimeter window.
Maryland requires licensees to track people entering and leaving the building. Licensees need to badge agents and scan visitor driver’s licenses and ask them to sign a log. The state does not require escorts for visitors, but licensees should track them by a video camera, Sutton says.
The law only requires keyed locks, but Sutton recommends a mix of keyed and electronic locks. “You do not need to control every door electronically, but your entrance should be electronic as should your restricted areas, like your vault or anywhere where there will be plants. Your lab, your kitchen, your grow room do not have to be electronic, but I would make them electronic. This lets you control who goes in and provide an audit trail in for an investigation.”
Securing cannabis operations well involves a mix of surveillance cameras, access control, and alarms as well as security management and security operations plans utilizing these technology tools. Savvy licensees know and understand the recent changes to Maryland law and do what it takes to implement them. Meeting the new requirements improves security at a reduced cost.
About the author: Patrick Chown is the owner and president of security system integrator, Safe and Sound Security, and the president of Seed to Sale Security, a national brand serving the cannabis industry. Seed to Sale Security offers security system installation, cannabis security plans, and cannabis security consulting to cannabis companies.