Cannabis has been legal in California for recreational use since late 2016. This has triggered a wave of entrepreneurs looking to start their own businesses, but California has strict security and access control requirements for opening a cannabis dispensary. Follow these rules and you will be most of the way there.
Please note: This article does not constitute legal advice. Please refer to the complete cannabis requirements document for California or consult counsel.
Access Control for Cannabis Businesses
It’s crucial to set up a robust access control system for your cannabis business to ensure compliance with established statewide regulations and guidelines.
Access Control Rules
- Ensure that only the business licensee or their authorized employees can access the premises
- Authorized individuals may include outside vendors, contractors, and other people conducting business who require access to restricted areas
- Any unauthorized individual must be escorted by an employee at all times
- The business owner must keep complete records of everyone authorized to access the premises, including: name, company, reason for access, dates of access, time when the person entered and exited the restricted area.
- All restricted areas should have a solid door and a lock. This door should remain closed when not in use during regular business hours.
Key Card Badge Requirements
While an employer can choose any form of access control system, such as key cards, mobile access control, or biometrics, state regulations require that, at all times when engaging in commercial cannabis work, every employee carry a laminated or plastic coated ID badge issued by the business owner.
Here are the requirements for display badges for cannabis businesses:
- Every person should carry a visible badge issued by the employer
- The badge should include employee’s first name
- The badge should display the business name or the “doing business as” name
- The badge should include the employer’s cannabis license number
- The badge should contain the unique employee number
- The badge should have a color photograph of at least 1 inch width and 1.5 inch height that clearly shows a front view of the employee’s face
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Video Surveillance Requirements
- Video surveillance system resolution must be at least 1280 x 720 pixels
- The system should be on all the time and clearly record images of the restricted areas
- Cameras should be permanently mounted
- The system should be able to record activity occurring without 20 feet of all points of entry and exit of licensed premises
- Cameras footage should be able to clearly identify people and activities that are required to be filmed as per the regulations
- Cameras should be working 24 hours a day, at minimum of 15 frames per second
- The storage media for cameras need to be secured from tampering or theft
- Footage should be stored for at least 90 days
- Surveillance footage should be accessible by the California Bureau of Cannabis Control, so it can be accessed immediately upon request. The Bureau might require a copy of recording if requested.
- All images should contain timestamps
- The system should have failure alerts in case of any issues
Areas That Need Video Surveillance
- Areas where cannabis goods are weighed, packed, stored, loaded, unloaded for transportation, preparation and moving within the premises
- Limited-access areas
- Security rooms
- Areas like server rooms that store the video surveillance footage; there should be a camera that monitors the doors leading into the server rooms
- Entrances and exits to licensed premises
- All point of sale areas and display areas
Sharing Video Surveillance Across Multiple Cannabis Businesses
In certain cases, if you are running multiple licensed cannabis businesses in the same facility, you might have additional requirements for sharing. For example, when a business owner has multiple licenses for different brands occupying the same building, the owner needs to ensure that:
- Each licensee maintain premise diagrams that depict the area that belongs to that specific licensee
- Each licensee diclosess where their specific video recordings are stored
- Each applicant mentions in their license application how the video surveillance system is stored, who is responsible for monitoring the video footage and storing video clips.
- All licensees have access to the video surveillance system at any time. The business should be able to present the footage to the Bureau immediately upon request.
All the licensees are responsible for any violations of these requirements by any other licensee(s).
Requirements for Hiring Security Guards
- The security guard must be at least 21 years of age
- If there is no storefront or display of goods, the business might not be required to hire a security guard
- All entrances to a cannabis business, as well as all limited-access areas, should be secured using commercial grade locks
- Residential-grade locks are prohibited
Alarm System Requirements
- Only a licensed alarm company operator or its licensed agents may install, monitor and respond to alarms
- The Bureau may request a license for the alarm company, which should be kept on hand at the cannabis business
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