PAY ATTENTION TO THESE 5 AREAS TO PASS HEALTH CANADA’S MARIJUANA SECURITY INSPECTION
Medical marijuana is a new industry in Canada. Both investors and operators are faced with many security challenges in setting up facilities to produce this medical product.
There is a simple reason for this: a medical marijuana processing plant is not that different security wise from a casino or a bank.
Health Canada, the nodal body in charge of issuing licenses to Licensed Providers, simply borrowed the security best practices that are applicable to areas where high value and easy to carry items are present.
Security requirements according to the law
Medical marijuana producers are governed by the Marijuana for Medical Purposes Regulations (MMPR) regime. These rules cover everything, from how to apply for licensing to shipping out the finished product.
Division 3 of the Regulations deals with the security specific sections.
Because marijuana is not legal for recreational use in Canada, storage of medical marijuana is governed by Health Canada’s Directive On Physical Security For Controlled Substances. Appendix C of this Directive lays down 11 levels of security for storage of controlled substances, with level 11 being the most stringent.
This document, along with a guidance document gives applicants, investors, operators and other stakeholders enough information on designing foolproof systems that pass Health Canada’s stringent security inspections.
Security design principles
Here is a quick summary of the points to keep in mind while designing for security:
1) Results of risk analysis- Every site has a different risk profile depending on proximity to high- risk areas. Some areas historically have a higher incidence of break-ins and thefts. So, if a producer plans a medical marijuana facility in that area, security levels would have to be comparatively higher than a location with lower risk.
2) Balancing security needs and operational requirements- Securing a facility spread over thousands of square feet involves imposing a number of restrictions on movement that could hamper the efficiency of workers. At the same time, being too lax is not an option, as that could encourage pilferage and theft. Thus, right from the blueprint stage the security system should be able to balance these two extremes while also being resistant to obsolescence.
3) Implementing Rings of Protection – While storing potentially illicit and valuable substances like medical marijuana, the ring of protection concept in terms of security can provide the maximum deterrence. Essentially, this strategy focuses on putting a number of barriers, such as alarms, cameras, fences, locks and vaults between the intruder and the target. When complemented with responsive law enforcement machinery, this system can be highly effective in curbing robberies.
Implementing these rules in real life
According to updated MMPR rules, only those licensed providers who are at Level 7 security and above can grow and sell medical marijuana. Here are some general recommendations
1) Physical access- Sections 41, 42 and 47 of MMPR deal with regulations around securing your site. A 10 feet tall security fence topped with barbed wire should be the outer perimeter of the site. Appropriate signage should indicate that it’s a restricted area.
The building design should minimize the number of entrances, openings, ducts and mechanical/electrical pass through to prevent unauthorized physical access. Doors must be fire rated and have electronic lock systems to guard against unauthorized access. Slab to slab construction, use of steel mesh to reinforce structural joists, and keeping pipes inside steel sleeves can guarantee structural strength.
Where glazing panels are installed (for instance, on the roof of the greenhouse) , sensors or electrically conductive foil should be used to detect breakage of panels. All openings should be otherwise covered with steel screens or bars.
2) Monitoring- Sections 43(1), 43 (2), 44, 45(1), 45(2), 48(1), 48(2), 51(1) and 51(2) of MMPR deal with how to monitor your facility.
24/7 live video surveillance through CCTVs must be in all areas where marijuana is present, as well as in the perimeter of the site and entrance and exit points. The site operator needs to arrange sufficient lighting so that the footage can be usable.
Health Canada also requires archival of these recordings for up to two years.
3). Access control- Sections 42, 46(1), 46(2) and 46(3) of the MMPR deal with access control.
While video surveillance is one way of controlling access to the site, there are other ways, including swipe cards and biometric systems that ensure multiple layers of security.
Additionally, vault codes and safe combinations, alarm codes and passkeys must be managed by the senior person responsible for security. He or she should frequently change them so that control of the site does not fall into unaorized hands.
4) Intrusion detection- Sections 44, 45(1), 45 (2), 49 and 51 of MMPR deal with intrusion detection.
Some recommendations to ensure foolproof marijuana security revolve around having a well drilled response plan when intrusion is detected, and keeping a record of all attempts of security breaches into restricted areas.
Additionally, site operators must arrange for uninterrupted power supply so that sensors, cameras, control units and other security elements can keep functioning without any interruption. Cameras and sensors should be tamper resistant, and security should be immediately alerted in case any attempt is made to interfere with these systems.
5) Air filtration- Section 50 of the MMPR deals with air filtration issues, which has to be considered given that marijuana is a plant that produces spores and pollen, and buildup can pose health risks.
Health Canada recommends air filters like the H13 HEPA filter to scrub the exhaust air of particulate matter.
Security needs for every facility will be unique, depending on variables such as size, location or number of employees. Contacting a qualified security integrator at the planning stage can make your life significantly easier and minimize expenses and headaches down the line