On April 1 2014, Health Canada’s security guidelines on growing and selling medical marijuana for licensed providers with a rating of 7 or higher would have come into effect, had its implementation not been placed on hold by an injunction.
The trend seems to be moving towards bigger corporate growers and away from individual and mom and pop growerswho flourished under the previous MMAR regime.
The Directive On Physical Security Requirements For Controlled Substances released by Health Canada recognizes 11 levels in ascending order of security. Most LPs and applicants are designing their facilities to be Level 8, 9 and 10 compliant.
Different categories of security requirements
Every security level is categorized into the following areas:
- General Section- This section deals with security rules pertaining to electrical detection requirements, design of cameras, alarm and other monitoring systems. Other requirements relate to the specifications of the ventilation and air conditioning system.
- Vault – This section details the specifications that have to be met for secure areas where the processed product will be stored prior to delivery. It lays down minimum acceptable requirements for construction of walls, ceilings, floors, doors and locks, including protocols around lock safety.
- Safe- In cases where a vault is not used, this section details the requirements of a safe, including security rating of the lock as per ULC norms
This post will not deal with Level 11 because this level is overkill for obtaining medical marijuana security clearance.
Common features across security levels
For facilities that are rated at levels 7 to 10 there are some common requirements that every operator has to meet.
The Minimum Electrical Detection Requirementsrequire that
- Smoke detectormust be inside the vault.
- Sufficient detectors must be present to indicate when there is an unauthorized attempt to access, penetrate, remove, or open the vault or safe.
- Detectors must indicate when there is an unauthorized opening of the vault or safe door or when any attempt to circumvent the detector is made.
- All vault and safe alarms on one zone must be separated from other detection devices installed in the warehouse.
- Vault or safe alarm equipment must be monitored by a U.L.C. (Underwriters Laboratories of Canada) approved central monitoring station.
- Proximity detector (capacitance detector) if used in combination with a safe must be placed either inside or underneath the safe whenever feasible.
Divergences for this section include
- For Level 7 and 8, Grade B line supervision is sufficient. It is bumped up to Grade A line supervision for Level 9 and Grade AA for Level 10 (these grades divide burglar alarms on the basis of quality of equipment used, form of signal transmission and maximum allowable guard response time.)
- In all the levels, control boxes for the security system should be located inside the safe or vault. However, Levels 9 and 10 mandate additional requirements in the form of keyed time delay circuit or digital code call in.
- In the event where complete perimeter security coverage is not possible, Level 8, 9 and 10 facilities need to install motion detectors to detect movement across accessible exterior vaults, doors and ceilings.
Other commonalities around regulations relating to electric conduits, ventilation systems, location of vaults/safes and walls include
- The electric systems that power alarms, lights and telephones must follow acceptable codes.
- The electrical conduit cannot not be more than 3.8 cm in diameter.
- The secure areas like vaults and safes must be at a minimum distance of 1meter from any outside wall or any accessible roof. Even in cases where a structure like a cement pylon is present the 1 meter rule has to be followed.
- The ventilation ducts must not be larger than 15 cm on one side, and the area of the opening cannot be more than 619 cm2.
- The opening must be covered by installing 15mm steel reinforcing rods or 3.5 mm expanded metal mesh welded into a 6mm metal frame.
The differences in requirements of various security elements for Levels 7-10 include
Vault Walls and door
|Level 7||Level 8||Level 9||Level 10|
|High density 15 cmthick concrete block reinforced with 15 mmdeformed steel bars||High density 20 cmthick concrete block (other spec is same)||High density 30 cmthick concrete block (other spec is same)||Poured concrete 45 cmthick with compression strength of at least 20.7 MPa, reinforced by 4 grids of 15 mmdeformed steel bars|
|Fire resistant bank vault type door, with inside escape handle removed and a minimum 3 tumbler combination lock with spy proof dial||Same type of door, and lock, with a steel faceplate which is at least0.62 cm thick. Also, should be relockable||Same type of door and lock, with steel faceplate’s minimum thickness 1.25 cm||Same type of door and lock. Steel faceplate thickness at least 2.5 cm|
For the ceiling/floor, the thickness of concrete goes from reinforced poured concrete 10 cm thick (Level 7) to 15 cm (Level 8), 20 cm (Level 9) and 45 cm (Level 10).
The quality ofsafes will also vary. Level 7 needs a ULC-TL-30 rated safe, 8 needs TRTL-30, 9 needsTRTL-30×6 and 10 needs TXTL-60×6. Additionally, for Levels 8, 9, and 10 the safe has to be inside a caged area and anchored to the floor.
Operators are free to exceed these requirements. For example, a Vida Cannabis facility has thermal imagers on the roof, three meter high perimeter fences dug two feet underground and special security mesh between interior and exterior walls.
Link between production and security levels
Higher security levels can reduce the efficiency of secure processing areas such curing areas. Besides, a sufficiently sized high-level vault or safe that can store the final product might be too expensive.
But these issues are not deal breakers, and proper planning can ensure that you can have your cake and eat it too.
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