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HomeMy WebLinkAboutSecurity Plan Overview Holistic Health Group, Inc. • 477 Wareham St. Middleboro, MA 02346 • hhgma.com Security Plan Overview In support of its special permit application, HHG provides the following information relative to security measures and “diversion control” at the proposed location pursuant to internal policies of HHG as well as 935 CMR 501. State licensing requires all marijuana establishments undergo on-site inspection(s) for compliance with these regulatory requirements at the point of Post Provisional Licensing, and that such regulations are met prior to final licensing, and only then may obtain subsequent authorization to commence operations. While this overview describes generally required security characteristics for a MMTC, the applicant has additionally agreed to communicate directly with the Barnstable Police Department on specific details concerning its security plans as the project proceeds. Seed to Sale Inventory Tracking Massachusetts regulations require that all marijuana establishments, including medical treatment centers, employ a seed-to-sale inventory tracking system of record in the form of Metrc to monitor all quantities of marijuana and marijuana products for the purposes of: general security, prevention of diversion, storage and transportation of marijuana, and inventory tracking. The system tracks marijuana in the possession of any such licensed facility through all stages of production to the point of sale. E.g. at 501.101(2)(b)8. Audits of inventory take place on a daily basis, and any discrepancies in physical inventory are addressed immediately upon discovery via reconciliation of inventory on hand, POS software, Metrc and camera surveillance records, as may be necessary. Discrepancies that cannot be resolved within 24 hours will result in a report to the Cannabis Control Commission inspections department and/or disciplinary action in the case of employee malfeasance. All marijuana waste generated for reasons of product expiration, contamination or returns will be documented and processed in the company’s internal and Metrc waste log and deposited physically into “green waste” receptacle(s). Any exterior waste receptacles located on the establishment’s premises must be locked, secured and under video surveillance to prevent unauthorized access. Access Control & Limited Access Areas Any marijuana establishment must keep and store all marijuana and marijuana products at all points leading up to the point of sale in designated “limited access areas,” accessible only by agents registered at that facility. Limited access areas must be identified physically by 12”x12” signage, as well as clearly described by filing with the Cannabis Control Commission in a form and manner showing walls, partitions, counters, and all areas of entry and egress. Safes, vaults and other storage areas are maintained securely to permit only essential personnel, and only for as long as is necessary to execute tasks related to the employee’s duties in said areas. Registered agents must visibly display an identification badge issued by the Cannabis Control Commission (CCC) prior to gaining entry and at all times in the facility and while handling marijuana. 935 CMR 501.110(4). Upon final licensure, any visitors, contractors or vendors may only gain entry to limited access areas under escort by a registered agent of the facility, after having been logged into the establishment’s visitor records and positive identification. Holistic Health Group, Inc. • 477 Wareham St. Middleboro, MA 02346 • hhgma.com After operations commence, other than employees and registered guests, only patients registered with the Massachusetts Cannabis Control Commission will be permitted onto the sales floor, and only after displaying a valid registration card with positive identification of the individual. A registered agent of the establishment will, in addition to verifying patient and identification status, also verify that the patient has remaining purchasing capacity on his/her MassCIP account pursuant to CCC regulations. Any patient that has exhausted his/her 60 day supply of marijuana or marijuana products will not be permitted to purchase marijuana or marijuana products. Camera Coverage & Lighting All limited access and cash handling areas, and points of entry thereto and exit therefrom, where marijuana or cash is handled or kept must be maintained under complete and plenary visual camera surveillance, of a quality sufficient to identify persons entering any such areas within the establishment. In addition, all perimeter and parking areas of the establishment will feature camera coverage appropriate for the normal lighting conditions of those surveillance areas. Trees, bushes and other landscaping elements must be maintained so as to prevent a person or persons from concealing themselves from sight. All security systems, equipment and recordings are maintained in a secure location to prevent theft, loss, destruction and alterations, where only key personnel, law enforcement, public safety, and designated CCC staff will receive access. Surveillance footage is kept for a minimum of 90 days on the company’s internal file storage, and audited by visual and physical inspection on a weekly basis to ensure system functionality. In the event of an incident, the company is ready and able to provide footage with unaltered date and time stamp details to the CCC and law enforcement immediately upon request. Security & Alarm Requirements The establishment will maintain an adequate security system to prevent and detect diversion, theft or loss of marijuana or unauthorized intrusion, utilizing commercial grade equipment, which shall, at a minimum, include: perimeter alarms on points of entry and windows, a failure notification indicating any failure in the surveillance system, duress/panic alarms at key locations including all cash handling locations and marijuana vaults, safes & storage areas.