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HomeMy WebLinkAboutRevised Security Plan - HHG 120 Airport Road CONFIDENTIAL – DO NOT COPY, REPRODUCE OR DISTRIBUTE WITHOUT WRITTEN CONSENT Property of Holistic Health Group, Inc. • 477 Wareham St. Middleboro, MA 02346 • hhgma.com To: Police Chief Challies, Planner James Kupfer From: Tim McNamara, President & General Counsel Re: Security Plan Description / Confidential Disclosures Date: March 2, 2025 This document is intended only for the reference of necessary officials with the Town of Barnstable charged with the assessment of a security plan to be applied to 120 Airport Road, Hyannis, MA 02601. It provides a general overview of security requirements imposed by the State Cannabis Control Commission for every marijuana establishment licensed under its regulations. Supplemental visual aids including imagery, screenshots etc. are provided for context where helpful, and contain protected information from the Company’s existing headquarters in Middleborough. Security Plan Overview 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 State regulations at 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,” at which point State inspectors visit for a second time, to ensure all security details are intact. Only then may the proposed licensee be placed on the agenda of the Cannabis Control Commission to commence operations, which will occur no sooner than 72 hours request from the licensing department by the applicant. While this overview describes generally required security characteristics for a MMTC, the applicant provides examples of its existing operation for additional guidance, and will continue 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. See, e.g. 935 CMR § 501.101(2)(b)8. Audits of inventory in a medical retail location 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 mandatory report to the Cannabis Control Commission inspections department, report to the Barnstable Police 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 locked “green waste” receptacle(s). Any exterior waste receptacles located on the establishment’s premises must also be locked, secured and under video surveillance to prevent unauthorized access. 935 CMR § 501.105(12) CONFIDENTIAL – DO NOT COPY, REPRODUCE OR DISTRIBUTE WITHOUT WRITTEN CONSENT Property of Holistic Health Group, Inc. • 477 Wareham St. Middleboro, MA 02346 • hhgma.com MA Mandated Inventory Database “Seed to Sale” Tracking All Cannabis Inventory Dashboard Access Control & Limited Access Areas Marijuana Establishments 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 at all entry points, as well as clearly illustrated 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 photo identification badge issued by the Cannabis Control Commission (CCC) prior to gaining entry, and at all times in the facility and while handling marijuana. Agent registrations are renewed annually, after completion of an updated CORI check. See, e.g. 935 CMR § 501.110(4). Upon the facility’s receipt of 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, verified by positive and valid photo identification credentials. 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 Massachusetts medical program 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 CONFIDENTIAL – DO NOT COPY, REPRODUCE OR DISTRIBUTE WITHOUT WRITTEN CONSENT Property of Holistic Health Group, Inc. • 477 Wareham St. Middleboro, MA 02346 • hhgma.com 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. 935 CMR § 501.140(3). Access Control Matrix for Departments of Vertically Integrated Marijuana Dispensary 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. 935 CMR §§ 501.105(13)(a)15 & 501.105(13(b). CONFIDENTIAL – DO NOT COPY, REPRODUCE OR DISTRIBUTE WITHOUT WRITTEN CONSENT Property of Holistic Health Group, Inc. • 477 Wareham St. Middleboro, MA 02346 • hhgma.com Surveillance Grid at Medical Dispensary Showing Secure Entrance and 100% Plenary Coverage Camera Key: Sales Floor Frontward Cam Sales Floor Rearward Cam Secure Patient Entrance Cam 1 Back Vault Cam 1 Back Vault Cam 2 Rear Office Cam 1 Front Vault Cam 1 Front Vault Cam 2 Rear Office Cam 2 Alarm Requirements The establishment will maintain a robust security system with features included to: prevent and detect diversion, theft or loss of marijuana product, and prohibit 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. In addition, motion and/or vibration sensing sensors will be employed at vulnerable points of entry. Alarm notification incident groups will be established for the order of contact of responsible parties, based on job description, proximity and availability. 935 CMR 501.110(5). CONFIDENTIAL – DO NOT COPY, REPRODUCE OR DISTRIBUTE WITHOUT WRITTEN CONSENT Property of Holistic Health Group, Inc. • 477 Wareham St. Middleboro, MA 02346 • hhgma.com Security Application to 120 Airport Road While the Company’s engineer and architect continue to assess and draft plans for renovating and upgrading the proposed location, the below floor plan is a rendering of suggested locations for camera sites both inside, and outside of the building. These plans are naturally subject to change at this early stage, but should provide some guidance on the scope of surveillance at the subject property. Preliminary Camera Layout at 120 Aiport Road Public Safety Commitment Lastly, as a lifelong Barnstable resident, Tim McNamara, President & General Counsel of Holistic Health Group, Inc. has a demonstrated commitment to the people here. Having built a life in Barnstable, he is dedicated to preserving its safety and character not least for the members of his family, and decades of friends, co-workers and law firm clients who continue to build here today. In support of this commitment he also sits as a co-chair of the Harm Reduction Workgroup on the Barnstable Regional Substance Abuse Coalition. Members of that Coalition are on the front lines of substance abuse in the area, and Tim holds himself and company to the guidance and recommendations made within it.