HomeMy WebLinkAboutNarrative to revised Security planHello Anna,
Attached please find an updated security plan which incorporates answers to the Chief's
comments, to which I have also responded below, in kind:
1. The waste management plan – Chris said that the system in Middleboro was good so we would
want to make sure that what gets installed in Hyannis is similar.
Waste management protocols for any solid waste containing marijuana are identical to what
Detective Kelsey observed in Middleborough, i.e. locked and secured, and "ground up and
mixed . . . such that the resulting mixture renders any Marijuana unusable for its original
purpose." 935 CMR 501.110(12)
2. With regard to Access Control and Limited Access Areas – the plan states that Safes, vaults, and
other storage areas are maintained securely to permit only essential personnel, and only for so
long as is necessary to execute tasks related to the employee’s duties in said areas… How is the
length of time monitored?
Staff time spent in the vault is monitored most frequently as part of managing the business in
general. This would typically first be the responsibility of the manager on duty, and then of
those reviewing surveillance footage as part of any time management audit. For reference the
length of time spent in the vault does vary by duty, from 10-30 seconds for picking inventory for
fulfillment of a patient's order, to around 1 minute for picking and packing an online pickup
order, and potentially an hour or more for tasks like inventory audits, package labeling and full -
time fulfillment shifts.
3. The plan lists who is eligible to access the facility both upon final licensure and after operations
commence (bottom of pg 1 and top of pg 2). There is no mention of law enforcement so I would
like to ensure that without being a “registered guest” that law enforcement is entitled to enter
the premesis.
Access to the facility by law enforcement, acting within their lawful jurisdiction (and/or as
emergency responders) is explicitly authorized by the Commission regulations at 935 CMR
501.105(14)(b).
4. With regard to Camera Coverage and Lighting – in the event of an incident I would ask that they
be required to report immediately to us. In addition, I would like clarification on the statement
about their ability to provide security footage with unaltered date and time stamp details to the
CCC and law enforcement immediately upon request. In many instances when we try to access
video from commercial establishments, we have to wait until they clear requests with corporate
offices or until someone with access to the system can get to the facility. Is this really
immediate access?
Commission regulations explicitly require as part of the surveillance camera system "[t]he
ability to produce a clear, color, still image" with embedded date and time stamp. 501.110(5) 6
& 7. In practice the manager on duty at the location, and any owners with remote access, can
obtain and provide both still and video imagery immediately for electronic transmission and/or
thumb drive from the system to local law enforcement.
5. With regard to the alarm requirements, we would just want them to honor the alarm
registration requirements for the TOB.
In addition to following the Commission's alarm requirements at 935 CMR 501.110 (5), the
alarm system will be registered with the Town of Barnstable Police Department per those
requirements.
When the property is available for inspection, Chris Kelsey and I can do a walk-through. He said he did
not believe it was at that stage. Let me know if you need anything else. Thanks.
We can make the property available for inspection at any time, however, no security apparatus
will be installed until mid-way through any building process, subject to all necessary approvals.
Likewise the property will continue to be available to law enforcement as previously
referenced.
Thanks Anna,
Tim