Why do you need a dispensary security plan for your cannabis products? Very simply, there are two components that are critical to your approval for a state license: your overall business plan and your security plan. Infrastructure is essential to getting out of the gate.
Know Your State Regulations
Both medical and recreational cannabis are gaining widespread acceptance on the state level despite its continued standing as a Schedule II drug in the eyes of the DEA. As such, discriminating between state versus federal security requirements can be confusing. Federal law is crystal clear; mandating that cannabis be secured in either a vault or safe, and facilities reinforced with additional layers of protection including electronic security. State law, on the other hand, is far more obscure. It really depends on the state. Connecticut is generally regarded as one of the strictest with regard to cannabis security regulations, while Alaska has some of the least restrictive regulations. Nevertheless, your best option is usually to adhere to the higher standard; in most cases, the federal law, in order to ensure that your product and your business is protected in the way that it should be. Use your best judgement as advised by a security professional with industry experience.
Make it Professional
Your formal dispensary security plan should look professional, regardless of whether you submit electronically or on paper. Should you use an online template? While these are useful, they rarely can take the place of working with a consultant who knows their business and has a reputation of successfully securing license approvals.
No matter what your direction, be sure to keep the presentation clean, and only include images that enhance the report. These include a floor plan, which clearly indicates all entrances, exits, and limited-access areas (such as the vault and delivery areas). You should also include security details like camera installations and physical barriers to entry. Furthermore, including a list of contractors who will complete the work is wise. Your state will want to know if those contractors hold proper licenses to complete the work you hire them to do.
In general, you need two major sections for a dispensary security plan: Facility Security and Operational Security. Each is broken out into subsections requiring laborious attention to detail.
1. Facility Security
Facility security focuses on the physical security measures in place that keep your products safe from burglary.
Sections for facility security include:
a) The Physical Building
- Building specifications, including product ingress/egress points
- Floor plan
- Perimeter security
- Guards (if any)
- Access conditions for patients, customers (public) and employees
- Internal and external access points (customers and employees)
- Vault, refrigerator safe and/or wire cages
Notably, floor plans outline key physical attributes of the building, such as the location of the vault, entrances and exits, designated restricted areas, alarm locations, register locations, and security hardware to be installed.
b) Electronic Security
Electronic security reinforces the physical measures in place to protect your products while limiting access.
- Video surveillance system
- Intrusion and motion detection
- Alarm system and panic buttons
- Access control systems, potentially leveraging biometrics
- Internal communications
- Fire security
- Maintenance of testing of said systems
If you have any contractors and installers lined up to perform work, you will need to outline who will install the lighting, vaults, security systems, and doors. It would be even better if you could show the dates when these contractors will be on the premises.
c) Policies and Standard Operating Procedures
- Emergency response
- Incident management
- Outside partnerships with the community and local law enforcement
- Opening and closing procedures and timing/schedules
- Theft prevention
- On-site consumption prevention
- Incident log
- Suspicious activity
Your policies and procedures should be accessible to all employees for consultation at any time, and each new employee must understand these documents as they come onboard.
2. Operational Security
Operational security outlines how your employees handle patients and the public on your property. Every employee should know operational security integrates with their daily work at your dispensary. Your dispensary security plan highlights what employees will do during the day-to-day operations of your cannabis business with regard to following security procedures.
- Threat planning
- Delivery security
- Human resources policies
- Employee security training
- Inventory control system
- Customer procedures
- Neighborhood relationships
- Emergency response procedures, including natural disaster response
What Information to Include in Various Subsections
Each subsection of your dispensary security plan needs basic information, such as the hardware to be installed, where your policies and procedures manual will be located, and basic steps to ensure day-to-day security. For contractors and installers, list the hardware to be installed and the names and phone numbers of the contractors doing the work. The exact details are delegated by the state regulations. However, the more details you can provide to your state regulators, the better.
Don’t Forget Federal Compliance If That is the Standard
Although you need a state license to operate a dispensary, don’t forget about following federal regulations. Your vault system, safes, and electronic security must all comply with 21 CFR 1301.72 for controlled substances.
Professional Planning With CustomVault Convergint
CustomVault Convergint has decades of experience in the pharma/cannabis vault industry. Our professional engineers will sit down with you to discuss your requirements for a dispensary security plan ahead of applying for your state license.