Physical Security in the Cannabis Industry

With 100 acres surrounded by 8,300 feet of chain link and barbed wire fencing, 102 video cameras, infrared and vibration sensors, 48North's Good Farm southeast of Brantford will be one of the largest outdoor cannabis operations in Canada. The licensed producer has received the green light from Health Canada to begin cultivation on its Brant County farm. Brian Thompson/Postmedia Network
Kalpna Mistry

Kalpna Mistry

If you’re thinking of starting a cannabis business, there are a few hurdles you’ll need to get over before you’re licensed and ready to go. One of the largest portions of the application process, as well as getting your site ready for production, is physical security. Under the Cannabis Act and Regulations, there are a number of requirements that must be met when it comes to site design and security measures, which are necessary to secure sites where licence holders conduct cannabis activities. Here are some of the basics when it comes to the various federal cannabis licences and the security requirements that accompany them.

Before getting into the details, we should first clarify the different areas that compose a cannabis producer’s site:

GROW AREA: refers to an area of the site where cannabis plants are cultivated, harvested or propagated.

OPERATIONS AREA: refers to an area of the site — other than a storage area — where cannabis is present, as a result of any activities conducted under a licence. It includes a grow area.

STORAGE AREA: refers to an area where cannabis is stored.

Now, let’s take a look at the different security measures required for the various classes and subclasses of cannabis licences:

Standard Licences (Cultivation, Processing) and Sale for Medical Purposes (with Possession of Cannabis) Licence

Physical security requirements for these licences are the most extensive and fulsome, as these licences are not restricted in terms of grow space and production quantity. This means, at any given time, there may be a very large quantity of cannabis on site and therefore, the most protection is required for these licences.

Here are some of the physical security requirements for these licence holders:

  • The site must be designed in a manner that prevents unauthorized access.
  • The perimeter of the site must be monitored at all times by visual recording devices to detect any attempted or actual unauthorized access. The devices must, in the conditions under which they are used, be capable of making a visible recording of any unauthorized breach.
  • The perimeter of the site must be secured by an intrusion detection system that operates 24/7, and that allows for the detection of any unauthorized access to the site, as well as any attempted or actual tampering with the system. The detection system must be monitored at all times. The holder of the licence must determine the appropriate measures to be taken if any intrusions are detected.
  • Access to each operations area and storage area must be restricted to individuals whose presence in the area is required by their duties. A record must be maintained of the identity of every individual entering or exiting a storage area.
  • Each operations area and storage area must be surrounded by a physical barrier that prevents unauthorized access.
  • Each operations area and storage area must be monitored at all times by visual recording devices to detect illicit conduct. For a grow area, only the entry and exit points of the area must be monitored by the devices. The devices must, in the conditions under which they are used, be capable of making a visual recording.
  • Each operations area and storage area must be secured by an intrusion detection system that operates 24/7, and that allows for the detection of any unauthorized access to the area, any unauthorized movement in the area, and any attempted or actual tampering with the system. The intrusion detection system is not required to detect unauthorized movement in a grow area. This intrusion detection system must be monitored at all times. The holder of the licence must determine the appropriate measures to be taken if any intrusions are detected.

Micro Licences (Cultivation, Processing) and Nursery Licence

Physical security requirements for micro class licences and the nursery licence are more relaxed, as licence holders are restricted in the amount of grow space available, as well as the amount of cannabis that can be processed annually. Furthermore, nursery licence holders are restricted to harvesting 5 kg of flowering heads, with the exception of cannabis plant seeds. Flowering heads (with the exception of the cannabis plant seeds), leaves and branches of the plants must be destroyed within 30 days of harvesting them.

A micro-cultivation, micro-processing or nursery licence holder must ensure that the following security measures are complied with in respect of the site type set out in the licence:

  • The site is designed in a manner that prevents unauthorized access.
  • The site is surrounded by a physical barrier that prevents unauthorized access.
  • Storage areas are surrounded by a physical barrier that prevents unauthorized access.
  • Access to each storage area is restricted to individuals whose presence in the area is required by their duties.

Research Licence

A holder of a licence for research must ensure that operations areas at the site are designed in a manner that prevents unauthorized access.

In order for your application to be considered, you should already have a facility or building that is dedicated to your research project and is already built out. As part of your application, you will have to show some information regarding your site, including a site plan, floor plan and description of the physical security that is in place to prevent unauthorized access to the cannabis storage and operations areas.

Analytical Testing Licence

A holder of a licence for analytical testing must ensure the following security measures are complied with:

  • Storage areas are surrounded by a physical barrier that prevents unauthorized access.
  • Access to each storage area is restricted to individuals whose presence in the area is required by their duties.

In order for your application to be considered, you should already have a facility or building unit that is built out and is dedicated to your analytical testing activities. This means the site where your proposed analytical testing lab will be located will need to have some basic security measures in place. A description of the physical security plan must be submitted with your application, including a brief overview of the site, including its perimeter and storage areas and how they are designed to prevent unauthorized access.

Sale for Medical Purposes (without Possession) Licence

A holder of a licence for sale for medical purposes (no possession) is not required to demonstrate physical security measures, as the licence holder will not actually have possession of any cannabis. However, we still recommend these licence holders have some basic physical security (e.g. cameras, locks) in place to protect their business and client records.

So, there you have it! Remember, physical security is a key component of federal cannabis licence applications, so it’s important that your business and your site are compliant with all the necessary requirements.

How we can help you

At Cannabis License Experts, we provide you with the guidance to plan your cannabis business, acquire funding, navigate the legal requirements, and acquire the appropriate licence for your operations. As the Canadian cannabis industry develops, more and more licensed producers will be needed to meet the demands of consumers.

Cannabis License Experts offers support from day one of starting your cannabis business, including strategic planning, floor plan preparation, site audits, SOPs, Preventive Control Plans (PCPs), cannabis product label reviews and more.

Our Edibles Compliance division can provide you with a solid plan for your edibles business to help get your products on store shelves.

Contact us today to discover how we can license and legalize your cannabis business to meet federal or provincial regulations.

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