Full Manual - Cannabis Security Operations - Ver 19
Transcript of Full Manual - Cannabis Security Operations - Ver 19
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SECURITY OPERATIONS
FOR THE
MEDICAL & RECREATIONAL CANNABIS INDUSTRY
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Legal Disclaimer
Reader is responsible for learning, knowing, and following the
laws that are in effect wherever they are. Reader shall obtain advice
of an attorney & accountant, when becoming involved with the
cannabis industry. The International Security Training, LLC and/or
Brian K. Allen do not accept any accountability or responsibility for
any wrong-doings of the reader.
This industry is very dynamic and fast changing. The
information contained in this manual was correct as of the date of
publishing. By the time the reader studies this manual, things may
be different… and laws may have changed. It’s the responsibility
of the reader to act lawfully in regards to the topic(s) covered in this
manual.
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Table of Contents
(1) Introduction To The Legal Cannabis Industry 4
(2) Legal Issues & Agency Oversight 9
(3) Current Industry Challenges Creating Highest Risks 11
(4) Security via Technology 14
(5) Security via Personnel 17
(6) Security Operating Procedures 22
(7) Common Job Requirements Of Cannabis Employees 25
(8) Physical Security Programs 56
(9) In Conclusion 67
(10) Resources 68
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Introduction To The Legal Cannabis Industry
The legalization movement of cannabis in The United States and
Australia has been picking up its pace in recent years. As of January 2016,
Austria decriminalized the possession of up to 5 grams. States and territories
across the many nations are adopting new regulations to allow for the medical
and/or recreational use of cannabis. Uruguay is still the most cannabis-
friendly nation, with Spain coming in second. Then we have the Netherlands.
Their decriminalization and allowed practices for coffee shops is another
Nation worth researching in regards to the cannabis industry.
Whether it’s a dispensary in one area or a cultivation farm in another…
more and more cannabis businesses are looking for professional security
companies, to enhance their security. Those companies are looking for
educated, trained, and experienced security personnel to help meet the staffing
demands of the businesses they’re hired to protect. That’s YOU! Now,
because of the nature of the industry, former military and law enforcement are
often sought after… due to their comfort and experience with basic security
and firearms. This leaves a bit of a “lack of industry specific professionalism”
among the ranks of many security departments in the cannabis industry. Well,
until now.
Professionals who complete THIS course will not only have the
physical security knowledge but in addition will be able to increase the
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knowledge of their clients, employers, etc. on how to successfully and
lawfully operate their cannabis business.
The threats to this industry are unique but we must not forget, it’s still
just a product. So, this course will provide anyone new to the topic with an
understanding of cannabis… marijuana… as a Product. Here are the nine
most popular products we’ve seen for sale in shops from California, USA to
the Netherlands:
Flowers
Edibles (Marijuana infused)
Pre-rolled Joints
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Concentrates (dabs, oil, hash, wax,
shatter, etc.)
Vapor Pens (used to consume
concentrates)
Beverages
Tinctures and Sublinguals
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Topical
Capsules
In addition to cash, which we’ll discuss later, stores worry about
protecting their product. After all, the plants and dried, ready-to-sell product
are just as valuable as cash, and always on site.
Plants are typically part of what's monitored by the cameras, alarms,
and a security team. Dried, sellable products, are typically locked away in a
steel room similar to a bank vault. Anyone who’s worked around controlled
substances in the USA will be familiar with these vaults… as they’re required
by the DEA CFR’s.
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Later, in the Physical Security Programs portion of the course – we’ll
discuss the five main “arms” of the cannabis industry. Each ‘arm’ needs a
security plan in place to deter criminal activity and prevent / minimize loss.
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Legal Issues & Agency Oversight
It’s vitally important that business owners, their staff, and their security
officers do everything right… everything that’s required by the law. They
need to focus on doing everything legal so they don’t provide any reason for
those who fight against cannabis… to lobby or fight against the industry.
It’s the responsibility of the business owners & management team to
know what agency or agencies, in the area(s) they operate in, establish the
rules under which the medical and retail marijuana industries must operate. In
most cases, those agencies put forth minimum security requirements that all
marijuana businesses must meet.
This may be easier to say - than do - for some business owners. In the
USA, many of these owners have been growing and selling cannabis out of
their homes, apartments, back yards, and garages for many years. If you or
your employer falls into that category - teach them to work WITHIN the law,
now. Everyone in the industry needs to prove that they are viable, legitimate
businesses that don’t cut corners… and don’t have anything to hide.
Here are some of the more popular agencies or government programs
that control the cannabis laws & regulations in their areas. Be sure you, as the
security professional, STUDY the laws that pertain to any location that your
business operation ‘touches’. This list is just a sample… it’s not all-inclusive.
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Australia - Australian Drug Misuse and Trafficking Act (1985 & 2006)
The usage of medicinal cannabis became legal at the federal level on 1
November 2016, with implementation varying from state-to-state.
Austria – Austrian Health Authority
Chile - The Chilean Agriculture Service (SAG)
Croatia - Ministry of Health
Canada - Controlled Drugs and Substances Act
Philippines - Comprehensive Dangerous Drugs Act of 2002
United States – The United States Supreme Court has ruled in Gonzales
v. Raich that the federal government has the power to regulate and
criminalize cannabis, even for medical purposes. Each state controls
their cannabis laws. Here are a few that you can research:
Nationwide Information: www.mpp.org
Arizona - Arizona Medical Marijuana Act --- Arizona
Department of Health Services
California - California Bureau of Medical Cannabis Regulation
Colorado – CO Dept of Revenue - Marijuana Enforcement
Division (MED)
Oregon -
http://www.oregon.gov/olcc/marijuana/Documents/BusinessRe
adinessGuide_RecreationalMarijuana.pdf
Also: http://www.oregon.gov/olcc/marijuana/pages/default.aspx
Washington State –
http://lcb.wa.gov/mjlicense/marijuana-licensing
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Industry Challenges Creating Highest Risks
Cash & Employees
To date, the highest risks we’ve been able to identify in the industry
come from two basic arenas. The first area, is the cash nature of the business.
The second arena is pilferage / employee theft. As a security professional, it’s
your job to number one, see if our findings are the same in your area and
number two, to deter any criminal activity in those arenas.
Cash (Banking Problems)
In the United States, at the time of this course was printed, the sale of
marijuana, remains illegal on a federal level. It's considered a sale of a
Schedule I substance. Also, banks are not allowed to perform transactions
with businesses that are associated with Schedule I substances. Do you see a
problem here?
It is true that some banks are willing to do business with marijuana
dispensaries, under the store owner's name. Just remember, there's always a
good chance those accounts may be abruptly closed… if a compliance
investigation occurs.
Since this challenge exists, the majority of the businesses we’ve
examined operate on a cash basis. Imagine that! They only accept cash, pay
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their employees in cash, transport cash, and store huge amounts of cash. As
a security professional… you can imagine how the scenario makes a
criminal’s mouth water.
The government in the USA, really needs to fix this. If not for the
business owners, they should do it for their own greed. The state and federal
government cannot tax businesses accurately, for which it cannot follow the
money. When it comes down to it, cannabis businesses deserve to conduct
their banking affairs in a "normal manner" like any other business in the area.
Providing banking, would be a solution for these problems.
Many legal cannabis businesses have stacks of money onsite. Many go
to their state revenue office, with stacks of money, just to pay their payroll
taxes. This is a huge risk for the business and the employees responsible for
this task. What about federal taxes? Money orders are used most of the time.
Imagine a shop or facility manager standing in line with several thousand
dollars in bank bag… buying money orders. This needs to stop.
Employee Pilferage
Employee theft is nothing new. Unfortunately, when some people think
there is a way they can steal from their employer… and not get caught… they
give it a shot. In all of the interviews I’ve done with people I’ve caught
stealing, there’s always one common aspect to their “why”. They justify it by
saying the company makes all this money… and I only make this little
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amount. They have to justify it in their minds because most of them do not
self-identify as thieves. So, as a business owner and/or security
professional… you need to create overlapping layers of security that include
policies that prove to the employees that… if I steal, I will get caught.
Embedding this internal paradigm will cause an employee NOT to steal…
even when the desire or thought enters their mind.
Most of the robberies we’ve seen happen in warehouses and cultivation
so, that's what's getting broken into right now. Unfortunately, they’re inside
jobs. An employee gets pissed off… they know the schedule for the current
crop to come down… and they break in. If they don’t physically participate
in the break-in, the supply the needed intel to the crew, that does the actual
break-in. Why? Because the plants are incredibly valuable."
The concern of insider threats should always be present. Remember,
you’re dealing with cash and marijuana! When we get to the section on
Security Operating Procedures, we’ll discuss system attributes that minimize
this threat.
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Security via Technology
Now that we’ve discussed how we have to protect our employers cash
& product… as well as protect the business from internal threats / pilferage, I
think it’s obvious why a complete security system is a blend of both human
and technological assets. Remember – technology is a TOOL that we use in
security. We should never use it as a CRUTCH in an attempt to not have to
hire human security officers. If we do that – our Security Program will be
lacking in a big way.
Here is a list of technology items related to physical security that you’ll
need to have an understanding of when creating your security program:
1. Intrusion Detection System
2. Access Control System
a. RFID Badges
b. Keypad Entry
c. IRIS / Retina Scanners
d. Thumbprint & Fingerprint Inputs
e. Facial Recognition
3. Cameras - Internal & External
a. High definition, Infrared, and Night Vision
4. Motion Sensors
5. Laser Beams
6. Glass Break Sound Detectors
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7. Smart Phone Viewable
The above items need to be blended in with your physical barriers, your
natural surveillance, security signage, and your security operating procedures.
Here are four very important areas of security technology that need to
be considered when developing your security assets and procedures:
IP Everything
If your physical security system isn’t already heavily reliant on IP
technology, now is the time to make the move. It’s especially important to
offer IP cameras and networked access control. Consider starting with HD,
megapixel, and even 4K cameras and then adding more advanced devices and
capabilities as you can.
Use Cloud-Based Storage and Features
As the security industry becomes increasingly dependent on digital
technology, it only makes sense to take advantage of cloud-based capabilities.
For your video surveillance system, that might mean storing video data in the
cloud to avoid on-site storage… or to prevent an insider thief access to the
video logs. For access control users, cloud features can enable remote access
and management, which comes in handy when decision-makers aren’t on site.
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Install Wireless Locks
Wireless locks are experiencing a rise in popularity. Many security
professionals realize that they offer a new level of flexibility for both new and
existing access control systems. These devices can be quickly and easily
added to doors, and they offer cost savings over time, in reduced energy
consumption, making them an ideal fit for businesses of all sizes.
Consider ‘Access Control As A Service’ (ACaaS)
Fueled by the boom in cloud-based features, ACaaS has been one of the
fastest-growing segments of the industry. ACaaS is an especially compelling
offer for smaller businesses, that are looking for added flexibility in their
access control system, but without the associated up-front and ongoing costs
and maintenance requirements.
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Security via Personnel
Two groups of employees within a business are responsible for
the overall effectiveness of the security program. The first group is, the
security staff. The second group is, everyone else. Let’s examine both.
Security Staff
Every member of the security staff must have, be, and reinforce:
1. Integrity
Inherent honesty and inclination to do the right thing, by nature, is
essential to building and maintaining trust. This is critical in the cannabis
business. The industry needs all the help it can get because it’s still defending
itself against the “anti-cannabis” crusaders and politicians.
2. Vigilance
Being able to quickly and effectively gauge, the nature of the actions of
people surrounding them, and identify possible threats to the security of
people and property under their care.
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3. Training
Beyond simply obtaining the state licensing and training required, they
should demonstrate a willingness and ability to understand the policies and
procedures of the company they serve.
4. Critical Thinking
Being able to bring together - vigilance and training - to quickly identify
the best course of action to deal with, or prevent, threats to the security to their
company and personnel.
5. Communication
Effectively communicate with employees, management, customers and
outside law enforcement.
6. Flexibility of Roles
Often required to switch between leading and following direction, one
of the most important characteristics to look for in security guards, is the
ability to know when to give - and when to take, orders.
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7. Low Profile
While some situations require a visible security presence, most security
personnel need to be able to blend and to keep incidents low key when they
occur.
8. Psychological Insight
The goal of good security is to prevent major incidents. An
understanding of human psychology allows the guard to identify possible
problems early, and de-escalate confrontations.
9. Respect
Security personnel require the respect of those they work with. In order
to get that respect, they must FIRST demonstrate the utmost respect toward
all those they deal with.
10. Teamwork
Not only is a security guard part of the security team in a company, they
are part of the larger company itself, and must be willing to work to represent
the company with excellence - in all of their dealings.
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Everyone Else (All Other Employees)
No number of rules and minimum regulations can protect against
insider threats. The first step to fight them, comes in the form of background
checks, which in most cases, are handled by the local government oversight
agency. All employees, security… operational… etc. need to be fully vetted
prior to being assigned to their job.
Background checks include criminal and financial background checks.
In many jurisdictions, it also includes checks on unpaid child support. In some
cases, determining if aplicants are delinquent on student loans.
Employees also have to be badged and fingerprinted through the local
government oversight agency, in order to work in this industry. If there are
any issues… on any level… they shouldn’t be hired or retained as an
employee.
In addition to the minimum legal requirements, a cannabis business
should have employees agree to take polygraph examinations, upon request,
during the hiring process.
An employees' loyalty to the company goes a long way, in preventing
them from stealing cash, or product to sell on the side.
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Finally, all employees should be empowered to challenge unknown
people without visitor badges… in addition to challenging known co-workers
onsite without their employee badge. Why? Many incidents have occurred as
a result of an employee giving their badge to someone else… in an effort to
“just be helpful”. In the cannabis industry, loaning your badge to someone
else should be a terminable offense.
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Security via Operating Procedures
So far, we’ve discussed the main two security assets that pertain to a
security program. (1) Security Technology and (2) Security Staff. In this
section, we’ll discuss the overlapping connective element… Security
Operating Procedures. These procedures tell your staff, management, and any
oversight authority HOW & WHEN you use your security technology and
staff.
Procedure # 1
Transport cash sporadically. Change the route… from the vault, to the
front door, then sometime to the back door. Different times of the day,
different days of the week, using different vehicles. Don’t have a set schedule
or routine. Implement a method for deciding at the last moment, which route
will be taken. (Similar to, but more complicated than, flipping a coin.) Also,
consider having decoy vehicles in play, as well. Don’t store a lot of cash on
the premises. For example, if you’re a cannabis shop, never have more than
a day or two of deposits in the facility.
Procedure # 2
Implement the “Buddy System” for opening product / cash cages, vaults
and safes. For example, one company has a procedure that states it will take
at minimum, two authorized employees to open a cage. (1) A manager,
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(because only managers have the combination / keypad code) and (2) A
supervisor, (because only Supervisors are authorized to request the key from
security.)
Now, this is even better than it appears because when the Supervisor
requests (and signs for) the key from security… the security staff is mandated
to observe all routes leading to and from the cage/vault/safe being opened
before the door is opened. They are also mandated to observe the activities
of the staff entering the area, while they are inside. Of course, the video
surveillance is recording and storing the video… at an offsite location. (Cloud
technology).
Employing a procedure like this is simple but not easy. Why? Because
of staffing. If a manager & supervisor are off the floor handling the vault
task… there must be enough staff on the floor, so that operations continue
smoothly.
Procedure #3
Video footage storage requirements. Keep 40 days' worth of backed up
footage. Your video footage should be saved to a cloud server and not an
onsite server. Also, where the DVR or Video Control Panel is located, there
has to be a separate camera that's watching that area… that's not linked to that
DVR. It’s all about checks & balances.
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Procedure #4
Implement a “Picture Taking” policy. When developing this, you’ll
want to create rules for both employees and visitors. Since almost every
mobile device has a built-in camera ability, limiting mobile device behaviors
may be needed. For instance, I once caught a guy taking picture in an
unauthorized area. He knew about the no picture policy… so he was trying
to act like he was texting. His mannerisms were peculiar so I began watching
him closer. Before and after each text, he would angle his phone up just
right… take a picture… then go back to typing.
People of all ranks & job titles have tried this, so don’t think that just
because someone holds a high-level job… that they will comply.
Procedure #5
Implement a daily inventory requirement. This staunch inventory
control should be performed three times a day. This will help raise a “red
flag’ if something is odd or suspicious has gone on.
You need a lot of checks and balances on inventory control.
Remember, an ounce of cannabis can make approximately 30 pre-rolls, or be
used for making 30 edibles. So – you need to track ounces! Heck, ¼ and ½
ounces! Employees have been caught stealing these smaller amounts many
times.
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Common Job Requirements Of Cannabis
Industry Employees
In protection work, there are two “people” an agent has to know, inside
& out. We have to know our ‘principal’, who is the person we’re protecting.
We have to know their work and home environment & norms. This allows us
to be able to detect anything that is out of place, and direct our focus there.
We also have to know the ‘threat’, who we can call the bad guy.
Unfortunately, in the cannabis industry – employee theft occurs. For this
reason, we need to know enough about their job so that we can tell when
someone is doing something that is out of character for the situation / location
/ etc.
By studying the seven job descriptions below, you’ll have a head-start
in gaining the abilities mentioned above.
1. Pre-Packager – Colorado, USA
2. Armed Dispensary Security Guard – California, USA
3. Asset Protection Associate - Overnight Security – Colorado, USA
4. Safety Associate – California, USA
5. Manufacturing Technician – New York, USA
6. Facility Security Coordinator – Colorado, USA
7. Security Guard – California, USA
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(1) Pre-Packager
Position Summary:
This position is responsible for sifting through cured batches;
separating, weighing, packaging, sealing, labeling and tracking the product
precisely and effectively. They are also responsible for the tracking of each
batch, making sure that all product is accounted for, packaged appropriately
and noted on all forms appropriately and according to company policy and
practices, as well as state, local and MED laws and regulations.
Essential Functions:
1. Identify retail needs based on store inventory levels and prioritize
packaging based their warehouses current cured inventory.
2. Breakdown cured batches into multiple different weight increments
(1.75 g, 3.5 g, 7 g, etc…) and package them accordingly; adhering to a
retail requested 2:1 ratio of 1/8ths to 1/16ths.
3. Employee must package product without degrading the quality,
weighing it on a state certified scale to an exact weight and placing the
product in the bag without damaging it.
4. Properly note all packages and increments on the batches Cure Form
for reconciliation.
5. Employee is responsible for printing labels for each package and
adhering them to the bag.
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6. Employee is required to fill the bags with nitrogen, close them and heat-
seal them according to company policy and procedure.
7. Employee should be trained and have a basic knowledge of MJ Freeway
as it pertains to the department.
8. Employee must be able to competently enter strain, batch, package ID,
weight increment and quantity information into MJ Freeway purchase
orders.
9. Pre Pack staff is responsible for delivery of product from OPC to MMC
and must be familiar with and follow all security procedures and
guidelines.
10. Pre-Pack staff must prove they are trustworthy, cautious and attentive
when delivering product.
11. Pre-Pack staff must follow the rules, regulations, policies, and
procedures in accordance The Companies Medical Marijuana Center's
mission, vision, goals, and objectives in all areas of their work.
12. Employee must show up on time for work every day ready to work.
13. Employee must exhibit consistent processing technique, tracking and
meeting of production goals.
14. Employee must exhibit personal hygiene and follow the health
guidelines set forth by The Company and the state while
processing/packaging patient medicine.
15. Pre-Pack staff is responsible for clean-up of all processing areas and
equipment at the end of every day.
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Additional Functions:
16. Ability to be flexible and work in various sectors of the department as
needed and/or requested by their direct supervisor; this may include but
is not limited to, helping grow staff with small tasks, cleaning and/or
moving supplies and equipment and/or helping the trim department as
needed.
17. Must work well with others and be able to adapt quickly to changes in
policy, procedure and technique.
18. Must exhibit caution and reliability with delivery of product to store in
regards to personal safety, as well as product safety.
19. Help create a proactive and positive environment; a positive attitude
and self-motivation to help produce high quality pre-packed medicine
for patients, while meeting and/or exceeding personal & company
goals.
20. Be able to work with, help, guide, challenge and motivate other pre-
pack team members in order to create a cohesive unit.
21. Ability to research, evaluate and adapt to new methods, in order to meet
or exceed goals, as well as quality of finished product, and useable by-
product.
22. Employee must be able to adapt to various strains, styles and types of
marijuana they are packaging; making quality control decisions as
necessary.
23. Employee must have basic organizational capabilities, as well as be
able to run basic computer tasks.
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24. Time management; employee must manage their time during work
efficiently in order to meet goals while consistently producing quality
product.
25. Employee must be able to follow basic instructions as well as be able
to take constructive criticism from their managers, so they can help
maintain quality standards and production goals.
Job Specifications:
26. Basic knowledge and understanding of marijuana processing; proper
technique and handling of finished product so as not to degrade the
quality while packaging.
27. Basic knowledge of tracking system as it relates to Cure Forms as
batches are packed and shipped.
28. Basic knowledge of MJ Freeway in regards to store inventory, as well
as creating a purchase order and entering all data correctly.
29. Understanding and implementation of the techniques, policies,
procedures and goals of The Clinic Medical Marijuana Center and
affiliates, with an emphasis on continual personal growth and goals.
30. Basic knowledge and understanding of local, state and MMED laws
and statues; with an emphasis on continual knowledge and
understanding.
31. Fundamental knowledge, as well as the ability to be taught and guided
in areas related to harvesting, drying, trimming and curing; initially
focusing curing and packaging with other areas being taught as the
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employee shows interest while still maintaining their capabilities as a
trimmer.
32. Skill in analyzing potential problems with a plant or the product being
processed/packed; ability to identify problems with batches that may
have been over looked, and bringing these issues to their managers
attention.
33. Show self-motivation/innovation and the ability to work well with all
members of their staff and the company, as well as with their direct
supervisor.
34. Ability to listen well and communicate effectively orally and in writing
with various audiences, especially with the direct supervisors and other
team members.
35. Ability to use initiative and independent judgment appropriately while
not overstepping chain of command.
36. Ability to establish and maintain effective working relationships with
all employees, upper management, and other departments.
37. Ability to perform a monotonous task with great efficiency over 8 hour
work periods without losing quality or ability to track properly.
Additional Requirements:
38. Colorado driver's license or State ID card
39. Must be a minimum of 21 years of age
40. Must pass all required background checks
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 31 of 68
41. Must be and remain compliant with all legal or company regulations
for working in the industry
42. Must be approved by the MMED to receive a support badge.
43. Must have a vehicle registered in the state of Colorado.
(2) Armed Dispensary Security Guard
Description:
Armed security officer will be responsible for securing personnel and
premises of dispensary (inside & out). This will be done by thoroughly
patrolling property by foot, and visually monitoring surveillance equipment,
inspecting buildings, and any/all persons. May do some light computer work
to include - checking in patients, vendors and confirming valid paperwork and
ID’s.
Requirements:
1. Valid CA Guard Card
2. Valid CA Exposed Firearm Permit
3. Must own firearm (of qualifying caliber)
4. Must have reliable transportation
5. Must possess a valid CA driver’s license
6. Must be punctual
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 32 of 68
(3) Asset Protection Associate - Overnight Security
Summary
The Asset Protection Associate is primarily responsible for protecting
company assets by performing loss prevention duties and ensuring
compliance with company security policies and procedures. Performs
surveillance duties, information gathering, and site inspections of company-
owned facilities. Responsible for adhering to policies to mitigate risk and
reduce loss. Maintains knowledge of progressive loss prevention methods and
shrink prevention strategies, as well as surveillance systems. The Asset
Protection Associate reports to the Asset Protection Manager who manages
all Asset Protection Department staff.
Essential Duties and Responsibilities
1. Maintains a friendly, courteous, and compassionate demeanor at all
times;
2. Adheres to company mission statement and core values and maintains
high ethical standards and professionalism in all business interactions;
3. Coordinates with Investigator(s) and law enforcement to assist with
performing investigations;
4. Coordinates with management and Executive Officers to report
investigation findings;
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 33 of 68
5. Responsible for maintaining the integrity of all confidential
information;
6. Works independently to perform asset protection duties with minimal
oversight;
7. Proactively identifies high-risk areas of loss, high-risk employees, and
responds to notices of reported criminal activity by employees or at
company-owned facilities;
8. Understands the complexity of compliance requirements governing our
businesses, including the following types of regulatory agencies:
Marijuana Enforcement Division, Fire Department, City Zoning and
Planning, Colorado Department of Public Health and Environment, and
more.
9. Responsible for reading and understanding regulatory requirements and
company policy to relay information to stakeholders;
10. Performs research and coordinates with retail managers to gather
information and observe employee activity to prevent loss and
determine compliance with Standard Operating Procedures and
company policy;
11. Adapt to a variety of working environments including offices, with
ability to professionally interface with a range of employees and the
public;
12. Responsible for reading and understanding all department-specific
Standard Operating Procedures and documentation;
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 34 of 68
13. Completes a variety of Reports following incidents or investigations to
initiate next steps for Management staff, Investigator(s) and Executive
Officers;
14. Prepare Bank Deposits by performing cash handling duties, such as,
counting and verifying logs and adhering to all cash handling policies
15. Adheres to coin vault policy and provides coinage distribution
16. All other job duties as assigned.
Qualifications / Education
17. High School Diploma or GED required;
18. Associate or Bachelor’s degree in any field required; Criminal Justice
degree preferred;
Training
19. Must maintain current knowledge of and adhere to all policy and
regulations of the Colorado Marijuana Enforcement Division (MED);
Colorado Department of Public Health and Environment (CDPHE),
and Health Insurance Portability and Accountability Act (HIPAA), and
TGS Management.
Required Skills & Experience
20. Excellent computer, mathematical, language, and reasoning skills;
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 35 of 68
21. High-level attention to detail, administrative skills, and highly
organized;
22. Experience using web browser applications and familiarity with current
versions;
23. Knowledge of Colorado marijuana laws, MED regulations, HIPAA,
and CDPHE requirements;
24. Ability to work independently with little or no direct supervision.
Preferred Skills & Experience
25. Previous law enforcement, military, government and/or security
experience;
26. Previous marijuana industry experience preferred with priority given to
candidates with experience in CO licensed facilities.
27. Previous high-volume cash handling with cash register and banking
services experience.
Other Requirements Physical Requirements
28. Must be able to individually lift up to 25 lbs.;
29. Must be able to sit, stand, stoop, crouch, reach, and lift for long periods
of time.
** Reasonable accommodation(s) may be made to enable individuals
with disabilities to perform the essential functions **
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 36 of 68
Work Requirements
30. Must be able to work in an office environment with moderate to loud
noise level;
31. Must be able to work off-site in retail, manufacturing, or production
facilities with moderate to loud noise level and changing working
conditions; May require use of safety equipment or personal protective
equipment, as needed;
32. Must have and be able to maintain valid driver’s license;
33. Must be able to acquire City & County of Denver Merchant Guard
badge (Application Fee: $50.00, Annual License Fee: $25.00, CBI
Name Check: $6.85 [$81.85 Total] Fees to City) prior to beginning
employment;
34. Must be able to acquire MED Key badge ($300 Fee to State of CO)
prior to beginning employment.
Travel Requirements
35. Regularly requires local travel, as needed.
Required education
36. High school or equivalent
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 37 of 68
Required experience
37. Loss Prevention: 1 year
38. Security: 1 year
39. Asset Protection: 1 year
Required license or certification
40. MED Badge
(4) Safety Associate
PLEASE NOTE: All applications MUST be accompanied by a cover
letter that clearly describes your interest in the medical cannabis industry. Any
application received without such a cover letter will not be considered.
SUMMARY
Maintain a high profile and be a visible deterrent while positioned at
each post to ensure the safety of all staff, patients, visitors, and assets of
Company. Interact with visitors, vendors and staff members in a positive
manner while maintaining order and compliance with Company policies and
rules of conduct. Provide exceptional service in all interactions. Understand,
embrace and embody the mission of Company.
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 38 of 68
ESSENTIAL FUNCTIONS AND DUTIES
(This list is not intended to be all inclusive)
1. Provide excellent service and exceptional interactions with all visitors,
patients and staff to achieve Company standards
2. Utilize effective communication skills and demonstrate a sense of
urgency to ensure that all phases of the visitor experience remain
seamless and exceed their expectations
3. Verify Government Issued identification and other credentials of
visitors prior to allowing entry to the Company farm
4. Conduct routine foot patrols of the farm, and property to insure
compliance with rules and restrictions
5. Accurately and effectively communicate with other staff members
using a handheld two-way radio of any condition or event that may pose
a safety or security concern
6. Monitor CCTV surveillance equipment for potential threats and
suspicious activity
7. Resolve visitor issues and de-escalate, as appropriate
8. Protect visitors, staff and farm assets from harm and/or theft
9. Maintain a positive, caring attitude and treat visitors/co-workers with
respect and compassion
10. Listen and respond to visitor and coworker needs/requests
appropriately and timely
11. Maintain neatness, cleanliness, and organization of the department
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 39 of 68
12. Maintains discretionary practices with all vendors, voucher and
contractor information; tactful with all sensitive business information
13. Follow and integrate Company policies and procedures into all on-the-
job interactions, tasks and behaviors
OTHER FUNCTIONS AND DUTIES
(This list is not intended to be all inclusive)
14. Complete incident reports accurately and timely
15. Assist to maintain and ensure departmental equipment is functioning
and in good working order
16. Attend required meetings and participate in team and professional
development activities
17. Fill in when short-staffed
18. Provide timely and appropriate feedback to Supervisor
19. Perform other duties as assigned by Supervisor
JOB SPECIFIC PERFORMANCE REQUIREMENTS:
(Knowledge, Skills and Abilities)
20. Knowledge of safety procedures and protocols
21. Strong problem solving and interpersonal skills
22. Ability to remain calm and professional in difficult situations
23. Ability to lead and follow directions
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 40 of 68
24. Exceptional conflict resolution skills and the ability to de-escalate
situations
25. Excellent communication skills
26. Basic computer operating skills
27. Basic email correspondence skills
28. Basic math skills
29. Speak and be literate in English to the extent of writing, reading and
understand printed regulations, orders, instructions, etc.
WORK CONTEXT:
Physical Requirements
30. Requires prolonged standing and some bending, stooping and
stretching
31. Ability to operate a computer, and other office equipment
32. Moving up to 50 pounds on occasion
Working Conditions
33. Work will generally be performed both inside and outside the farm
34. Work is subject to weather conditions, including rain and extremely hot
or cold temperatures at times
35. Involves frequent contact with vendors, patients and staff
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 41 of 68
36. Will require working varied hours/day, including nights weekends,
holidays, and/or events, on occasion
37. May include working an alternative workweek
EDUCATION, EXPERIENCE AND OTHER REQUIREMENTS
38. Experience in working as a security officer, military police, law
enforcement, corrections officer, and/or some college with emphasis on
criminal justice or related field (prefer 2+ years)
39. HS diploma, GED or equivalent
40. 21+ years old and pass a criminal background check
41. Experience working in the medical cannabis and/or health industry
highly desirable
42. Guard card/certification a plus
CERTIFICATIONS OR LICENSES REQUIRED
43. Current medical cannabis recommendation
Job Type: Full-time
Required education:
44. High school or equivalent
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 42 of 68
Required experience:
45. Law Enforcement: 2 years
Required license or certification:
46. Guard
(5) Manufacturing Technician
The Manufacturing Technician will contribute, as necessary, to the
uninterrupted supply of safe, pure and of controlled potency finished
medicinal products, ensuring no lapse in patient access. The Manufacturing
Technician will professionally represent the company in all daily activities.
Essential Functions:
* Reasonable accommodations may be made to enable individuals with
disabilities to perform the essential functions.
1. Perform weigh and dispense actives of finished product raw materials
and recipients.
2. Operate downstream manufacturing machinery including, but not
limited to, agitators, liquid filling, encapsulation, compression,
packaging and labeling.
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 43 of 68
3. Document all manufacturing activities consistent with Good
Manufacturing Practices.
4. Participate in the commissioning of new process equipment.
5. Perform manual manufacturing activities as required.
6. Perform manual, semi-automatic and automatic equipment cleaning,
including controlled drying and storage procedures.
7. Maintain manufacturing and facility spaces in a clean state.
8. Maintain room and equipment logbooks.
9. Maintain a safe work environment, actively contributing to continuous
improvements. This may include inspection of fire suppression
equipment, personnel emergency showers and eye wash stations as well
as ensuring the local availability and use of required personal protective
equipment.
10. Maintain personal training status and records consistent with company
policies and procedures.
11. Train less experienced manufacturing technicians, ensuring their
documentation of same.
12. Contribute to the creation of and revision to Manufacturing Standard
Operating Procedures.
13. Perform minor equipment and facility maintenance activities.
14. Utilize proprietary software regarding detailed, regulated material
identification labeling, location and inventory level tracking.
15. Submit consistent with identified standard lead-times regulatory
agency notifications of both sample and finished product delivery
movements.
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 44 of 68
16. Perform cannabis plant de-stemming procedures.
17. Support as necessary Cultivation personnel and activities.
18. Perform periodic manufacturing raw material and component inventory
counts, ensuring uninterrupted material supply in advance of their
scheduled use.
19. Contribute to process improvements including machine
recommendation and purpose as well as work flow assessments.
20. Lead compliance activities regarding instrument calibrations and
preventive maintenance.
21. Communicate daily and effectively with the Manufacturing Manager
and Technician peer group.
Competencies:
22. The ability to perform general mathematical calculations including
addition, subtraction, multiplication and division.
23. Attention to detail in all aspects of job responsibilities, including but
not limited to good documentation practices, strict adherence to
Standard Operating Procedure and Manufacturing Batch Record
instructions, equipment and area hygiene and safety, gowning
requirements adherence, the release versus quarantine status of all
manufacturing materials, general labeling requirements.
24. The ability to liaise constructively and effectively with manufacturing
support groups including, but not limited to, Quality Assurance, Quality
Control, Process Sciences, Cultivation, Facility Maintenance, Security
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 45 of 68
as well as contract vendors or equipment start-up and/or maintenance
representatives.
25. The ability to accurately and precisely operate laboratory scales.
26. The ability to professionally represent the company in all personnel
interactions including those associated with regulatory agency
inspection and/or audits.
27. The ability to perform all job functions in direct compliance with
written instruction.
28. The ability to recognize machine normal operating conditions (e.g.
sound, temperature, speed, accuracy, smell) and the initiative to take
direct action in the event of any equipment anomaly including, machine
shut-down, product protection and informing Manufacturing and/or
Quality management.
29. The ability to quickly comprehend the set-up, operation, controls and
trouble-shooting of new machine equipment.
30. The ability to interpret in-process and finished product analytical
assays.
31. The ability to maintain the flexibility required to support the company
through anticipated continual growth and expansion.
Supervisory Responsibility
32. This position has no supervisory responsibilities.
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 46 of 68
Work Environment
33. This position works in a manufacturing facility that contains potent
chemicals and machinery. Employees are required to wear appropriate
protective clothing and equipment when handling these materials.
Physical Demands
34. The physical demands described here are representative of those that
must be met by an employee to successfully perform the essential
functions of this job.
35. While performing the duties of this job, the employee is regularly
required to talk or hear. The employee is regularly required to stand,
walk or sit; use hands to finger, handle or feel objects, tools, or controls;
and reach with hands and arms. Specific vision abilities required by this
job include close vision and the ability to adjust focus.
Position Type and Expected Hours of Work
36. This is a full-time position. Typical days and hours of work are Monday
through Friday 9:00 a.m. to 6:00 p.m. Some overtime is required.
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 47 of 68
Travel
37. No travel is expected for this position.
Required Education and Experience
38. High School Diploma or Equivalent
39. 1-2 yrs experience in audited/regulated laboratory environment.
Preferred Education and Experience
40. BS/BA in the Sciences (preferably Biological Science, Organic
Chemistry or Pharmacology)
Additional Eligibility Qualifications
41. SQF, HACCP, SOP, ISO, GMP Knowledge/Certifications.
Work Authorization/Security Clearance
42. No Hi-B sponsorship. Completion and successful passing of
Background and Drug Screen. No relocation package available.
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 48 of 68
Job Type: Full-time
Required education:
43. High school or equivalent
Required experience:
44. manufacturing raw material and component: 1 year
45. laboratory scales: 1 year
46. agitators, liquid filling, encapsulation, compression, packaging and
labeling: 1 year
47. year of related: 1 year
(6) Facility Security Coordinator
Summary
The Security Coordinator is primarily responsible for supporting
effective operations by performing facility audits through verifying key
assignments, access and security codes, badge possession, coinage logs,
performing regularly-scheduled camera reviews, and verifying facility access
logs; Responsible for creating Audit Reports to initiate next steps and
coordinating with management staff in response to audit findings.
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 49 of 68
Essential Duties and Responsibilities
1. Maintains a friendly, courteous, and compassionate demeanor at all
times
2. Adheres to company mission statement and core values and maintains
high ethical standards and professionalism in all business interactions
3. Coordinates with Manager, staff and stakeholders in small group
settings to execute company mission statement and to establish, update
and implement auditing procedures
4. Understands the complexity of compliance requirements governing our
businesses, including the following types of regulatory agencies:
Marijuana Enforcement Division, Fire Department, City Zoning and
Planning, Colorado Department of Public Health and Environment, and
more
5. Responsible for reading and understanding regulatory requirements and
company policy to relay information to stakeholders
6. Responsible for legal compliance with all regulatory requirements, by
researching, auditing and verifying a variety of data
7. Audits internal security policies and makes recommendations for
improvements and best practices, in adherence to Crime Prevention
Through Environmental Design (CPTED) standards
8. Performs research and coordinates with retail managers to gather
information and observe employee activity to determine compliance
with Standard Operating Procedures and company policy
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 50 of 68
9. Performs perimeter checks and facility inspections to verify compliance
with all company security and access policies;
10. Performs regularly-scheduled alarm system checks and replaces
batteries to ensure ongoing operations
11. Adapt to a variety of working environments including offices, with
ability to gather information from a range of employees
12. Responsible for accessing and updating documentation using a variety
of software applications and operating systems
13. Responsible for reading and understanding all Standard Operating
Procedures and documentation accessed during audits and the
verification process
14. Responsible for performing daily audits of the following systems: key
assignments, access and security codes, badge possession, perform
regularly-scheduled camera reviews, and verify facility access logs
15. Acts as a checks and balances auditor of Armored personnel and
operations in all divisions
16. Completes Audit Reports following daily audits to initiate next steps
for Investigators, Auditors, and Management staff
17. May assist with employee training programs including New Hire
Orientation and facility security
18. Coordinates with management staff of retail stores and cultivation
facilities to troubleshoot DVR, alarm and surveillance system issues
19. Identifies physical security environmental needs and maintains a master
list of security coeds and security schedules
20. All other job duties as assigned
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 51 of 68
Qualifications Education
21. High School Diploma or GED required
22. Associate or Bachelor’s degree in any field preferred
Training
23. Must maintain current knowledge of and adhere to all policy and
regulations of the Colorado Marijuana Enforcement Division (MED);
Colorado Department of Public Health and Environment (CDPHE),
and Health Insurance Portability and Accountability Act (HIPAA), and
TGS Management
Required Skills & Experience
24. Excellent computer, mathematical, language, and reasoning skills
25. High-level attention to detail, administrative skills, and highly
organized
26. Experience using Microsoft Office applications and familiarity with
current versions
27. Ability to follow established company protocol for digital and printed
document storage
28. Risk analysis experience required, auditing experience preferred;
Locksmith knowledge helpful
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 52 of 68
29. Knowledge of Colorado marijuana laws, MED regulations, HIPAA,
and CDPHE requirements
30. Ability to work independently with little or no direct supervision
Preferred Skills & Experience
31. Previous locksmith, key duplication and/or facility security experience
32. Familiarity with Crime Prevention Through Environmental Design
(CPTED) standards
33. Previous marijuana industry experience preferred with priority given to
candidates with experience in CO licensed facilities
34. Interviewing, interrogation and/or information gathering experience
helpful
35. Retail, operations and/or security experience a plus
Other Requirements Physical Requirements
36. Must be able to individually lift up to 25 lbs.
37. Must be able to sit, stand, stoop, crouch, reach, and lift for long periods
of time
**Reasonable accommodation(s) may be made to enable individuals
with disabilities to perform the essential functions**
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 53 of 68
Work Requirements
38. Must be able to work off-site in retail, manufacturing, or production
facilities with moderate to loud noise level and changing working
conditions; May require use of safety equipment or personal protective
equipment, as needed
39. Must have and be able to maintain valid driver’s license
40. Must be able to acquire MED Key badge ($300 Fee to State of CO)
prior to beginning employment
Travel Requirements
41. Regularly requires local travel, as needed.
Job Type: Full-time
Required license or certification:
42. MED Badge
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 54 of 68
(7) Security Guard
PRIMARY DUTIES:
1. Greet and confirm the legal age of all customers ensuring compliance
with all current regulations around identification.
2. Enforce store directives around issues such as loitering in front or back
of store, smoking and/or vandalism of the store or store property.
3. Remain stationed at front of store, for long periods of time and to
provide a strong visible presence to customers and staff.
4. Follow all directives and policies regarding firearms, intoxicated
customers and regulations around open products.
5. Support staff with all customer situations that may require your
assistance such as hostility, inappropriate language, inappropriate
touching etc.
6. Ability to work closing shifts and work with the closing Manager to
insure the safety of all staff exiting the building.
7. Work with the store Management team to insure a safe workplace for
all staff.
QUALIFICATIONS:
8. Must be at least 21 years of age
9. Previous security experience desired
10. A calm but firm demeanor that is also polite and helpful
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11. Ability to adapt and deal with the unexpected
12. Must be willing to participate in our random (illegal) drug testing
13. Consistent work history
BENEFITS INCLUDE:
14. Competitive wage
15. Generous product discounts
16. Working in an environment focused on Educating, Celebrating and
Elevating the Cannabis industry!
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 56 of 68
Physical Security Program
Security concerns are of utmost importance for the medical &
recreational cannabis industry. Apart from the obvious reasons, is the reason
of validating the professionalism on today’s business owners & practices. We
need to do this thing right! Too many patients & customers who benefit from
cannabis will be affected in a negative way… if the industry were to get shut
down.
That being said, let’s look at the six most common places you may find
yourself working as a security professional… in the cannabis industry:
1. Dispensaries
2. Cultivators
3. Nurseries
4. Distributors
5. Transporters
6. Testing labs
Each of the above places will have its’ own ‘heartbeat’ or ‘feeling’. As
a security professional, you need to be acutely aware of and in tune with…
the heartbeat / feeling of the environment you’re protecting. Develop your
‘6th sense’ in regards to this matter. When you do that, creating or working
within a quality security program will be much easier.
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 57 of 68
All security programs must do five basic things. Those five things are:
1. Deter
2. Detect
3. Delay
4. Alert
5. Respond
Let’s look at the above model, in regards to the two risks we mentioned
in the beginning of this manual, Cash & Employees. We’ll do this by turning
the model into questions.
Risk of cash being stolen from non-employees
1. How does my security system deter bad guys from choosing my
location to steal from?
2. If a bad guy does break in or rob us, how does my security system
detect this?
3. Once a break-in or robbery is under way, how does my security
system slow down the tempo of the crime? Specifically, from
the initial entry to the point where they put their hands on our
cash.
4. How and who does my security system alert, when a break-in or
robbery occurs?
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 58 of 68
5. Who responds to the alert? How should they respond? What
should the response force NOT do? (For example, physically
intervene… or chase off property.)
Risk of employees stealing cash or product
1. How does my security system deter employees from attempting
to steal or provide information to non-employee bad guys?
2. If an employee does steal from us or conspire to do so, how does
my security system detect this?
3. Once an employee theft is under way, how does my security
system slow down the tempo of the crime? Specifically, from
the point where they acquire company cash / product… to the
point they leave the building… and then property-line, with it.
4. How and who does my security & inventory system alert, when
a product / cash diversion occurs?
5. Who responds to the alert? How should they respond? What
should the response force NOT do? (For example, physically
intervene… or chase off property.)
The above two sets of questions will normally be drawn up and
answered by security management… in the first stage of program
development. Then, human resources, legal, and production management -
along with senior leadership should meet to review the program.
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 59 of 68
During this review meeting, the group will study, verify, challenge, and
punch holes in the program. Then security management takes all of that input
back to their office - and updates / revises the plan.
Knowing this ahead of time, the security professional creating the first
draft of the program will want to do a very complete and respectable job with
the task. I recommend creating a plan with an “Outside, In” approach. For
example, a program outline may look something like this:
Outer Property Line
Signage
Lighting
Video surveillance
Water & Electrical Post / Box Sensors & Alarms
Fence Line
Signage
Vibration sensors & alarms
Lighting
Video surveillance
Parking Lots / Walkways / Break Areas (inside the fence line)
Signage
Lighting
Video surveillance
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 60 of 68
C.P.T.E.D. (Crime Prevention Through Environmental Design)
Doors / Windows / Emergency Egress Ladders; Etc.
Contact Sensors
Glass Break Sensors
Environmental Sensors
Video Surveillance
Building Interior (Hallways; Offices; Breakrooms; Stairwells; etc.)
Video Surveillance
Restricted Areas (Production; Exec Offices; Storage; etc.)
Signage
Contact Sensors
Glass Break Sensors
Environmental Sensors
Video Surveillance
Employee Access Cards With Specific “Shift Times Allowed”
Cages / Vaults
Contact Sensors
Video Surveillance
Panic Buttons
In addition, I frequently recommend:
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 61 of 68
1. Having A Dog Handler On Duty, To Respond To Alarms
2. 24/7 Manning
3. Stationary Guards, Armed & Unarmed
If you’re ever in need of ideas concerning cages, vaults, fencing, etc.
for your operation / facility… go look at what the D.E.A. Manuals say. Their
information is free and online! Since the US Gov’t (at the time of this writing)
still considers Cannabis a Schedule 1 controlled substance… they provide
security requirements to both practitioners & non-practitioners. Let’s define
those two terms, from the D.E.A.’s perspective.
‘Non-practitioners’ include manufacturers, packagers, labelers,
distributors, importers, exporters, narcotic treatment programs, and
compounders for narcotic treatment programs.
‘Practitioners’ include physicians, dentists, veterinarians, researchers,
hospitals, pharmacies, or other persons registered to do research, to dispense,
or to use in teaching or chemical analysis a controlled substance in the course
of professional practice.
In order to gain the respect and cooperation of oversight agencies, it’s
imperative we speak their language. For that reason, I want to share with you
a few excerpts from the DEA’s public website.
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 62 of 68
Minimum Standards: Handlers of CI&II Controlled Substances
Small quantities of CI&II raw materials, bulk materials awaiting further
processing, and finishing products must be stored in an Underwriters Lab
(UL) listed burglary-resistant safe with a Group 1-R lock, or a General
Services Administration (GSA) Class V rated security container, or the
equivalent, which affords the following security protection:
1. 30 man minutes against surreptitious entry,
2. 10 man minutes against forced entry,
3. 20 man hours against lock manipulation,
4. 20 man hours against radiological attack.
This safe or security container must be bolted, strapped, or otherwise
securely fastened to the floor or wall in such a way that it cannot be readily
removed if it weighs less than 750 pounds. Depending upon the quantities and
types of controlled substances stored, this safe or security container must be
equipped with an alarm system which upon attempted unauthorized entry
transmits a signal directly to a central protection company, a local or state
police agency which has a legal obligation to respond, a 24-hour proprietary
central station operated by the registrant, or such other protection as DEA may
approve.
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 63 of 68
Large quantities of such controlled substances which do not permit
storage in a safe or security container may be stored in a vault meeting the
following specifications or equivalent, if constructed after September 1, 1971:
1. The walls, floor and ceiling are constructed of at least eight inches of
reinforced concrete or other substantial masonry reinforced vertically
and horizontally with #4 (half inch) steel rods tied six inches on center,
or UL listed modular vault panels.
2. The door and frame unit are UL listed burglary-resistant, GSA Class V
rated or equivalent, i.e., multiple position Group 1-R combination lock,
relocking device, special metal alloy that resists carbide drilling, and in
general affords the overall security protection set forth above for safes
and security containers.
3. If operations require the vault/container to remain open to frequent
access, the door is required to be equipped with a day gate which is self-
closing and self-locking. If the operation requires only that the vault be
opened infrequently, such as to remove raw material in the morning and
return it at night, and is always relocked immediately after use, a day
gate is not required.
4. The walls or perimeter are equipped with an alarm system which upon
attempted unauthorized entry must transmit an alarm directly to a
central protection company, local or state police agency which has a
legal obligation to respond, a 24-hour proprietary central station
operated by the registrant, or such other protection as DEA may
approve. If necessary due to local condition or other problems, holdup
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 64 of 68
buttons may be required to be placed at strategic points of entry or exit
from the perimeter.
5. The door is equipped with a contact switch(es) and there is complete
electrical lacing of the walls, floors and ceiling, sensitive ultrasonic or
infrared sensors within, a sensitive sound accumulator system, or other
such devices or equipment designed to detect unauthorized entry as
may be approved by the Drug Enforcement Administration (DEA).
Security Requirements For Practitioners
Minimum security standards for practitioners are set forth in the
regulations (Title 21 CFR 1300 to end) and are to be used in evaluating
security. They may not necessarily be acceptable for providing effective
controls and operating procedures to prevent diversion or theft of controlled
substances. For example, a hospital that keeps large quantities of controlled
substances on hand may need a safe or vault similar to the requirements for a
distributor. The same reasoning also applies to other practitioners.
A practitioner's overall security controls will be evaluated to determine
if they meet the intent of the law and regulations to prevent theft or diversion.
Minimum Standards for Practitioners' Handling of Controlled Substances
Controlled substances must be stored in a securely locked cabinet of
substantial construction. Pharmacies have the option of storing controlled
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 65 of 68
substances as set forth above, or concealing them by dispersal throughout their
stock of non-controlled substances.
Even though the Federal regulations do not specifically define locked
cabinet construction, the intent of the law is that controlled substances must
be adequately safeguarded. Therefore, depending on other security measures,
a wooden cabinet may or may not be considered adequate. In an area with a
high crime rate, a strong metal cabinet or safe may be required.
Some of the factors considered when evaluating a practitioner's
controlled substances security include:
1. The number of employees, customers and/or patients who have access
to the controlled substances.
2. The location of the registrant (high or low crime area).
3. Use of an effective alarm system.
4. Quantity of controlled substances to be kept on hand.
5. Prior history of theft or diversion.
Again, an overall evaluation of the practitioner's security will be made
by DEA using the general and minimum security requirements as outlined in
this manual to assure that the controlled substances are stored securely.
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 66 of 68
Other Security Controls for Practitioners
In order to minimize the opportunities for theft or diversion of
controlled substances, practitioners have an obligation not only to provide
effective physical security, but also to initiate additional procedures to reduce
access by unauthorized persons as well as to provide alarm system where
necessary.
Loss or Theft
A practitioner shall notify the nearest DEA Field Office of the theft or
significant loss of any controlled substance upon discovery of such loss or
theft. The practitioner shall promptly complete and submit DEA Form 106
regarding the theft or loss.
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 67 of 68
In Conclusion
Providing high-end security for businesses in the cannabis industry is
vitally important to the progression - of that industry. Supporters need to be
calm, professional, articulate, and COMPLIANT. This cannot be overstated.
All it takes is one business doing something illegal… and a powerful political
opponent can use that incident to halt or even reverse the progress made over
the past few years.
I’m passionate about the industry because I know the value of cannabis.
I’ve had terminally ill family members find relief with the product. I’ve also
had many military friends use medical marijuana to help manage their
symptoms. Hopefully this course will become an increasingly positive part
of the success, the cannabis industry needs.
In addition, I’m passionate about helping security guards, officers,
supervisors, and managers improve their careers. Professional security is
about assessment, anticipation, awareness, and calm response. By studying
this course and putting the knowledge into action… you can be a major part
of the growth and success of your employing company. (or your own
business).
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International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 68 of 68
International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 68 of 68
Resources
The Leading Cannabis Business Security Provider
http://www.security-mpsi.com/
Medical Marijuana Laws by State
http://healthcare.findlaw.com/patient-rights/medical-marijuana-laws-by-
state.html
Arizona Dispensary Laws – The Basics
http://naturesmedicines.com/arizona-dispensary-laws-the-basics/
New York State Medical Marijuana Program
https://www.health.ny.gov/regulations/medical_marijuana/
Open A Dispensary
http://www.greenrushconsulting.com/open-a-dispensary
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