Full Manual - Cannabis Security Operations - Ver 19

International Security Training, LLC © Security Operations For The Medical & Recreational Cannabis Industry Page 1 of 68


SECURITY OPERATIONS

FOR THE

MEDICAL & RECREATIONAL CANNABIS INDUSTRY



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.



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



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



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



Concentrates (dabs, oil, hash, wax,

shatter, etc.)

Vapor Pens (used to consume

concentrates)

Beverages

Tinctures and Sublinguals



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.



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.



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



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



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



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



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.



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.



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.



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.



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,



(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.



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.



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



(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.



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.



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.



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



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



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



(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;



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;



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;



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 **



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



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.



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



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



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



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:




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.



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.



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



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.



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.



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.



Job Type: Full-time

Required education:


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.



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



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



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



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**



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



(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



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!

___________________________________________________________

___________________________________________________________

___________________________________________________________

___________________________________________________________

___________________________________________________________

___________________________________________________________

___________________________________________________________



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.



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?



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.



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



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:



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.



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.



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



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



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.



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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_____________________________________________________________

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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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_____________________________________________________________



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

- End -