Compliance Resources
As we know, the Maine Cannabis industry is still evolving.
Keep up to date with the latest compliance requirements.
Find the most current documentation from the State of Maine Office of Cannabis Policy: https://www.maine.gov/dafs/ocp/medical-use/rules-statutes
Maine State Ordinance | Adult Use Cannabis Program Rule 18-691 C.M.R.
How can DL Automation help?
DL Automation can help you be complaint by providing consulting services including:
On-site walk through to create and provide a detailed site map showing all devices to become part of your required Written Security Plan outlined in section 3.3.4
Give Brian a call today 207-200-8343.
Office of Marujuana Policy 18-691 Chapter 4 | Section 6 Manufacturing Facility Security Requirements
6.1 – Security
A. The manufacturing facility must develop and implement security protocols that can ensure the security and tracking of marijuana on the premises, and prevent diversion, theft and loss of medical use marijuana.
B. The security protocol must be documented in writing and available to all registered manufacturing facility personnel during normal business hours.
C. The manufacturing facility must ensure that personnel have a thorough understanding of the security protocol and must take disciplinary action against any owner, officer, assistant or board member who negligently or willfully violates the security protocol.
6.2 – Access Control
The manufacturing facility must deter the unauthorized entrance into its premises by controlling access to those areas through the following means:
A. Limiting access to specific personnel who have cause to access the area to execute their specific job function and duties;
B. Implementing an access-control-card system capable of preventing unauthorized access through access control points and recording the transaction history of all entrants;
C. Using an actively monitored security alarm system;
D. Installing security cameras at all access points to the premises and in storage areas for medical use marijuana, products and concentrates; and
E. Maintaining a visitor arrival and departure log, which must contain, at a minimum, the name of the visitor, date and time of arrival and departure, and the purpose of the visit.
6.3 – Storage Areas
A. The manufacturing facility must store and secure marijuana with a commercial-grade lock in a room or cabinet capable of preventing diversion, theft and loss. Secured areas must be locked at all times, except when managing or retrieving a secured item or items. The total weight, measure or count of marijuana products and concentrates on the premises must be reported for compliance monitoring and auditing purposes.
B. The registered manufacturing facility must designate secure areas for storage of the following:
(1) Marijuana, marijuana products and marijuana concentrates;
(2) Test samples of marijuana for medical use;
(3) Waste containing marijuana; and
(4) Records of analytical tests, including certificates of analyses and data packages.
Chapter 1. Effective July 1, 2022 | Section 3.2.3 LIMITED ACCESS AREAS
3.2.3 Limited Access Areas.
A. Limited access areas include, but are not limited to:
(1) Areas in cultivation facilities in which mature cannabis plants, mother plants, immature plants or seedlings are grown; or cannabis is cut, stored, trimmed, cured or otherwise cultivated; cannabis is packaged for transfer; or cannabis waste is stored or processed.
(2) Areas in testing facilities in which cannabis or cannabis products are received, stored, handled, tested, transferred or discarded.
(3) Areas in cannabis product manufacturing facilities in which cannabis or cannabis concentrate is received, stored, combined with other ingredients or otherwise manufactured; cannabis products are stored, cooled, cut, packaged or labeled; cannabis or cannabis products are refrigerated; or cannabis waste is discarded or destroyed.
(4) Areas in cannabis stores in which a person would be able to touch or handle cannabis or cannabis products, including point of sale areas intended for employees only.
B. Any other area that is used to cultivate, store, weigh, manufacture, package or otherwise prepare for sale adult use cannabis and adult use cannabis products is also considered a limited access area.
C. It is the sole responsibility of the licensee to control access to limited access areas and limit access only to the following persons:
(1) The establishment’s owners, managers or employees who are displaying a valid individual identification card issued to that person;
(2) Sample collectors who are displaying a valid individual identification card issued to that person;
(3) Employees of a testing facility who are displaying a valid individual identification card issued to that person;
(4) Contractors aged 21 or older (including, but not limited to, electricians, plumbers, engineers or alarm technicians) who will not handle cannabis plants, cannabis or cannabis products, in compliance with this subsection;
(5) Staff or agents of the Department;
(6) Law enforcement officers; and
(7) Employees or agents of other local or state agencies with regulatory authority, including but not limited to fire marshals, electrical inspectors, pesticide control staff, and environmental inspectors.
D. Staff or agents of the Department, and employees or agents of local or state agencies with regulatory authority shall provide proof of identification but shall not be considered visitors and shall not be denied entry to any area of the premises.
E. Security.
(1) Nurseries and cannabis stores that admit persons 21 years of age or older for the purpose of purchasing cannabis plants, cannabis, or cannabis products shall use identification checks, locked doors, video surveillance, counters, and locked displays, in accordance with their Department approved security plan, to prevent unauthorized entry to limited access areas
(2) Other licensees shall use identification checks, locked doors, and video surveillance, in accordance with their Department-approved security plan, to prevent unauthorized entry to limited access areas.
(3) Any security breaches must be reported within 24 hours, in writing, to the Department.
F. Required Signage
(1) All areas of ingress and egress to limited access areas on the premises shall be clearly identified by posting a sign which shall be no smaller than 8.5 inches high and 11 inches wide, composed of letters not less than a half inch in height, which shall state: “Pursuant to State Law: Do Not Enter Authorized Persons Only.”
(2) If a person must pass through a limited access area to reach other limited access areas, and there is no other route through which a person can gain access to the subsequent limited access areas, then signage must only be posted on the first limited access area through which a person must pass.
G. Contractors and other authorized visitors.
(1) Contractors and other authorized visitors who will not handle cannabis plants, cannabis or cannabis products, including but not limited to electricians, plumbers, engineers and alarm technicians, do not require an individual identification card.
(2) A contractor may enter a limited access area only if wearing a visitor identification badge, signed in and recorded on a visitor entry log.
(3) At all times while in a limited access area, the contractor shall display in a conspicuous place on their person a visitor identification badge.
(a) The visitor identification badge must display an identifying mark, which may be a clearly identifiable letter, number or symbol or combination thereof.
(b) The visitor identification badge may be displayed on a sticker, a card on a lanyard, a card pinned to the clothing of the visitor, or by other effective means.
(4) A visitor entry log must include, at a minimum:
(a) The date and time of the visitor’s entry;
(b) The date and time of the visitor’s departure;
(c) The full name of the visitor;
(d) The identifying number of the visitor’s state- or federally-issued identification;
(e) The identifying mark on the visitor identification badge; and
(f) The purpose for which the contractor is accessing the limited access area[s].
Chapter 1. Effective July 1, 2022 | Section 3.3 SECURITY
Cultivation facilities, testing facilities, products manufacturing facilities, and cannabis stores must provide adequate security at the licensed premises. This section does not apply to sample collectors.
3.3.1 Mandatory Requirements for Cultivation Facilities, Testing Facilities, Products Manufacturing Facilities and Cannabis Stores. As applicable, cannabis establishments must enact security measures to prevent the diversion of cannabis or cannabis products that are being cultivated, manufactured, tested, packaged, stored, displayed or transported.
A. Lighting
(1) Any gate or perimeter entry point of a cannabis establishment must have lighting sufficient for observers to see, and cameras to record, any activity within 10 feet of the gate or entry.
(2) A motion detection lighting system may be employed to light required areas in low-light conditions.
B. Doors and windows
(1) Commercial grade locks, appropriate for facilities requiring high levels of physical security, are required on all perimeter entry doors and on all doors separating limited access areas from areas open to visitors and customers.
(2) All external entrances to indoor facilities on the licensed premises must be able to be locked.
(3) All perimeter windows must be in good condition and lockable.
C. Alarm system
(1) Monitored sensors are required on all perimeter entry points and perimeter windows, except that perimeter windows may be protected by appropriately located motion sensors
(2) Alarm systems must be monitored by a licensed security company capable of contacting the licensee and, if necessary, law enforcement.
(3) The system must include an audible alarm, which must be capable of being disabled remotely by the security company.
D. Video surveillance
(1) Placement and coverage of cameras shall be sufficient:
(a) Cameras must be permanently fixed inside each entry/exit point (perimeter and limited access area) to allow identification of persons entering the premises and limited access areas.
(b) Cameras must be permanently fixed outside each entry/exit point (perimeter and limited access area) to allow identification of persons exiting the premises and limited access areas.
(c) A sufficient number of cameras must be permanently fixed to allow the viewing, in its entirety, of any area where cannabis, cannabis plants, immature cannabis plants, seedlings, seeds, cannabis concentrate or cannabis products are cultivated, manufactured, stored or prepared for transfer or sale or where samples for mandatory testing are collected, and prepared and sealed for transport to a cannabis testing facility;
(i) Except that outdoor cultivation areas must have only a sufficient number of cameras permanently fixed to allow the viewing of the entirety of the perimeter of the cultivation area inside of the exterior fence; and
(ii) Indoor cultivation areas, including each grow room and each drying room, must have only a sufficient number of cameras permanently fixed to allow the viewing of all points of ingress and egress to and from the cultivation area.
(d) A sufficient number of cameras must be permanently fixed to allow the viewing, in its entirety, of any area where cannabis waste is stored before being made unusable, or where cannabis waste is made unusable.
(e) A camera must be permanently fixed at each point of sale to ensure identity of the purchaser.
(f) A sufficient number of cameras shall be permanently fixed to allow recording of all transactions conducted in areas designated by a cannabis store for curbside pickup by customers, including any areas not included in the licensed premises of the cannabis store but immediately adjacent to the primary public ingress and egress of the cannabis store where the cannabis store intends to conduct curbside pickup by consumers.
(i) Any curbside pickup location outside the licensed premises must be in a place designated for parking or standing and capable of being entirely within the view of cameras permanently fixed to the exterior of the licensed premises where such cameras can clearly capture the entirety of the transaction conducted via curbside pickup.
(g) A sufficient number of cameras shall be permanently fixed to allow recording of all areas outside of the premises within 10 feet of the exterior fence and gates of a cultivation facility with outdoor growing.
(h) Cameras, either mobile or fixed, must be maintained to allow recording of all transactions conducted via delivery. Cameras recording sales via delivery must be sufficient to record the entirety of the transaction and to ensure identity of the purchaser.
(2) Video surveillance shall meet the following minimum requirements:
(a) Minimum camera resolution is 720p.
(b) System storage and cameras are internet protocol (IP) compatible.
(c) All cameras must record continuously twenty-four hours per day or be motion activated and at a minimum of 15 frames per second.
(i) Motion activated video storage must capture and store footage for no less than 120 seconds prior to motion activation and 120 second following the cessation of motion.
(d) All recorded images must clearly and accurately display the time and date. Time is to be measured in accordance with the U.S. National Institute Standards and Technology standards.
(e) The surveillance system storage device must be secured on the premises in a lockbox, cabinet or closet, or must be on a third-party server or secured in another manner to protect from employee tampering or criminal theft.
(f) Surveillance equipment used to record deliveries shall be secured when not in use and recordings shall be uploaded to the surveillance system server, including if applicable, a third-party cloud-based server, within 24 hours of the transaction.
(g) Video surveillance is not intended to include the use of any computer software or application that performs facial surveillance as defined by 25 MRS § 6001 (1) (D) and (E).
(3) All surveillance recordings, including recordings made of deliveries, must be kept for a minimum of 45 days on the licensee’s recording device.
(4) All videos are subject to inspection by any Department employee and must be copied and provided to the Department upon request.
(5) Licensees shall maintain a list of all persons with access to video surveillance recording and procedures for controlling access to recordings.