What type of remote security access is required to be provided to the Department per 19 CSR 100-1.090(1)(C)?

The Department interprets 19 CSR 100-1.090(1)(C) to mean we will make one (1) request during the Commencement Inspection process for continuous 24 hour access to the facility’s security system and that the system must be capable of complying with that real-time access request.  To be in compliance with 19 CSR 100-1.090(1)(C), licensees are required to provide the Department with continuous, 24 hour access to the facility’s security system via remote login. The Department should be able to gain access at all times without requesting further access.


Is key card loss or theft considered a reportable security malfunction, or could the facility just handle internally by deactivating the card?

The Department would not consider a lost or stolen key card as a reportable security malfunction. The Department would consider this act to be attempted theft if the loss or stolen key card was used to access the facility. An example of a reportable security malfunction would be a security camera losing connection.


Are continuous recording capabilities required pursuant to 19 CSR 100-1.090(1)(C)?

Yes. Video cameras are to provide continuous monitoring and must be capable of being accessed remotely at all times by the department or a law enforcement agency in real time. The use of motion detection as a method of continuous monitoring is not permitted where marijuana product is or will be present. Facility licensees shall store recordings from the video cameras for at least sixty (60) days and must provide copies of the recordings to the department upon request.

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