Are You Complying With The BCC Requirements For Video Surveillance?

Cannabis businesses in California have taken off. And more will undoubtedly start up as cannabis is predicted to be a $6.59 Billion industry by the year 2025. California’s cannabis industry policies and rules are still evolving just like with other states. There are even regulations for video surveillance of cannabis facilities. If you don’t keep up with these requirements, your cannabis business could be at risk of non-compliance.

To help we’ve provided some specifics about the Bureau of Cannabis Control (BCC) requirements for video surveillance.

Do All Licensed Cannabis Businesses In California Need Video Surveillance?

Licensed businesses and licensed microbusinesses authorized to engage in the sale of cannabis must record point-of-sale areas and areas where cannabis goods are displayed for sale on a video surveillance system. The same is true for nurseries, cultivation, transportation, distribution, manufacturing, and retail businesses.

At each point-of-sale location, camera placement must allow for the recording of the facial features of any person purchasing or selling cannabis goods, or any person in the retail area, with sufficient clarity to determine identity.

What Are The Requirements For A Digital Video Surveillance System?

• Each licensed premises must have a digital video surveillance system with a minimum camera resolution of 1280 × 720 pixels.
• The video surveillance system must be able to effectively and clearly record images of the area under surveillance at all times.
• Each of your cameras must be permanently mounted and in a fixed location, and each camera must be placed in a location that allows it to clearly record activity occurring within 20 feet of all points of entry and exit on your premises.
• Placement of the video cameras must provide clear and certain identification of any people or activities in the areas that are required to be filmed.

 

What Areas Of Our Cannabis Facility Must Be Surveilled?

1. Areas where cannabis goods are weighed, packed, stored, loaded, and unloaded for transportation, prepared, or moved within the licensed premises;

2. Limited-access areas;

3. Security rooms;

4.Areas storing a surveillance-system storage device with at least one camera recording the access points to the secured surveillance recording area; and

5. Entrances and exits to your premises, which must be recorded from both indoor and outdoor vantage points.

 

Do We Need To Provide A Diagram Of Our Video Surveillance System To The BCC?

You must provide a diagram that shows where all of your video surveillance cameras are located. You must also assign a number for each of your cameras for identification purposes. You are exempt from this if you have a Distributor Transport Only License.

What Other Regulations For Video Surveillance Must We Follow?

• Cameras must record continuously 24 hours a day and at a minimum of 15 frames per second (FPS).
• The physical media or storage device on which surveillance recordings are stored must be secured in a manner to protect the recording from tampering or theft.
• Video surveillance recordings must be kept for a minimum of 90 calendar days.
• Your surveillance recordings are subject to inspection by the Bureau of Cannabis Control and must be kept in a manner that allows the Bureau to view and obtain copies of the recordings at your premises immediately upon request.
• You must also send or otherwise provide copies of the recordings to the BCC upon request within the time specified by the Bureau.
• Your recorded images must clearly and accurately display the time and date. The time should be measured in accordance with the standards issued by the United States National Institute of Standards and Technology (NIST).
• Your video surveillance system must be equipped with a failure notification system that notifies you of any interruption or failure of the video surveillance system or video surveillance-system storage device. (Note: Your IT Service Provider should be capable of providing this along with exception reporting.)
• If you have multiple licensed premises in the same building, a single video surveillance system covering the entire building may be used by each licensee under the following conditions:

1. You must disclose on your premises a diagram where the surveillance recordings are stored.

2. You must include in your security operating procedures (submitted with the application pursuant to Security Procedures, Form BCC-LIC-018 (New 10/18) in section 5002(c)(29)(D)) an explanation of how the video surveillance system will be shared, including who is responsible for monitoring the video footage and storing any video recordings.

3. You must have immediate access to the surveillance recordings and be able to produce them pursuant to inspection by the Bureau. They must be kept in a manner that allows the Bureau to view and obtain copies of the recordings at the licensed premises immediately upon request.

4. You will be held responsible and subject to discipline for any violations of the video surveillance requirements.

What About Mobile Surveillance?

As BCC requires 24-hour video surveillance for transport of cannabis, you should also implement video surveillance in your delivery vehicles. Once your facility has a reliable video surveillance system and the proper cameras in place, it’s advised to extend video surveillance to your delivery trucks, vans, cars, etc. With this, you can ensure your product is tracked with video to ensure it’s securely transported from one location to another.

What Else Do We Need To Know About Video Surveillance?

Make sure that the provider you choose for your video surveillance system understands all of these requirements so you won’t violate the BCC’s Requirements For Video Surveillance.