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The information within this article is current as of February 8, 2022.
Published by SLGA
Cannabis Regulatory Policy Manual
Appendix: Facility Security
SLGA has developed the following physical security requirements for cannabis wholesale, retail store, and retail off-site storage facilities located in Saskatchewan (referred to in this document as cannabis permitted premises). A detailed description of proposed security measures will be required as part of any permit application, and any changes to an approved plan or system must be authorized by SLGA in advance of implementation.
Subsection 1 describes requirements for cannabis wholesale, standalone retail, and off-site retail storage facilities. Physical security requirements for integrated retail stores, described separately in subsection 2, have been modified on the assumption that integrated stores in small communities will not typically have large amounts of cannabis on the premises at a given time.
However, SLGA reserves the right to impose additional security requirements before or after permitting as deemed necessary depending on individual business models and operations.
1. Wholesale, standalone retail, and off-site storage
a. Alarm System
A cannabis permitted premises must be protected by a professionally installed and monitored alarm system with the following minimum features. All malfunctions must be immediately repaired by a professional technician.
i. detectors to indicate unauthorized attempts to tamper with, open, enter or penetrate perimeter entry points, perimeter windows and secure cannabis storage area;
ii. detectors to indicate unauthorized movement within the premises including the secure cannabis storage area;
iii. capability to detect any attempts to tamper with the system or malfunctions with the system;
iv. smoke detectors in any areas where cannabis is stored; and
v. panic/robbery button(s) installed at all point of sale positions (retail store only).
b. Digital Camera Security System
i. A cannabis permitted premises must have a digital camera security system with the following minimum features. All malfunctions must be immediately repaired by a professional technician.
ii. cameras that are enclosed in the ceiling or domes and linked to a monitor and recording system located in a secure area within the premises;
iii. cameras and lighting that are positioned to clearly capture 24 hour coverage of activity identifying all individuals entering/exiting the premises and all individuals within the premises including the:
• point of sale area(s) (retail stores only);
• customer area(s) (retail stores only);
• areas where cannabis is displayed for sale (retail stores only);
• receiving area(s);
• offices and other staff area(s); and
• any cannabis storage areas.
iv. system must have on premises 60 calendar day minimum recording retention in a common format that is easily accessible, captured, viewed and capable of producing real time digital colour video (meaning at least 30 frames per second) and still images that clearly identify individuals and contain a time/date stamp not obscuring the image;
v. recording and viewing system must be located in a secure location within the premises along with a maintained surveillance plan showing camera numbers, locations, coverage, authorized users list and operating instructions;
vi. if the permittee has knowledge, or should have had knowledge, of any pending criminal or regulatory investigation, recorded data and relevant information must not be destroyed after the 60 calendar day minimum recording retention period and must be provided to SLGA and police upon request; and
vii. the system must be tested weekly to ensure all cameras and recording equipment are functioning properly and a log of the test results must be kept and available to SLGA upon request.
c. Perimeter Security
i. Standalone cannabis retail stores, off-site retail storage facilities, and cannabis wholesale warehouses must secure perimeter entry points against unauthorized access by, at a minimum:
ii. the use of 1.5mm (16 gauge) hollow metal doors with 1.9mm (14 gauge) metal frame and tamper‐proof hinges at all entry points;
iii. commercial grade non‐residential locks on all access points with secured tamper‐proof strike plate and locking device that penetrates the doorframe at minimum 1.25cm;
iv. an overhead receiving door (if required) constructed of commercial grade material and locking device sufficient to secure against unauthorized access;
v. perimeter locking devices not on a master key system;
vi. loading/unloading bay and entry door areas located outside the secure structure for cannabis storage, with any walls or interior access doors adjoining the secure structure meeting the requirements outlined in subsection d below; and
vii. a customer entrance constructed of commercial grade material sufficient to secure against unauthorized access (retail stores only).
d. Cannabis Storage
Any areas within a cannabis permitted premises where cannabis is stored, including any receiving or staging areas where cannabis is kept after operating hours, must be fully enclosed in a secure structure that meets the following minimum requirements (this secure structure may form the external walls of the building if preferred, excluding any loading/unloading bays and entry door areas). Cannabis edibles and samples are exempt from this requirement and may remain in the retail area after operating hours.
Subsection e below outlines an alternative option available to retail stores only. SLGA may also consider other alternatives on a case-by-case basis as long as they provide security at least equivalent to the requirements outlined below.
i. walls, floors, and ceiling constructed of Flattened Metal Mesh, EMMA 557‐99 style ¾‐9F, nominal strand thickness of 0.120” (0.108” to 0.132”) diamond opening of 0.563” x 1.688” or Sheet steel 16ga, A1008/A1008M (cold rolled) or A1011/A1011M (hot rolled) or equivalent, OR 30 cm (12") high density cement blocks with cores filled with type "M" mortar and reinforced to meet structural codes, OR 20 cm (8") thick poured concrete (20.7 MPa (3000 lbs/in2) minimum), reinforced to meet structural codes;
ii. if sheet steel or steel mesh is used, it is to be mounted on the outside (attack side) of the room, including the ceiling, in the following manner:
• support all edges by anti‐spread bracing, studs orcorners;
• align sheet edges at every vertical and horizontal seam on centre‐line of steel stud or anti‐spread bracing; and
• secure all sheets with screws, welds or rivets.
iii. 16 gauge (1.6mm) steel sheets, HR Commercial quality, ASTM A366, matte finish, shall extend 1200mm around doorframe on inside of room and attached to the doorframe with screws, welds or rivets. Where the dimensions of the secure structure do not allow for 1200mm clearance around the doorframe, the steel sheets may be bent to conform to the inside of the secure structure walls and/or ceiling);
iv. minimum 1.5mm (16 gauge) hollow metal door(s) not exceeding 91.44cm (36 inches) width with 1.9mm (14 gauge) metal frame;
v. commercial grade door lock(s) with locking device(s) that penetrates doorframe at least 1.25cm and tamper‐ proof hinges;
vi. locking device(s) not on a master key system; and
vii. ventilation openings with one dimension 15cm (6 inches) or less and the total area of the opening not exceeding 619 cm2 (96 inches2).
e. Alternative Cannabis Storage (retail stores only)
Instead of a storage room, a retail store may choose to secure cannabis in a burglar resistant safe or similar device (such as a locking refrigeration unit) that meets the following requirements:
i. the safe is a burglary resistant safe (according to either standard ULC-S324 or standard UL-687 rated at TL-15 or higher.;
ii. has a locking system that secures the door in multiple parts of the door structure as well on more than one axis; and
iii. the safe weighs at least 341 kilograms or is anchored to the permanent structure of the building in such a manner that it cannot be removed without first opening the door to the safe.
2. Integrated retail
a. Alarm System
Integrated cannabis retail store permitted premises must be protected by a professionally installed and monitored alarm system with the following minimum features. All malfunctions must be immediately repaired by a professional technician.
i. motion sensors that indicate entry at common entry points (such as exterior windows and doors); and
ii. panic/robbery button(s) installed at all cannabis point of sale positions.
b. Digital Camera Security System
The cannabis permitted premises must have a digital camera security system with the following minimum features. All malfunctions must be immediately repaired by a professional technician.
i. cameras that are enclosed in the ceiling or domes and linked to a monitor and recording system located in a secure area within the premises;
ii. cameras and lighting that are positioned to clearly capture 24 hour coverage of activity identifying all individuals entering/exiting the cannabis permitted premises and any secure storage areas, and all individuals within the cannabis retail area including the:
• cannabis point of sale area(s);
• any areas where cannabis is visibly displayed for sale; and
• any areas where cannabis is stored.
iii. system must have on premises 60 calendar day minimum recording retention in a common format that is easily accessible, captured, viewed, and capable of producing real time digital colour video and still images that clearly identify individuals and contain a time/date stamp not obscuring the image;
iv. recording and viewing system must be located in a secure location within the premises along with a maintained surveillance plan showing camera numbers, locations, coverage, authorized users list and operating instructions.
v. if the permittee has knowledge, or should have had knowledge, of any pending criminal or regulatory investigation, recorded data and relevant information must not be destroyed after the 60 calendar day minimum recording retention period and must be provided to SLGA and police upon request; and
vi. the system must be tested weekly to ensure all cameras and recording equipment are functioning properly and a log of the test results must be kept and available to SLGA upon request.
c. Perimeter Security
A cannabis permitted premises must secure perimeter entry points against unauthorized access by ensuring that all entry points are secured with commercial grade non-residential locks.
d. Cannabis Storage
Cannabis products, excluding edibles and display samples, must be secured after operating hours using one of the methods described below. SLGA may also consider equivalent methods on a case by case basis.
i. a commercial safe, gun locker, or similar device located within the cannabis permitted premises that meets the following minimum requirements:
• is rated by the Underwriter Laboratories (UL) as a residential storage container (according to standard UL-1037) or a burglary resistant safe (according to either standard ULC-S324 or standard UL-687).
• has a locking system that secures the door in multiple parts of the door structure as well as on more than one axis; and
• weighs at least 341 kilograms or is anchored to the permanent structure of the building in such a manner that it cannot be removed without first opening the door to the safe.
ii. a secure storage area within the same facility as the cannabis permitted premises that meets the following minimum requirements:
• minors are prohibited access at all times;
• is used to store only products owned by the cannabis retail store permittee and intended for sale in the cannabis permitted premises and any related online store;
• is protected by an alarm system and digital camera security system as described in subsections a and b above;
• is secured using 1.5mm (16 gauge) hollow metal doors with 1.9mm (14 gauge metal frame and tamper-proof hinges, plus commercial grade nonresidential locks, a secured tamper-proof strike plate and locking device that penetrates the doorframe at minimum 1.25cm; and
• is secured with automatic locking doors on any entry points that open onto an unpermitted area or an area not monitored by staff at all times.
iii. An off-site secure storage facility that is authorized as part of the cannabis retail store permit and meets the off-site storage security requirements outlined in subsection 1 above, as well as any operating requirements described elsewhere in this document.