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Department of Licensing and Regulatory Affairs (LARA)
Marijuana Regulatory Agency (MRA)
611 W. Ottawa
P.O. Box 30205
Lansing, MI 48909
What prompted your inquiry about cannabis laws and security plans in Michigan? What is the best plan for security of cannabis and currency at a dispensary or cultivation facility?
*Please note that this resources page contains only the security compliance requirements relevant to a cannabis or marijuana business in Michigan. Details on the full set of regulatory requirements and standards for operational protocols (SOPs) can be found at the links above and below.
In Michigan, security requirements vary by municipality. It is imperative one checks the local code for a potential business to correctly implement the adequate standard. It is of the utmost importance that recreational businesses/operators are complying with regulations as these establishments are available for inspection at any time.
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARIJUANA REGULATORY AGENCY
ADULT-USE MARIHUANA ESTABLISHMENTS
Filed with the Secretary of State on July 3, 2019
These rules take effect upon filing with the Secretary of State and shall remain in effect for 6 months. (By authority conferred on the marijuana regulatory agency by sections 7 and 8 of the Michigan regulation and taxation of marihuana act, 2018 IL 1, MCL 333.27957 and 333.27958, and Executive Reorganization Order No. 2019-2, MCL 333.27001) FINDING OF EMERGENCY These rules are promulgated by the marijuana regulatory agency (agency) to establish emergency rules for the purpose of implementing the Michigan regulation and taxation of marihuana act (act), 2018 IL 1, MCL 333.27951 to 333.27967, and safeguarding the health, safety, and welfare of persons 21 years of age or older engaging in activities regulated by the act, which took effect December 6, 2018. The act provides for a state regulatory structure to license and regulate marihuana establishments and prescribe fines, sanctions, and remedies.
To date, no administrative rules have been promulgated under the authority granted to the agency. Specifically, there are no current administrative rules to provide for the lawful cultivation and sale of marihuana to persons 21 years of age or older or to ensure the safety, security, and integrity of the operation of marihuana establishments. There is a need for clarity in the implementation of this act.
PART 2. STATE LICENSE
Rule 8. Application requirements; complete application. (1) A complete application for a state license must include all the information specified in Rule 7 and all of the following: (a) A description of the type of marihuana establishment that includes all of the following: (i) An estimate of or actual number of employees. (ii) The projected or actual gross receipts. (iii) A business plan. (iv) The proposed location of the marihuana establishment. (v) A security plan, as required under the act and these rules. (b) A copy of the proposed marihuana establishment plan, as required under Rule 11. (c) An applicant shall pass the prelicensure inspection as determined by the agency and as required in Rule 12.
Rule 11. Marihuana establishment plan.
(2) The marihuana establishment plan must include, but is not limited to, all of the following:
(2) The marihuana establishment plan must include, but is not limited to, all of the following: (a) The type of proposed marihuana establishment, the location of the marihuana establishment, a description of the municipality where the marihuana establishment will be located, and any of the following, if applicable: (i) A statement in the marihuana establishment plan that a combination of state licenses will operate as separate marihuana establishments at the same location, as provided under Rule 31.
(b) A diagram of the marihuana establishment including, but not limited to, all of the following: (i) The proposed marihuana establishment’s size and dimensions. (ii) Specifications of the marihuana establishment. (iii) Physical address. (iv) Location of common entryways, doorways, or passageways. (v) Means of public entry or exit. (vi) Limited access areas and restricted access areas within the marihuana establishment. (vii) An indication of the distinct areas or structures for separate marihuana establishments at the same location as provided in Rule 31. (c) A detailed floor plan and layout that includes all of the following: (i) Dimensions of the marihuana establishment including interior and exterior rooms. (ii) Maximum storage capabilities. (iii) Number of rooms. (iv) Dividing structures. (v) Fire walls. (vi) Entrances and exits. (vii) Locations of hazardous material storage. (viii) Quantities of hazardous materials, such as chemical, flammable/combustible liquids and gases, and the expected daily consumption of the hazardous materials. (d) Means of egress, including, but not limited to, delivery and transfer points. (e) Construction details for structures and fire-rated construction for required walls. (f) Building structure information, including but not limited to, new, pre-existing, freestanding, or fixed. (g) Building type information, including, but not limited to, commercial, warehouse, industrial, retail, converted property, house, mercantile building, pole barn, greenhouse, laboratory, or center. (h) Zoning classification and zoning information. (i) If the proposed marihuana establishment is in a location that contains multiple tenants and any applicable occupancy restrictions. (j) A proposed security plan that demonstrates the proposed marihuana establishment meets the security requirements specified in Rule 35. (k) Any other information required by the agency if not inconsistent with the act and these rules. (3) Any changes or modifications to the marihuana establishment plan under this rule must be reported to the agency and may require preapproval by the agency. (4) The agency may provide a copy of the marihuana establishment plan to the BFS, local fire department, Michigan state police, local law enforcement, and building officials for use in review and planning. (5) The agency may reinspect the marihuana establishment to verify the plan at any time during the establishment’s hours of operation and may require that the plan be resubmitted upon renewal.
Rule 16. Notification and reporting. (1) Applicants and licensees have a continuing duty to provide the agency with up-todate contact information and shall notify the agency in writing of any changes to the mailing addresses, phone numbers, electronic mail addresses, and other contact information they provide the agency. (2) Applicants and licensees shall report to the agency any changes to the marihuana establishment operations that are required in Rule 30 through Rule 40 and as required in these rules, as applicable. (3) Applicants and licensees shall report to the agency any proposed material changes to the marihuana establishment before making a material change that may require prior authorization by the agency. Material changes, include, but are not limited to, the following: (a) Change in owners, officers, members, or managers. (b) Change of location. Upon notification of a change in location, the agency may determine that a new state license and new inspection are required for the change of location pursuant to Rule 22. (c) A description of a violation of an ordinance or a zoning regulation adopted pursuant to section 6 of the act, MCL 333.27956, committed by the licensee, but only if the violation relates to activities licensed under the act and these rules, or the MMFLA and its associated rules, or both. (d) The addition or removal of a person named in the application or disclosed. (e) Change in entity name. (f) Any attempted transfer, sale, or other conveyance of an interest in a state license. (g) Any change or modification to the marihuana establishment before or after licensure that was not preinspected, inspected, or part of the marihuana establishment plan or final inspection including, but not limited to, operational or method changes requiring inspection under these rules, additions or reductions in equipment or processes at a marihuana establishment, increase or decrease in the size or capacity of the marihuana establishment, alterations of ingress or egress, and changes that impact security, fire and building safety.
Rule 33. Marihuana establishments; general requirements. (1) A marihuana grower shall operate a marihuana establishment under either of the following conditions: (a) The marihuana grower operations are within a building that meets the security requirements and passes the inspections in these rules and has a building permit pursuant to Rule 34 and these rules. (b) The marihuana grower operations are within a building, except that cultivation may occur in an outdoor area, if all of the following conditions are met: (i) The outdoor area containing the cultivation of marihuana plants is contiguous with the building, fully enclosed by fences or barriers that block outside visibility of the marihuana plants from the public view, with no marihuana plants growing above the fence or barrier that is visible to the public eye and the fences are secured and comply with the applicable security measures in these rules, including, but not limited to, locked entries only accessible to authorized persons or emergency personnel. (ii) After the marihuana is harvested, all drying, trimming, curing, or packaging of marihuana occurs inside the building meeting all the requirements under these rules. (iii) The building meets the security requirements and passes the inspections in these rules and has a building permit pursuant to Rule 34 and these rules.
Rule 35. Security measures; required plan; video surveillance system. (1) An applicant for a state license to operate a proposed marihuana establishment shall submit a security plan that demonstrates, at a minimum, the ability to meet the requirements of this rule. (2) A licensee shall ensure that any person at the marihuana establishment, except for employees of the licensee, are escorted at all times by the licensee or an employee of the licensee when in the limited access areas and restricted access areas at the marihuana establishment. (3) A licensee shall securely lock the marihuana establishment, including all interior rooms, windows, and points of entry and exits, with commercial-grade, nonresidential door locks. Locks on doors that are required for egress shall meet the requirements of NFPA 1, local fire codes, and the Michigan building code, R 408.30401 to R 408.30499. (4) A licensee shall maintain an alarm system at the marihuana establishment. Upon request, a licensee shall make available to the agency all information related to the alarm system, monitoring, and alarm activity. (5) A licensee shall have a video surveillance system that, at a minimum, consists of digital or network video recorders, cameras capable of meeting the recording requirements in this rule, video monitors, digital archiving devices, and a color printer capable of delivering still photos. (6) A licensee shall ensure the video surveillance system does all the following: (a) Records, at a minimum, the following areas: (i) Any areas where marihuana products are weighed, packed, stored, loaded, and unloaded for transportation, prepared, or moved within the marihuana establishment. (ii) Limited access areas and security rooms. Transfers between rooms must be recorded. (iii) Areas storing a surveillance system storage device with not less than 1 camera recording the access points to the secured surveillance recording area. (iv) The entrances and exits to the building must be recorded from both indoor and outdoor vantage points. The areas of entrance and exit between marihuana establishments at the same location if applicable, including any transfers between marihuana establishments. (v) Point of sale areas where marihuana products are sold and displayed for sale. (vi) Anywhere marihuana or marihuana products are destroyed. (b) Records at all times images effectively and efficiently of the area under surveillance with a minimum of 720p resolution. (7) A licensee shall install each camera so that it is permanently mounted and in a fixed location. Each camera must be placed in a location that allows the camera to clearly record activity occurring within 20 feet of all points of entry and exit on the marihuana establishment and allows for the clear and certain identification of any person, including facial features, and activities, including sales or transfers, in all areas required to be recorded under these rules. (8) A licensee shall have sufficient lighting to meet the video surveillance system requirements of this rule. (9) A licensee shall have cameras that record continuously 24 hours per day and recorded images must clearly and accurately display the time and date. (10) A licensee shall secure the physical media or storage device on which surveillance recordings are stored in a manner to protect the recording from tampering or theft. (11) A licensee shall keep surveillance recordings for a minimum of 30 days, except in instances of investigation or inspection by the agency in which case the licensee shall retain the recordings until the time as the agency notifies the licensee that the recordings may be destroyed. (12) Surveillance recordings of the licensee are subject to inspection by the agency and must be kept in a manner that allows the agency to view and obtain copies of the recordings at the marihuana establishment immediately upon request. The licensee shall also send or otherwise provide copies of the recordings to the agency upon request within the time specified by the agency. (13) A licensee shall maintain a video surveillance system equipped with a failure notification system that provides notification to the licensee of any interruption or failure of the video surveillance system or video surveillance system storage device. (14) A licensee shall maintain a log of the recordings, which includes all of the following: (a) The identities of the employee or employees responsible for monitoring the video surveillance system. (b) The identity of the employee who removed the recording from the video surveillance system storage device and the time and date removed. (c) The identity of the employee who destroyed any recording. (15) The requirements of this rule do not apply to an applicant for or a licensee who holds: (a) A designated consumption establishment license. (b) A marihuana event organizer license. (c) A temporary marihuana event license.
Rule 38. Storage of marihuana product. (1) All inventories of marihuana products must be stored at a marihuana establishment in a secured limited access area or restricted access area and must be identified and tracked consistently in the statewide monitoring system under these rules. (2) All containers used to store marihuana products for transfer or sale between marihuana establishments must be clearly marked, labeled, or tagged, if applicable, and enclosed on all sides in secured containers. The secured containers must be latched or locked in a manner to keep all contents secured within. Each secured container must be identified and tracked in accordance with the act and these rules. (3) All chemicals or solvents must be stored separately from marihuana products and kept in locked storage areas. (4) Marihuana-infused products, edible marihuana products, or materials used in direct contact with such marihuana-infused products or edible marihuana products, must have separate storage areas from toxic or flammable materials. (5) All marihuana products must be stored in compliance with current good manufacturing practice in manufacturing, packing, or holding human food, 21 CFR part 110. Marihuana products not in final packaging must be stored separately from other types of marihuana product in compliance with these rules. (6) A marihuana retailer shall store all marihuana products for transfer or sale behind a counter or other barrier separated from stock rooms. (7) A marihuana safety compliance facility shall establish an adequate chain of custody and instructions for sample and storage requirements. (8) A licensee shall ensure that any stock or storage room meets the security requirements of these rules and any other applicable requirements in the act and these rules.
333.27952 Purpose and intent.
The purpose of this act is to make marihuana legal under state and local law for adults 21 years of age or older, to make industrial hemp legal under state and local law, and to control the commercial production and distribution of marihuana under a system that licenses, regulates, and taxes the businesses involved. The intent is to prevent arrest and penalty for personal possession and cultivation of marihuana by adults 21 years of age or older; remove the commercial production and distribution of marihuana from the illicit market; prevent revenue generated from commerce in marihuana from going to criminal enterprises or gangs; prevent the distribution of marihuana to persons under 21 years of age; prevent the diversion of marihuana to illicit markets; ensure the safety of marihuana and marihuana-infused products; and ensure security of marihuana establishments. To the fullest extent possible, this act shall be interpreted in accordance with the purpose and intent set forth in this section.
333.27958 Rules; limitations.
- The department shall promulgate rules to implement and administer this act pursuant to the administrative procedures act of 1969, 1969 PA 306, MCL 24.201 to MCL 24.328, including:
(a) procedures for issuing a state license pursuant to section 9 of this act and for renewing, suspending, and revoking a state license;
(b) a schedule of fees in amounts not more than necessary to pay for implementation, administration, and enforcement costs of this act and that relate to the size of each licensee or the volume of business conducted by the licensee;
(c) qualifications for licensure that are directly and demonstrably related to the operation of a marihuana establishment, provided that a prior conviction solely for a marihuana-related offense does not disqualify an individual or otherwise affect eligibility for licensure, unless the offense involved distribution of a controlled substance to a minor;
(d) requirements and standards for safe cultivation, processing, and distribution of marihuana by marihuana establishments, including health standards to ensure the safe preparation of marihuana-infused products and prohibitions on pesticides that are not safe for use on marihuana;
(e) testing, packaging, and labeling standards, procedures, and requirements for marihuana, including a maximum tetrahydrocannabinol level for marihuana-infused products, a requirement that a representative sample of marihuana be tested by a marihuana safety compliance facility, and a requirement that the amount of marihuana or marihuana concentrate contained within a marihuana-infused product be specified on the product label;
(f) security requirements, including lighting, physical security, and alarm requirements, and requirements for securely transporting marihuana between marihuana establishments, provided that such requirements do not prohibit cultivation of marihuana outdoors or in greenhouses;
(g) record keeping requirements for marihuana establishments and monitoring requirements to track the transfer of marihuana by licensees;
(h) requirements for the operation of marihuana secure transporters to ensure that all marihuana establishments are properly serviced;
(i) reasonable restrictions on advertising, marketing, and display of marihuana and marihuana establishments;
(j) a plan to promote and encourage participation in the marihuana industry by people from communities that have been disproportionately impacted by marihuana prohibition and enforcement and to positively impact those communities; and
(k) penalties for failure to comply with any rule promulgated pursuant to this section or for any violation of this act by a licensee, including civil fines and suspension, revocation, or restriction of a state license.
History: 2018, Initiated Law 1, Eff. Dec. 6, 2018
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Information gathered from sources deemed reliable, but not guaranteed. Subject to change without notice.
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