Massachusetts: Chapter 369 of the Acts of 2012: Security Camera System Requirements for Cannabis Farms and Dispensaries

Resolution, Placement, Retention, and Remote Viewing Requirements

Massachusetts: Chapter 369 of the Acts of 2012

Massachusetts Cannabis Security Requirements

Here are the requirements as listed in as listed in "Massachusetts: Chapter 369 of the Acts of 2012: Security Camera System Requirements for Cannabis Farms and Dispensaries"

(10) Ensure that the outside perimeter of the RMD is sufficiently lit to facilitate surveillance;

(11) Ensure that trees, bushes, and other foliage outside of the RMD do not allow for a person or persons to conceal themselves from sight;


(D) Security and Alarm Systems

(1) A RMD shall have an adequate security system to prevent and detect diversion, theft, or loss of marijuana or unauthorized intrusion, utilizing commercial grade equipment, which shall, at a minimum, include:

(a) A perimeter alarm on all entry points and perimeter windows;

(b) A failure notification system that provides an audible, text, or visual notification of any failure in the surveillance system. The failure notification system shall provide an alert to designated employees of the RMD within five minutes after the failure, either by telephone, email, or text message;

(c) A duress alarm, panic alarm, or holdup alarm connected to local public safety or law enforcement authorities;

(d) Video cameras in all areas that may contain marijuana, at all points of entry and exit, and in any parking lot, which shall be appropriate for the normal lighting conditions of the area under surveillance. The cameras shall be directed at all safes, vaults, sales areas, and areas where marijuana is cultivated, harvested, processed, prepared, stored, handled, or dispensed. Cameras shall be angled so as to allow for the capture of clear and certain identification of any person entering or exiting the RMD or area;

(e) Twenty-four hour recordings from all video cameras that are available for immediate viewing by the Department upon request and that are retained for at least 90 calendar days. Recordings shall not be destroyed or altered, and shall be retained as long as necessary if the RMD is aware of a pending criminal, civil, or administrative investigation, or legal proceeding for which the recording may contain relevant information;

(f) The ability to immediately produce a clear, color, still photo (live or recorded);

(g) A date and time stamp embedded on all recordings. The date and time shall be synchronized and set correctly and shall not significantly obscure the picture;

(h) The ability to remain operational during a power outage; and

(i) A video recording that allows for the exporting of still images in an industry standard image format, including .jpg, .bmp, and .gif. Exported video shall have the ability to be archived in a proprietary format that ensures authentication of the video and guarantees that no alteration of the recorded image has taken place. Exported video shall also have the ability to be saved in an industry standard file format that can be played on a standard computer operating system. All recordings shall be erased or destroyed prior to disposal.

(2) All security system equipment and recordings shall be maintained in a secure location so

Regulation As Approved by the Public Health Council – Last Modified 5.8.13

105 CMR: Department of Public Health as to prevent theft, loss, destruction, and alterations.

(3) In addition to the requirements listed in 105 CMR 725.110(D)(1) and (2), the RMD shall have a back-up alarm system, with all capabilities of the primary system, provided by a company supplying commercial grade equipment, which shall not be the same company supplying the primary security system.

(4) Access to surveillance areas shall be limited to persons that are essential to surveillance operations, law enforcement authorities acting within their lawful jurisdiction, security system service personnel, and the Department. A current list of authorized employees and service personnel that have access to the surveillance room must be available to the Department upon request. If on-site, surveillance rooms shall remain locked and shall not be used for any other function.

(5) All security equipment shall be in good working order and shall be inspected and tested at regular intervals, not to exceed 30 calendar days from the previous inspection and test.

Massachusetts: Chapter 369 of the Acts of 2012

How to Comply with the Massachusetts Regulations:

2 Different Alarms, Sufficient Lighting, Trimmed Bushes, Printer, and Computer

Massachusetts has a rather unique clause about how you need to both provide sufficient lighting and keep your bushes trimmed as to prevent anyone from hiding in them (or anything else), so keep that in mind. Also, you are required to produce a photograph on demand, so you will want a printer and a PC or Mac onsite as you cannot connect a printer to your NVR. Lastly, you need to have 2 (!) completely different alarms and alarm monitoring companies. Ouch.

Battery Backup or a Generator?

So, Massachusetts seems to have copied part of their law from New York, so here' what we had to say about that in the New York section:

"[T]he ability to remain operational during a power outage" should strike you as incredibly odd, if you have read any of the other state regulations. Normally states add a timeframe after this; Nevada says "5 minutes," for example. Why? Because battery backups don't work forever. We have a load calculator so that you know how much power your surviellance system would be using and can use that to select the correct battery backup product for you. Once you have a quote from us, our staff can tell your approximate power draw for our products. If you were any other state, you then you could pick out the appropriate battery backup that would last the amount of time regulated by that state. New York (and Massachusetts who seems to have copied it word for word) is unique; there's no timeframe listed. The only way to have 100% certainty that you are within the law is to have a local generator that automatically turns on when power is lost; we doubt that this is what was intended by this regulation, but it does appear to be what it says. Additionally, it isn't clear from this regulation what is required to remain operational during a power outage. Talk to a lawyer.

The "Failure Notification System" Requirement

All of NVRs and cameras have notices that go out if the cameras are tampered with, disconnected, damaged, or moved. You can also enabled motion detection alerts and many other video analytics on our cameras. However, it seems more likely that this regulation is referencing the alarm or access control system, but it is pretty unclear. Either way, you should be fine.

Date and Time stamps.

Just about every commercial grade surveillance system does this. SCW systems have this option enabled by default.

Image Export Filetypes.

Again, just about every commercial grade surveillance system does this.

Storage Regulations:

You are required to have 24/7 recording.

So, motion detection based recording as a way to conserve space is out.

You are required to have 90 days of recording.

We cover storage requirements pretty in depth on the main Cannabis regulations page. For New York, you would only need 2X of what a provider in Washington State (who we used as an example on that page) would need on the charts we have listed there.

*We're not lawyers and laws do change. We try our best to keep this page updated with changes to the law, but you should always do you own research or hire your own lawyer to guarantee compliance with the law.