Natural Medicine Security Plan for Colorado Psilocybin Application

Natural Medicine Security Plan for Colorado Psilocybin Application

The Colorado Department of Revenue Natural Medicine Division recently opened up the process to accept applications for companies who wish to distribute psilocybin. Sapphire has been following psilocybin legalization for years now, and this application process will certainly be seen as a milestone in the history of its usage and potential. However, psilocybin is still a Schedule I substance; therefore, applicants will need to work on their natural medicine security plan before opening.

We also acknowledge that the Division had an impressive turnaround compared to other states’ cannabis program launches. Yes, Colorado was a pioneer for the industrialization of cannabis back in 2012, but that was long enough ago to worry that the rollout of another risky initiative would not go smoothly; fortunately, our concerns were calmed by the publication of rules and regulations as well as the application launch. It remains to be seen how quickly approvals are granted; however, we consider this a step in the right direction both for Colorado and nationally.

The application does require a Security Plan, identification of access-restricted areas, and a Security and Surveillance Diagram. These are only a few of the many documents required. While psilocybin and cannabis are not strictly overlapping industries, and are very different consumables, so far it is hard to deny that the program drew inspiration from cannabis legalization. For instance, the security checklist emphasizes video surveillance of any product handling as well as access regulation throughout the facility.

Natural Medicine Security Plan Requirements and Prompts

Below also are details from the Security Checklist issued by the Natural Medicine Program.

General Standards for Healing Centers, Cultivations, Product Manufacturers, and Testing Facilities

General Requirements

  • Ensure all Regulated Natural Medicine and Regulated Natural Medicine Products are protected from theft or diversion
  • Implement safeguards for secure transportation between Licensed Premises’
  • Prevent unauthorized access to restricted areas and business records
  • Keep a list of authorized employees and service personnel who have access to the alarm and surveillance systems

Access Control

  • Exterior doors lock
  • Exterior doors are monitored during business hours
  • Business records are stored in a secure location
  • Restricted areas are only accessible to licensed personnel

Alarm System

  • Install a fully operational security alarm system, activated at all times when the Licensed Premises is closed
  • Ensure the security alarm system detects unauthorized entry and activity within the Licensed Premises
  • Alarm must notify licensee or authorized personnel in case of unauthorized entry at the Licensed Premises

Security Plan

  • Protocol for end-of-day handling and storage of Regulated Natural Medicine and Regulated Natural Medicine Product
  • Protocol for reporting theft or burglary when it is discovered to state or local law enforcement and the Natural Medicine Division using the Reporting Form
  • Protocol for reconciliation of inventory after a theft or burglary has been discovered
  • Identification of exterior lighting of the Licensed Premises and any exterior camera angles, and protocols for maintaining lighting and cameras
  • Identification of entrances and exits for the property and any access control measures taken outside of the Licensed Premises
  • Points of contact are identified for the security alarm system and video surveillance notifications

Surveillance & Records

  • All entrances and exits to Restricted Areas must be visible on camera 24 hours
  • Any areas storing video surveillance must be visible on camera
  • Capture clear and unobstructed views of any area that Regulated Natural Medicine is grown, sampled, weighed, packaged, tagged, tested, stored, manufactured, and prepared for transport or disposal must be visible on camera.

Equipment

  • A fully operational video surveillance system must be functioning, properly maintained, and equipped with a failure notification system

Placement of Cameras

  • Video surveillance equipment must consist of at least:
    • Digital or network video recorders,
    • Cameras capable of capturing video footage,
    • One on-premises video monitor, which can be a computer, tablet or phone

Records Storage

  • Video surveillance records and recordings must be securely stored in a location that is identified on the diagram of a Licensed Premises. If the Licensed Premises has a Restricted Area, then surveillance records must be stored there
  • Retain video surveillance recordings of the past 30 days for a minimum of 30 days
  • Ensure date and time are embedded in all video surveillance footage
  • Maintain 30 days of continuous recording, including motion-detected footage
  • Provide access to surveillance records upon request to relevant authorities

Micro-Healing Centers & Micro-Cultivations

Micro-Healing Centers are permitted to store no more than 750 milligrams of Total Psilocin. Micro-Cultivations are permitted to store no more than 750 grams of dried fruiting bodies.

Storage of Regulated Natural Medicine and Records

  • Store all Regulated Natural Medicine and Regulated Natural Medicine Products in a secured, locked place accessible only to licensed personnel
  • Ensure that only authorized personnel have access to restricted areas containing regulated natural medicine. These areas should be clearly marked with signs such as “Authorized Personnel Only”
  • Secure the entire Licensed Premises, particularly when it is not in operation. Unauthorized access should be prevented at all times, both to the physical premises and the business records

How Can Sapphire Risk Help?

Tony Gallo and the team of experts and consultants at Sapphire Risk Advisory Group have worked to secure medical marijuana and recreational cannabis businesses in 37 states. Follow us on social media to stay up to date with more security best practices and cannabis industry updates!