Safe Access Best Practice

CANNABIS DEFENSE COALITION
SAFE ACCESS COMMITTEE
“BEST PRACTICES”
Version 1.0
August 16, 2011

The Cannabis Defense Coalition (CDC) is a nonprofit, nonpartisan, membership organization devoted to reducing the harms associated with drug use. We advocate sensible, science-based drug policy, and for the health, safety and civil liberties of individuals and communities affected by drugs.

Having formed the “Safe Access Committee” - For patients, collectives, medical professionals, or any access point as defined by law in the future as well as anyone else interested in seeing safe access to medical cannabis. Will work on devising best practices to help inform the regulatory process. May ultimately break down into smaller committees for focused efforts.

The goal of this section is to assist medical cannabis patients and participants in maintaining safe collective gardens, processing establishments, and co-operatives/agencies by offering suggestions for different types of security measures, both indoors and out.

It is strongly recommended that you seek legal and accounting services for ongoing support, this industry while supported by the City of Seattle, remains in conflict with Federal laws.

Location

  • Choose a location that is zoned appropriately for your cannabis business.
  • Develop and maintain positive relationships with neighbors and community or maintain anonymity (growers/gardens)
  • 1000 feet from schools
  • ADA access is strongly recommended even if not required by ordinances
  • No loitering or on-site consumption should be tolerated with the exception of Private clubs with adequate filtration, which are in compliance with local laws and properly authorized.
  • Good neighbor policies (reference below)
  • Manage odor through use of can filters/carbon filters

Security

    It is imperative that all security personnel be trained
  • No weapons policy (Staff with proper training may use non-lethal weapons for self- defense)
  • Two way communication between security and back office staff encouraged
  • CCTV on all entrances/exits/medicine room/safe/cash register
  • Door buzzer entry for entrance/medicine room
  • Cameras in parking lot and surrounding building
  • Outdoor lighting (depending on hours of operation?)
  • Floor mounted safe
  • Alarm/window breaks
  • POS system
  • Offsite record storage
  • Security staffing (as needed)
  • Escorts to vehicles if the area and/or situation warrant it
  • Employees should easily be identifiable (uniforms, name badges, shirts etc)
  • SPD Relations: Meet with SPD Precinct representatives as often as necessary to discuss operational issues, solutions to common problems, neighborhood trends, security concerns, etc.

Employees

  • Background/Reference checks
  • Ensure that staff is trained to understand and comply with RCW 69.51A and ESSB 5073
  • Ensure that staff is trained regarding security and safety measures.
  • Ensure that staff is trained to comply with Washington State and HIPPA privacy laws.
  • Train staff regarding emergency procedures, (ie robbery, fire, etc.)
  • Ensure that staff trained with applicable employee handbook.

Policies

  • Keep permits, licenses and registrations up to date and posted at location
  • Create a Business Plan and Procedures Manual:
    Procedures Manual should include but not limited to:
    • New patient intake procedure (verifying authorizations)
    • Membership/Cooperative/Agency agreements
    • Collective Garden agreements (posted at garden/ physical or video monitor)
    • Documented inventory control process, procedures.
    • Record keeping procedures
    • No On-site consumption policy with the exception of Private clubs with adequate filtration, which are in compliance with local laws and properly authorized.
  • Security Processes
  • Banking processes
  • HIPPA guidelines/waivers
  • Document disposal policies for expired or unusable cannabis –
  • Quality control
  • Handling difficult and very ill patients
  • Documented employee theft policy/procedures – ZERO TOLERANCE
  • Conflict management policies
  • Good Neighbor Policies
    • Support the businesses near you by using them for your needs and encouraging patient support.
    • Greet and be courteous to your business neighbors - it costs nothing and builds trust and relationships
    • Ask for neighborhood feedback (chamber of commerce or business leader in your community)
    • Implement the feedback (where reasonable)
    • Offer to use your resources to build the community infrastructure and appearance – Landscaping outside of business area, painting, neighborhood cleanup day, neighborhood watch
    • Tasteful and professionally crafted exterior signage
    • Façade to emulate the surrounding community – Blend in!
    • Comply with limited advertising requirements by advertising in industry specific publications
    • No displays of cannabis in public view, picture or otherwise.
    • Membership Agreements to include but not limited to:
    • Understanding and documentation of patient 60 day supply (do not exceed)
    • Loitering policy
    • Agreements not to resell/distribute, etc.
    • Right to refuse

Processing

  • All of the above apply to processing when applicable, ie, security, zoning, odor, etc, additionally
  • All processed products should be prepared in a commercial grade kitchen
  • Sanitation procedures adhered too.
  • Labeling defining; recommended dosage, date of manufacturing, ingredients, and warnings
  • Tamperproof packaging

Growing

  • All of the above apply to the growing area when applicable, ie, security, zoning, odor, etc,
  • Aditionally –
  • Facility should be in compliance with City/Seattle Building Code
  • Be environmentally conscientious of your processes