In the July issue of Marijuana Venture, we explored the risks and benefits of choosing certain types of security cameras. A choice that was afforded by a murky and ill-defined section of Initiative 502 (Washington Administrative Code 314-55-083), allowed for multiple interpretations of the same rule. Since that time, the Washington State Liquor Control Board has released a modified version of this section, thereby clarifying exactly what type of cameras must be used. The new regulations clearly state that the systems must be IP compatible, but also that the cameras themselves must be IP cameras. The regulation now requires marijuana businesses to have:
“…a complete video surveillance with minimum camera resolution of 640×470 pixels and cameras must be internet protocol (IP) compatible.”
Pardon me while I do a little dance over here and thumb my nose at certain experts in the industry who chose profit over protecting their clients by selling them non-compliant analog camera systems and promising compliance (at a lower price, but higher profit margin, mind you). So after descending from my soap box, I feel it appropriate to explain the new, highly edited version of the I-502 security camera section and what it does and does not mandate.
As an indication of how much the regulation has been edited, there have been 394 words removed from the regulation and 287 words added to a section of the regulations that originally only contained 537 words. Almost 75 percent of it has been rewritten. Let that sink in.
The most common assumption is that if cameras are IP compatible, they must be connected to the Internet in order to function. This is not only a false assumption, but having the camera system connected to the Internet is not even something that is required by the regulation. It is definitely preferred by the inspector, but I see nowhere in the regulation where an actual Internet connection for the surveillance system is a requirement (similar to the fact that nowhere in the regulation does it say that your alarm system must be monitored, just that it must exist and make noise).
When setting up an IP camera system, internal IP addresses are applied to each device. This is done via programming, and not through a connection to the Internet. The actual Internet connection is of great benefit though, in that it does allow for remote management and alarm verification. It’s also nice to be able to pull up your smart phone and check on your plants and employees.
Another clarification made by the new edits to the regulation is that “all cameras must be fixed and allow for clear and certain identification.” This means we are not to use pan, tilt and zoom (PTZ) cameras. PTZ cameras are motorized and can be controlled by the user or by a program. The problem with PTZ cameras is that when they are looking over here… something is bound to happen over there. When using PTZ cameras, there is a tendency to use fewer cameras to justify the use of the more expensive motorized camera. This justification leads to blind spots and lower quality than would otherwise be had for the same amount of money with more cameras.
The new regulation gives a solid definition to video speed. We now know we must have a minimum of 10 frames per second per camera. Be careful out there: many systems meet this requirement on live view, but are limited to 7.5 frames per second on recorded video.
We have been given a bit of respite with this new edit as well in that “areas where marijuana or marijuana waste is never present are not considered control areas and do not require camera coverage.” This is wonderful news because we have all been operating under the assumption that 95-100 percent area coverage was required regardless of whether product would be within a specific area (excluding those areas, like restrooms, where the assumption of privacy precluded camera placement).
One final clarification which has helped bring camera counts down is the final paragraph limiting the 20-foot rule to outdoor grow areas. The previous version was written in a way that we had to assume that we needed coverage of a 20-foot perimeter of all entrances. The newly edited regulation requires this only of fences and entrances specifically for outdoor grow operations.
Now that the regulation is clear, we can all get on with providing surveillance systems that provide compliance and satisfy the Liquor Control Board without breaking the bank, and hopefully do so in a way that actually provides some value to the operator. Unfortunately, even today, a full month after these edits were released, I have heard of a Liquor Control Board inspector who recently passed a system with analog cameras. The next challenge is ensuring a level playing field, not just for the 25 percent excise tax, which is what all the regulations are focused on, but a level playing field for all the players on the field as well. This also begs the question, what about the operators who passed inspection with what is now clearly a non-compliant camera system?
Armando Perez is the general manager of CCTV Dynamics (www.i502CCTV.com), a surveillance equipment distributor with a focus on system design and custom security camera systems.