Philman's Pharm: "German Quality, California Ingenuity." Est. 1977

Pharmaceutical industry lessons for cannabis – by Rebecca Cicarelli and Matt Gifford

When it comes to developing and implementing an appropriately comprehensive security plan, the pharmaceutical industry knows what it is doing.  You might say that this is not their first rodeo.

That is not, however, the case with many cannabis businesses newly charged with mapping out security for the purposes of licensing and daily operations.

The pharmaceutical industry and a comprehensive approach to security

Pharmaceutical companies must be compliant with Drug Enforcement Administration (DEA) regulations in order to remain operational.  But their accountability does not end there. Ultimately, companies that deal with controlled substances and other drugs are held responsible for the welfare of the American public. As such, both large and small scale pharmaceutical entities manage their security plans as a long-term proposition.

Whether they are laboratories, manufacturers or distributors, those that operate within the pharma space evaluate the here and now, but also project future facility and product needs when mapping out security. They go to great lengths to ensure full compliance with all federal, state and industry regulations; often exceeding them.  And while their “toolbox” certainly includes security equipment, it is also comprised of three other critical elements: policy, procedure and people.

It all begins with culture

The cannabis business would be wise to mimic pharma efforts to establish a clear and consistent company culture. Culture does, in fact, define the character and personality of the organization. Want employees to be honest and trustworthy? It helps to begin by saying so, and emphasizing your zero tolerance culture. Ultimately, clear cultural communication helps the cannabis business owner find and keep the kind of people it seeks to employ.  Of course, it is critical to back that up with…

Policy and procedures

Policy and procedures is another area where cannabis can follow the pharma lead. Upon hire, employees should be apprised of all company policy via written agreements and handbooks. And reinforcement will be critical to ensure compliance – via internal signage, written reminders and in-person communication as needed. Of course, change should be anticipated. Policy must be reassessed regularly to gauge and prevent new threats, and communicated as such.

All good policy is supported by detailed procedure. This begins with hiring and training. Employment must be contingent on background/reference checks, credit checks and drug screening in an effort to hinder diversion risk. Once hired, all employees should be required to participate in diversion training programs to prepare them for detection and appropriate response. And those with access to security equipment must be properly trained in operation, trouble-shooting and response. Failure to do so can be catastrophic.

Standard operating procedures should identify and then address any area that might expose a company to internal or external threats. This must, at the very least, include public access protocol, visitor procedures, internal monitoring, alarm testing and response and perimeter controls.

Equipment mandates

The last piece of the security puzzle for pharmaceutical companies and cannabis is equipment. The Code of Federal Regulations, 21 CFR 1301.72 specifically dictates storage in a precisely defined vault/safe for controlled substances or DEA Schedule I-II. Subsequently, the vault or safe is indeed the cornerstone of physical security for many pharmaceutical companies and all cannabis operations.

This is complemented by other physical security elements including safes, mantraps, safe entry portals and bullet resistance. And, prompted by regulatory requirements, electronic security components include video surveillance, access control and alarm.  All equipment ultimately works together to support optimal compliance and business success.

Author: Cenedella.de

Over the last 4 decades I have been involved in the fight for patient rights in America, and now here in Germany. During my career I have served as a Board of Director for the World Trade Center San Diego and as a Lead Consultant for Deutsche Telekom's Executive Board, Co-Founded the San Diego Software Council and the Dayton Human Trafficking Accords and was Director of LawInfo's Lead Council Program. Previously I was a C-Level Business Development Executive in the technology sector, but also involved with the cannabis industry since 1977. More recently I have been fulltime in the legal medical marijuana industry here in Europe, helping international companies navigate the biggest potential market in the world. This website is light on details due to confidentiality issues with clients but be rest assured I am knowledgeable, professional and with street cred in the industry that can immediately assist your growth in some way. Consulting Services: Sales and Business Development Assist with Strategic Direction Professionally represent your firm Special Projects management Licensing and compliance Sales and Distribution networks Qualify potential partners I am your resource on the ground in Europe, contact me directly to schedule an initial discussion on the German Cannabis-as-Medicine market. Thank you, Philip J. Cenedella IV Call +1.888.206.3264 USA + GERMANY Skype: philip.j.cenedella eMail: phil@cenedella.de LinkedIN: https://www.linkedin.com/in/cenedellade/

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