Video Security Licensing Requirements For Oregon Cannabis Growers

We are putting together a proposal for a client that needs approx 22 cameras recording 720P @ 10 FPS, 24/7. The state requirement for recording retention is: “Keep all surveillance recordings for a minimum of 90 calendar days” and “maintain surveillance recordings in a format approved by the commission that can be easily accessed for viewing and easily reproduced.

I need some assistance regarding how might be the most efficient way to meet these requirements. NVR with (X) storage and then a backup solution, or ???

This is for a cannabis grower in Oregon. The state rules are still evolving, but the statements above in “ “ are verbatim.

Most of these growers are only doing this because they have to and are definitely looking for the lowest cost to meet the licensing requirements.

There is an additional rule that states "Back up the video surveillance recordings for the surveillance room or surveillance area off-site". My understanding is that off-site could simply be a location away from the building. The licensed premises, in this case is the building itself, so installing some sort of weatherproof cabinet 6' away from the building would be considered off-site. Since it only requires the video from the camera in the equipment room to be backed up offsite, I am not sure what the best way to do this would be as the primary VMS will be in the building.

I welcome any input or ideas.

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Undisclosed #2

IPVMU Certified

22 cameras recording 720P...

Why so many lower resolution cameras? Are the FOV's disjoint?

With the price of 4MP cameras being so afforable, you might want to look at less cameras.

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Michael Miller

When required by the government most customers don't go above and beyond the spec. Especially when it is a tool for the government to monitor your own business.

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Undisclosed #2

IPVMU Certified

What do you mean 'go beyond the spec'?

I'm talking about doing it cheaper.

Do you think the spec says 22 720p cameras?

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Michael Miller

845-025-1450 Video Recording Requirements for Licensed Facilities

Looks like 720P is the minium.

(1) A licensee must have cameras that continuously record, 24 hours a day: (a) In all areas where mature marijuana plants, usable marijuana, cannabinoid concentrates, extracts or products may be present on the licensed premises; and (b) All points of ingress and egress to and from areas where mature marijuana plants, usable marijuana, cannabinoid concentrates, extracts or products are present.

(2) A licensee must:

(a) In limited access and point of sale areas, use cameras that record at a minimum resolution of 1280 x 720 px and record at 10 fps (frames per second); Effective August 23, 2016 Page 30 of 88

(b) In exterior perimeter and areas on the licensed premises that are not limited access areas, use cameras that record at a minimum resolution of 1280 x 720 px and record at least 5 fps, except where coverage overlaps any limited access areas such as entrances or exits and in those overlap areas cameras must record at 10 fps;

(d) Keep all surveillance recordings for a minimum of:(A) 90 calendar days for licenses issued or renewed after August 31, 2016; and(B) 30 calendar days for licensed issued prior to August 31, 2016;

(e) Maintain surveillance recordings in a format approved by the Commission that can be easily accessed for viewing and easily reproduced;

(f) Upon request of the Commission, keep surveillance recordings for periods exceeding the retention period specified in section (2)(d) of this rule;

(g) Have the date and time embedded on all surveillance recordings without significantly obscuring the picture;

(h) Archive video recordings in a format that ensures authentication of the recording as a legitimately-captured video and guarantees that no alterations of the recorded image has taken place;

(i) Make video surveillance records and recordings available immediately upon request to the Commission in a format specified by the Commission for the purpose of ensuring compliance with ORS Chapter 475B and these rules;

(j) Immediately notify the Commission of any equipment failure or system outage lasting 30 minutes or more; and (k) Back up the video surveillance recordings for the surveillance room or surveillance area off-site.

(3) Notwithstanding the requirements in section (1) of this rule a licensee may stop recording in areas where marijuana items are not present due to seasonal closures or prolonged periods of inactivity. The licensee must provide notice to OLCC when recording is stopped and must keep a log of all times that recording is stopped due to marijuana items not being present. The log and notice must identify which cameras were not recording, the date and time recording stops, the date and time recording resumes or is scheduled to resume, and a description of the reason why the recording stopped and started.

(4) In lieu of complying with subsection (2)(k) of this rule, a licensee may keep all required back up video surveillance recordings on site in the surveillance room or surveillance area as described in OAR 845-025-1460(1)(a) and (b), if that surveillance room or surveillance area: (a) Is fully enclosed on all sides within a limited access area; and (b) Is secured by an all metal door within a metal frame with a fire rating of 90 minutes or more and commercial grade, non-residential lock that is kept locked at all times.

(5) Failure to comply with subsections (2)(d)(e), (f), (h) or (i) of this rule is a Category I violation and may result in license revocation. Stat. Auth.: ORS 475B.025, 475B.070, 475B.090, 475B.100 & 475B.110 Stats. Implemented: ORS 475B.025, 475B.070, 475B.090, 475B.100 & 475B.110

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Undisclosed #2

IPVMU Certified

Its not likely the minimum price, though is it?

That's the minimum growers want to meet, right Mike?

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Michael Miller

There are many ways you can meet that spec. The thing is the government doesn't care how much or how little you spend. Meeting the spec is what is most important.

Also from the conversations I have had. Most of the growers don't want better they want to meet the minimum.

What is going to cost more to store 90 days of 24/7 video? 22 720P cameras or 22 4MP cameras?

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Undisclosed #2

IPVMU Certified

There are many ways you can meet that spec. The thing is the government doesn't care how much or how little you spend.

No, but the Customer does, as the OP says at top

Meeting the spec is what is most important.

Who suggested not meeting the spec?

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Michael Miller

What is going to cost more to store 90 days of 24/7 video? 22 720P cameras or 22 4MP cameras?

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Undisclosed Integrator #1

The rules were changed from 30 days to 90 days as of August 2016. Definitely changes things. It looks like it will also apply to any licenses being renewed after that date as well. I would imagine that many of the early licensee's might be looking at some major upgrading when renewal time comes...

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Undisclosed #2

IPVMU Certified

Oh, come off it, you know I'm talking about less cameras where its possible to have one camera capture a greater area.

Hey, I'm not talking crazy like replace 95 cameras with 1, just maybe 1 for 2 or even 2 for 3.

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Michael Miller

I find this is the typical response from people that have little to no experience with those cameras. We have used them extensively for outdoor parking lot and stadium coverage. They are a tool just like other cameras and when used in the right application they are extremely impressive.

The biggest cost of the project will be to store video for 90 days and the higher the resolution cameras you use the more this will cost. I do agree there may be some areas that you can reduce your camera count but I would think they would be minimal. You have a lot of obstructions hanging from the ceiling and when the plants grow they will also start blocking the FOV which is going to cause issues.

The last thing you want to do is undersize the camera count than have the inspector require you to add more cameras which would require you to completely redo the storage and back-up storage which will cost a lot of money.

Anyway, I think I made my point. Good luck on this project!

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Undisclosed #2

IPVMU Certified

I do agree there may be some areas that you can reduce your camera count but I would think they would be minimal.

Without even seeing the floorplan? Now that's extremely impressive!

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Undisclosed #2

IPVMU Certified

...the higher the resolution cameras you use the more this will cost.

Not if the views of the low-res overlap.

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Undisclosed Integrator #1

Correct. The camera "views" are dictated in the rules and using higher resolution would not mean less cameras.

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Undisclosed #2

IPVMU Certified

This is all I see about it, is there something else you are referring to?

Camera coverage is key, no mention of number of cameras.

Now the topology could be such that in order to meet the requirement you need distinct cameras for all of these areas.

That's why I asked are the FOV's are disjoint, i.e. no overlap is possible, is that the case?

How big is the facility?

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Undisclosed Integrator #1

The building is 132' x 60' with multiple rooms. It is possible that we might be able to eliminate a few of the cameras, but ultimately it is up to the inspector if it meets the requirements or not. I would not want to undersize the system and then discover later that we need to add more cameras and more storage.

I am not sure how to attach the pdf floor plan to this?

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Undisclosed #2

IPVMU Certified

Are you familiar with IPVM's camera calculator?

I believe it lets you import a pdf floorplan, and then you can share a generated link with everyone.

It would be a great way to discuss it!

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Michael Miller

Please review the link I posted above which is the OAR 845-025-1015 they reference and looks to be the latest revision (Effective September 20, 2016).

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Undisclosed #2

IPVMU Certified

I did review the link, that's where I got my screenshot.

btw, 845-025-1015 is just definitions, the only part that I see as relevant is

(61) “Security plan” means a plan as described in OAR 845-025-1030(4)(f) that fully describes how an applicant will comply with applicable laws and rules regarding security.

Which just leads back to the camera coverage section, I believe.

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Undisclosed Integrator #1

I agree, the growers are only doing this because they have to in order to have a license. I would imagine that many of them would want a handful of cameras in order to keep any eye on things, but no way would most go to the extent that the license requires.

I am sure that the spec could be met using low cost cameras and NVR's loaded with a bunch of hard drives, but I am not sure I would be comfortable supporting that. We had even considered using a single "four camera" NVR in an outdoor enclosure as the "off-site" storage solution, but again are not sure that we can/want to support that. In some cases it might be feasible to do some sort of cloud storage for the single camera, assuming that an adequate broadband service is available.

I am hoping to hear some ideas about any alternative solution.

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Michael Miller

Most enterprise VMS solutions meet the back-up requirements. I am most familiar with Avigilon so I will talk about that. Currently, you would need ACC Enterprise licenses. You would install the main server to meet the 90days min then you could put a NAS in another building on the property and setup the system automatically archive the video once a day to the NAS. There would be no recurring costs besides your maintenance labor for this solution

Genetec has a cloud storage option which allows you to archive to the cloud. You would need a good upload pipe and this would be a recurring cost for the cloud storage.

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Undisclosed #2

IPVMU Certified

There is an additional rule that states "Back up the video surveillance recordings for the surveillance room or surveillance area off-site".

Actually there is an exemption to that rule as long as you have the NVR in a fire-rated enclosure:

(k) Back up the video surveillance recordings for the surveillance room or surveillance area off-site.
(3) Notwithstanding the requirements in section (1) of this rule a licensee may stop recording in areas where marijuana items are not present due to seasonal closures or prolonged periods of inactivity. The licensee must provide notice to OLCC when recording is stopped and must keep a log of all times that recording is stopped due to marijuana items not being present. The log and notice must identify which cameras were not recording, the date and time recording stops, the date and time recording resumes or is scheduled to resume, and a description of the reason why the recording stopped and started.
(4) In lieu of complying with subsection (2)(k) of this rule, a licensee may keep all required back up video surveillance recordings on site in the surveillance room or surveillance area as described in OAR 845-025-1460(1)(a) and (b), if that surveillance room or surveillance area: (a) Is fully enclosed on all sides within a limited access area; and (b) Is secured by an all metal door within a metal frame with a fire rating of 90 minutes or more and commercial grade, non-residential lock that is kept locked at all times.

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Undisclosed Integrator #1

That is an interesting exception. It does not say that it needs to be in a fire rated enclosure, but a fully enclosed room secured by a metal door with a metal frame and a fire rating of 90 minutes or more. I will look into that option, thanks for pointing that out!

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Undisclosed #2

IPVMU Certified

It does not say that it needs to be in a fire rated enclosure, but a fully enclosed room...

This is what it says:

So there can just be a surveillence area, with a metal door and frame. Whether the 'area' can consist of the just recording equipment, in a metal enclosure, inside of a limited access area, I'm not sure.

But I think there is good reason to believe that would work, since the concern is the safety of the video, not how big the room is.

Of course, check with the AHJ.

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Michael Miller

Do you have any links to fire rated server racks?

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Undisclosed #2

IPVMU Certified