13 December 2016

The Guideline: Security of Medicinal Cannabis (the Security Guideline) outlines a number of mandatory requirements to support the secure cultivation, production and transportation of medicinal cannabis. The purpose of this approach to security is to put in place controls which prevent the diversion of cannabis into the recreational or black market.

The Security Guideline is designed to be implemented at a level of rigour relative to the risk of diversion. In other words, the higher the diversion risk, the more stringently the Security Guideline should be applied. Where the risk of diversion is lower, the need for extensive security arrangements is commensurately reduced.

In prior consultation with industry representatives, the Office of Drug Control identified that the greatest risk of diversion lies in that of high tetrahydrocannabinol (THC) content cannabis. A high THC content is reflective of cannabis that can be abused to obtain the psychoactive effect.

For cannabis with a low THC content but relatively higher cannabidiol (CBD) content, there is still some risk of crop interference, but that risk is likely to be more opportunistic rather than recreational in nature and would therefore be far less attractive to black market diversion. Essentially, low THC medicinal cannabis is no more attractive to criminal diversion than is industrial hemp.

Subsequently, the application of the Security Guideline needs to be considered in light of the type of medicinal cannabis crop a licence holder may wish to cultivate. If, for example, a licence holder has agreed as a condition of their licence that they will only cultivate low THC and high CBD crops, then the expectations around intruder resistance and access controls are substantially reduced.

Conversely, where an applicant does not restrict their license conditions (i.e. they have high THC or mixed type crops) then the Security Guideline should be more closely followed.

Without limiting the way in which people may wish to establish appropriate security, the following are some examples of the difference between high THC and low THC sites:

Requirements High THC Low THC
Intruder resistant cannabis site Two layer perimeters such as building walls or climb-proof fencing Sturdy high fencing, greenhouses, or other method which demonstrates the crop is intruder resistant
Physical security systems Alarms, monitoring and CCTV Back to base alarm system
Destruction and disposal processes Monitored incineration or other tracked destruction Local incineration or mulching