Contrary to what has been published in this magazine previously, analog surveillance cameras are now officially allowed under the regulations and requirements for I-502 businesses in Washington.
On Oct. 24, the Washington State Liquor Control Board issued its second major revision of the surveillance requirements for state-licensed marijuana businesses. This part of the regulation now states: “The surveillance system storage device and/or the cameras must be internet protocol (IP) compatible.” (Emphasis is mine.) Adding the word “or” makes all the difference in the world.
Now, we know that analog cameras are without a doubt allowed for marijuana businesses.
The controversy over surveillance cameras stems from the poorly-written original security requirements. A few months later, when regulators released the first round of revisions, nearly 75% of the original wording had to be changed.
That first revision stated the requirements included “… a complete video surveillance with minimum camera resolution of 640×470 pixels and cameras must be internet protocol (IP) compatible.” The word “and” usually means that there is no choice in the matter. In terms of regulations, I have always preached the difference between following the spirit of the law the letter of the law. The letter of the law seemed pretty clear.
Even then, the wording was vague when it came to the biggest question: Does I-502 require Internet Protocol cameras, or can an applicant simply install an IP-compatible recorder? It was a question that cost applicants tens of thousands of dollars. Up to that point, I had personally seen applicants pass their inspection with analog cameras, and I had also seen many fail because they had analog cameras. At least from my perspective, it seemed individual inspectors were given authority to decide for themselves what exactly “IP compatible” meant. I tried my best to educate people without forcing them to any one conclusion with the understanding that this is an evolving market driven by inexperienced regulators, and that even the safe bet is not guaranteed.
Now that that matter has been revised and cleared up, the question remains — why did the Liquor Control Board choose to backtrack on its previous rules that required the cameras themselves to be IP addressable?
There are two motivations that make sense. One is that this change more aptly represents the original spirit of the law, and that regulators simply didn’t know what they were doing when they first wrote it. This is possible, but a bit hard to swallow.
To me, the more likely scenario is that investigators had already passed several applicants who did not have fully IP-compatible systems as the law required at that time. Not wanting to renege on approved businesses that were already operating, particularly when the bad publicity would be extremely harmful for the whole I-502 experiment, the regulations were revised. It’s easier to allow what you have already allowed than it is to say you were wrong and publicly recall multiple approvals. This is probably the best outcome, honestly, and one that should have been easy to foresee. The thought of all those applicants having to redo their entire systems has made me cringe many times.
Regardless of the motivation, this change is a good thing. Even though some may see what I’ve been saying as preaching that you need IP cameras, that is not the case. I have been preaching that you need to be as compliant with the letter of the law as you can reasonably afford to be. Until this revision, my honest interpretation of the law was that it required IP cameras, and doing otherwise was a compliance risk.
So, now we have some history under our belts, and we can talk about the future. The good news is that the cost of a guaranteed compliant camera system has dropped by about 50% over night because of this change. This is good news for everybody that is still setting up their surveillance system. The cost is lower for the applicants, and there are more choices in equipment and fewer compatibility challenges, which is good for the vendors. Hopefully, for the inspectors, a clearer understanding of what is actually required will make it easier for them to pass more applicants. It’s also good for previously approved applicants who took a risk with analog systems as we now know they will not be forced to convert to IP.
There may still be some times where you would be better served with an IP camera system, but now it’s really a matter of preference and not a compliance-based decision. Since the regulation now says “and/or” we are not precluded from using any particular technology; IP and analog, as well as several different HD over COAX technologies, are all fair game and able to be fully compliant.
This latest revision to the rules is not nearly as comprehensive as the previous revision, but in its limited scope, it is far more freeing and effective than any other change I have seen the Liquor Control Board enact. I must say, it is nice to see the Liquor Control Board making changes based on freeing up choices for applicants and enacting revisions that allow us all to make decisions based on what is right for each individual business.
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.