The short answer
California Department of Cannabis Control regulation 4 CCR 15044 requires a licensed cannabis premises to record continuously at 1280 by 720 pixels or better, 24 hours a day at 15 frames per second or better, and to keep 90 calendar days of recordings the Department can view and copy at the premises on request. Cameras must be permanently mounted in fixed locations, must clearly record activity within 20 feet of every entry and exit, and must allow clear and certain identification of any person in the areas the rule requires to be filmed. At each point of sale, placement must record the facial features of anyone buying or selling cannabis goods, or anyone in the retail area, clearly enough to determine identity. The rule does not apply to a premises authorized exclusively for cultivation or to the cultivation area of a microbusiness.
| Regulation | 4 CCR 15044, DCC Article 5 Security Measures |
|---|---|
| Minimum resolution | 1280 by 720 pixels |
| Frame rate | 15 fps minimum, continuous 24 hours per day |
| Retention | 90 calendar days minimum |
| Entry and exit | Clear record within 20 feet of every point |
| Alarm system | 4 CCR 15047 requires a licensed BSIS operator |
What 4 CCR 15044 requires, subdivision by subdivision#
Video surveillance for licensed cannabis premises is governed by Title 4 of the California Code of Regulations, section 15044, in Article 5, Security Measures, of the Department of Cannabis Control regulations. The table pairs each requirement with what it forces in design.
| Requirement | Citation | Design consequence |
|---|---|---|
| Digital system, 1280 by 720 pixels minimum. Not applicable to a cultivation only premises or the cultivation area of a microbusiness | 15044(a) | A floor, not a target. Confirm the carve out before assuming a cultivation site is in scope |
| Effectively and clearly record images of the area under surveillance | 15044(b) | A separate test from the pixel count. Verify at the darkest hour |
| Cameras permanently mounted, fixed location | 15044(c) | A pan tilt zoom camera cannot cover a required area. Fixed field of view per scene |
| Clearly record activity within 20 feet of all points of entry and exit | 15044(c) | Approach coverage on every door, roll up and gate, not just the doorway |
| Allow clear and certain identification of any person and activities in all areas filmed under (d) | 15044(c) | Identification, not presence. Pixels on target per scene |
| Record areas where goods are weighed, packed, stored, loaded, unloaded, prepared or moved | 15044(d)(1) | Coverage follows product flow, including the dock |
| Record limited access areas | 15044(d)(2) | Every vault, cage and back of house room holding product |
| Record security rooms | 15044(d)(3) | Including the room staff call the security office |
| Record the surveillance storage device area and its access points | 15044(d)(4) | The recorder room gets its own camera on the door |
| Record entrances and exits from indoor and outdoor vantage points | 15044(d)(5) | Two cameras per opening; the outdoor one needs weather rating and night performance |
| Retailers and retail microbusinesses also record point of sale areas and display areas | 15044(e) | Register positions and every display case in the sales floor layout |
| At each point of sale, record facial features of any person buying or selling, or any person in the retail area, clearly enough to determine identity | 15044(e) | An identification camera per register, framed on the face. Area coverage of the sales floor does not satisfy this |
| Continuous recording, 24 hours per day, 15 fps minimum | 15044(f) | No motion recording, no schedules, no frame rate throttling. Storage is deterministic |
| Storage media secured against tampering and theft | 15044(g) | Locked, access controlled room, not an open office or a back counter |
| 90 calendar days minimum retention | 15044(h) | Sets the array size. See the example below |
| Viewable and copyable at the premises immediately on request, and copies sent or otherwise provided on request within the time the Department specifies | 15044(i) | Local playback and export on site, plus a way to deliver a file off site on the Department clock |
| Images clearly and accurately display time and date, NIST time standard | 15044(j) | Time sync to a NIST traceable source, checked after a reboot |
| Failure notification system for any interruption or failure of the system or storage device | 15044(k) | Health monitoring with a named recipient, tested |
| One system may serve multiple licensed premises in the same building or parcel, if all licensees have immediate access to produce recordings under (i) | 15044(l) | Shared recorder is permitted; agree in writing who administers it and how each licensee gets access |
Subdivision (m) carries a narrow exception for a distributor transport only licensee self distributing on the same parcel as its licensed cultivation premises.
Where cameras must go, and where they must not#
Coverage under subdivision (d) is written around product and access rather than square footage. Walk the building the way product moves: receiving, the scale, the vault, processing, staging, the sales floor, the dock. Then walk it the way people move: every exterior door, every door into a limited access area, the security room and the recorder room. A limited access area is defined at 4 CCR 15000 as an area where cannabis is stored or held that is accessible only to a licensee and authorized persons.
Two placement rules trip people up. Subdivision (c) requires each camera to be permanently mounted in a fixed location, so a pan tilt zoom camera cannot be counted toward a required scene, because that scene has to be recorded whether or not somebody moved the camera. And subdivision (d)(5) requires entrances and exits recorded from indoor and outdoor vantage points, which is two cameras per opening, not one camera seeing through a glass door.
The requirement that changes a retail layout most sits in subdivision (e), and it is an identification standard rather than a coverage standard. At each point of sale location, camera placement must allow for the recording of the facial features of any person purchasing or selling cannabis goods, or any person in the retail area, with sufficient clarity to determine identity. A dome looking down on the sales floor records that a transaction happened and cannot establish who was at the register. Each register needs a camera framed on the customer side of the counter at face height, and the retail area has to meet the same standard. Subdivision (c) carries the general version across the rest of the premises: placement must allow the clear and certain identification of any person and activities in all areas required to be filmed under subsection (d). Verify both on the recorded stream at the worst lighting hour.
Where cameras must not go is not in section 15044, which is why it gets missed. California Labor Code section 435 bars an employer from causing an audio or video recording of an employee in a restroom, locker room or changing room absent a court order. Section 15044 does not require audio, and California Penal Code section 632 makes it unlawful to record a confidential communication without the consent of all parties. The conservative design records no audio and puts no camera in those rooms. Where a layout forces a hard call, that is a question for counsel.
What 90 day retention does to storage sizing#
Because subdivision (f) forecloses motion recording and frame rate reduction, the storage number is arithmetic. The example below is a planning exercise; a real design substitutes the bit rates the selected cameras actually produce.
| Planning assumption | Value used in this example |
|---|---|
| Cameras recording continuously | 24 |
| Stream per camera | 1080p, H.265, 15 fps, constant bit rate |
| Average bit rate per camera | 2 Mbps |
| Recording hours | 24 per day, per 15044(f) |
| Retention | 90 calendar days, per 15044(h) |
| Array type assumed | RAID 6 across eight drives, 75 percent usable |
| Free space headroom | 20 percent |
| Step | Calculation | Result |
|---|---|---|
| Bits per camera per day | 2 Mbps times 86,400 seconds | 172,800 Mb |
| Bytes per camera per day | divided by 8 | 21.6 GB |
| Per camera for 90 days | 21.6 GB times 90 | 1.94 TB |
| Twenty four cameras for 90 days | 1.94 TB times 24 | 46.7 TB recorded |
| Plus 20 percent headroom | 46.7 TB times 1.2 | 56 TB usable |
| Raw capacity at 75 percent usable | 56 TB divided by 0.75 | About 75 TB raw |
The shortcut worth writing on the takeoff: one megabit per second of continuous recording consumes roughly 0.97 TB per camera over 90 days. Multiply by bit rate and camera count and the array size falls out. At 1 Mbps the same 24 camera system needs about 23 TB; at 4 Mbps, about 93 TB before headroom and parity.
Three assumptions carry the risk: bit rate, because a busy sales floor produces far more data than a static vault; codec, because H.264 consumes more than the H.265 figure above at the same quality; and camera count, because the coverage rules drive it rather than the floor plan. Size the array against the highest bit rate the design can produce, and verify consumption after two weeks.
Network and power so the recording does not stop#
Subdivision (k) requires a failure notification system that notifies the licensee of any interruption or failure of the system or the storage device. The regulation assumes failures happen and puts the burden on knowing about them. The design job is to make them rare and detectable.
- Put the recorder, the switch feeding the cameras and the network gateway on the same uninterruptible power supply, and on generator where one exists. A recorder on a UPS behind a switch on utility power records nothing.
- Power cameras over Ethernet from that switch. Budget the switch for the sum of the camera classes plus margin, not for the port count.
- Give the cameras their own VLAN with no route to the guest or point of sale network, and keep the recorder off the open internet.
- Point time synchronization at a NIST traceable source and confirm it survives a reboot, because subdivision (j) makes the displayed time and date part of compliance.
- Configure the health monitoring in subdivision (k) to reach a named person, and test it by pulling a camera and a drive.
- Put the recorder in a locked, access controlled room that satisfies subdivision (g), with the camera on its access points that subdivision (d)(4) requires.
- Use the cable listing the space requires, as our plenum and riser article explains.
Our network room buildout page covers the recorder room, including the power and cooling a C-10 contractor coordinates.
What an inspector actually asks to see#
The requirements that get tested are written as capabilities rather than equipment. Expect an inspection to work through this list.
- Live view of every required area, compared against the premises diagram on file.
- Playback of a specific date and time, chosen by the inspector, from the far end of the 90 day window.
- An export of that clip at the premises while the inspector waits, per subdivision (i), and a way to provide copies to the Department within the time it specifies.
- A recorded face at a point of sale position, clear enough to determine identity, per subdivision (e).
- The time and date on the image, and the time source.
- Both the indoor and outdoor camera on each entrance and exit.
- The recorder room, its lock, and the camera watching its door.
- The failure notification, demonstrated or recorded, and who receives it.
- Coverage of every limited access area, matched against the diagram.
The gap that shows up most often is not a missing camera. It is a premises diagram that no longer matches the building after a remodel, or an export nobody has used since commissioning.
Documentation to keep#
Section 15037 requires licensees to keep records for at least seven years from creation unless a shorter time is specified. Recordings have their own 90 day floor under 15044(h); the records about the system fall under the general rule. Keep the following current after every change:
- An as built camera plan keyed to the premises diagram, with each area required by 15044(d) and (e) mapped to the camera that covers it and the point of sale identification cameras marked as such.
- A camera schedule listing make, model, resolution, frame rate, mounting height and field of view.
- A recorder configuration export showing retention days, frame rate and resolution per channel.
- The time synchronization source, and the failure notification configuration with its recipient list.
- Commissioning and test records, including a night verification of every exterior scene.
- Service records for camera, drive and firmware changes.
Our cabling testing and audits page covers how that package is assembled on an existing plant.
Scope note: where the C-7 classification stops#
Cameras, recorders, cabling, switching, pathway and mounting are within the C-7 Low Voltage Systems classification defined at 16 CCR 832.07, which names closed circuit video systems. Telelink Business Services is a licensed C-7 Low Voltage Systems Contractor, CSLB License #472017.
The alarm system is a different license. Section 15047 requires a licensee to maintain an alarm system as defined in Business and Professions Code section 7590.1(c) and to ensure a licensed alarm company operator, or its registered alarm agents, installs, maintains, monitors and responds to it. Telelink does not hold a BSIS Alarm Company Operator license, does not sell, install, monitor or service intrusion alarm systems, and refers that scope to a licensed alarm company. Our BSIS and C-7 article explains the boundary and how a mixed scope gets bid.
Two other items sit outside a low voltage scope: locks under section 15046 are door hardware and security personnel under section 15045 are contracted separately. Line voltage and panel work are C-10 electrical scope.
Next step#
Send the premises diagram, the limited access area designations and the door schedule and we will return a camera layout keyed to each requirement in 15044, with storage sized against the cameras selected. Start at request a bid. Our camera coverage calculator and the security camera systems page cover pixels on target.
This article is general information for planning and specification, not a bid, engineering advice or legal advice. Codes and standards change; confirm the current edition with the authority having jurisdiction. Scope and price for a specific building come only in a written proposal.