In New Jersey, a call for more video surveillance at Atlantic City casinos

February 26, 2014

Long view of the Maryland Live poker room, via one of the casino’s pan-tilt-zoom surveillance cameras. Faces in the screencap have been blurred by casino officials to protect player identities. (Courtesy photo.)

In my story on the front page of Sunday’s print edition about the surveillance operation at Maryland Live Casino, I mentioned that Rob Norton, the property’s president and general manager, asked me at one point if I’d ever seen “Casino.” He was specifically referring to the scene where Robert De Niro — who plays Tangiers boss Ace Rothstein — explains the way things work in the gambling world:

In Vegas, everybody’s gotta watch everybody else. Since the players are looking to beat the casino, the dealers are watching the players. The box men are watching the dealers. The floor men are watching the box men. The pit bosses are watching the floor men. The shift bosses are watching the pit bosses. The casino manager is watching the shift bosses. I’m watching the casino manager. And the eye in the sky is watching us all.

“You can quote from that,” Norton told me. “It’s still pretty accurate.”

But the notion that every casino is watching (or at least recording) everybody, at all times, isn’t exactly true.

Consider what’s happening in New Jersey, where one lawmaker has proposed legislation that would require Atlantic City casinos to put surveillance cameras throughout their hotels and parking garages. The bill, according to the Press of Atlantic City, was prompted by “a brutal attack in a casino stairwell.”

New Jersey law “ensures that gambling floors are monitored,” according to the Press, which adds that “no such requirement exists that casinos likewise record activity in their hotel and parking facilities, although some properties choose to do so.” 

(That’s true of Maryland Live’s parking facilities, by the way; I got to watch several archival videos in which parking-garage surveillance cameras were used to identify people who’d perpetrated various crimes at the Arundel Mills casino, including a woman who took several $500 chips from a blackjack dealer. Surveillance video from the casino’s expansive parking areas was also used to help identify suspects in the fake-chip scheme that was revealed by Maryland State Police on Tuesday.)

Anyway, from the Press story about the New Jersey proposal:

Assemblywoman Celeste Riley has sponsored the legislation arguing that stairwells should be monitored with the same degree of attention as the heavily watched gambling floors overseen by thousands of cameras. The legislation would give casinos three months to install the systems in the stairwells of every hotel and parking garage. Footage would be preserved for one year.

“You’ve got surveillance cameras in the gaming areas. Can you not spend a little bit more in your stairwells, in your hallways, to promote added security and safety?” Riley said. “In light of what we’re trying to do as a state with promoting Atlantic City as a family-friendly destination, I think you should also be able to feel safe inside the casinos.”

According to the Press, Riley declined to provide details of the stairwell incident and wouldn’t name the casino where it occurred.

Casinos meanwhile are fighting back, calling the legislation onerous and unnecessary in light of myriad other safety precautions already taken at the properties, including 24-hour security officers and bike and vehicle patrols.

Kevin Ortzman, president of the Casino Association of New Jersey, said the industry already goes to “great lengths” to employ wide-ranging security techniques. Requiring casinos to go above and beyond the requirements of security measures in other public buildings places an unfair burden on the industry, said Ortzman, also the senior vice president and general manager for Caesars, Bally’s and Showboat.

“We believe that this legislation requires an unreasonably onerous commitment of resources and unfairly singles out Atlantic City casino hotels as the only public buildings in the city and state that would be required to comply with it,” Ortzman said, adding that the casino industry is supportive of the citywide camera program that would increase surveillance throughout the resort.

Maryland does not explicitly require the state’s casinos to put surveillance cameras in their parking lots — though in reading the monthly casino compliance reports, it’s clear that the four existing properties have extensive coverage in their lots.

Just what does the state require from casino surveillance operations?

Here is some of the relevant information from the Code of Maryland Regulations (aka, COMAR). Read if you dare.

36.03.10.11 Surveillance System Design Standards:

A. A facility operator shall install in its facility a surveillance system that complies with the requirements of this regulation.

B. A facility operator’s surveillance system shall be reviewed and approved by the Commission under Regulation .12 of this chapter.

C. A facility operator’s surveillance system shall include:

(1) Light sensitive cameras enabled by:

(a) Lenses of sufficient magnification to read a video lottery terminal reel strip and credit meter;

(b) Lighting which is continuous and of sufficient quality to produce clear video recordings and still pictures; and

(c) 360-degree pan, tilt, and zoom capability, without camera stops, configured to clandestinely monitor and record:

(i) Play and transactions conducted at video lottery terminals;

(ii) Transactions conducted in the cashiers’ cage and any satellite cage including the face of each individual transacting business with a cashier;

(iii) Transactions conducted at ticket redemption units, automated jackpot payout machines, and automated teller machines;

(iv) Activity in the count room;

(v) Movement of cash and cash storage boxes within the facility;

(vi) Entrances and exits to the facility and the gaming floor;

(vii) Activities in all other restricted areas; and

(viii) Other areas and events designated by the Commission;

(2) A monitor room located in the facility:

(a) Staffed by employees of the facility operator’s surveillance department 24 hours per day; and

(b) Equipped with:

(i) A communication system capable of monitoring all security department communications;

(ii) Connections, direct or through a documented communication protocol with the security department, to all facility alarm systems;

(iii) A surveillance failure notification system that provides an audible, as well as a visual notification, of any failure in the surveillance system or the digital video recording media storage system;

(iv) An emergency power system, tested by the facility operator in the presence of the Commission at least once a year, which can be used to operate the surveillance system in the event of a power failure;

(v) Computer terminals permitting event notification to, and read only access by authorized surveillance department employees to, the facility operator’s video lottery system;

(vi) An updated photo library, consisting of photographs that are no more than 4 years old, of all current employees of the facility;

(vii) A copy of the facility operator’s gaming floor plan required under COMAR 36.03.11.05;

(viii) A copy of the procedures addressing the evacuation of the facility in the event of fire or other emergency required under Regulation .14 of this chapter; and

(ix) Copies of the surveillance system contingency plans required under Regulation .12 of this chapter;

(3) Digital video recording capability equipped to:

(a) Superimpose the date and time on all monitoring and recording;

(b) Identify and locate, through the use of a meter, counter, or other device or method, a particular event which was recorded;

(c) Identify on video recording disks or other storage media the type of media player and software prerequisite to viewing the digital images; and

(d) Be authenticated through use of an embedded video verification encryption code or watermark;

(4) Audio recording capability in the count room that is:

(a) Installed and disclosed to employees of the facility; and

(b) Consistent with Courts and Judicial Proceedings Article, §§10-401—10-414, Annotated Code of Maryland; and

(5) An access system which:

(a) Controls:

(i) Physical and logical access to the surveillance system; and

(ii) Physical access to the surveillance monitor room; and

(b) Restricts access to the security administration capabilities of the system.

D. A facility operator shall configure its surveillance system to record all areas and transactions enumerated in §C(1)(c) of this regulation at a minimum of 30 frames per second with a resolution of 4 common image format.

E. A facility operator may configure its surveillance system to record activity in areas of the facility not covered by §D of this regulation at a reduced frame rate with a resolution of 4 common image format, as follows:

(1) Public areas shall be recorded at a minimum frame rate of 15 frames per second; and

(2) Areas not accessible to the public shall be recorded at a minimum frame rate of 7.5 frames per second.

F. Except as provided in §G of this regulation, a facility operator shall retain surveillance recordings:

(1) For a minimum of 7 days for transactions or events in the areas covered under §E of this regulation; and

(2) For a minimum of 14 days for transactions or event in the areas covered under §D of this regulation.

G. Upon the request of the Commission or a law enforcement agency that has proper jurisdiction over the facility, a recording shall be retained and stored in accordance with the directives of the Commission or law enforcement agency pertaining to that recording.

H. Except as provided in this regulation, the surveillance system shall be under the exclusive control of the facility operator’s surveillance department.

I. A facility operator shall provide the Commission with timely and unfettered access to its surveillance monitor room, surveillance system, and all transmissions.

J. A facility operator shall timely comply with a request from the Commission to:

(1) Use, as necessary, any monitor room in the facility;

(2) Display on the monitors in its monitor room or in the Commission’s on-site monitor room any event capable of being captured by the surveillance system;

(3) Relinquish control of a camera or monitor;

(4) Discontinue monitoring a particular camera or recording activity captured by it;

(5) Make a video recording or photograph of any event capable of being captured by the surveillance system; and

(6) Restrict or deny access to a recording or photograph.

K. A surveillance system may not be remotely accessed from a location outside the surveillance monitor room without the prior written approval of the Commission.

L. An entrance to a surveillance monitor room may not be visible from the gaming floor.

36.03.10.12 Surveillance Department Operating Procedures:

A. At least 60 days before video lottery terminal or table game operations are to commence, a facility operator shall submit to the Commission for review and written approval:

(1) A surveillance system meeting the requirements of Regulation .11 of this chapter including, at a minimum, details pertaining to:

(a) Camera configuration inside and outside the facility;

(b) Monitor room configuration;

(c) Video recording format and configuration specifications;

(d) Authentication of digital recordings, including Commission access to the system’s video verification encryption code or watermark;

(e) Audio recording format; and

(f) System access controls; and

(2) Surveillance department operating procedures conforming to this regulation.

B. A facility operator may not commence operations until its surveillance system and surveillance department operating procedures are approved in writing by the Commission.

C. A facility operator’s surveillance department operating procedures shall, at a minimum, require:

(1) Coverage of all areas and transactions enumerated in Regulation .11 of this chapter;

(2) Contingency plans addressing:

(a) Full and partial failure of the surveillance system including:

(i) A contact list with telephone numbers for individuals required to be notified in the event of a failure; and

(ii) Facility closure protocols; and

(b) Planned shutdown of the surveillance system;

(3) A surveillance incident log:

(a) Maintained by monitor room employees in:

(i) A book with bound numbered pages that cannot be readily removed; or

(ii) An electronic format equipped with software that prevents modification of an entry after it has been initially entered into the system; and

(b) Documenting the scheduled coverage in §C(1) of this regulation and all other nonroutine surveillance activity as follows:

(i) Date and time surveillance is commenced;

(ii) Name and Commission license number of the individual initiating, performing, or supervising the surveillance;

(iii) Reason for the surveillance;

(iv) Whether the suspicious activity involves an alleged regulatory violation or criminal activity;

(v) Name, if known, alias, or description of an individual being monitored;

(vi) Description of the activity in which the individual being monitored is engaged;

(vii) Reading on a meter, counter, or device that identifies the point on the video recording at which the event was recorded;

(viii) Time at which a video recording is commenced and terminated, if different than when surveillance is commenced or terminated;

(ix) Date and time surveillance is terminated;

(x) Summary of the results of the surveillance; and

(xi) Description of the time, date, and cause of any equipment or camera malfunction which occurred during the conduct of surveillance;

(4) A surveillance room entry log:

(a) To be signed by an individual entering the surveillance monitor room who is not a surveillance department employee assigned to the monitor room’s work shift at the time of entry;

(b) Maintained by monitor room employees in:

(i) A book with bound numbered pages that cannot be readily removed; or

(ii) An electronic format equipped with software that prevents modification of an entry after it has been initially entered into the system; and

(c) Documenting the following:

(i) Date and time of entering the monitor room;

(ii) The entering individual’s name and department or affiliation;

(iii) The reason for entering the monitor room;

(iv) The name of the individual authorizing the individual’s entry into the monitor room; and

(v) The date and time of exiting the monitor room;

(5) That surveillance monitor room employees notify:

(a) Security department supervisory personnel within 5 minutes of an incident of equipment failure affecting coverage of the facility; and

(b) The Commission within 30 minutes of an incident of equipment failure affecting coverage of the facility citing:

(i) Date and time;

(ii) Cause of the malfunction; and

(iii) Time the facility operator’s security department was notified of the malfunction;

(6) That the facility operator confirm in writing a notice given verbally to the Commission under §C(5) of this regulation; and

(7) That, on a daily basis, the facility operator synchronize the date and time on the surveillance system to the date and time on the central monitor and control system and its video lottery system.

D. A facility operator may not implement a change or amendment in its surveillance system or surveillance department operating procedures approved by the Commission under §B of this regulation without the prior written approval of the Commission.

E. Surveillance department employees shall be reasonably segregated and independent of all other departments at the facility.

F. A surveillance department employee may not transfer to any other department in the facility without the prior written approval of the Commission.

36.03.11.03 Facility Design Standards:

[Note: I’ve edited this one down, so that it only includes surveillance-related code]

A. A facility operator shall, at its own expense, construct its facility in accordance with specifications established by the Commission, including:

(1) Computer space for the central monitor and control system contractor that is:

(e) Covered by a surveillance system enabled to record all entry and exit to the computer space and activity in the area;

(8) A surveillance system approved in writing by the Commission that is:

(a) Configured to provide surveillance of all video lottery terminal and table game related activities within the facility in accordance with standards established by the Commission;

(b) Enabled with a digital video recording format in accordance with standards established by the Commission; and

(c) Equipped with a monitoring station for the exclusive use of the Commission which is configured with full camera control capability over the surveillance system and is capable of overriding the camera control capability of the facility operator;

36.03.11.04 Table Games Surveillance Requirements:

A. Surveillance System. In addition to the surveillance system requirements in Regulation .03 of this chapter and COMAR 36.03.10, a facility operator that offers table games shall have a surveillance system that includes:

(1) Light sensitive cameras with lenses of sufficient magnification to allow the certificate holder to clandestinely monitor in detail:

(a) The gaming conducted at each gaming table in the licensed facility with sufficient clarity and coverage to simultaneously:

(i) Identify patrons and dealers; and

(ii) View the table and determine the configuration of wagers, card, dice and tile values and game outcomes;

(b) The movement of cash, gaming chips, and plaques, tip boxes, and drop boxes within the facility; and

(c) Any other activity or areas designated by the Commission; and

(2) Stationary cameras dedicated to table games, including:

(a) Except for Craps, Baccarat, Roulette and Big Six Wheel, at least one stationary camera for each table game offered by the facility;

(b) At least two stationary cameras for each Craps table, with one camera covering each end of the table;

(c) At least two stationary cameras for each Baccarat table, with one camera covering each end of the table;

(d) At least two stationary cameras for each Roulette table, with one camera covering the Roulette wheel and one camera covering the Roulette table layout;

(e) At least two stationary cameras for each Big Six Wheel, with one camera covering the Big Six Wheel and one camera covering the Big Six Wheel table layout; and

(f) Additional cameras as required by the Commission, which may include cameras with 360-degree pan, tilt, and zoom capabilities.

B. Required Recordings. A facility’s surveillance system must continuously record transmissions from cameras used to observe the:

(1) Gaming conducted at table games;

(2) Collection of drop boxes and tip boxes;

(3) Distribution of cards, dice, and tiles to gaming pits;

(4) Inspection of cards, dice, and tiles in the gaming pits and at the gaming tables;

(5) Retrieval of cards, dice, and tiles from the gaming pits at the end of the gaming day; and

(6) Delivery of cards, dice, and tiles to the location designated and approved by the Commission for inspection, cancellation, destruction, or, if applicable, packaging for reuse.

C. Retention.

(1) The surveillance recordings required under §B of this regulation shall be retained for a minimum of 7 days.

(2) A surveillance recording of suspicious activity, suspected or alleged regulatory violations, or suspected or alleged criminal activity shall be retained for a minimum of 30 days.

(3) A surveillance recording shall be made available for review upon request by law enforcement.

D. Commission approval of monitoring rooms.

(1) Prior to the commencement of table game operations, a facility shall submit to the Commission a revised minimum staffing submission for the facility operator’s surveillance monitor rooms.

(2) The minimum staffing submission must consider the size and layout of the licensed facility as well as the number of table games and must at all times provide for surveillance of activities inside and outside the licensed facility.

(3) A facility operator may not implement a surveillance plan, or an amendment to a surveillance plan or minimum staffing submission, without prior Commission approval.

There will be a quiz on all of this in the morning.

J. Freedom du Lac is the editor of The Post's general assignment news desk. He was previously a Local enterprise reporter and, before that, the paper’s pop music critic.
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