July 21, 2019 CSI Filing

Created by Executive Order 2011-01K, the Common Sense Initiative (CSI), and Senate Bill 2 of the 129th General Assembly, require state agencies, including the Casino Control Commission, to draft rules in collaboration with stakeholders, assess and justify any adverse impact on the business community (as defined by Senate Bill 2), and provide opportunity for the affected public to provide input on the rules. 

The Ohio Casino Control Commission submitted the following proposed rules to the CSI office for review on July 17, 2019: 

Brief Explanation of the Rules 
The amendments contained within this rule package govern electronic gaming equipment and table games operations. One consistent change, a reflection of present practice, is codifying the Executive Director’s approval authority throughout the rules, given that role’s responsibility to administer casino gaming pursuant to R.C. 3772.06. This will allow for day-to-day casino operations to generally be more dynamic, without sacrificing regulatory oversight.  

OAC 3772-9, 3772-10 and 3772-11 (3 RULES)

3772-9-02 and appendix – titled, “Approval for use in a casino facility.” This rule governs which electronic gaming equipment (“EGE”) may be used in a casino facility and includes an appendix of standards, which the EGE must be tested against and meet. Most of the changes are non-substantive, made for the sake of readability, or to reflect present practice.  One change of note is the removal of the specific procedure for submission of EGE for approval because it does not reflect present practice and unnecessarily restricts the methods for submission and the Commission’s management of the process. With respect to the appendix, non-substantive edits were made for readability and language clarified that EGE must meet the standards, rather than the entities submitting the EGE for testing. Finally, updated versions of GLI Standards One, Seven, and Eleven replace older versions and a thirteenth standard, “Card Shufflers and Dealer Shoes” is proposed for adoption, as well.


3772-10-18 – titled “Table drop boxes and electronic gaming equipment bill validator canisters: physical requirements and transportation.” This rule governs the physical requirements and transportation procedures for both table game drop boxes and electronic gaming equipment bill validator canisters. Nearly all of the amendments are proposed to reflect present practice, including the use of the Executive Director’s authority to administer casino gaming, as discussed above. Casino operators will no longer need to include the specific times and procedures for transport of these items in their internal controls, which requires approval at a monthly public Commission meeting. Rather, their dynamic nature merits a more flexible approval procedure, resulting in the amendment for submission to the Executive Director. Finally, some non-substantive edits were made for readability. The purpose of this rule is to ensure adequate controls are in place for table game drop boxes and electronic gaming equipment bill validator canisters while allowing each casino operator to determine the appropriate methods for doing so at each casino facility.


3772-11-17 – titled Counterfeit chips. No changes are proposed for this rule, which requires casino operators to immediately deliver a counterfeit chip to Commission gaming agents upon discovery. The purpose of this rule is to ensure that the Commission can commence an appropriate investigation of the use of counterfeit chips without unnecessary interruptions in the chain-of-custody. 

Associated CSI Documents
Business Impact Analysis

Contact Information for Comments
The Commission welcomes comments regarding these proposed rules. To ensure your comments are considered as part of the Common Sense Initiative (“CSI”) review period, the Commission should receive them no later than July 31.

Any questions or comments with respect to these rules may be directed to Michelle Siba via email at Michelle.Siba@casinocontrol.ohio.gov or U.S. Mail at 100 East Broad Street, 20th Floor, Columbus, Ohio 43215. Comments may also be directed to the CSI Office at csipubliccomments@governor.ohio.gov.

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