205 CMR 146.53
Pai Gow Tiles: Receipt; Storage; Inspections, and Removal From Use
(1) When sets of tiles to be used at pai gow are received from the manufacturer or distributor
thereof, they shall immediately following receipt be inspected by a member of the security
department and a supervisor to assure that the seals on each package are intact, unbroken and free
from tampering. Packages that do not satisfy these criteria shall be inspected at this time to
assure that the tiles conform to Bureau standards and there is no evidence of tampering.
Packages satisfying these criteria, together with packages having unbroken, intact, and
untampered seals shall then be placed for storage in a locked cabinet within a primary or
secondary storage area. Sets of tiles which are to be distributed to gaming pits or tables for use
in gaming shall be distributed from a locked cabinet in the cashiers’ cage or from another secure
primary storage area, the location and physical characteristics of which shall be approved by the
Bureau. Secondary storage areas shall be used for the storage of surplus tiles. Tiles maintained
in secondary storage areas shall not be distributed to gaming pits or tables for use in gaming until
the tiles have been moved to a primary storage area. All secondary storage areas shall be located
in secure areas, the location and physical characteristics of which shall be approved by the
Bureau.
(2) All primary and secondary storage areas, other than the cashiers’ cage, shall have two
separate locks. The security department shall maintain one key and the casino department or
cashiers’ cage shall maintain the other key; provided, however, that no person employed by the
casino department below the table games shift manager in the organization hierarchy shall have
access to the casino department key. Tiles stored in a cabinet within the cashiers’ cage shall be
secured by a lock, the key to which shall be maintained by a table games shift manager or casino
supervisor thereof.
(3) Immediately prior to the commencement of each gaming day and at such other times as may
be necessary, the table games shift manager or supervisor thereof, in the presence of a security
officer, shall remove the appropriate number of sets of tiles for that gaming day from a primary
storage area. Tiles are to be inspected by surveillance prior to the game beginning for the gaming
day or when new tiles are being put into play.
(4) All envelopes and containers used to hold or transport tiles shall be transparent. The
envelopes or containers and the method used to seal them shall be designed or constructed so that
any tampering shall be evident.
(5) The table games shift manager or casino supervisor thereof shall distribute sufficient sets
of tiles to the pit boss in each pai gow pit. The pit boss shall then distribute the sets to the dealer
at each table, and shall place extra sets in reserve at the pit stand. Sets of tiles in reserve shall
be placed in a locked compartment, keys to which shall be in the possession of the pit boss or
casino supervisor thereof.
(6) If during the course of play any damaged tile is detected, the entire set of tiles shall be
immediately replaced. The dealer or floorperson shall request that the pit boss bring a substitute
set of tiles to the table from the reserve in the pit stand. The set of damaged tiles shall be placed
in a sealed envelope, identified by table number, date and time and shall be signed by the dealer
and casino supervisor. The pit boss shall maintain the envelope or container in a secure place
within the pit until collection by a casino security officer.
(7) Tiles used at pai gow shall be changed at least every 12 hours. The supervisor shall collect
used tiles which shall be placed in a sealed envelope or container. A label shall be attached to
each envelope or container which shall identify the table number, date and time and shall be
signed by the dealer and casino supervisor. The pit boss shall maintain the envelopes or
containers in a secure place within the pit until collection by a casino security officer.
(8) The gaming licensee shall remove any tiles at any time of the gaming day if there is any
indication of tampering, flaws, scratches, marks or other defects that might affect the integrity
or fairness of the game, or at the request of the Commission or the Bureau.
(9) All extra sets of tiles in reserve which have been opened shall be placed in a sealed envelope
or container, with a label attached to each envelope or container which identifies the date and
time and is signed by the pit boss.
(10) At the end of each gaming day or at such other times as may be necessary, a security
officer shall collect and sign all envelopes or containers with damaged tiles, tiles used during the
gaming day, and all extra tiles in reserve which have been opened, and shall return the envelopes
or containers to the security department.
(11) At the end of each gaming day or at such other times as may be necessary, a table games
shift manager or supervisor thereof may collect all extra sets of tiles in reserve which have not
been opened. If collected, all unopened sets of tiles shall either be cancelled or destroyed or
returned to the storage area.
(12) When the envelopes or containers of used tiles and reserve sets of tiles which have been
opened are returned to the security department, they shall be inspected for tampering, marks,
alterations, missing or additional tiles or anything that might indicate unfair play.
(a) The gaming licensee shall cause to be inspected all sets of tiles used during the gaming
day.
(b) The procedures for inspecting all sets of tiles shall at least include the following:
1. The sorting of tiles by pairs;
2. The visual inspection of the sides and back of each tile for tampering, markings or
alterations;
3. The inspection of the sides and back of each tile with an ultra-violet light; and
4. White light to ensure no light can be seen coming through the tile ensuring that it is
not transparent or translucent.
(c) The individual performing the inspection required by 205 CMR 146.53 shall complete
a work order form which shall detail the procedures performed and list the tables from which
the tiles were removed and the results of the inspection. The individual shall sign the form
upon completion of the inspection procedures.
(d) Evidence of tampering, marks, alterations, missing or additional tiles or anything that
might indicate unfair play discovered at this time, or at any other time, shall be immediately
reported to the security department and the Bureau.
A security department member shall complete a two-part Discrepancy Report, which
Report along with the evidence shall be retrieved by an agent of the Bureau.
The original and duplicate Report shall contain at a minimum:
1. The date and shift of inspection;
2. The name of the supervisor conducting the inspection. The inspection required by
205 CMR 146.53(12)(a) shall be performed by a supervisor other than the one who
originally inspected the tiles;
3. The pit number, table number, and type of game;
4. A description (for example, shaved corners);
5. The signature of the supervisor conducting the inspection;
6. The signature of the security representative taking custody of the tile; and
7. The signature of the agent of the Bureau inspecting or accepting the tile, who shall
retain the original and return the duplicate to security. A receipt shall be issued to the
agent of the Bureau for any tile retained by the Bureau. The receipt shall be signed the
by the security representative releasing the tile to the Bureau and the agent of the Bureau
accepting the tile. The receipt shall be retained with the Security copy of the Discrepancy
Report. Any tile not retained by the Bureau shall be destroyed in accordance with the
licensee’s destruction procedures.
(e) If after completing the inspection procedures required in 205 CMR 146.53, it is
determined that a complete set of 32 tiles removed from a gaming table is free from
tampering, markings, or alterations, that set may be returned to the pai gow storage area for
subsequent gaming use in accordance with the gaming licensee’s internal control procedures.
In no event may individual tiles from different sets be used to make a complete set for
subsequent gaming use.
(13) The gaming licensee shall include in their internal control, procedures for:
(a) An inventory system which shall include the recordation of at least the following:
1. The balance of sets of tiles on hand;
2. The sets of tiles removed from storage;
3. The sets of tiles returned to storage or received from the manufacturer;
4. The date of the transaction; and
5. The signatures of the individuals involved;
(b) A reconciliation on a daily basis of the sets of tiles distributed and the sets of tiles
destroyed and cancelled, the sets of tiles returned to the storage area and, if any, the sets of
tiles in tile reserve; and
(c) A physical inventory of the sets of tiles at least once every three months. This inventory
shall be performed by an individual with no incompatible functions and shall be verified to
the balance of the sets of tiles on hand as required 205 CMR 146.53(13)(a)1. Any
discrepancies shall immediately be reported to the Bureau.
(14) Other than tiles retained for Bureau inspection, tiles shall be cancelled or destroyed within
72 hours of collection by the security department. In addition, once tiles retained as evidence
by the Bureau are released to the security department, the tiles shall immediately be destroyed
or cancelled.
(15) Destruction and cancellation of tiles shall take place in a secure place, the location and
physical characteristics of which shall be approved by the Bureau. The adequacy of the
destruction and cancellation process shall be approved by the Bureau. Destruction of tiles shall
be by shredding by the security department or a vendor approved by the Bureau. Cancellation
of tiles shall be by drilling a circular hole of at least ¼ of an inch in diameter through the center
of each card in the deck.