6 NFPA Regulations for Cannabis Extractors You May Have Missed

To keep up with the fast-moving cannabis industry, new building and safety codes have been introduced and it is our responsibility to stay aware and up to date. Common hazards in production and extraction are addressed by the National Fire Protection Association (NFPA)’s addition of Chapter 38 to the 2018 Edition of NFPA 1 Fire Code., “Marijuana Growing, Processing, or Extraction Facilities.”

1. Extraction Equipment

The Regulation

Equipment that isn’t listed for the specified use must submit a technical report to the AHJ for review in accordance with Section 1.15 documenting the design and peer review of the equipment.

 

The Explanation

The NFPA often relies on third-party reviewers to grant cannabis oil extraction equipment approval. In other industries, NRTL, or “Nationally Recognized Testing Laboratories,” would be required, and this is fast becoming a legal necessity in this industry. Not to toot our own horn, but it’s worth mentioning that Beaker & Wrench has already gone above and beyond to ensure our components are NRTL-certified.

 

  1. Signage

 

The Regulation

Extraction rooms shall have easily accessible safety data sheets (SDS). Additionally, the NFPA 704 hazard rating diamond sign and no smoking sign shall be displayed in front of the extraction room door. Any other hazard warning signs shall be posted where applicable.

 

The Explanation

As in any manufacturing industry, employees and contractors must be aware of workplace hazards associated with the materials and equipment with which they work. This regulation requires that all this information is compiled into a Safety Data Sheet or, “SDS.” These standardized sheets communicate risk to employees and help them better manage those risks. The no-smoking sign is, hopefully, self-explanatory. However, one must be careful about sparks and sources of sparks as well such as metal countertops. NFPA hazard diamonds prove invaluable in an emergency when they are used by emergency responders to assess and treat any situation that may arise. This quick frame of reference for emergency response allows them to know what hazards they can expect and appropriately plan and execute their response.

  1. A Clear Way Out

The Regulation

Extraction rooms that handle hazardous materials shall provide at least one exit access door fulfilling the following:

  • The door shall swing open in the direction of egress travel
  • The door shall self-close or automatically close
  • The door shall have panic or fire exit hardware

The Explanation

During an unexpected event, anyone in your extraction room must be able to exit the area quickly and efficiently. We wouldn’t want anyone getting caught at the door, which is why it is required that it swings out. The door should automatically close to minimize the threat of hazardous materials getting out of the room. Panic and fire exit hardware also aid in getting out quickly, a less fancy way of saying, “egress.” The hope is, of course, to never need to use any of these features, but being prepared is always the best (and required!) course of action.

4. Extraction Room Only

The Regulation

Extraction processes besides CO2 and nonhazardous materials, the equipment shall be located in a room of noncombustible construction. The room shall strictly be used for extraction processes.

 

The Explanation

In life and in business, we always want to minimize risk, right? The standard engineering control is to limit exposure to hazardous areas to mitigate health and safety risks. So it follows that the extraction room must be used exclusively for extraction processes and not for anything else. This keeps employees safer –  they are only exposed to hazardous areas or materials when it is absolutely necessary. The Occupational Safety and Health Administration uses this as the standard for all industries when hazardous materials are or may be present.

 

Significantly for us, Wiped-Film Evaporators are not solvent extractors and this means that Wiped-Film Evaporators should be housed separately from any extraction equipment.

5. Gas Detection System

The Regulation

Extractors shall use an approved continuous gas detection system. The system shall alert the extractor when the gas detection threshold is no greater than 25 percent of the gas LEL/LFL. Systems shall be provided with constant non-interlocked power.

 

The Explanation

Depending on method, many or even most of the hazardous solvents one uses in cannabis extraction are both odorless and colorless. As a result, those working on the process won’t be able to see or smell that something has gone wrong or even know they are experiencing a safety event. To combat this, you are required to install a continuous gas detection system. This ensures you and your employees will be aware should there ever be a dangerous level of any hazardous vapor.

6. Change of Extraction Medium

The Regulation

Where the medium of extraction or solvent is changed from approved material in the technical report, the report shall be revised at the owner’s cost and submitted for review prior to use.

 

The Explanation

Your technical report is approved based on the specific methods and materials you use. Naturally, if any of these conditions change, the results of the technical report would change as well. For this reason, a second review is required should any of the conditions of your initial report change or shift.

 

Developing extraction facilities with the highest possible fire service standards is in all of our best interest for more reasons than just the obvious. Most industries have national standards to which they can look to ensure they’re operating at the appropriate level of safety and preparedness. The set of regulations put forward in NFPA Chapter 38 allow marijuana extraction facilities to improve function with prominent fire service concerns addressed.

 

  1. The difference between NRTL, PE certified, Peer Reviewed

 

The California Regulation:

 

  • 40225. Closed-Loop Extraction System Requirements. (a) Chemical extractions using CO2 or a volatile solvent shall be conducted in a professional closed-loop extraction system. The system shall be commercially manufactured and bear a permanently affixed and visible serial number. The system shall be certified by a California-licensed engineer that the system was commercially manufactured, safe for its intended use, and built to codes of recognized and generally accepted good engineering practices, such as:

 

(1) The American Society of Mechanical Engineers (ASME);

(2) American National Standards Institute (ANSI);

(3) Underwriters Laboratories (UL); or

(4) The American Society for Testing and Materials (ASTM).

 

The certification document must contain the signature and stamp of a California licensed professional engineer and the serial number of the extraction unit being certified.

 

(b) Professional closed loop systems, other equipment used, the extraction operation, and facilities must be approved for use by the local fire code official and meet any required fire, safety, and building code requirements specified in:

 

(1) National Fire Protection Association (NFPA) standards;

(2) International Building Code (IBC);

(3) International Fire Code (IFC); and

(4) Other applicable standards including all applicable fire, safety, and building codes related to the processing, handling, and storage of the applicable solvent or gas. Authority: Section 26130, Business and Professions Code. Reference: Section 26012, subdivision (a)(3); 26050; and 26180, Business and Professions Code.

 

The Explanation:

 

This is a long regulation, but we’ll simplify for you! Closed Loop Extraction is exactly that. Wiped Film Evaporation does NOT use solvents, meaning many of the complicated regulations explained above do not apply. Just another Wiped Film Evap perk…

 

But since we’re here, we’ll also use this space to clear up some general common misconceptions we often hear. “Peer review,” is not required by this regulation, however, certification is required. Underwriters Laboratories is one of the better-known options of Nationally Recognized Testing Facilities (or NRTLs), but it is far from the only option and there are many to choose from. You can find the full, current list of NRTLs here and contact them directly to move forward with that phase of certification.

 

Additionally, all systems must have the “signature and stamp” of a California licensed engineer. Beaker & Wrench goes one further in respect: Our CEO and Mechanical Engineer is a “California licensed engineer.” Not only is our system approved by a CA Engineer, but it was also designed by one from the very beginning.

 

To recap, we are referring to three things you may be thinking about if you’re planning to use Closed Loop Extraction for your business or in your facility:

  1. Peer Review, which is not required by the regulation

2.Certification, which can be done by any number of Nationally Recognized Testing Laboratories or NRTLs listed by OSHA

  1. Signature and stamp of a California licensed engineer.

 

Disclaimer: As the cannabis industry grows and changes, we will continue to better learn how to protect ourselves, our employees, and our communities from risk, which in turn increases the overall legitimacy and success of our fast-advancing industry. It must be stated, however, that while we are experts in this field, we aren’t attorneys. The above is our interpretation of the current CA regulations, intended to help you inform yourself as you make decisions about your business. Always check in with your own attorney(s) about any of these decisions to ensure you are dealing with the most up-to-date, accurate information possible.

 

Additionally, keep in mind that we have been discussing California state regulations. Make sure you check with City and County authorities about your plans, as local restrictions may be slightly different. It is up to you to your due diligence, and we are grateful to be a part of your research, fact-finding, and solution-building process.

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