Like everything else in modern times, things change at a rapid pace. The treadmill of life presents us with new challenges every second of every day. In the context of fire protection, the most current change to the regions landscape is the legalization of cannabis for recreational use. This new legislature has created a new fire load the fire protection industry has not had to consider in the past. The state of Colorado has blazed a path for the rest of the country into the world of fire protection systems over the intricacies of cannabis growth, extraction, sales and consumption facilities. The NFPA is diligently working on a new code that will set the framework for the codes, standards and recommended practices when working with a cannabis related occupancy. NFPA 420.
The cannabis industry is a billion-dollar business that has taken off like a rocket in sales numbers since it has been legalized a few years ago in Colorado. Often, cannabis-related facilities will focus on one aspect of the industry: as stated above, grow facilities, processing / extraction facilities, and sales / consumption facilities. Grow facilities are just what the title suggests. They are typically located in a large warehouse setting that uses state of the art high wattage lighting and watering technology. In addition, the grow rooms are closely monitored by measuring devices and sensors to ensure the temperature and humidity numbers are exactly in the range they need to be to maximize on plant growth. Extraction / processing facilities are occupancies that take the physical plant and turn it into a sellable product for consumption. In addition to harvesting the plant for smoking, the plant is put through the extraction process where the chemicals are removed from the plant for use in other cannabis-based products such as soaps, tinctures, and food. Lastly sales and consumption facilities are locations where the cannabis product itself is available for purchase and consumption. These locations can be isolated, or in a shopping mall with other occupants such as a storefront or café.
Each one of the three different facilities presents unique hazards and related safety issues. The most fundamental question when it comes to cannabis facilities is: what is the occupancy classification? Not all hazards present in cannabis facilities are unique to the industry, so it is important to remember that the fire code, building code and other applicable regulations may already have provisions for dealing with some of the hazards that are already on site. The hazards that are not your average hazards and are unique to the cannabis industry can be found in Chapter 38 of the 2018 edition of NFPA 1 fire code. This code covers the safety of occupants in the building and protection of property in the most basic spectrum. The occupancy classification of the facility should be based on the occupancy definitions found in Chapter 6 of NFPA 1 and the building code (IBC). Depending on the nature of business the three-cannabis facilities conduct, dictates its classification. Growing and extraction facilities are classified as industrial storage. Selling facilities are classified as mercantile while consumption facilities may be classified as assembly or business depending on the occupant load. Much like any other business in the country, hazards of contents would also need to be evaluated. As stated in chapters 60-75 of NFPA 1, if the facility was found to have high hazard contents and are likely to burn with extreme rapidity or likely to explode, then the high hazard contents provisions would be applied to the occupancy.
Besides sales and consumption facilities having the usual hazards of a café or storefront, grow and processing facilities have several hazards that pose fire protection challenges. Although the plants themselves do not pose much of a fire load because of their moisture content, the containers the plants are grown in are typically resin petroleum-based products that burn quickly, drip and off gas faster than a non-synthetic. In addition to the grow trays, fertilizers and fumigants are being used which could be hazardous materials, oxidizers and or hazardous to humans. The lighting being used in grow facilities are very high wattage and produce a lot of heat which can be a hazard. Processing facilities pose the most potential for fire hazards because of the chemicals and gasses used during the extraction process. The process of extraction is commonly completed by using solvents such as LP-gas or carbon dioxide to strip the oils holding the chemicals from plant clippings. Other safety risks are bulk handling and mixing of gases, off gassing from products, and improper design, installation, and or maintenance of equipment that can lead to a leak or explosion from on site materials. For example, compressed gas such as propane and butane and cryogenic fluids held under pressure.
The current codes and standards being used for all the different types of cannabis facilities in and around the region derives from the current codes and standards in use by the state of Colorado. The referenced standards are:
- NFPA 13–Standard for the installation of Sprinkler Systems
- NFPA 30–Flammable and Combustible Liquids code
- NFPA 58–Liquified Petroleum Gas code
- NFPA 70–National Electrical code (2014)
- NFPA 55–Compressed Gases and Cryogenic Fluids code
- NFPA 497–Recommended Practice for the Classification of Flammable Liquids, Gases, or Vapors and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas
(Colorado Fire Marshals’ Special Task Group – Marijuana Facility Guidance v.1 – Based on the 2015 International Fire Code).
The National Fire Protection Association (NFPA) announced on May 4th, 2022, that the NFPA Standards Council has approved the development of NFPA 420, Standard on Fire Protection of Cannabis Growing and Processing Facilities. The new standard, which was originally proposed in response to serious fires that have occurred at cannabis facilities in recent years, will provide clear guidance on fire protection standards for facilities that produce, process and extract cannabis.
“With the rapid legalization of medical and/or recreational use of cannabis throughout the U.S. and the exponential growth of cannabis facilities around the globe, developing provisions that minimize fire and associated risks for facility staff and first responders – as well as nearby structures and occupants – is critical to safety.” (Kristin Bigda, technical lead of building and life safety at NFPA)
NFPA 420 will build upon the work started several years ago in NFPA 1, Fire Code, which addresses the fire protection aspects of the growing and processing facilities. The new stand-alone document will expand upon those requirements, referencing appropriate resources as needed, with the overall goal of addressing the protection of facilities from fire and related hazards where cannabis is being grown, processed, extracted, tested, and sold. The scope of NFPA 420 will include requirements for inspecting, systems testing, and maintenance of cannabis growing, processing, and extraction facilities. It also is anticipated to establish the general skills, knowledge and experience required among facility operators and facility managers responsible for ensuring adequate levels of safety at these facilities. The release date and final publication of NFPA 420 has yet to be released but is suspected to be sometime in 2023.