Fire Protection Concerns with Cannabis Facilities
With more states legalizing cannabis for medicinal and recreational purposes, the fire protection industry must be prepared to address the challenges that come with the growth of this industry. Currently, 38 states and the District of Columbia have legalized the use of cannabis for medicinal purposes. Nineteen states along with the District of Columbia have legalized the use of cannabis for recreational purposes. Chances are you probably live in a state where the use of cannabis has been legalized in one form or another. If not, legalization of cannabis may be coming to your area soon.
Fire protection challenges with cannabis facilities
NFSA has received questions from code officials and fire sprinkler designers on how to address these types of facilities from a sprinkler design perspective. Because of the unique nature of cannabis facilities, this blog is unable to provide specific guidance related to design or hazard classification based on NFPA 13. In many cases, the cannabis plant is processed like other plants, such as lavender and tobacco. Each facility is different depending on if it is used for growing or cultivating the plants, processing and extracting the oil and solvent, selling the product to the consumer, or a combination of all three. It may be necessary to involve a registered design professional to assist with the hazard classification process. For the authorities having jurisdiction (AHJs), you also have the option to require a third-party review to assist with the code requirements based on International Fire Code (IFC) Section 104.8.2. The goal of this blog is to encourage those involved in the design to ask the right questions early, while the building is still in the design stage.
Since the extraction process typically involves the use of hazardous materials, the Owner’s Certificate outlined in NFPA 13 Section 4.2 should provide the sprinkler designer and the AHJ with necessary information on what is occurring as part of the operation. The Owner’s Certificate should include the use of any hazardous materials (flammable liquid, flammable gas, asphyxiant, etc.), the quantities of each, and the type(s) of equipment that will be used to process and extract the oil and solvents. There are primarily three different occupancies that cannabis facilities will fall under. The sprinkler design and hazard classification will depend on what is happening inside the building.
Types of cannabis facilities
Cultivation and grow facilities: As the names imply, this is where the cannabis plants are grown until they reach their maturity for processing and extraction of the oil from the plants. These facilities are often very clean, sterile environments. Filtered air is often used to control the introduction of outside contaminants. Growers will often use carbon dioxide to assist with the growing process, which is a concern fire safety officials will need to address through the fire code. For the AHJs, cultivation and grow facilities can fall under a Group F-1, Group S-1 (high piled storage) or Group U classification. There are significant differences between the code requirements for a Group F-1 occupancy and a Group U occupancy. Therefore, it is important the owner provide as much information and detail as possible on the Owner’s Certificate about the growing process so the AHJ and sprinkler designer can make an informed decision. Cultivation facilities where the plants are grown outdoors are not regulated by the IBC and IFC. However, outdoor facilities are rare because security for these facilities is important.
Processing and extraction facilities: This is the most hazardous part of cannabis production because it often involves the use of hazardous materials to extract the solvent and oil from the plant. The processing of oils from plants is not new, it has been done for many years to extract materials like lavender and tobacco. However, the process is even more of a hazard when operators do not have the right equipment or are not properly trained. The extraction process often uses flammable liquids, such as ethyl alcohol, flammable gases, such as butane or propane, and/or hazardous gases, such as carbon dioxide (an asphyxiant) in the processing and extraction process. Ethyl alcohol is classified as a Class I-B flammable liquid and is the most common hazardous material used in the extraction process. Processing and extraction facilities will typically fall under the Group F-1 occupancy classification. It could also be a Group S-1 occupancy if “storing” materials and equipment. These facilities can also be considered Group H when the maximum allowable quantity for hazardous materials exceeds what is allowed for a control area based on chapter 50 of the IFC.
Dispensaries: Dispensaries were created to distribute the (medicinal or recreational) marijuana and involves the retail operation part of the cannabis business. Security is often very high for these occupancies. Because cannabis is currently illegal at the federal level, most banks will not work with these businesses. Many retail operations have large amounts of cash on hand. For that reason, security personnel will typically be close by. Dispensaries will typically be considered Group M occupancies and treated the same as any other mercantile occupancy. However, if processing and extracting occurs in the same building, or large amounts of hazardous materials are present, additional criteria from the IBC, IFC, and NFPA 13 will apply.
Hazardous materials and cannabis facilities
From an AHJ perspective, the plan review must take into consideration all hazardous materials that will be used, dispensed and/or stored on the premises. The use of carbon dioxide, for example, will likely drive additional requirements from the IFC for ventilation or gas detection. Any flammable liquids and gases used in the processing operation would be subject to the maximum allowable quantity provisions from IFC chapter 50. If the maximum allowable quantity is exceeded, the facility becomes a Hazardous, Group H occupancy, under the IBC and IFC. Hemp is considered a combustible fiber and subject to all the requirements found in IFC chapter 37 and the maximum allowable quantities in chapter 50. The IBC and IFC provide options for the design professional to avoid classifying the building as a Group H occupancy. One option is to separate the building into fire areas where each control area is below the maximum allowable quantity.
Also be aware that cannabis plants are combustible, and they do burn. If the plants are stored above 12 feet in height, the high piled storage provisions may apply. It is important to work with the local AHJ to determine the applicable fire code requirements since some AHJs consider the growing of plants a “process” and not storage.
As a member of NFSA, you have access to the Expert of the Day (EOD) benefit to ask fire protection questions. Members of NFSA have access to this service where you can receive a timely response (often 1 business day or less) to your question. In some cases, responses are sent out within a few hours of when they are received. NFSA has staff on numerous ICC and NFPA technical committees, including NFPA 420, Standard on Fire Protection for Cannabis Growing and Processing Facilities. We encourage you to utilize the EOD service as a resource for any of your fire protection related questions.