to Cannabis Facilities AKA: Marijuana and the building...

Marijuana and the Building Code

© 2018 Colorado Code Consulting, LLC 1

Applying the 2018 codes to Cannabis Facilities

AKA:Marijuana and the building codes

January 21, 2020 St George, Utah

Bill Clayton, CBOColorado Code Consulting, LLC

• Over 28 years in Building Code Enforcement and Administration

• Combination Building Inspector since 1992• Plans Examiner since 1996• Recovering CBO, 8 years + 1 year interim CBO at another

jurisdiction• Code consultant, inspector, plans examiner, instructor

with CCC 4 + years• Past member ICC IEBC Committee during 2009 & 2012

code cycle• Past member ICC IBC General Committee during 2015

code cycle


Wisdom the hard way?"The only true wisdom is in

knowing you know nothing.”

-Socrates-

© 2018 Colorado Code Consulting, LLC3

“You know nothing, Jon Snow.”-Ygritte-



What are we going to talk about?

• Types of Facilities

• Building Code Issues

• Fire Code Issues

• Energy Code Issues

• Plumbing, Mechanical, Electrical Code Issues

• Open Discussion



Source: Governing Magazine, Current as of May 22, 2019

State Marijuana Laws, 2019

History of Utah Cannabis law


• 1915: Utah banned Cannabis—one of the first states to do so.

• 2014: House Bill 105 signed legalizing CBD use

• 2018: March 21, Governor signs bill allowing Medical use by terminally ill patients

• 2018:Medical use was legalized by ballot measure in November, 2018



Profitable Business

Calendar YearRevenue By

Calendar YearTotal Revenue

Since Feb 2014

2014 (Feb - Dec) $67,594,323 $67,597,323

2015 $130,411,173 $198,005,496

2016 $193,604,810 $391,610,306

2017 $247,368,473 $638,978,779

2018 $266,529,637 $905,508,416

2019 (Jan - May) $111,611,720 $1,017,120,136


The table below shows Colorado medical and retail marijuana tax and fee collections totals by calendar year starting in 2014. Although sales of medical marijuana began prior to 2014, the Department of Revenue did not report tax collection data until February of 2014, after retail marijuana sales began.

Colorado Marijuana Taxes, Licenses and Fee Revenue

Updated June 2019 Source: colorado.gov

Facilities Categories

• Retail Shops• Commercial Grow Operations• Bakeries/Food Products (Edibles)• Drying/Curing/Trimming/Processing• Testing Labs• Personal Grow Operations• Coffeehouses• Vacation/Spa Experiences• Van/Bus Tours?


What is it and why do we care?

• Issues for building departments– Occupancy classification

– Security (state laws)

– Electrical (high demand)

– Ventilation (odors)

– Political pressure

• Legal issues

• Vulnerable neighbors




TERMINOLOGY

“EDIBLE RETAIL MARIJUANA PRODUCT"

means any retail marijuana product for which the intended use is oral consumption, including but not limited to, any type of food, drink, or pill.


"LIMITED ACCESS AREA"

means a building, room, or other contiguous area upon the licensed premises where retail marijuana is grown, cultivated, stored, weighed, packaged, sold, or processed for sale, under control of the licensee.


“FLAMMABLE SOLVENT”

means a liquid that has a flash point below 100 degrees Fahrenheit.




“FOOD-BASED RETAIL MARIJUANA CONCENTRATE”

a retail marijuana concentrate that was produced by extracting cannabinoids from retail marijuana through the use of propylene glycol, glycerin, butter, olive oil or other typical cooking fats.


“HEAT/PRESSURE-BASED RETAIL MARIJUANA CONCENTRATE”

means retail marijuana concentrate that was produced by extracting cannabinoids from retail marijuana through the use of heat and/or pressure. This method of extraction may be used only by a retail marijuana products manufacturing facility and can be used alone or on a production batch that also includes water-based retail marijuana concentrate or solvent-based retail marijuana concentrate.


“LIMITED ACCESS AREA”

means a building, room, or other contiguous area upon the Licensed Premises where Retail Marijuana is grown, cultivated, stored, weighed, packaged, Transferred, or processed for Transfer, under control of the Licensee.




"MEDICAL MARIJUANA BUSINESS"

means a medical marijuana center, a medical marijuana-infused product manufacturing business, or an optional premises cultivation operation.


“RESTRICTED ACCESS AREA”

means a designated and secure area within a licensed premises in a retail marijuana store where retail marijuana and retail marijuana product are sold, possessed for sale, and displayed for sale, and where no one under the age of 21 is permitted.


"RETAIL MARIJUANA CULTIVATION FACILITY"

means an entity licensed to cultivate, prepare, and package retail marijuana and sell retail marijuana to retail marijuana establishments, but not to consumers.




"RETAIL MARIJUANA ESTABLISHMENT"

means a retail marijuana Store, a retail marijuana cultivation facility, a retail marijuana products manufacturing facility, or a retail marijuana testing facility.


“RETAIL MARIJUANA PRODUCTS MANUFACTURING FACILITY”

means an entity licensed to purchase retail marijuana; manufacture, prepare, and package retail marijuana product; and sell retail marijuana and retail marijuana product only to other retail marijuana products manufacturing facilities and retail marijuana stores.


“RETAIL MARIJUANA TESTING FACILITY”

means an entity licensed and certified to analyze and certify the safety and potency of retail marijuana.




“SOLVENT-BASED RETAIL MARIJUANA CONCENTRATE”

means a retail marijuana concentrate that was produced by extracting cannabinoids from retail marijuana through the use of an approved solvent.


“WATER-BASED RETAIL MARIJUANA CONCENTRATE”

means a retail marijuana concentrate that was produced by extracting cannabinoids from retail marijuana through the use of only water, ice or dry ice.


State Regulations

• Licensing

– Retail Marijuana Establishments

– Medical Marijuana Business

– Retail Cultivation Facilities




Retailers

• Permitted to dispense marijuana

• Permitted to sell edible food products using medical marijuana


Marijuana Facilities

• Each licensed premises shall have a security alarm system, installed by an alarm installation company, on all perimeter entry points and perimeter windows.


Marijuana Facilities, continued…

• Each licensee must ensure that all of its licensed premises are continuously monitored.

• Licensees may engage the services of a monitoring company to fulfill this requirement.





• At all points of ingress and egress, the Licensee shall ensure the use of a commercial-grade, nonresidential door locks.



• Prior to exercising the privileges of a retail marijuana Establishment, an applicant must install a fully operational video surveillance and camera recording system.

• The recording system must record in digital format and meet the requirements outlined in this rule.


Waste Disposal

• Retail marijuana and retail marijuana product waste must be made unusable and unrecognizable prior to leaving the licensed premises.




Waste Disposal

• Grinding and incorporating the marijuana waste with non-consumable, solid wastes listed below such that the resulting mixture is at least 50 percent non-marijuana waste: a. Paper waste; b. Plastic waste; c. Cardboard waste; d. Food waste; e. Grease or other compostable oil waste; f. Bokashi or other compost activators; g. Soil;h. Sawdust; andi. Other wastes approved by the Division that

will render the Retail Marijuana, Retail Marijuana Concentrate and Retail Marijuana Product waste unusable and Unrecognizable.


Waste Disposal

• Rendered waste shall be: 1. Disposed of at a solid waste site

and disposal facility that has a certificate of designation from the local governing body;

2. Deposited at a compost facility that has a certificate of designation from the Department of Public Health and Environment; or

3. Composted on-site at a facility owned by the generator of the waste and operated in compliance with the Regulations Pertaining to Solid Waste Sites and Facilities (6 CCR 1007-2, Part 1) in the Department of Public Health and Environment.


Waste Disposal

• A Licensee shall not dispose of Retail Marijuana and Retail Marijuana Product waste in an unsecured waste receptacle not in possession and control of the Licensee.




How do they grow it?


Plant Growth Process

• Osmosis

– The plant takes up water and minerals from the soil through its roots and transfers it to the leaves through the stem and branches.

• Photosynthesis

– The plant uses absorbed light and air to transform water and minerals received through osmosis into plant tissue.


Plant Life Cycle

• Germination

• Seedling

• Vegetative Growth

• Pre-Flowering

• Flowering




Reproduction

• Plants can be reproduced by:

– Germination of seeds, or

– Cloning

• A clone is always taken from an adolescent female plant

• Will have the same characteristics of the mother plant


Harvesting/drying

• Hang plants upside down

• Place buds in canning jars


In home harvesting/drying

• Ovens

– 125-140 degrees F.

• Flat piece of foil under 100 watt lamp within 2-4 inches

• Wrap in paper and place over water heater, radiator or back of television

• Microwave oven




Lighting

• Metal Halide (Blue Spectrum)

• High Pressure Sodium (Red Spectrum)

• 400- to 1,000-watt bulbs


Heat and Temperature Control

• Ventilation

• Fans

• Air Conditioning

• Temperature Control is KING

• Lights & ballasts give off lots of heat


What Does It Need To Grow?

• Water

• Air

– Often enriched with CO2

• Medium

• Nutrients

• Chemicals

– To control pH levels




Ventilation

• Large amounts of plants, photosynthesis uses up all the carbon dioxide and fills the room with oxygen

• Plants need a fresh supply of CO2 in the room or they stop growing


Temperature

• Marijuana grows best at 68 – 72 degrees and will stop growing at temps above 90 degrees


Concerns

• Heat

• Electrical Loads

• Ventilation Rate

• Carbon Dioxide

• Egress

• Humidity

• Odor




Ventilation Equipment

• Large Squirrel Cage Fans

• Inline Fans

• Blowers

• Induction Fans

• Flex Hose Insulated Ducts



• CO2 Bottles

• CO2 Generators

• Environmental Controllers

– Temp

– Humidity

– CO2 Levels

• Carbon Filters



• Charcoal Filters

– Reduce Odors

• Ionizers

– Reduce Odors

• Ozone Generators

– Odor Control

– Humidity Control

• De-Humidifiers





• Oscillating Fans

– Move the CO2

– Strengthen the stalks

– Cool the plants

• Exhaust fans to eliminate the heat and excess oxygen


Types of Grow

• 3 Stages

– Propagation

– Vegetation

– Flowering

• Indoor or Outdoor

• Need high ceilings

– Plants at harvest 6’ – 10’


Types of Grow

• Propagation to Harvest– 90 – 110 days

• Minimum 3 crops per year

• Advantage– More yield per plant

• Disadvantage– Plants need more space,

water, nutrients, electricity and care




Types of Grow

• 2 stage

– Eliminates Summer stage

– Propagation and Flowering

• Timers set with equal amount of daylight and darkness (12 hours ea.)

• Smaller flowering plants at harvest

– 20” – 36”


Types of Grow

• Minimum 3 oz. bud per plant

• Propagation to harvest

– 60 Days

• Minimum 6 crops per year

• Advantages

– More crop/yield per year, more plants in limited space, less electricity, nutrients and water


Types of Grow

• Modified 2 Stage

– Eliminates the dark stage

• Advantages

– Similar to normal 2 stage process.




Yield per Harvest

• Outdoors– 1 pound per plant

• 3 stage– 7 – 11 oz. of buds per

plant

• 2 stage– 3 – 5 oz. of buds per

plant

• Modified– 4 – 7 oz. of buds per

plant


Lighting

• High Intensity Discharge (HID) Grow Lights

– High pressure sodium

– Metal halide

• 250-1,000 watt bulbs

• Requires ballast

= increased heat and fire hazard


Lighting

• Compact Fluorescent Grow Lights

– 300 W

• LED Grow Lighting

– Lower temperature




Lighting

• Lighting Reflectors

– Ceiling and walls

– Directs lights onto plants

– Reduces waste of lighting

– Mylar used on walls


Power Consumption

• One 1,000 watt HID lamp draws approximately 1KW/Hr.

– 12/12 light cycle will drawing 12KW per day or 360 KW per month

• Most growers will use more than one light


Power Consumption

• Average Home utilizes between 700 – 1200 KW per month

• Most homes can probably handle the increased loading of 305 HID lamps without additional wiring




Hydroponics

• Grow plants in an inert, sterile growing medium instead of soil. – Rockwool

– Perlite

– Clay pellets

• Flowering begins in 2-4 weeks

• Harvest two months later


Hydroponics

• Nutrients

– Nitrogen (N)

– Phosphorus (P)

– Potassium (K)

• Basic plant food

– Liquid

– powder


Hydroponics

• Ebb & flow system

– Reservoir with solution

– Pump on timer

– Pumps water and nutrient solution to the plants

– Solution drains back to reservoir




Home Based Grow Issues

• Electrical

– Unsafe electrical practices

– Open wiring

– Inadequate fuses or circuit breakers

– Bad connections

– Overloading of circuits

– 24 more times likely to catch fire


Home Based Grow Issues• Carbon Dioxide Poisoning

– Propane CO2 generators

– Vent furnaces and water heaters into grow rooms

– Normal levels• 300 – 600 ppm

– Desired grow levels• 1,000 – 3,000 ppm

– Lethal Level• 100,000 ppm

– OSHA• 30,000 ppm

© 2018 Colorado Code Consulting, LLC

65


• Ozone Gas

– Eliminates odor

– Consumes excess oxygen from plants

– Reduces mold growth





• Chemical Hazards

– Explosive/toxic fumes from “weed oil” extraction

– Butane, Sulfuric Acid, Methanol, Isopropyl Alcohol, Toluene

– Fertilizers

– Plant & water conditioners



• Mold

– Heat

– Humidity

– Cellulose

• Optimal conditions for mold growth



• Lighting Hazards

– Grow light surface temperature • Approximately 500

degrees

– Grow lights are under pressure




Commercial Grow Issues

• Power Consumption

– HID Grow lamps

– Usually obtain proper permits

– Work performed by electrical contractors



• Ventilation

– High humidity issues

– Odor control



• Means of Egress

– Security control

– Limited access





• CO2 Generation

• Ozone Generation

• Fertilizers

• Oil Extraction operations


Big Picture…

Not

“Minutia

Myopia”


What are these things?

• Dispensaries

• Grow Facilities

• Processing and Packaging

• Legal vs. Illegal Facilities




Dispensaries

• Mercantile Group M occupancy includes, among others, the use of a building or structure or a portion thereof, for the display and sale of merchandise and involves stocks of goods, wares or merchandise incidental to such purposes and accessible to the public.


Smoking/Treatment Rooms

• Group B

– Less than 50 occupant assembly area


Grow Facilities

• Group F-1

Factory Industrial Group F occupancy includes, among others, the use of a building or structure, or a portion thereof, for assembling, disassembling, fabricating, finishing, manufacturing, packaging, repair or processing operations that are not classified as a Group H hazardous or Group S storage occupancy.




Grow Facilities

• Group UBuildings and structures of an accessory character and miscellaneous structures not classified in any specific occupancy shall be constructed, equipped and maintained to conform to the requirements of this code commensurate with the fire and life hazard incidental to their occupancy. Group U shall include, but not be limited to, the following:

– Agricultural buildings


Processing & Packaging

• COMBUSTIBLE FIBERS. – Readily ignitable and free-

burning materials in a fibrous or shredded form, such as cocoa fiber, cloth, cotton, excelsior, hay, hemp, henequen, istle, jute, kapok, oakum, rags, sisal, Spanish moss, straw, tow, wastepaper, certain synthetic fibers or other like materials. This definition does not include densely packed baled cotton.


Processing and Packaging

• Group H-3

– Buildings and structures containing materials that readily support combustion or that pose a physical hazard shall be classified as Group H-3. Such materials shall include, but not be limited to, the following: • Combustible fibers, other than densely packed baled cotton




Extraction

• A solvent is used to extract the oil from the dried plant.

• The product is soaked, mixed and stirred in the solvent.

• The solvent/oil solution is then boiled to evaporate the solvent to leave the oil.


Extraction

• Solvents include

– Alcohol

– Naphtha

– Ether

– Butane

• All flammable liquids or gases


Extraction

• Depending on the amount of solvent that is used, the extraction area could be classified as a Group H-2.

• Ventilation is required regardless of occupancy classification.




Is it a Group H Occupancy?307.1High-hazard Group H occupancy includes, among others, the use of a building or structure, or a portion thereof, that involves the manufacturing, processing, generation or storage of materials that constitute a physical or health hazard in quantities in excess of those allowed in control areas complying with Section 414, based on the maximum allowable quantity limits for control areas set forth in Tables 307.1(1) and 307.1(2).


TABLE 307.1(1)MAXIMUM ALLOWABLE QUANTITY PER CONTROL AREA OF HAZARDOUS

MATERIALS POSING A PHYSICAL HAZARD

307.1.1 Uses other than Group H

• 3. Closed piping system containing flammable or combustible liquids or gases utilized for the operation of machinery or equipment.

• 8. The storage or utilization of materials for agricultural purposes on the premises.


Table 307.1(1)


Butane = Flammable GasEthyl Alcohol = Class IB Flammable Liquid



Maximum Allowable QuantitiesMAQ

• Butane

– 150 pounds storage

– 150 pounds closed use

– N/A open use

• Ethyl Alcohol

– 120 gallons storage

– 120 gallons closed use

– 30 gallons open use


Table Footnotes

• d. Maximum allowable quantities shall be increased 100 percent in buildings equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1. Where Note e also applies, the increase for both notes shall be applied accumulatively.

• e. Maximum allowable quantities shall be increased 100 percent when stored in approved storage cabinets, day boxes, gas cabinets, gas rooms or exhausted enclosures or in listed safety cans in accordance with Section 5003.9.10 of the International Fire Code. Where Note d also applies, the increase for both notes shall be applied accumulatively.


Is it a Group H Occupancy?

• Probably Not

• However, Section 414 still applies

– Control Areas

– Ventilation

– Explosion control

– Storage, dispensing and use

• IFC Requirements




CO2 Extraction

• Equipment isolates cannabinoid oils with a CO2 extraction process.

• No part of the cannabis plant is wasted.

• The cannabis by-products that would usually be discarded as waste are used in the extraction process.

• The CO2 equipment uses cannabis “trim” to produce a clean oil extract that can be used in food products and vape pens.


CO2 Extraction

• Compressed gas

• IFC Requirements

– Chapter 53

– Storage

– Use & Handling


Fire Sprinklers

• F-1 exceeding 12,000 square feet

• All Group H Occupancies

• Group M Occupancies fire area exceeds 12,000 square feet.




Means of Egress

• Security Issues

• Egress doors shall be readily openable from the egress side without the use of a key or special knowledge or effort.


1010.1.9.8 Sensor release of electrically locked egress doors

• The electric locks on sensor released doors located in a means of egress in buildings with an occupancy in Group A, B, E, I-1, I-2, I-4, M, R-1 or R-2 and entrance doors to tenant spaces in occupancies in Group A, B, E, I-1, I-2, I-4, M, R-1 or R-2 are permitted where installed and operated in accordance with all of the following criteria:



1. The sensor shall be installed on the egress side, arranged to detect an occupant approaching the doors. The doors shall be arranged to unlock by a signal from or loss of power to the sensor.

2. Loss of power to the lock or locking system shall automatically unlock the doors.





3. The doors shall be arranged to unlock from a manual unlocking device located 40 inches to 48 inches vertically above the floor and within 5 feet of the secured doors. Ready access shall be provided to the manual unlocking device and the device shall be clearly identified by a sign that reads “PUSH TO EXIT.” When operated, the manual unlocking device shall result in direct interruption of power to the lock—independent of other electronics—and the doors shall remain unlocked for not less than 30 seconds.

4. Activation of the building fire alarm system, where provided, shall automatically unlock the doors, and the doors shall remain unlocked until the fire alarm system has been reset.


Access-Controlled Egress Doors1008.1.4.4

5. Activation of the building automatic sprinkler system or fire detection system, where provided, shall automatically unlock the doors. The doors shall remain unlocked until the fire alarm system has been reset.

6. The door locking system units shall be listed in accordance with UL 294.


Delayed Egress Locks1010.1.9.7

• Approved, listed, • Permitted in any occupancy

except Group A, E and H occupancies

• NFPA 13 sprinkler system or automatic smoke or heat detection system

• Doors must unlock in accordance with Items 1 through 6 below.

• Cannot pass through more than one door equipped with a delayed egress lock before entering an exit.





1. The doors unlock upon actuation of the automatic sprinkler system or automatic fire detection system.

2. The doors unlock upon loss of power controlling the lock or lock mechanism.

3. The door locks shall have the capability of being unlocked by a signal from the fire command center.



4. The initiation of an irreversible process which will release the latch in not more than 15 seconds when a force of not more than 15 pounds is applied for 1 second to the release device.

Exception: Where approved, a delay of not more than 30 seconds is permitted



5. A sign shall be provided on the door located above and within 12 inches of the release device reading: PUSH UNTIL ALARM SOUNDS. DOOR CAN BE OPENED IN 15 [30] SECONDS.

6. Emergency lighting shall be provided at the door.




High Humidity

• No Code Requirements for excessive humidity


Ventilation

• IMC Section 403.3

– Smoking Lounges

– 60 cfm of outdoor air per person

– All air must be exhausted including air in excess of that required by Table 403.3


Exhaust DischargeIMC 501.2.1

• Product Conveying Exhaust– 10’ from the property lines; 3’

from exterior walls and roofs; 10’ from operable openings into buildings; 10’ above adjoining grade.

• Environmental Air Exhaust– 3’ from property lines; 3’

from operable openings into buildings for all occupancies other than Group U, and 10’ from mechanical air intakes. Such exhaust shall not be considered hazardous or noxious.




Odor Ventilation

• Local requirements

– Ventilation rates

– Charcoal filters

– Exhaust termination

– Effect on neighboring properties


City of Boulder Ventilation Requirements

• “A medical marijuana business shall be properly ventilated to filter the odor from marijuana so that the odor cannot be detected by a person with a normal sense of smell at the exterior of the medical marijuana business or at any adjoining use or property”.


Contaminant sourcesIMC 401.6

• Stationary local sources producing airborne particulates, heat, odors, fumes, spray, vapors, smoke or gases in such quantities as to be irritating or injurious to health shall be provided with an exhaust system in accordance with Chapter 5 or a means of collection and removal of the contaminants.

• Such exhaust shall discharge directly to an approved location at the exterior of the building.




City of Boulder Ventilation Requirements

• Walls should be sealed between units to avoid odors from migrating into adjacent spaces.

• Exhaust from space filtered with a listed & labeled filter to avoid odors.

• Inlet for ventilation system located in area of highest contaminant concentration.


Required Outdoor Ventilation AirIMC Table 403.3

• Cultivation Facilities

– 60 cfm/person (similar to smoking lounges)

• Dispensaries

– 7.5 cfm/person (retail sales)


Exhaust Outlets IMC 501.2.1

• Cultivation Facilities

• Product-conveying outlets– 10 feet from the

property lines;

– 3 feet from exterior walls and roofs;

– 10 feet from operable openings into buildings;

– 10 feet above adjoining grade.




Exhaust Outlets IMC 501.2.1

• Dispensaries

• Environmental air exhaust– 3 feet from property

lines;

– 3 feet from operable openings into buildings for all occupancies other than Group U, and

– 10 feet from mechanical air intakes.


Carbon Dioxide Generators

• Listed Appliance?

• Gas Piping

– Sizing

– Installation

• Proper Venting

– Is it really vented?


Plumbing Issues

• Backflow Protection?

– Lawn Irrigation system

– Chemical fertilizer dispensers

• Pipe installations

– Support

– Sizing




Energy Code Issues

• Total connected interior lighting power

Exceptions:

6. Task lighting for plant growth or maintenance


Electrical Code Issues

• Illegal installations

• Total Electrical Load

• Wiring methods


Electrical Code Issues

• GFCI Protection

• Ballast Installations

• Homeowner installations




Electrical Code Requirements

• One-line diagram

– Existing system

– Proposed electrical system

– Include main electrical service

• All electrical equipment to be listed and labeled by an approved testing agency



• Flexible cords not permitted to be substituted for fixed wiring systems

• Can’t run through walls, doors, ceiling, etc.

• Approved wiring methods required



• NM cable not allowed for use in damp locations such as cultivation facilities




2018 IFC Requirements

• Plant Extraction

– F338-16

– New Chapter 39

• CO2 Enrichment

– F369-16

– New Section 5307


PROCESSING AND EXTRACTION FACILITIESChapter 39

• Plant processing or extraction facilities shall comply with this chapter and the IBC.

• The extraction process includes the act of extraction of the oils and fats by use of a solvent, desolventizing of the raw material, production of the miscella, distillation of the solvent from the miscella and solvent recovery.

• The use, storage, transfilling and handling of hazardous materials in these facilities shall comply with this chapter, other applicable provisions of this code and the IBC.


3903.2 Prohibited occupancies

• Extraction processes utilizing flammable gases or flammable cryogenic fluids shall not be located in any building containing a Group A, E, I or R occupancy.




3903.3 Location

• The extraction equipment and extraction processes utilizing hydrocarbon solvents shall be located in a room or area dedicated to extraction.


3903.4 Post-process purification and winterization

• Post-processing and winterization involving the heating or pressurizing of the miscella to other than normal pressure or temperature shall be approved and performed in an appliance listed for such use.

• Domestic or commercial cooking appliances shall not be used.


3903.5 - Use of flammable and combustible liquids

• The use of flammable and combustible liquids for liquid extraction processes where the liquid is boiled, distilled or evaporated shall be located within a hazardous exhaust fume hood, rated for exhausting flammable vapors.

• Electrical equipment used within the hazardous exhaust fume hood shall be rated for use in flammable atmospheres.

• Heating of flammable or combustible liquids over an open flame is prohibited.




3903.5 - Use of flammable and combustible liquids

• Exception:

• The use of a heating element not rated for flammable atmospheres, where documentation from the manufacture, or approved testing laboratory indicates the element is rated for heating of flammable liquids.


3904Systems and equipment

• General requirements. Systems and equipment used with the processing and extraction of oils and products from plants shall comply with Sections 3904.2 through 3904.4 and 5003.2, and other applicable provisions of this code, the International Building Code and the International Mechanical Code.


3904.2 Systems and equipment

• Systems or equipment used for the extraction of oils from plant material shall be listed or approved for the specific use.

• If the system used for extraction of oils and products from plant material is not listed, the system shall be reviewed by a registered design professional.

• The registered design professional shall review and consider any information provided by the system’s designer or manufacturer.




3904.2 Systems and equipment

• For systems and equipment not listed for the specific use, a technical report in accordance with Section 3904.3 shall be prepared and submitted to the fire code official for review and approval.

• The firm or individual preparing the technical report shall be approved by the fire code official prior to performing the analysis.


3904.4 Site inspection

• Prior to operation of the extraction equipment, where required by the fire code official, the engineer of record or approved professional, as approved in Section 3904.2, shall inspect the site of the extraction process once equipment has been installed for compliance with the technical report and the building analysis.


• The engineer of record or approved professional shall provide a report of findings and observations of the site inspection to the fire code official prior to the approval of the extraction process.

• The field inspection report authored by the engineer of record shall include the serial number of the equipment used in the process and shall confirm that the equipment installed is the same model and type of equipment identified in the technical report.




3905.1 Gas detection

• For extraction processes utilizing flammable gases as solvents, a continuous gas detection system shall be provided.

• The gas detection threshold shall be not greater than 25 percent of the lower explosive limit/lower flammability limit (LEL/LFL) of the materials.


3905.1.3 Operation

• Activation of the gas detection system shall result in all the following:– 1. Initiation of distinct

audible and visual alarm signals in the extraction room.

– 2. Deactivation of all heating systems located in the extraction room.

– 3. Activation of the mechanical ventilation system, where the system is interlocked with gas detection.


3905.1.4 - Failure of the gas detection system

• Failure of the gas detection system shall result in the deactivation of the heating system; activation of the mechanical ventilation system where the system is interlocked with the gas detection system; and initiation of a trouble signal to sound in an approved location.




3905.1.5 Interlocks

• Electrical components within the extraction room shall be interlocked with the gas detection system.

• Activation of the gas detection system shall disable all light switches and electrical outlets.


3905.2 Emergency shutoff

• Extraction processes utilizing gaseous hydrocarbon-based solvents shall be provided with emergency shutoff systems in accordance with Section 5803.1.3.


5307 - Compressed gases not otherwise regulated

• Compressed gases in storage or use not regulated by the material-specific provisions of Chapters 6, 54, 55, and 60 through 67, including asphyxiant, irritant and radioactive gases, shall comply with this section in addition to other requirements of this chapter.




5307.2 Ventilation

• Indoor storage and use areas and storage buildings shall be provided with ventilation in accordance with Section 5004.3.

• Where mechanical ventilation is provided, the systems shall be operational during such time as the building or space is occupied.

Exceptions:– 1. A gas detection system

complying with Section 5307.2.1 shall be permitted in lieu of mechanical ventilation.

– 2. Areas containing insulated liquid carbon dioxide systems used in beverage dispensing applications shall comply with Section 5307.3.


5307.2.1 Gas detection system

• In rooms or areas not pro-vided with ventilation in accordance with Section 5307.2, a gas detection system complying with Section 916 or, where approved, an oxygen depletion alarm system, either of which initiates audible and visible alarm signals in the room or area where sensors are installed, shall be provided.


5307.4 Carbon dioxide enrichment systems

• The design, installation and maintenance of carbon dioxide enrichment systems with more than 100 pounds of carbon dioxide, and carbon dioxide enrichment systems with any quantity of carbon dioxide having a remote fill connection, shall comply with Sections 5307.4.1 through 5307.4.7.





• A gas detection system complying with Section 916 shall be provided in rooms or indoor areas in which the carbon dioxide enrichment process is located, in rooms or indoor areas in which container systems are located, and in other areas where carbon dioxide is expected to accumulate.

• Carbon dioxide sensors shall be provided within 12 inches of the floor in the area where the gas is expected to accumulate or leaks are most likely to occur.



• The system shall be designed as follows:– 1. Activates a low-level

alarm upon detection of a carbon dioxide concentration of 5,000 ppm.

– 2. Activates a high-level alarm upon detection of a carbon dioxide concentration of 30,000 ppm.


5307.4.3.1 System activation

• Activation of the low-level gas detection system alarm shall automatically:– 1. Stop the flow of carbon

dioxide to the piping system.

– 2. Activate the mechanical exhaust ventilation system.

– 3. Activate an audible and visible supervisory alarm signal at an approved location within the building.




• Activation of the high-level gas detection system alarm shall automatically:– 1. Stop the flow of carbon

dioxide to the piping system.

– 2. Activate the mechanical exhaust ventilation system.

– 3. Activate an audible and visible evacuation alarm both inside and outside of the carbon dioxide enrichment area, and the area in which the carbon dioxide containers are located.


5307.4.4 Pressurization and ventilation

• A mechanical ventilation system shall be provided in accordance with the International Mechanical Code that complies with all of the following:– 1. Mechanical ventilation in the

room or area shall be at a rate of not less than 1 cfm per square foot.

– 2. When activated by the gas detection system, the mechanical ventilation system shall remain on until manually reset.

– 3. The exhaust system intakes shall be taken from points within 12 inches of the floor.

– 4. The ventilation system shall discharge to the outdoors in an approved location.


5307.4.5 Signage

• Hazard identification signs shall be posted at the entrance to the room and indoor areas where the carbon dioxide enrichment process is located, and at the entrance to the room or indoor area where the carbon dioxide containers are located.

• The sign shall be not less than 8 inches in width and 6 inches in height and indicate:

CAUTION – CARBON DIOXIDE GAS

VENTILATE THE AREA BEFORE ENTERING.

A HIGH CARBON DIOXIDE (CO2) GAS

CONCENTRATION IN THIS AREA CAN CAUSE ASPHYXIATION.




A Sample Checklist

Marijuana Inspection Checklist:

Building Guidelines:

A building permit is required for work conducted to create a marijuana business as required in Article 4-512.I.of the Boulder County Land Use Code, effective June 8, 2010. You may need a Site Plan Review (SPR) under Article 4-800.

• A COPY OF THIS CHECKLIST SHOULD ACCOMPANY THE BUILDING PERMIT APPLICATION.


Sample Checklist, continued…1. Plans and permits are required per Boulder County Building Code Sections 105 and 107. Please provide this.

Provide a registered design professionals’ seal and signature on the plans including pages for structural, fire and life safety, plumbing, mechanical, and electrical. Please provide this.

Provide address numbers and /or unit number. Please provide this.

2. Unsafe structures and equipment shall be deconstructed and removed or made safe per 116.

3. Grow facilities are to meet IBC Chapter 3 requirements based on Use and Occupancy classification for factory industrial, F-1, moderate hazard occupancy (IBC 306.2), applicable Heights and Areas of IBC Chapter 5, Types of Construction of IBC Chapter 6, and Fire Protection Systems required by IBC Chapter 9. Please provide this.

4. Dispensaries are to meet IBC Chapter 3 requirements based on use and occupancy classification for mercantile, M, occupancy (IBC 309.1), applicable Heights and Areas of IBC Chapter 5, Types of Construction of IBC Chapter 6, and Fire Protection Systems required by IBC Chapter 9. Please provide this

Marijuana infused product (MIP) facilities are to meet IBC Chapter 3 requirements based on use and occupancy of Factory Industrial, F-1, moderate hazard occupancy (IBC 309.1), applicable Heights and Areas of IBC Chapter 5, Types of Construction of IBC Chapter 6, and Fire Protection Systems required by IBC Chapter 9. Please provide this.

Provide room uses above, below and on each side of your tenant space. Please provide this.


Sample Checklist, continued…Review the whole building for compliance with the Code, not just the individual tenant space. Please provide this.Provide a hazardous materials code analysis per IBC Section 307.1.1 and Table 307.1(1). Please provide this.Provide a hazardous materials code analysis per IBC Section 307.1.1 and Table 307.1(1). Please provide this.Applicable Means of Egress, IBC Chapter 10.Hardware, 1008.1.9.1. Door handles, pulls, latches shall not require tight pinching, grasping, or twisting. Please provide this.Door operations, 1008.1.9. Except as specifically permitted by this section egress doors shall

be readily operable from the egress side without use of a key or special knowledge or effort. Please provide this.Locks and Latches, 1008.1.8.3(similar). In buildings in occupancy Group B,F,M the main exterior door and doors are permitted to be equipped with key-operated locking devices from the egress side provided: Please provide this.2.1 The Locking device is readily distinguishable as locked. Please provide this.2.2 A readily visible durable sign is posted on the egress side on or adjacent the door stating: THIS DOOR TO REMAIN UNLOCKED WHEN BUILDING IS OCCUPIED. The sign shall be letters 1 inch (25mm) high on a contrasting background. Please provide this.2.3 The use of the key-operated locking device is revocable by the building official for due cause.




Sample Checklist, continued…Doors shall require only one operation to open the lock, latch or both. There are three general types of door hardware that meet this requirement: 1. Panic bar hardware.2. Mortise locksets (this hardware has a lever knob that releases the latch and the deadbolt in one motion).3. Full-throw “accessible” type deadbolts or Keyed deadbolts are allowed at the main exterior door only when a sign reading “THIS DOOR TO REMAIN UNLOCKED WHILE BUILDING OCCUPIED” IS POSTED ON OR ABOVE THE DOOR. Keyed and Full-throw deadbolts shall indicate green for “open” and red for “Closed”.Note:

1. All new door hardware shall be accessible per Chapter 11.2. Per State of Colorado requirements use commercial grade II door hardware at the main door and security room.3. Existing doors other than the main entrance door that currently require more than one motion to open will need to be changed to door hardware that allows only one operation to open the door. A mortise lockset could be an easy way to achieve this though you may choose panic hardware or other types of door hardware that are approved.Guards, 1013.1. Please provide this.Handrails, 1012. Please provide this.

Spaces with one means of egress, 1015.1. Two exits required at occupant load of 50 and 75” common path travel distance. (100’ if fire-sprinklered). The occupant load factor (O.L.F.) for dispensaries is 30 sq. ft. per person. The O.L.F. for grow and business areas is 100 sq. ft. per person. Please provide this. © 2018 Colorado Code Consulting, LLC

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Sample Checklist, continued…

6. Applicable flame spread ratings for interior finishes based on IBC Chapter 8 and F-1 Occupancy group.

Thermal barrier, 2603.4 (ignition barrier). Please provide this.Plastic film. Foam plastic insulation. Please provide the ICC evaluation service report for this product.Paper facing on fiberglass insulation.

7. Applicable glass and glazing requirements based on IBC Chapter 24.Hazardous location, 2406.4 #6 (within 24” of a door, tempered glazing or approved film will meet this requirement).

Mechanical Guidelines:Required Outdoor Ventilation Air IMC Table 403.3: For grow facilities use 8 persons per 1000 sq. ft. at a ventilation rate of 60 cfm/person. For dispensaries and MMIP use 8 persons per 1000 sq. ft. at 15 cfm per person. Please provide this.

Registers, grills, diffusers, IMC 603.17. Please provide this.

Location of exhaust outlets, IMC 501.2.1. #3 For all environmental air exhaust: 3 feet from property lines; 3 feet from operable openings into buildings for all occupancies other than Group U, and 10 feet from mechanical air intakes. Such exhaust shall not be considered hazardous or noxious. Please provide this.


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Listed and Labeled, IMC 301.4: Cooking equipment shall be listed and labeled for the use involved. Please provide this.Connecting appliances, IFGC 411.1. Fuel gas appliances shall use listed and labeled gas

connectors per ANSI Z21.24 or other approved means. Please provide this for MMIPs.

Additional requirements for grow facilities:Carbon dioxide generation shall be listed and labeled, properly installed and functioning with a concentration level of no more than 1500 ppm. Provide a chain restraint for the tanks. Please provide this.

Other related requirements:Prohibited locations, IMC 303.3. Fuel fired appliances cannot be located in storage areas.

Equipment and appliances on roof or elevated structures, IMC 306.5. Provide access. Please provide this.

Condensate disposal, IMC Section 307. Please provide this.

Backflow prevention, IPC 608.1. Please provide this.


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Walls sealed between units to avoid energy migrating into adjacent spaces. Please provide this.

Storage lofts shall be designed for 125 PSF minimum. Please post this design load in the storage area on a permanent sign. Provide guards at storage lofts. Please provide this.

Please provide ComCheck showing compliance for this project. Please provide this.

Provide Accessibility per IBC Chapter 11 and Chapter 34. Please provide this.

Plumbing fixtures shall be EPA Water Sense certified. Please provide this.

Trash Storage and Recycling Areas, IECC Chapter 10. 1001. Onsite recycling. The following standards shall apply to the construction of trash storage and recycling areas for attached business and industrial building uses:

(a) Covered Area: Trash storage and recycling area shall be accommodated within the structure, or adequate common area and shall be included on a site plan.

(b) Hard Surface Required, Screening and Landscaping: All outdoor trash recycling storage and containers shall placed on a hard surface, including, without limitation, concrete, and shall be screened.

(c) Maintenance and Service: Trash storage and recycling area shall include adequate space for the maintenance and servicing of containers for recycling materials that are provided for the collection and storage of trash materials.


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(d) Adequate Space for Trash and Recyclables: The amount of space provided for the collection and storage of recyclable materials shall be at least as large as the amount of space provided for the collection and storage of trash materials.

(e) Convenience and Accessibility: The recycling area shall be at least as accessible and convenient for tenants and collection vehicles as the trash collection and storage area.

(f) Minimum Clearance: A minimum height clearance of eight feet shall be required if the space is provided in a covered enclosure. Please provide this.

Electrical Guidelines:

All Electrical systems and permitting are required to be done by licensed electricians and contractors. Please provide this.

1. A single line diagram or the existing and proposed electrical system, including the main electrical service shall be provided to the county. NEC 215.5. Please provide this.

2. All electrical equipment is to be listed and labeled by an approved testing agency. NEC 110.3. Please provide this.

3. Flexible cords (extension cords) are not to be used as a substitute for fixed wiring nor run through or concealed by hole in walls, structural ceilings, suspended ceiling, dropped ceilings of floors: run through doorways, windows or similar openings: attached to building surfaces. NEC 400.8 Please provide this.


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Sample Checklist, continued…4. Approved wiring methods utilized in grow facilities with in accordance with “wiring methods and materials”. NEC Chapter 3. Please provide this.

5. NM cable (romex) is not allowed for use in damp locations like grow facilities, NEC 334.10. Please provide this.

6. All electrical equipment and building components shall be completed inspected and approved prior to stocking of any marijuana. Boulder County Building Code Section 110 Inspections and Section 111 Certificate of Occupancy. Please provide this.

7. Please show how individual tenant occupants can access their electrical equipment and panels without entering another tenant space. Access to equipment shall be maintained at all times. Please provide this.

Other Items:

If this is a MMIP please provide a letter stating the nature of the business, including ingredients, processes, and quantities.

Please contact our plans examiners at ___-___-____ or on line at http://www._________.org/property/build/pages/askbuilding.aspx

for building/mechanical/plumbing related questions.

For Licensing related issues, please contact ___ ________ at ___-___-____ or _________@______.org. A copy of this document will be emailed to you within ten business days.


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http://www._________.org/property/build/pages/askbuilding.aspx

mailto:[email protected]



“Colorado Code Consulting, LLC” is a Registered Provider with The American Institute of Architects Continuing Education Systems (AIA/CES). Credit(s) earned on completion of this program will be reported to

AIA/CES for AIA members. Certificates of Completion for both AIA

members and non-AIA members are available upon request.

This program is registered with AIA/CES for continuing professional

education. As such, it does not include content that may be deemed

or construed to be an approval or endorsement by the AIA of any

material of construction or any method or manner of handling, using,

distributing, or dealing in any material or product.

Questions related to specific materials, methods, and services will be

addressed at the conclusion of this presentation.


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© Colorado Code Consulting, LLC, 2015


Colorado Code Consulting, LLC

4610 S Ulster, Suite 150

Denver, CO 80237

Ph. 303-400-6564

Fax 303-693-0630

www.coloradocode.net

Bill Clayton

Ph. 720-271-6066

[email protected]


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