Marijuana facility guidance
“Electrical: Wiring, Extension Cords, Appliance, Lighting, Extraction Equipment,
Electrical systems are a common cause of ignition for fires. In 2011, an estimated 64,100 structure fires across the United States were reportedly caused by some type of electrical failure or malfunction. When firefighters are working to extinguish a fire in a building, they need to be able to turn the electricity off so they can operate more safely. For these reasons, there are several considerations that must be taken by marijuana facilities in order to ensure that electrical systems are installed and maintained safely.
General electrical requirements for all facilities follow Section 605 of the IFC:
- Doors into electrical control panel rooms are required to be marked with a sign stating ELECTRICAL ROOM. The means for turning off electrical power to each electrical service and each individual electrical circuit must be clearly and legibly marked.
- Electrical panels and electrical disconnect switches must be accessible at all times. A clearance of 30 inches wide (wider for panels and equipment that exceeds 30 inches in width), 36 inches deep, and 78 inches high is required to be maintained free from storage.
- Electrical systems must be maintained in good repair without exposed wiring, open junction boxes, or damaged equipment that could present an electrical shock or fire hazard.
Marijuana Facility Guidance Page 11 of 24
- Power strips with built-in overcurrent protection (“circuit breakers”) are allowed, provided they are plugged directly into a permanent electrical receptacle. Power strips may not be plugged into additional power strips (daisy chaining). A power strip’s cord may not be run through walls, above ceilings, or under doors or floor coverings. If power strips show evidence of physical damage, they must be replaced.
- Extension cords may only be used to provide temporary power to portable electric appliances. Extension cords may not be used as a substitute for permanent wiring, and may not be affixed to structures, extended through walls, ceilings or floors, or under doors or floor coverings. Multi-outlet extension cords that do not have built-in overcurrent protection (“circuit breakers”) are not allowed. If extension cords show evidence of physical damage, they must be replaced immediately.
Special requirements for cultivation and extraction:
The amount of electricity needed for a cultivation operation can easily exceed that of other types of businesses. If the cultivation business/facility moves into an existing building, there is a strong likelihood that the electrical panel and the wiring inside the building will require upgrading in order to accommodate the required power needed to cultivate plants utilizing grow lamps and ventilation equipment. It is not uncommon to have the electrical utility provider upgrade the amount of electricity feeding the building from the transformer outside.
Flammable gases and liquids often used for marijuana oil extraction have the potential to create an explosive environment for which the electrical system can be an ignition source. Rooms or areas where extraction equipment utilizes these materials are subject to special wiring and equipment requirements to minimize this risk. These requirements keep the electrical system isolated from the remainder of the space in a way that typical electrical systems do not.
Most cultivation and extraction operations try to remain discrete. This is often part of their overall security method and not wanting to draw a lot of attention to what they are doing. It is not unusual for the businesses to remove all markings from the building. All buildings are required to be provided with address identification. This address must be visible from the street or road fronting the property and contrasting with the background of the building. Signage that identifies the name of the business is not regulated by fire code, but may be regulated by local city or county government.
While it is understood that security is very important to marijuana facilities, this security cannot create risks to employees, the general public, and emergency responders. Not only do occupants need to be able to exit the facility in an emergency, but firefighters must be able gain access. There are several factors that must be considered when balancing security with fire code compliance:
- Egress doors are required to be readily openable from the egress side without the use of a key or special knowledge or effort, and cannot have hardware that requires tight grasping, tight pinching, or twisting of the wrist to operate. This means that double-cylinder deadbolts that allow the door to be locked with a key from either side are generally prohibited. Also prohibited are many styles of doorknobs and deadbolts that are often marketed for residential use. Door bars, surface bolts, and other security devices which require more knowledge or effort than the typical operation of a door latch are prohibited. (Section 1010)
- The unlatching of an egress door cannot require more than one operation. This means that adding several locking devices to a door for increased security is prohibited. For example: the installation of a deadbolt to
Marijuana Facility Guidance Page 12 of 24
a door that has an existing locking door latch is prohibited. Again, if it takes any more effort than the
typical operation of a door latch, the device is most likely not permitted on an egress door. (Section 1010) 3. The installation of security features designed to disable, injure, maim or kill intruders is prohibited.
Appliances: Extractor, Still, Vacuum Oven, Kitchen, CO2 Generator, Sulfur Evaporator
If required by the AHJ, a code analysis regarding compliance with the IFC in the use of all processing phases can be required to be provided by a third party, State Certified Professional Engineer or Fire Protection Engineer. The code analysis should cite all applicable building code, fire code/standards and identify compliance and/or non- compliance. Operational processes involving compressed gases should be documented in the analysis including annual LPG use and storage amounts; annual CO2 enrichment system process and storage amounts – including natural gas generators and for any system containing more than 100 lbs. of CO2; annual compressed gas use and storage (required for 6,000 cu/ft. or more of an inert – 1 lb. of CO2 = 8.74 cu/ft).
The AHJ should provide a list of requirements prior to the construction of a medical infused products (MIP) facility or processing room using the above listed appliances in the extraction, cultivation or processing of marijuana. Areas of interests include atmospheric monitoring, ventilation, posted proper emergency procedures, loading and offloading of compressed gases, storage of compressed gases and proper placarding on the building.
The AHJ is to confirm the recommendations made by the third party peer review that the room or space of use is in compliance with their recommendations before issuing a certificate of occupancy. Once the Engineer and the AHJ have both signed off on the proper setup of the room and all state regulations, such as proper licensing, has been completed the owner will then be granted permission to use the space as designed. Any alterations to the room of appliance will require a second review following the same requirements listed above.”