For a text version of these new codes, visit: http://lawfilesext.leg.wa.gov/law/wsr/2015/14/15-14-064.htm
The stated purpose of these emergency rules is found at the link above, and quoted below:
“Purpose: This rule is established to provide regulatory guidance to marijuana processing or extraction facilities. This new industry in Washington state produces marijuana for sale in specially licensed retail stores throughout the state. At this time there are no specific regulations in place to ensure safety in the processing plants or extraction facilities. This rule will establish specific requirements for handling hazardous materials, establish inspection standards, and provide construction and permit requirements to ensure the life/safety of occupants, first responders, and the general public.”
The document goes on to cite an explosion in Bellevue caused by an at home butane extraction in 2013 that resulted in a fatality. With such incidents to refer to, it is no surprise that some authority in the state would seek to bring the manufacture of cannabis resins up to industry safety standards.
The rules go into effect as follows:
- July 1, 2016 for any marijuana extraction facility in operation prior to July 1, 2015
- July 1, 2015 for all others
Meaning that even if you are “grandfathered” in, you must be in compliance by July 1 of next year. If you think that these rules go easy on carbon dioxide (CO2) based extraction operations, think again. There are many more rules that are specific to CO2 based extractions than are specific to any other method of extraction. And no matter what, everyone is required to have an Operational Permit according to the new code (WAC 51-54A-105.6.47). In addition, any new facility must also seek a Construction Permit effective July 1, 2015 (WAC 51-54A-105.6.47).
Besides permits, in order to be compliant your extraction system must have been designed or reviewed by a Washington Professional Engineer (WAC 51-54A-3802.3.3.2).
According to WAC 51-54A-3801.3.3.4: “The technical report documenting the design or peer review shall be submitted for review and approval by the fire code official prior to the equipment being located or installed at the facility.”
According to WAC 51-54A-3802.3.3.4.2, this technical report is to be composed of no less than 15 sections including:
“6. Methodology of the design or peer review process used to determine minimum safety requirements. Methodology shall consider the basis of design, and shall include a code analysis and code path to demonstrate the reason as to why specific code or standards are applicable or not.”
“7. Equipment description. A list of every component and subassembly (clamp, fittings, hose, quick disconnects, gauges, site glass, gaskets, valves, pumps, vessels, containers, switches, etc.) of the system or equipment, indicating the manufacturer, model number, material, and solvent compatibility. Vendor cut sheets shall be provided.”
“12. Comprehensive process hazard analysis considering failure modes and points of failure throughout the process. This portion of the review should include review of emergency procedure information provided by the manufacturer of the equipment or process and not that of the facility, building or room.”
In addition, there are construction requirements (WAC 51-54A-3802.4), building analysis requirements (WAC 51-54A-3802.3.3.5), and site inspections (WAC 51-54A-3802.3.3.6) that must be met prior to initiating extraction operations at the facility.
A couple of CO2 specific requirements include additional signage (WAC 51-54A-3802.5.7) warning of a potentially oxygen deficient atmosphere and adequate ventilation (WAC 51-54A-3802.5.8) including that the “exhaust system intake shall be taken from a point within 12 inches of the floor.”
After you read the emergency rules in their entirety, I believe you will agree with me that they seem quite onerous, especially for CO2 extraction operations.
Dr. T’s EasyExtracts method is far easier to implement under these new rules, and that’s not the only benefit. Dr. T’s EasyExtracts will provide high-quality, consistent results through a simple and safe process. Contact Dr. Towle to learn more!