At CodeNext Inc., we have had the opportunity over the past few years to join the design community involved in the development of cannabis oil extraction facilities in Canada. It is an exciting community – the technology is evolving at a rapid pace, projects move quickly, and the momentum within the sector is remarkable. 

With such momentum, it is critical that the design team establishes a clear, consistent, and comprehensive description of the fire and explosion risks that will be present during the oil extraction processing and refinement activities. Accurate project definition promotes efficient design, expeditious permit review, and cost-effective project management. It has been our experience that the early engagement of Code consultants and design teams familiar with hazardous materials regulations and the cannabis extraction process can have a positive impact on the overall design process.

The following list outlines fundamental elements of an extraction project that the design team and the Authority Having Jurisdiction must understand for Canadian applications of the Building and Fire Codes.

Know your Solvents

There are numerous cannabis oil extraction and refinement technologies available in Canada. The most common rely on flammable solvents. Flammable solvents include flammable liquids such as ethanol and pentane and flammable gases such as butane and propane (Liquified Petroleum Gas, LPG). Additionally, carbon dioxide extraction which uses the non-flammable, non-toxic compressed gas as a solvent, is frequently adopted in industry.

Once the solvents intended for use in a facility are established, the designer can determine which Codes will regulate the solvent storage, handling, and processing activities.

Once the solvents intended for use in a facility are established, the designer can determine which Codes will regulate the solvent storage, handling, and processing activities. Flammable liquid solvents are typically regulated under Part 4 of the provincial Fire Code. LPG is typically regulated under the provincial Gas Code, or under other standards recognized for good engineering practice, such as NFPA 55, “Compressed Gases and Cryogenic Fluids Code”. Additionally, the storage and use of carbon dioxide is regulated under the provincial Fire Code or the National Fire Code of Canada; however, the regulations vary somewhat province-to-province. 

Know your Solvent Life Cycle

Cannabis oil extraction is not typically conducted from start to finish in a single vessel or even within a single room in a facility. Depending on the initial extraction medium used, numerous refinement stages or down-stream processing may be required. Each processing stage can involve the introduction of new solvents, or the removal and collection of waste solvents.

A full life-cycle review of the hazardous solvents in a facility must be conducted to ensure that the Building and Fire Codes are applied to all regulated activities.

We have encountered a range of suitable Code applications for cannabis oil extraction and refinement activities, which consider the level of risk associated with each process. To consider a life-cycle review, we often ask: Where are solvents stored, indoors or outside? What rooms will solvents be used in? What concentration of solvents will be retained in the extraction oil in each process? And, where and how is waste solvent collected and stored? In addition to cannabis oil extraction rooms, we often find that facilities will require flammable liquid storage and dispensing rooms, bulk tank storage areas, or warehouse spaces designed for hazardous materials.

Know your Process

Once the solvent classification and solvent life-cycle have been determined, then the specific characteristics of the extraction activities and their associated level of risk establish the most suitable application of the Codes. The level of risk attributed to cannabis oil extraction and refinement activities is based on the types of solvents used, the volumes of solvents required, the processing activities, and equipment selected for the project. 

For example, consider the different levels of risk associated with large volumes of flammable liquids stored at very low temperatures versus a comparatively small volume of liquified flammable gases used in a processing application. The risks are different; therefore, the Codes prescribe different design requirements for these activities. 

We have encountered a range of suitable Code applications for cannabis oil extraction and refinement activities, which consider the level of risk associated with each process.

We have encountered a range of suitable Code applications for cannabis oil extraction and refinement activities, which consider the level of risk associated with each process.Applications for cannabis oil extraction include: proof-of-concept laboratories (low risk), incidental-use of liquids (moderate risk), and process plants (high risk). Additionally, since certain processing activities require open-dispensing or regular off-gassing of flammable solvents, requirements for explosion protection and/or prevention systems must be assessed for each project.

Know your Building

When designing a new cannabis oil extraction space, designers determine requirements for: fire separations, mechanical systems, hazardous locations, combustible gas detection systems, and spill control systems, for example. However, it is also necessary to determine if the building that will house the extraction activities is suitable to support this new occupancy. 

A common challenge in designing extraction spaces involving hazardous solvents is occupancy classification.

A common challenge in designing extraction spaces involving hazardous solvents is occupancy classification. First, the evaluation of the extraction spaces as major or subsidiary occupancies under the provincial Building Code has a significant impact on the building design. Secondly,  the determination of the appropriate occupancy classification for the rooms or buildings involving the storage and use of hazardous solvents is critical. 

We recommend that these evaluations be determined on a project-by-project basis and be considered during the project feasibility assessment.

Know your Toolkit

While we must apply the provincial Building and Fire Codes, there are other guidance documents that can support the evaluation of cannabis oil extraction spaces. Though not yet adopted in the provincial Building and Fire Codes, new standards have been published recently to support the regulation and design of cannabis extraction facilities and equipment in Canada.These include: CAN/ULC-S4400, “Standard For Safety of Premises, Buildings and Equipment Utilized for the Cultivation,Processing and Production Of Cannabis”, and ANSI/CAN/UL/ULC 1389, “Standard for Safety – Plant Oil Extraction Equipment for Installation and Use in Ordinary (Unclassified) Locations and Hazardous (Classified) Locations”. 

In addition to the above standards, it may also be relevant to consider cannabis-related guidance from jurisdictions that supported the growth of the cannabis industry outside of Canada. For example, international standards such as NFPA 1: Fire Code, Chapter 38, “Marijuana Growing, Processing, or Extraction Facilities”, and the International Fire Code, Chapter 39, “Processing and Extraction Facilities”, provide valuable context for the design and evaluation of cannabis oil extraction environments.

Now you Know!

In Canada, the growth of the cannabis oil extraction sector will lead to a continued demand for facilities that are designed for the associated storage, handling, and use of hazardous solvents. Fire protection and life safety professionals, Authorities Having Jurisdiction, and design practitioners will continue to undertake these projects, and we must promote the best practices available to this growing sector.

In Canada, the growth of the cannabis oil extraction sector will lead to a continued demand for facilities that are designed for the associated storage, handling, and use of hazardous solvents.

Through education, collaboration, and fire safety design principles, we can develop consistent and appropriate design approaches for cannabis oil extraction environments.