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Committee Blog: Everything You Wanted to Know About Cannabis Facilities But Were Afraid to Ask Field Guide – Part 1 – Cultivation

by members of NCIA’s Facilities Design Committee
Jacques Santucci, Brian Anderson, David Vaillencourt, and David Dixon

Introducing our five-part series on the behind-the-scenes workings of the legal cannabis industry. This series focuses on all of the inner dealings and industry advice from established professionals to craft this unlimited How-to-Guide to assist you in setting up your own facility. These articles cover cultivation, extraction, infused products, and retail facilities as well as support activities. In general, remember to be compliant with all local rules and regulations and contact a licensed contractor and industry expert. 

Part 1, Cultivation: The Top Things to Consider When Planning Your Cannabis Cultivation Facilities

As you are planning to start your own indoor cultivation facility, there are some often ignored basic parameters that should be taken into account in the design and decision-making process. We have listed the key parameters that will ease the process of going live and may save time and money while you design your facility and the building process. Always remember to be compliant with all local rules and regulations. 

Lighting Recommendations

Depending on your goals, building setting, and local requirements, you have many options for lighting, from HPS light to LED lights. Lighting standards are measured in watts per square foot. Recommendations may vary per state or other criteria. For example, Massachusetts recommends an intensity of 36w/sft for energy consumption.

Water Recovery: Minimum Percentage

Cannabis is a water-intensive crop, and consideration of effluent capacity can be inefficient, expensive, and an issue for municipalities. Depending on your cultivation practices, you should consider a water recovery system and what percentage you are able to capture. There are two types of water recovery – leachate, and condensate. An effective system will recover at least 70% of the water for utilization, significantly reducing your water and sewer expenses. Your irrigation and fertigation selection will have an impact on your water consumption. 

Generator Capacity: Minimum Recommendations

Your area or your business model may dictate for a generator – which is a critical Business Continuity consideration as a power outage, even if for a brief period of time can destroy a crop. Make sure to calculate the minimum capacity requirements of your facility. Do you plan to have it for emergency or stand-by usage? Typically, 50% of your short lighting load capacity of cultivation, 100% for AHU (air handling), and some back-office and security system, including cameras, access, and server needs.

Carbon Dioxide Enrichment: New Versus Recaptured

You can consider 75% new tanked- or generated- natural gas and 25% recaptured sources, for cultivation rooms, gas-fired chillers, and gas-fired boilers.

Carbon Dioxide Alarms Levels: Cultivation and Common Areas

Carbon Dioxide monitoring is critical for worker safety. You should be monitoring common areas to ensure that you are below 3,500 ppm. Monitoring should be tied to the fire alarm system for building evacuation, with 2,000 ppm alarm levels for the cultivation area. 5000 ppm limits are required by NFPA/OHSA. Alarms should contain visual strobes, red/green room access indicator lights and/or possibly an exhaust system that is triggered by an alarm

Renewable Energy: Minimum Energy Production Percentage

To demonstrate a commitment to sustainability, a minimum target of 10% of your facility’s energy consumption should be from renewable energy production: i.e. solar power, wind energy, geothermal, biomass, and/or battery energy.

Refuse Disposal: Recycling and Composting

Consider certified disposal of horticulture byproducts with a minimum of 25% recycling or composting by volume; rendered unusable. You will want to establish and verify that your shredder or equivalent system is capable of breaking up debris to a specified size. 

Airlock Doors for In-Between Uses

You should install an airlock barrier, or at a minimum an air curtain, between the business and the production side, for outside and inside egresses, to keep a controlled environment. Keep in mind considerations for ventilation systems and cascading airflow. 

Wall Material

For best performance to mitigate biological hazards and contamination, depending on your region, recommend installing insulated metal panels, that are non-porous, solid core wall, insulated metal panels (IMP), with surface mounted devices. 

Security Entrance: Facility Safety

Consider creating a separate mantrap style entrance to allow for better safety at the entrance point, monitor visitors, keep a controlled environment as well as avoid weather-related issues, i.e. wet areas due to rain or snow, or temperature variance due to extreme heat or cold. 

Limiting doors access and key sets for employees needs to be part of your overall security plan, with proper door labeling and authorization levels. The idea is to prevent unauthorized personnel from accessing specific spaces, for proper environment control and to be compliant with the local regulatory body. Remember to be compliant with local rules and regulations.

Security Camera: Minimum Area of Coverage

In most states, you will need security coverage for 100% percent of your faculty where cannabis products will be stored or displayed, with proper recording and monitoring. Keep in mind that your security room will likely need its own dedicated HVAC systems

Security Camera: Minimum Data Storage and Resolution

You will need to store all security camera footage on-site for a minimum of 90-days, or more depending on regulations. You may need to store the data offsite for five years for future legal needs. Footage quality may need to be shot in 1080p minimum. An ASTM International Standard Guide for Video Surveillance System provides additional parameters to utilize.

Security Alarm: Monitoring

Security alarm needs to be monitored by a reputable company. A service level agreement (SLA) or similar to ensure there are redundancies in the event of a failure should be considered, and redundancy or a backup system might be necessary.

Odor Control: Exhaust Air Management

Odor mitigation is a crucial part of all operations. All exhaust airflow must be oxidized or ionized. You also need a fogger system and carbon filtration. Refer to local municipal bylaws and regulations for more information.

For interior odor control and non-cultivation areas, consider cascading air flows from non-cultivation areas to provide a common method of control for pressurization control. Plan to control air flow and exhaust. 

Fire Sprinkler: Maximum Bench Sizing

Sprinklers are designed to cover a limited surface area. When installed on cultivation tabletops wider than 48”, additional sprinkler coverage may be required.

Flooring Type: Continuous

Cultivation floors shall have continuous resin or epoxy coating with at least a four-inch lip onto the adjacent wall.

Energy Incentives: Minimum HVAC/D Efficiency Rating

Air Conditioning (AC) units should be no less than 16 SEER, High Point (HP) units no less than 9 HSPF. Incentives for this vary by state. Please check with your local utility company and regulatory commission for all available rebates.

HVAC Validation Requirements: 

Bi-Annual Third Party Controlled Environment Validation using required Trend Data Metrics is the validation and calibration of control sensors, including temperature, humidity, CO2, and other devices such as scales, flow meters, integral valves, PPM sensors, EC meters, TDS meters, HVAC dampers and other applicable devices that may drift from factory or initial installation specifications.

Good Agricultural and Collection or Manufacturing Practices (GACP/GMP): Ready Versus Complaint

Your operation should be designed with documentation to prepare for GACP or GMP requirements. Depending on final product types, specific food-based GMPs with appropriate risk assessment programs (such as HACCP, and others referenced within the Food Safety Modernization Act) will prepare you for any federal or international trade opportunities in a federally legalized framework. 

Employee Locker Access

Plan for gender-specific, male and female locker rooms, with six square feet per employee per shift expected to arrive at the facility at any given time. Employee supplied flock for locker or lock provided by the employer is a business decision. Keep in mind how you will keep the environment of your production facility under control. You might consider having locker access adjacent to the growing area with a proper gowning area. 

Locker Room Type

Make sure your locker room is correctly set up for employees to be able to change in a safe way. Specifications for Locker Room and Gowning/PPE Areas should allow access to faucets for washing hands as well as bathrooms. Note gowning areas should be separate from the bathrooms directly off the locker room area.

Employee Shower Access

Per International Building Code (IBC) and State Plumbing Codes, calculate the number of employees and determine the number of showers based on code requirements as well as business policies. Having gender-specific showers is a recommendation as well as a business decision. 

Emergency Eye Wash- Shower

For safety and based on OSHA standards, Integrated Pest Management (IPM), fertigation, and extraction operations must-have emergency eye wash showers. Eyewash stations need to be placed throughout the facility so that they are within 10-15 seconds walking distance from employees. Check local requirements for additional needs. 

Note: in a facility where corrosives and skin irritants could pose harm to employees and require immediate remediations, you should consider emergency showers.

First Aid Kit Distribution

First aid kits should be available in all rooms where sharp tools and other hazardous materials are intended to be used. These kits need to be within 10-15 seconds of employee walking distances. Per OSHA requirements, first aid kits should be located in all trim, extraction, flower hallway, and shredding areas. This is overall a must-have in your facility.

Safety and Injury Handling

We recommend that you ensure that you have enough first aid and burn kits available throughout your faculty, based on your activity and the number of employees.

Check Out These Related Articles for More Top Things to Consider When Planning:

Part 1 – Cannabis Cultivation Facilities
Part 2 – Cannabis Extraction Facilities
Part 3 – Cannabis Food Production Facilities
Part 4 –Cannabis Retail & Dispensary Facilities
Part 5 – Cannabis Facility Support Areas

Committee Blog: Future-Proofing Your Business – How Adopting Industry Standards Improves Your Bottom Line and Reduces Your Risks

by NCIA’s Facilities Design Committee

By developing and adopting standards now, operators in the cannabis space can avoid unnecessary future expenses they might incur when needing to rework established facilities to meet upcoming federal standards or third-party compliance

Upton Sinclair’s The Jungle in 1905 led to the Pure Food and Drug Act in 1906. The food sector has matured through additional governmental regulations, industry-led initiatives, consumer and trade guidelines and standards, and more recently, the Food Safety Modernization Act. Over one hundred years of progress helped to ensure what is arguably the safest food supply in the world. By comparison California, in 1996, 24 years ago, legalized Medical Cannabis. Since then, 36 states have legalized cannabis for medical or adult use. Confusingly, that is 36 different sets of regulations, none harmonized. And no consensus on how FDA will regulate cannabis when it is descheduled.

But investors and producers in the cannabis sector are seeking direction on how to future proof their businesses so they can manage the transition from fragmented state-level regulations to rigorous federal oversight. Developing and adopting cannabis industry best practices may be the greatest insurance available. 

NCIA’s Facility Design Committee is one of the few groups beginning this effort. The group has representatives from operations, regulatory compliance, quality, equipment vendors, design and construction, and allied industries. 

Standards can focus on several areas. Because the cannabis industry deals with substances that are ingested into the human body, standards that support consumer health and safety are paramount. Much of the current practice in the food sector, organized under the topic of current Good Manufacturing Practices (GMPs), can port over to Cannabis with some adjustments. These practices protect consumers and your brand. GMPs have, as a foundation, many aspects of facility and process design, but standards for these don’t yet exist. However, by developing and adopting standards now, operators in the cannabis space can avoid unnecessary future expenses they might incur when needing to rework established facilities to meet upcoming federal standards or third-party compliance. They also can control their own destiny, in effect, by establishing approaches that later can be considered as regulators write the rules in the future. 

As operators themselves, a number of our committee members have felt the direct impact of product recalls due to a lack of clear delineation at the intersection of cannabis and food safety regulations. Depending on the scope of the recall, a company can be crippled by not properly understanding and adhering to a common set of standards across the industry, especially when concerning safe food handling practices and similar regulations that control consumable product manufacturing. For example, one of our committee members had to recall a batch of infused gummies because public health regulators used safe food handling regulations to determine that the gummies were exposed for too long in a potentially contaminated environment during the setting process. Had the operator adhered to standards commonly used in food production, they would have avoided the costly impact of the product recall. With nearly 15% of flower failing tests for yeast and mold in Colorado, the cannabis industry has become no stranger to costly recalls.

Standards not only minimize risk to the consumer and the business, but also improve quality and consistency. Improve employee NPS (Net Promoter Scores). Reduce cost and production downtime. Increase the inherent value of the business. And offer a brand message that increases sales. 

Nearly all related industries follow best practices, known as cGMPS (current Good Manufacturing Practices), which can be adopted for our industry. If we look to examples from the food sector, you find mature and professional regulations at the federal level and experienced inspectors from USDA, FDA and state departments of Health or Agriculture, as well as global standards from the International Organization for Standardization (ISO) and the World Health Organization (WHO), initiatives from trade customers such as Global Food Safety Initiative (GFSI), equipment certifications from European Hygienic Equipment Design Group (EHEDG), NSF International, and 3-A Sanitary Standards. This constellation of resources is not yet published for the cannabis sector.

But the work is beginning with NCIA’s Facility Design Committee. Groups including 120-year-old ASTM International have established the D37 Committee on Cannabis, Safe Quality Foods (a GFSI scheme) is working on a Cannabis Supplement program, and Underwriters Laboratories (UL) and ISO recently announced the launch of a standards initiative at the end of November 2020. 

Join us in this exciting journey. Become involved, and stay aware of and ahead of the pending regulations. We don’t have 114 years to get this right! 

The Facilities Design Committee (FDC) focuses on providing NCIA members and regulators a framework and information about facilities design options through which legal producers can plan for GMP level production as the market transitions from a state to a federally regulated industry.

 

 

Member Blog: Cannabis Software Solutions – The Case for Connectivity

by Allison Kopf, CEO and Founder of Artemis

In the cannabis industry, it is critical for cultivators to track crops throughout their production. Traceability benefits and protects cannabis companies, state governments, and the consumer. Without proper tracking systems in place, it would be impossible for states to tax businesses appropriately, it would be dangerous for consumers, and the burden of risk is placed almost entirely on the operator. 

To combat this risk, states have mandated certain systems to track cannabis products called track-and-trace or seed-to-sale systems. There are a few leaders in the space – Metrc, MJ Freeway, and BioTrack. All three provide tracking software solutions for operators and contract their software to state governments. 

These systems are designed for regulators, not cultivators. Growers instead have to purchase a second system to manage their operation. We’ve highlighted why it’s important for growers to implement a cultivation management platform (CMP) in the past, but it’s important to note how difficult it is to implement a CMP in the current market. 

Growers are second class citizens in the cannabis world – and that’s a major failure of the industry right now. Growers are the backbone of this industry and we, as innovators, should be making it as easy as possible to track products through the supply chain. This is not just because it’s a good business decision or because it makes it easier for governments to tax products, but because it’s good for the industry. It’s good for the consumer. It’s the right thing to do. 

However, the industry is disconnected. For Metrc required states, it takes weeks before you will hear from the company regarding connectivity and months before integration can happen. The regulatory systems all tout their API as a way for other software companies to integrate into their systems, but in reality, it’s not that simple. 

Here’s what that means for growers. Growers are mandated to use regulatory systems to record weights and plant IDs (as well as other data) for the benefit of the regulator and the chosen software provider, but they cannot use those tools to their advantage. Instead, they have to choose to purchase a third-party system that may or may not be able to integrate into the regulatory system or they are forced to purchase the cultivation software from the same regulatory software provider, which again, may or may not fulfill their needs. If the grower chooses a system that they like but cannot integrate, it means they have to enter information twice. This is a costly burden and often leads to unnecessary data entry errors. 

Most of the regulatory systems on the market today are ill-equipped to provide enterprise-ready software in the first place, but it’s not the fault of those software providers. This is a new industry. Most of the software companies on the market are undercapitalized and many are outsourcing development as a result. This leads to serious security issues and system outages, like we’ve seen in Washington and Pennsylvania.  

A better way to handle the growth of this industry would be to regulate in a connected and open environment. Instead of mandating a particular software solution, mandate traceability and let the grower decide how to meet that requirement.

For example, under the Controlled Substance Act, the DEA requires certain reporting requirements and these are submitted to the DEA database ARCOS (Automated Reports and Consolidated Ordering System). However, a company could choose to use Microsoft NAV for its management solution and sync to ARCOS for submittal of reports.

In food, the USDA governs food safety requirements under FSMA (the Food Safety Modernization Act). FSMA mandates food producers create and maintain a food safety plan, however it does not require a specific format or content. There is guidance for how to create a plan, but FSMA also allows for flexibility in operations and there is trust that operators will create a plan that is right for their operation. 

This idea of trust in the grower and a unified framework of requirements is missing in the cannabis industry. Some software providers have tried to close that gap, but relying on mandatory software and changes on a state-by-state basis will only hurt the industry. We need to enable growers to scale efficiently and legally. We should support growers and provide tools that make it easier for them to implement new regulatory requirements, not harder. Our industry should consider opening up the software market for regulatory reporting and at a minimum should encourage data integrations, not limit them.  

Allison Kopf is the Founder and CEO of Artemis, the market-leading Cultivation Management Platform serving the fruit, vegetable, floriculture, cannabis, and hemp industries. Artemis won the highly coveted Disrupt Cup at TechCrunch Disrupt in San Francisco. Kopf was recently named one of Forbes 2019 30 Under 30 as well as one of New York Business Journal’s 2019 “Women of Influence.” Allison is an Investment Partner at XFactor Ventures and serves on the boards of Cornell University’s Controlled Environment Agriculture program and Santa Clara University’s College of Arts and Sciences. She is a Techstars Farm to Fork mentor and holds a BS in Physics from Santa Clara University.

Artemis provides a world-class Cultivation Management Platform that enables owners and managers of enterprise horticulture facilities to drive efficiency, profits, and growth while ensuring security and regulatory compliance. With Artemis, users can manage workflow and daily tasks, register crop batches, trace food safety issues, manage workers, and leverage data insights to increase workforce efficiency and crop productivity. Read our software buyer’s guide for more information.

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