NFPA Journal - July/August 2018 - 60

three of us drove through suburban
Denver. "The solvents run from water
to dichloromethane. Anything they can
experiment with they will try to use."
Rudolph is referring to the process of
making marijuana concentrate, an oily
substance of highly concentrated THC
or CBD, the two most widely used plant
compounds. While the uninitiated may
still think of marijuana primarily as a
smokeable plant, marijuana-infused
products like edibles and lotions,
made using concentrate, are expected

to soon account for nearly half of all
cannabis-related sales in Colorado and
elsewhere. An ounce of concentrate
sold for an average of $1,400 in the U.S.
last year, more than an ounce of gold,
according to industry sources.
This cannabis gold is produced via
an industrial process that uses solvents
to strip out THC and CBD from the
raw plant material. Solvents run the
gamut, from hydrocarbons like butane
and propane to liquid CO2 to alcohols
like isopropanol. After the extraction

process, the resulting concentrate is
further refined and purified utilizing
other potentially hazardous substances.
Concentrate manufacturers often tweak
their processes or alter their equipment
in an effort to follow new fads or to
experiment, just as brewers alter recipes for batches of beer, Rudolph said.
Less scrupulous manufacturers sometimes seek out newer and novel-and,
in some cases, potentially dangerous-solvents and methods, seeking to
make a slightly different product with

NFPA 420?
W

HILE A CANNABIS-SPECIFIC
CHAPTER IN NFPA 1, FIRE
CODE, IS A GOOD START, SOME
ARE CALLING FOR MORE.
Brian Lukus, an engineer with
the Denver Fire Department,
was one of several experts who
served on the NFPA task group
that developed the code's new
marijuana chapter. The project
began after Lukus submitted a
request to the Standards Council
in 2015 for NFPA to develop
a new standard on marijuana
facilities. The council decided,
at least initially, that a chapter in
NFPA 1 would suffice.
While Lukus is happy that the
chapter provides fire departments and authorities having
jurisdiction with guidelines for
the cannabis industry, he also
believes it's "too general" to
cover the myriad details he's
seen emerge over the last four
years in Denver. He intends to
resubmit his request for NFPA to
create a standalone marijuana
standard.
"There are a lot of industryspecific things that are unique,
and right now there is [no guidance]," Lukus told me. "There is
a lot of nitty-gritty stuff, and with
some of it guidance might exist,
but it's buried in five different
codes. The operators of this
industry don't sit around and
read codes all day, so it would
be nice to have it all in a single
document."
Over two days in Denver,
both Lukus and Mark Rudolph,
an inspector with the DFD,
peppered me with examples of

issues unique to the cannabis
industry that don't fit neatly
into any code, from ventilation
of pesticides in CO2-enriched
rooms-"nobody wants to ventilate a room that is CO2 enriched,
but at the same time you have
these chemicals in there, but
there is no guidance on that," Lukus said-to procedures for what
to do with spent plant material
soaked in alcohol or butane.
Guidance could also be provided
on common post-processing
techniques, they said, including
one referred to as winterizing, where manufacturers add
alcohol to marijuana concentrates, then freeze it so the fats
rise to the top, whereupon the
remaining alcohol is burned off.
Other concerns include the lack
of training for extraction workers
and the absence of rules on
how marijuana facilities handle
flammable liquids.
"You have to fill these solvent
tanks for the extractors, but
there is no guidance on how to
do that safely," Lukus told me.
"The closest thing we can find
is NFPA 58, Liquefied Petroleum
Gas Code, but it says specifically
it is not to be used for processing applications. Some manufacturers take big tanks from the
outside and bring them inside to
fill. Some do the opposite. Some
pipe it in from the outside."
When it comes to training
employees on how to use these
machines, Lukus said, "there
is literally no training. If you
wanted, you could go be an
extraction technician tomorrow."

60 | NFPA JOURNAL * J U L Y /A U G U S T 2 0 1 8

Denver requires operators within pesticides, etc.-went beyond
city limits to take a course that
the fire protection scope of
teaches them to fill a propane
NFPA 1.
tank, but Lukus admits "the
"In that case, we have to start
process of filling a propane tank asking whether those issues
and working an extractor are
warrant their own project,"
very different." One reason the
Bigda said of the idea for a
city doesn't mandate training
cannabis standard. "We could
on the extraction process itself
easily put together a commitis that no standardized method
tee of 30 people for that, and
currently exists for conducting
it might provide some of the
the process. He showed me a
detail Brian is looking for. I'm
grainy video on his phone of
curious if there is support for
an extractor blowing up and
it. If the industry truly wants to
spewing gas because the worker make this better, hopefully we
had not used a torque wrench to will hear from them."
properly tighten the assembly,
To submit a public input for
which failed as the pressure
the next edition of NFPA 1, visit
increased.
nfpa.org/1. -J.R.
"Sprinkler installers always use
a torque wrench
to properly calibrate how tight a
sprinkler head is,"
Lukus said. "That's
how they're
trained to do it.
That's not the case
in the marijuana
industry."
Kristin Bigda,
an engineer at
NFPA and the staff
liaison to NFPA 1,
told me she had
heard these concerns from Lukus
and others during
the development
of Chapter 38,
The pot industry contains a unique
but committee
variety of hazards, says engineer
members felt
Brian Lukus, pictured.
that that level of
detail-training,

JESSE ROMAN

THE CASE FOR A NEW STANDARD DEVOTED TO THE CANNABIS INDUSTRY

http://www.nfpa.org/1

Table of Contents for the Digital Edition of NFPA Journal - July/August 2018