Marijuana Production & Processing Requirements
Site Visits, Compliance Inspections
Concerns about cross contamination during inspections - It’s common practice for businesses to have an entrance protocol to address cross contamination. It’s standard practice for inspectors to follow facility protocols. It is standard practice for businesses to provide the necessary equipment or facilities for inspectors to meet the protocols. Examples include anti-static booties at electronic manufacturers; sterile garments for surgical suites; proper clothing and changing facilities for clean rooms. Because the same equipment and facilities are also necessary for employees and other visitors, issues seldom arise.
Other Requirements - All
Notification of any changes - all facilities, regardless of type, must notify SRCAA of any changes in operations. This also includes business closure, change of ownership, and name change. Additionally, before considering an expansion and/or relocation, contact SRCAA to determine what requirements apply to your type of facility.
Operational Requirements - Based on type
Indoor Producers are operations in fully-enclosed buildings that are permanently affixed to the ground, with permanent rigid walls, non-retractable roofs, and doors. The buildings are equipped to maintain control of environmental conditions.
Indoor Producers are required to:
- Use air pollution control equipment, facility design, or both to reduce air contaminants.
- Keep doors and windows closed, except for active ingress and egress.
- Follow an Operations & Maintenance plan for air pollution control equipment
- Keep maintenance records.
Outdoor Producers are operations on an expanse of open or cleared ground (no structures of any kind) and operate during Spokane County’s customary outdoor growing season, without controlling environmental conditions. Watering and short term covering of plants for a portion of each day as needed for frost protection are not considered controlling environmental conditions.
Outdoor producers are required to:
- For indoor propagation, use air pollution control equipment, facility design, or both to reduce air contaminants.
- Complete and submit SRCAA’s Harvest Schedule Notification form, no later than 30 days prior to the start of harvest. While it is impossible to know the exact harvest date(s) 30 days in advance, the expectation is to provide a window of likely “harvest date(s)” rather than a specific date(s).
Other Producers are operations that do not meet the indoor producer or outdoor producer definition. These include hoop houses, temporary structures, or other similar structures.
Other producers are required to:
- Have a written exemption from SRCAA. Applications for an exemption were due November 5, 2018. New or expansion of existing operations are not allowed.
- Comply with specific conditions of their production exemption.
Processors are operations that dry, cure, extract compounds, convert, package, and/or label usable marijuana and marijuana concentrates. All processing must occur indoors.
Processors are required to:
- Use air pollution control equipment, facility design, or both.
- Keep doors and windows closed except for active ingress or egress.
- Follow an Operations & Maintenance plan for air pollution control equipment and keep maintenance records.
Potential Odor and Emissions Control Measures
Indoor Producers and Processors
The following controls and practices have been employed alone or in combination at some marijuana production and processing operations. Control equipment must be properly-sized for the amount of airflow being treated. An Operations & Maintenance Plan must be in place for control measures being used.
Carbon adsorption filtration
- Vent all air exhausted from the operation through a properly-sized carbon adsorption canister or carbon filter. The canister or filter should be sized properly for the amount of exhaust air flow.
- Vent room air through floor mounted carbon adsorption canisters which then exhaust back into the room.
Outdoor Producers - Potential strategies include but are not limited to:
- Locate operation as far away as possible from the property line. This may improve air contaminant dispersion and decrease odor concentrations at and beyond the property line.
- Move indoors when performing trimming, pruning or harvesting of plants grown in moveable containers.
- Think in small increments or staging. For example, trim, prune or harvest small groups of plants at a time.
- Perform trimming, pruning or harvesting when they are least likely to have off-site impacts, such as:
- When weather conditions help disperse odors more readily. Avoid evenings and early mornings when temperature inversions are more likely to occur. Inversions inhibit air pollutants from dispersing.
- When nearby properties are least likely to be occupied. For example, in a business zone it may be weekends and evenings. In a residential area it may be week days versus evenings or weekends.
- Keep plant height below fence height.
- Vegetative environmental buffers (VEBs), when used in conjunction with other odor management techniques, have demonstrated some effect in reducing downwind odors from poultry and livestock operations. Many variables influence the effectiveness of a VEB including weather, topography, wind, type and size of plants in the VEB, and the operation’s Tier size.
Site-specific planning and design by a professional that has knowledge and experience with VEBs are critical for VEB effectiveness. Since it can take years for VEBs to reach maturity for effectiveness, interim control measures may be needed until VEB reaches an effective growth stage.
Depending on operations at the facility, “Other producers” with an Agency-granted production exemption, could use a combination of what is listed in Indoor and Outdoor.