What Are NEBB Firms Doing in the Cannabis Industry?

In 1996, the legalization of medical marijuana use signaled a shift in cannabis law that expanded to the majority of U.S. states over the next decade. As Colorado and Washington approved its recreational use in 2012, the cannabis market—and need for effective grow facilities—only continued to rise. Today, the demand for key players in the building industry, such as NEBB firms and professionals, continues to grow, offering vast opportunities to those ready to apply their expertise all over the country and even throughout the world.

Although some building and performance professionals may perceive the cannabis industry as uncharted territory paved with uncertainties, NEBB professionals need not look much further than their own experience with indoor environmental performance testing in familiar industries. Commissioning, test and balance, and cleanroom performance testing all apply. And despite how different this new industry may seem, it resembles certain aspects of the pharmaceutical, healthcare, manufacturing, and food and beverage industries more than you might think. Still, the industry is considered somewhat controversial within certain areas and groups, as cannabis remains a Schedule 1 drug under federal law.

“We don’t actively seek out this type of work due to personal convictions. It just doesn’t match the values that our company supports,” explains a NEBB Certified Professional (CP) that provides testing, adjusting, and balancing (TAB) work in the San Francisco Bay Area. “However, some of these clients have come to us and we’ve taken on the work. We’ve done 12 facilities in California over the past five years. At the end of the day, it’s still a job,” he continues.

NEBB Cleanroom Performance Testing Committee Chair and CEO of VanirTG Tiffany Russell views her work in the cannabis industry from another angle, stating, “This is a still controversial industry to some, but there’s really no difference for me. There’s the argument that the industry’s products are drugs, but so are pharmaceuticals. If I am helping them create a better, cleaner product, I’m doing my job. Small business owners need protection and help reducing waste and improving processes, so that is what we do for them.”

Similar Industries, Familiar Expertise

The work of NEBB professionals is just as vital to grow facilities in the cannabis industry as it is to facilities in many other industries that rely on critical building performance for the success of their end products, too. For instance, pharmaceutical, semiconductor, or food and beverage manufacturing.

“Grow facility clients are a little different than our normal customer, but overall, not too different in terms of commissioning,” comments Russell. “There’s similarities to several industries. For one, it is a type of agriculture, but they grow the plants mainly to extract the oils from them. So, I would definitely say they are related or linked to a form of manufacturing and/or processing, as well. Some only grow the product and sell to other companies that extract. Some facilities only extract the raw product from the harvested plants and sell that product to a refining facility. Larger facilities take the product full-cycle, grow, extract and refine,” affirms NEBB CP of Carter Air Balance Company David Galli.

The specifics of executing various NEBB disciplines do not seem to differ drastically, either. Similar to a cleanroom environment, precautions like wearing lab coats and gloves near plants are taken to keep the product pure from possible contaminants.

“It’s not too far off from a normal cleanroom, but instead of semiconductor, it’s an actual plant. They need to look out for contamination to ensure a clean, healthy product,” Russell clarifies. “The real difference is that it’s not regulated by the FDA so no certification is needed right now.”

“I have applied the TAB discipline to this industry and from my experience, most facilities are balanced the same as any other ‘normal’ facility. There can be some strict life-safety rules in regard to the extraction and refinement rooms and labs, but it is not much different from any other building in the way TAB is executed,” says Galli.

Approaching Technical Disciplines

In most cases, cannabis grow facilities consist of large warehouse buildings with many closely monitored rooms designed to ensure precise conditions that allow the plants to thrive. Each room contains a series of different climate zones, controlling everything from humidity to CO2 levels to PH levels in water that will come into contact with the plants.

Like NEBB work for many other clients, the critical conditions in these facilities require measuring and adjusting factors like temperature, humidity, and air flow. Standard equipment that is also used elsewhere is rightsized and utilized in these types of facilities just as it would be in other industries NEBB firms service. For example, humidity control strategies and hardware are often the same. Temperature controls are set to elevated set points with few degrees of variance. And, in geographic locations where possible, systems with economizers are applied to achieve 100 percent outside air.

“The two biggest differences in this industry are humidity control, which is already typical for semiconductor and surgical suite work, and odor control based on air change rates per hour,” says our anonymous NEBB CP in the Bay Area. “Both are more detailed and thought about in grow facility design.”

“We have to do a lot of educating on how to manage temperature and relative humidity. When heat goes up, relative humidity goes down. It’s not like a home where you just change the thermostat. Does the customer have an independent humidity system? Or an integrated system?” poses Russell. “We look at particle levels and filtration to ensure airborne cleanliness. There can’t be too much moisture in the air. They need to look out to prevent mold, fungus and bacteria so that their product is not compromised.”

“We measure viables, like microbial samples, to test for fungus and bacteria. We also do airborne and surface testing for them, as they need super sterile areas to grow the plants. We do air flow measurements and look at air changes per hour (loosely based on cleanroom standards), temperature, relative humidity, and the light intensity spectrum measured in nanometers,” she continues.

Russell’s firm also helps test the frequency strength of the specialized lights the facilities rely on to grow cannabis plants indoors. She explains, “As a third party, it’s all data driven versus trying to push a product. We don’t need them to buy new lightbulbs if it’s not necessary yet, and therefore, can test at given milestones and advise whether the bulbs really need replacement after 5000 hours or so, or if they can continue being used. That’s just one of the benefits of professional reporting, which can save them a lot in overhead, depending on the outcome of our reports.”

NEBB professionals can help cannabis grow facilities uncover fundamental resource savings that could positively impact their business’s bottom line. With energy consumption accounting for a large portion of these clients’ expenditures, looking at options like proper filtration in order to recirculate preconditioned air, rather than filtering it out after a one-time use, can go a long way.

Despite energy being so essential to the end product in these facilities, energy efficiency goals themselves are not always as prevalent as one may imagine. Many owners are apprehensive to take certain measures to make the facility more efficient and save a little in energy costs for fear that they stand to lose much more in end product revenue if something goes wrong and the energy needed for optimal plant growth cannot be achieved. However, through hydroponic growing rooms, some clients have been able to control and cut water use by nearly half.

Implementing Standards and Safety Protocols

One area in which NEBB professionals’ work in the cannabis industry may sound more difficult to navigate than it really is surrounds the lack of federal regulatory agencies overseeing facilities as they do in other industries.

“Since this is a fledgling industry there is not much regulation from any federal agency, and cannabis is still technically illegal in federal view. However, states are still in charge of creating regulation and laws pertaining to the design, construction and overall operation of these facilities,” states Galli.

Although facilities are regulated by state and local jurisdictions, most cannabis growers do not currently need to worry about ongoing regulations like inspections after obtaining licensing. In California, permits are allotted based on the projected number of plants to be grown within a particular facility in order to determine if the building’s location is feasible and appropriate.

In reality, NEBB firms can expect to see the application of many familiar codes and standards in grow facilities. While some guidelines are offered specifically for facilities in the cannabis industry, others apply to facilities design, construction, and operations in the same way that they do for many other industries.

The NFPA, for example, outlines some of the inherent dangers of various cannabis-related facilities and the fire life safety systems, equipment, and processes necessary to comply with applicable building codes and occupancy classifications. Cannabis growing and processing facilities are both classified as industrial or storage according to Chapter 6 of NFPA 1, but the unique hazards associated with these facilities are addressed in Chapter 38 of the 2018 edition of NFPA 1, Fire Code.

Familiar ASHRAE standards, including technical requirements for the commissioning and TAB process, used in most other facilities are at work in the cannabis industry, too. In terms of design, however, ASHRAE warns engineers of the importance of accurate load calculations while designing for building systems and equipment sizing. As living things, plants change throughout their lifecycle and growers need to be able to control temperature, humidity, and airflow differently throughout every different stage.

Both sets of guidelines address airborne contaminants in different ways: first, to limit employee exposure to airborne toxins like those used in the extraction process converting cannabis flower to concentrates and oils, and second, to protect the plants from airborne contaminates that could cause detriment to the facilities’ end products.

In addition to building codes and standards, Occupational Safety and Health Administration (OSHA) standards designed to protect all employees also apply. Common infractions for cannabis business owners not in compliance with OSHA requirements range from blocked exit routes or electrical panels to exposing employees to electrical hazards and allowing build-up of combustible materials.

None of this is foreign to NEBB firms, which habitually perform testing based on strict standards and regulations in a variety of industries, making them a great partner for cannabis facility owners and operators. In fact, in the state of California, NEBB firms are specifically sought out as providers of Title 24 Mechanical Acceptance Testing in order for owners to be able to obtain their building certificates of occupancy.

Future Focused: Anticipating Regulations

The best way to approach an industry, such as cannabis, that isn’t overseen by federal regulatory agencies is to refer to regulations in similar industries. Fortunate for NEBB firms and professionals, experience with highly regulated industries is second nature. For grow facilities, there is no harm in setting the bar higher than it is, because most hope that bar is actually set someday soon.

“Most clients in this field are proactive in terms of safety protocols in case regulations come later. They’ve been very responsible in my experience,” recalls Russell. “If the FDA steps in on regulations, we will likely see standards like ISO, ASHRAE, and NEBB mandated.”

Galli adds, “I would think they are always thinking ahead. This is an upstart industry and I believe it will eventually be legalized at the federal level.”

“Growers and retailers want the feds to come online,” asserts the anonymous NEBB CP. “Just keep in mind, due to federal restrictions on banking, this is a cash and carry industry, so make sure you know who your client is and that they are an upstanding person.”

“The processes within may be somewhat foreign, but the methods established by NEBB are used just the same when balancing these types of facilities. They are really not overly complicated (yet) and your professional experience and expertise could be the key to establishing new regulation for construction and oversight within this industry,” Galli encourages his NEBB peers.