NFPA 1, 2018 sneak peek: New requirements for marijuana growing, processing and extraction facilities, #FireCodefridays

Many exciting changes are coming to the 2018 edition of NFPA 1, Fire Code, that will address a number of new technical topics as well as revise and expand on existing topics.  Changes such as a completely revised and updated chapter on Energy Storage Systems, new requirements for mobile cooking operations (food trucks) and even a new chapter on marijuana growing, processing and extraction facilities reflect how the Fire Code stays up to date with industry needs and technological developments.

New Chapter 38 will address the growing and processing of marijuana (which includes all forms of cannabis as well as hemp) in both new and existing buildings.  It does not establish provisions for the retail sales of marijuana where growing and processing does not occur. You might be asking, "how did NFPA become involved in developing code requirements for marijuana buildings?" because yes, I have been asked that a bunch of times during this revision cycle.  The background on how this new chapter came about is important to both understanding how codes and standards are developed and is also a prime example of how NFPA is responding to the immediate needs of its stakeholders.


Dude with dark glasses walks through an indoor growing facility surrounded by marijuana plants

Photo from NFPA Journal Sept/Oct 2016 article "Welcome to the Jungle"


In the fall of 2015, a member of the Fire Code Technical Committee was approached by an AHJ about the increase in these types of facilities in their jurisdiction and the need for a model code to provide guidance on how jurisdictions can protect them as well as keep those responding to fires in these facilities safe.  These jurisdictions needed help, and NFPA 1 was a logical place to start.  During the First Draft meeting, the NFPA 1 committee approved a Committee Input which introduced a draft of the new chapter.  Throughout the year leading up to the Second Draft meeting a task group consisting of both committee members as well as industry professionals worked to refine and develop a revised draft of the chapter.  This new Chapter 38 was presented to the fill NFPA 1 Technical Committee at their Second Draft Meeting last October and after additional work during the meeting was accepted as a Second Revision and will be included in the 2018 edition of NFPA 1 when it is approved by the Standards Council later this summer.

Not every jurisdiction is dealing with these facilities.  However, as a country, we are seeing more and more states who are legalizing the use of marijuana either recreationally or medically.  To meet those demands, there are facilities, either built new or fit into an existing structure that have to grow and process the marijuana into the various products used by consumers.  There needed to be a baseline for those responsible for inspecting and enforcement of these facilities.

When developing the provisions for new Chapter 38, the task group was focused on addressing those hazards that are unique to marijuana growing and processing all while relying on existing provisions in the Code that may help contribute to the safety of the facility.  For example, it was not the goal of the task group to rewrite egress provisions when NFPA 101 adequately addresses egress and is contained in Chapter 14 of NFPA 1, or to copy electrical requirements as those are already addressed by Chapter 11 and NFPA 70.  The chapter is organized to address general provisions, provisions specific to growing and production, and those requirements specific to extraction processes.  The extraction section is then split up by general provisions and then requirements specific to the extraction solvent, as follows:

  • 38.1 Application
  • 38.2 Permits
  • 38.3 Fire Protection Systems
  • 38.4 Means of Egress
  • 38.5 Growing or Production of Marijuana (including ventilation, fumigation, and pesticide application)
  • 38.6 Processing or Extraction
    • General (extraction room, staffing, operator training, signage, equipment, approval for equipment with no listing, equipment field verifications)
    • LP Gas Extraction
    • Flammable and Combustible Liquids Extraction
    • CO2 extraction
    • Transfilling

Those interested can view the current draft of NFPA 1 and view new Chapter 38 in its entirely.  It is hopeful that the provisions introduced in this Chapter will help those jurisdictions faced with enforcing, inspecting and responding to incidents at marijuana processing and extraction facilities.  NFPA is also offering additional resources for our stakeholders including educational sessions at this years NFPA Conference, journal articles, photos, and links to existing regulations used in some jurisdictions that also contributed to the development of NFPA 1 requirements.  Check them out today!

Thanks for reading, Happy Friday!

You can follow me on Twitter for more updates and fire safety news @KristinB_NFPA

Download the Safety Issues for Cannabis-Related Facilities Fact Sheet
Kristin Bigda
Technical Lead and Principal Fire Protection Engineer with a focus on building and life safety related content.

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