12 Odor Control Plan
Odor Control/
Air Quality Plan
Odor Control Plan v1.3 | 1
Introduction
Procedures 2
Location of Cannabis Odor Emissions 2
Specific Odor Emitting Activities 3
Intensity of Odor Emitting Activities 3
Operational Mitigation Measures 3
Handling 4
Curing 4
Storage 4
Processing 4
Physical Measures 5
Negative Air Pressure 5
Exhaust 5
Filtration 5
Doors and Windows 5
System Maintenance 6
Schedule 6
Equipment Maintenance Log 6
Responding to Complaints 7
Resolution 7
Mandatory Notification 9
Appendix 1 10
Odor Control Equipment Maintenance Log 10
Appendix 2 11
Odor Complaint and Response Tracking 12
Odor Control Plan v1.3 | 2
Introduction
This Odor Control Plan is designed to explain Prime Arrow process for mitigating odors
generated by the cultivation of cannabis, so that a reasonable person of normal
sensitivities cannot detect odors outside the building.
This procedure explains the structural, mechanical, and operational measures
employed by Prime Arrow to maintain odor control. These measures pertain to
cultivation, harvesting, trimming, and storing cannabis.
All personnel are required to implement this odor control procedure in the normal course
of their work. Employees are also responsible for detecting and reporting odor control
problems to the Cultivation Manager, who will forward information to the Facilit ies
Manager.
The Cultivation Manager is responsible for ensuring that cultivation personnel are
trained to properly execute this odor control procedure. The Cultivation Manager is also
responsible for correcting any physical or operational deficiencies involved with th e
handling or processing of cannabis that result in the release of odors from the building
where cultivation occurs.
The Facilities Manager is responsible for ensuring that any non-cultivation employees
who work on odor control equipment are properly trained in the maintenance and use of
such equipment. He/she is also responsible for correcting and monitoring any
equipment-related malfunctions that result in the release of odors.
Location of Cannabis Odor Emissions
Odor eliminating activities occur in the following locations inside the facility
1. Cultivation areas where live plants are growing (labeled as “Cultivation” on
floor plan),
2. Harvesting areas (labeled “Harvesting”),
3. Processing areas (labeled “Processing”),
Odor Control Plan v1.3 | 3
4. Areas used for storage of harvested cannabis (labeled “Storage”), and
5. Locations of doors, windows, fans, filters and vents. Each location will be
physically labeled with a code that matches its label on the floor plan. This
code will be used when logging maintenance or other equipment-specific
activities.
Specific Odor Emitting Activities
1. Cultivation – Live plants emit natural odors, which increase throughout the life
cycle of the plant.
2. Harvesting – Mature cannabis plants emit odors during the process of being
cut for harvest.
3. Processing – Trimming, curing, cooking, extracting and packaging cannabis
causes odors to be emitted.
4. Storage – Stored cannabis may emit odors if it is not tightly sealed, or if the
storage containers are opened for any reason.
Intensity of Odor Emitting Activities
Stage/Activity Odor Level
Plants Prior to Flowering Low
Flowering plants High
Harvesting High
Curing High
Trimming High
Packaging Medium
Storage Low
Odor Control Plan v1.3 | 4
Operational Mitigation Measures
All personnel will be trained on this procedure and any additional training topics deemed
necessary by the Cultivation Manager. Records related to odor mitigation training will be
kept in accordance with the Record Keeping Plan.
The Facility Manager is responsible for periodically monitoring odors outside the
building in which cannabis is being cultivated, particularly when activities that produce a
high level of odor emission are in progress. Odors that can be detected by a reasonable
person of normal sensitivity should be reported, recorded, and corrected in accordance
with this procedure.
Handling
Cannabis plants and harvested materials should be handled as gently and infrequently
as possible to minimize odor emission.
Curing
Harvested material will be cured in a cool, dark, and properly ventilated area. The air
exhausted from the curing area will be scrubbed and treated using HEPA filtration.
Storage
All dried and cured material that is not being processed will be stored in sealed non-
porous plastic bags, in glass jars, or in other airtight containers approved by the
Cultivation Manager. Doors to each storage area will remain closed and locked except
when cannabis is being transferred in or out of the area.
Processing
Cured material will be trimmed and packaged over as short a duration as possible to
minimize its exposure to the air.
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Physical Measures
The Facilities Manager is responsible for ensuring the equipment related to the odor
control system is functioning properly on a day-to-day basis.
Negative Air Pressure
A Combination of intake fans and exhaust fans are used continuously to create negative
air pressure inside the main perimeter of the building. This results in air being pulled in
through any openings and cracks around the building, rather than positive pressure,
which would push potentially odorous air outward.
Exhaust
Air exits the individual rooms and the facility through separate exhaust fans of sufficient
capacity to ventilate the entire interior. In the case of the main inside perimeter of the
building, the exhaust fans have a higher capacity than the intake fans, creating negative
air pressure. This prevents odor-containing air from exiting the building through cracks
or doors.
The cultivation, trimming, drying and storage rooms are designed with positive pressure,
such that insects, molds, bacterial and fungal spores are deterred from entering rooms
where product quality could be negatively affected. The intake fans in these rooms have
a higher capacity than the outtake fans to create positive air pressure.
Filtration
All air leaving the building and the cannabis product-containing rooms passes through
an activated charcoal filter system combined with HVAC system.
Doors and Windows
All exterior doors and windows remain closed when not in use, and no windows are
used for routine ventilation. This prevents accidental or unnecessary odor emissions.
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Similarly, interior doors to areas used for cultivation, processing, and storing cannabis
remain closed when not in use. Internal doors will be equipped with spring-loaded auto-
closing systems so they cannot inadvertently be left open.
System Maintenance
Schedule
The equipment used for odor mitigation will be inspected on a schedule determined by
the Facilities Manager, consistent with manufacturer’s guidelines, and/or whenever
personnel or visitors detect a problem with odor control. The Cultivation Manager is
responsible for developing a reminder protocol to ensure activities are carried out in a
timely manner. Equipment to be inspected will include:
Equipment Responsible Personnel Frequency
Exhaust fans in work areas Facilities Manager or
trained designee
Weekly
Exhaust fans outside work
areas
Facilities Manager or
trained designee
Weekly
Ozone generator Facilities Manager or
trained designee
Weekly
Ventilation ducting Facilities Manager or
trained designee
Monthly
Activated charcoal filter Facilities Manager or
trained designee
Every 6 months
Equipment Maintenance Log
The Facilities Manager or a trained designee will maintain an equipment maintenance
log for all equipment related to odor control. The log will be maintained according to the
Record Keeping Plan. See Appendix 2 for the Odor Control Equipment
Maintenance Log. At a minimum, logs will contain:
Odor Control Plan v1.3 | 7
1. Specific identification of the equipment inspected using the code on the
floor plan;
2. The date of the inspection;
3. The name of the personnel conducting the inspection;
4. Clear notes about the condition of the equipment; and
5. What action, if any, the inspector carries out to correct or report a
malfunction.
Responding to Complaints
Any complaint of cannabis odor escaping the building will be documented on a form or
in a manner prescribed by the Cultivation Manager. Completed forms will be forwarded
to the Record Keeping Manager. See Appendix 3 for the Odor Complaint and
Response Tracking form. The form or documentation will contain, at a minimum:
1. The date and time of complaint
2. The name of the employee reporting the odor problem
3. The name and contact information of the person who noticed the odor if not an
employee, if he or she chooses to disclose that information
4. The date, time, and frequency of the noted odor emission
5. The distance from the building that the odor can be detected or approximate
location of odor detection
6. The outcome of the inspection of the incident, including confirmation of no further
odors outside and fully effective odor control equipment and procedures
7. The nature and date of any corrective action that was taken in the course of the
inspection
Resolution
An odor complaint is considered resolved when:
1. The Cultivation Manager confirms that the issue has been effectively inspected
and any necessary corrective actions have been taken, or the Cultivation
Manager determines that there was no odor escaping from the building that could
be detected by a reasonable person of normal sensitivity
2. The equipment maintenance log and complaint response documentation is
complete and filed
3. Any official enforcement action is completed or resolved to the satisfaction of the
agency or department initiating the action, if applicable
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Mandatory Notification
The Cultivation Manager will notify the Senior staff of the company of any citation,
notice, warning or other official communication alleging a nuisance activity or other
violations related to odor within 24 hours of learning of or receiving such
communication.
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Appendix 1
Odor Control Equipment Maintenance Log
Maintenance Frequencies (equipment code)
Weekly: Exhaust fans (EF), ozone generator (OG) Monthly: Ventilation (Vent)
Twice yearly: Activated charcoal filter (ACF)
Date Equip
Code
Room/
Locati
on
Check
if
Normal
Describe Problem
(use as many rows as
needed)
Describe Action Check
when
Fixed
Submit a copy of this completed form to the Facilities Manager and the Record Keeper.
Odor Control Plan v1.3 | 10
Appendix 2
Odor Complaint and Response Tracking
1. Date of Complaint: ____________________ Time of Day: _________________
2. Name of Employee Recording Complaint: _______________________________
3. If an employee noticed the odor, skip to item 8.
4. If the complaint is made by someone other than an employee, provide his/her
contact information here if they would like to provide it _____________________
________________________________________________________________
5. Describe when and how often the odor is detected (days of the week,
mornings/afternoons, particular day and time, frequency) or if it was a single
instance:________________________________________________________
_______________________________________________________________
6. From what address, general location, or distance from the building is the odor
being detected?
________________________________________________________________
________________________________________________________________
7. Does the person making the complaint wish to be contacted by a supervisor?
Yes _______ No _______
8. Describe the exterior locations where odor emissions could be detected by an
employee and/or mark the locations on an attached facility or premises map.
________________________________________________________________
________________________________________________________________
9. List equipment/locations checked to identify areas through which odor may be
escaping. (Locations may be marked on an attached facilities map.)
________________________________________________________________
________________________________________________________________
________________________________________________________________
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10. List results of inspections (location of problem, type of equipment problem)
______________________________________________________________
____________________________________________________________________
____________________________________________________________________
____________________________________________________________________
11. List maintenance, repairs, other actions taken to resolve the problem.
___________________________________________________________
___________________________________________________________
___________________________________________________________
___________________________________________________________
___________________________________________________________
___________________________________________________________
___________________________________________________________
___________________________________________________________
___________________________________________________________
___________________________________________________________
12. Check below once this issue is considered resolved according to the Odor
Control Plan and all relevant parties have been notified of the actions taken,
including the individual making the complaint, if indicated in Item 7 above.
Complaint resolved: _____________________ Date: ____________________
Name / Signature of Manager resolving complaint:
______________________________ / ______________________________________
Additional Notes:
Submit a copy of this completed form to the Facility Manager and the Record Keeper.