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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. Odor Control Plan v1.3 | 5 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. Odor Control Plan v1.3 | 6 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 Odor Control Plan v1.3 | 8 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. Odor Control Plan v1.3 | 9 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.) ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ Odor Control Plan v1.3 | 11 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.