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ULC tackles new standard for safety in cannabis production

With recreational cannabis set to become legal on Oct. 17 this year, the question of safety and security in cannabis producing facilities has taken centre stage. In fact, ULC Standards recently announced the proposed first edition of CAN/ULC-S4400, Standard for Safety of Buildings and Facilities Utilized for the Cultivation, Production and Processing of Cannabis.

September 5, 2018
By Ellen Cools

The standard is intended to:

• Provide minimum requirements for the protection of buildings and facilities used to cultivate, process and produce cannabis and cannabis-related products “to minimize dangers resulting from the effects of fire”;
• Provide minimum requirements regarding “cover devices, equipment and systems utilized for cannabis cultivation, processing and production”; and
• “Provide minimum requirements for the security of buildings and facilities from intrusion and infiltration, as well as considerations for secure access and safe egress.”

In an email to SP&T News, Theresa Espejo, project manager for the ULC Technical Committee S4400, explained the proposed standard has come “at the behest of local regulators concerned about security in a new and emerging industry.”

“There is a severe deficiency in code requirements, standards, regulations, by-laws, or even codified best practices specifically addressing the unique challenges facing this emerging industry,” she elaborated.


The proposed standard focuses solely on the safety of buildings and facilities used to cultivate, produce and process cannabis because “this is an identified priority concern of regulators and government stakeholders,” Espejo explained.

According to Espejo, Health Canada has said, “Mitigating the inversion and diversion of cannabis products is a primary goal to reduce and eliminate the black market. Hence it is crucial for all facilities storing, handling or processing cannabis to have a robust security system and be protected from intrusion and infiltration.”

“The standard aims to set the bar to an ideal, practical and attainable security set of requirements among all players,” she added.

To develop a consensus-based standard that can be applied nationally, ULC recently formed the ULC Technical Committee S4400. The committee is composed of 34 voting members and six associate, non-voting members, said Espejo.

Its members represent a mix of seven interest categories: AHJs (authorities having jurisdiction)/regulators, producers, supply chain, commercial/industrial users, general interest, standards and testing, and government. They will help develop technical requirements, address comments in their respective fields of expertise, attend meetings and vote on ballots.

CANASA is one of those members. According to Patrick Straw, CANASA’s executive director, they became involved after inviting Al Cavers, engineering manager of ULC, to sit on their national board.

He asked Cavers how CANASA could become more involved with ULC. This standard seemed to be a good fit, as it’s “pretty close to the security industry and there’s a lot of security companies that are already aggressively marketing to that business sector,” Straw said.

Consequently, he applied to be part of the committee. Three other CANASA members are also on the committee, he shared.

Straw believes it’s very appropriate that ULC develop a standard on security and safety in cannabis cultivation and processing, given the close relationship between electronic security and fire.

“To me, they’re [ULC] the perfect entity to come up with a national standard for protecting these facilities,” he elaborated.

Jeff Hannah, owner and principal of JH & Associates, a security consultancy with expertise in the Access to Cannabis for Medical Purposes Regulation (ACMPR), agrees. Although he is not on the committee, he is “definitely in favour.”

“There’s a lot of safety and egress [components] they’re going to develop, which, to be honest, I think is needed,” he elaborated. “Safety, egress,
building codes …don’t always combine well with a heavy security environment. It can be a real challenge to balance both interests. So to get some clarification and a defensible standard that balances all those interests with the regulatory influence taken into account would be a great thing to have.”

These types of cultivation and production facilities haven’t existed en masse before, so “that’s a great reason to have some good, solid, well-thought out standards to lean on when you’re designing these to be safe and secure,” he concluded.

ULC aims to complete the standard by Q2 of 2019, Espejo said.

Once complete, “it will be incumbent on the security companies that are working in that space to conform to whatever regulations come out of it,” Straw added.

This article originally appeared in the August/September 2018 issue of SP&T News.

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