[Massplanners] Odor - Marijuana Cultivation & Manufacturing
Dwight Merriam
dwightmerriam at gmail.com
Thu Oct 14 22:24:29 EDT 2021
Odor can be an issue if not controlled, but responsible growers know how to
prevent problems.
Here's the draft of some regulations I worked on (not Massachusetts, may
not be the final as adopted) to give you an idea as to how you might
regulate as to odor...just a start, not legal advice, just education, etc.
:)))...you know the usual caveats...
You really do have to consider what the Commonwealth is regulating (see
https://masscannabiscontrol.com/state-local-government/roles-responsibilities/)
and what is left to you, and, like all regulation, carefully tailor it to
your local needs.
(d) Odor.
(1) A Marijuana Cultivation Center and a Marijuana Testing Provider shall
be properly ventilated and the exhaust air filtered to neutralize the odor
from marijuana so that the odor cannot be detected by a person with a
normal sense of smell at the exterior of the Marijuana Cultivation Center and
a Marijuana Testing Provider or on any adjoining property. No operable
windows or exhaust vents shall be located on the building facade that abuts
a residential use or zone. Exhaust vents on rooftops shall direct exhaust
away from residential uses or zones.
(2) A Marijuana Cultivation Center and a Marijuana Testing Provider shall
have an Odor Control Plan including:
a. Facility Information
i.
Name of facility
ii.
Name, phone number, and email of facility owner
iii.
Name, phone number, and email of facility operator or licensee, and any
authorized designees
iv.
Facility physical address
v.
Facility mailing address (if different from physical address) f. Facility
type
vi.
Facility hours of operation
vii.
Description of facility operations
viii.
Emergency contact information
ix.
Business license application number(s) and/or business file number(s) (if
applicable)
x.
Air permit and permit number (if applicable)
b. Facility Odor Emissions Information
i.
Facility floor plan with a facility floor plan, with locations of
odor-emitting activities and emissions specified. Relevant information may
include, but is not limited to, the location of doors, windows, ventilation
systems, and odor sources. If the owner or operator of a Marijuana
Cultivation Center and a Marijuana Testing Provider believes that certain
information contained in its odor control plan is confidential, it should
clearly mark all information as such.
ii.
Description of the odor-emitting activities or processes that take place at
the facility, including the sources of those odors, and the locations from
which they are emitted, and phases of odor-emitting activities, with the
times at which odors may be most prevalent.
c. Odor Mitigation Practices
i.
For each odor-emitting source/process of the Odor Control Plan, specify the
administrative and engineering controls the facility implements or will
implement to control odors, including, but not limited to:
1. Administrative Controls
a. Procedural activities such as building management responsibilities
in isolating odor-emitting activities from other areas of the buildings
through closing doors and windows.
b. Staff training procedures describing the organizational
responsibilities and the staff members who will be trained about odor
control; the specific administrative and engineering activities that the
training will encompass; and the frequency, duration, and format of the
training.
c. Recordkeeping systems and forms with a description of the records
that will be maintained such as records of purchases of replacement carbon,
performed maintenance tracking, documentation and notification of
malfunctions, scheduled and performed training sessions, and monitoring of
administrative and engineering controls. Examples of facility recordkeeping
forms should be included as appendices to the Odor Control Plan.
2. Engineering Controls
a. The best control technology for marijuana cultivation facilities is
carbon filtration.
b. Engineering controls shall meet at least one of the following:
i. Are consistent with accepted and available industry-specific best
control technologies designed to effectively mitigate odors for all odor
sources.
ii. Have been reviewed and certified by a Professional Engineer or a
Certified Industrial Hygienist as sufficient to effectively mitigate odors
for all odor sources.
iii. Have been approved by the Rhode Island Department of
Environmental Management as sufficient to effectively mitigate odors for
all odor sources.
c. Components of engineering controls shall include, but is not
limited to, technical system design, a description of technical processes
and an equipment maintenance plan.
d. The system design should describe the odor control technologies that
are installed and operational at the facility (e.g., carbon filtration) and
to which odor-emitting activities, sources, and locations they are applied
(e.g., bud room exhaust; testing room) and describe critical design factors
and criteria, with supporting calculations presented as appropriate (e.g.,
desired air exchanges per hour required to treat odorous air from specific
areas, odor capture mechanisms, exhaust flow rates, rates of carbon
adsorption consumption).
e. The operational processes should describe the activities being
undertaken to ensure the odor mitigation system remains functional, the
frequency with which such activities are performed, and the personnel
responsible.
f. The maintenance plan should describe the maintenance activities
that are performed, the frequency with which such activities are performed,
and the personnel responsible. The activities should serve to maintain the
odor mitigation systems and optimize performance.
Dwight Merriam, FAICP
80 Latimer Lane
Weatogue, CT 06089
On Thu, Oct 14, 2021 at 9:30 PM robert leavens via MassPlanners <
massplanners at masscptc.org> wrote:
> Stephanie,
>
> I don't believe that you need a consultant on odor control/mitigation.
> The CCC does not allow odors to emanate from a facility. Check with the
> CCC and their licensure.
> I think that all you have to say is that the local license shall comply
> with the CCC requirements for no odors emanating from the facility.
>
> Betsy Ware
> Planning Consultant
> 262 Witchtrot Road
> South Berwick, Maine
>
> (former Dracut Community Development Director)
>
> On Thu, Oct 14, 2021 at 1:42 PM Stephanie Davies via MassPlanners <
> massplanners at masscptc.org> wrote:
>
>> Hi all,
>>
>>
>>
>> I am on the hunt for recommendations of mechanical engineers willing to
>> do peer reviews of odor control/mitigation measures at marijuana
>> cultivation/manufacturing facilities. I know this question has been asked
>> before and there were a few good referrals (specifically BLW Engineers, B &
>> L Mechanical Engineers, and Hallam-ICS), however we may have a conflict
>> with one and I’d like to make sure I receive at least a few good quotes.
>>
>>
>>
>> Your recommendations are much appreciated!
>>
>>
>>
>> Regards,
>>
>> Stephanie
>>
>>
>>
>> Stephanie Davies
>>
>> Senior Land Use Planner
>>
>> City of Attleboro
>>
>> 77 Park Street
>>
>> Attleboro, MA 02703
>>
>> 508.223.2222, ext. 3144
>>
>>
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