Design for Compliance Part 2: A Sustainable Future
The assumption that any new federally legal cannabis grow facility, and now legal industrial hemp production, will require a compliance pathway that is both future proofed and adaptable to the FDA’s Current Good Manufacturing Processes (CGMP) regulation is a sound one. At the time of this writing, the Agriculture Improvement Act of 2018, more commonly called the U.S. Farm Bill, has been approved by congress. State and federal governments are now working towards outlining industrial hemp processing rules that will meet FDA regulatory guidelines. Any new or existing facility that doesn’t conform to these regulations risks going out of business or should at the very least expect a costly integration or renovation.
Part 2A - Location, Location, Location
Once the decision is made to build a new cannabis grow or industrial hemp facility, the work begins with the most basic question, “Where do we put it?” In our experience, this is one of the most critical decisions and will affect your time to market and overall facility operating costs. In the categories below we will cover specifics of site selection, but the general premise is where to place it so that it’s most successful. Site discovery should always begin with a discussion with the city or county to determine the zoning and where your facility would be appropriate within the confines of the city or county borders. Once that’s established, the focus moves to the needs of your grow operation. A typical indoor facility needs three primary utilities: electricity, water and waste - the first two having the highest priority.
The availability and capacity of electricity and water requires special consideration because actual consumption represents a large, ongoing operational cost which impacts and affects your profit margins. When thinking about electricity, another key focus should be on the reliability of your power. Areas that are prone to blackouts represent risk to your operations and may require expensive generators to keep you from losing a valuable crop. Rogue Sky provides site surveys to our clients that address both operational costs and the reliability and availability of utilities.
We understand that significant focus is on the facility itself, but consider the following points we use in the analysis of a site:
Are the main power lines feeding the facility above or underground?
Where is the utility electrical substation and does the overhead path to your facility look like it’s been maintained (i.e. trees trimmed back, newer poles, etc.)?
Is three-phase power available versus single phase power?
Does the facility have a source of water and sewer provided by a utility, or will you have dig a well and drainage field at a considerable expense?
What is the quality of water that is available to you (i.e. how much pretreatment might be required)?
Part 2B - Lighting Perfection is a Moving Target
Today’s lighting options have exploded into many different types of lamp types (High Pressure Sodium (HPS), Ceramic Metal Halide (CMH), Light Emitting Diode (LED), etc.), configurations and manufacturers. Deciding on the right lighting can be an overwhelming and daunting task, especially when it comes to LED lighting options. Something to keep in mind is how much future operating costs will depend on the type of lighting fixture selected. Careful discussion and research needs to be spent on this design aspect because the value to the project is enormous. All lamps, whether they are LED, CMH or HPS, produce heat, some more than others. Rogue Sky sizes the heating, ventilation and air conditioning (HVAC) system to remove heat created by the lamps. Subsequently, the entire electrical system serving the facility needs to be sized to accommodate the power draw from both the lamps and HVAC. This represents the single largest infrastructure cost to any new or existing grow facility.
We recognize that every grower has their own opinion about what lamp makes the best product and we will not attempt to argue this point. We will argue, however, that in a saturated market where margins are slim and a majority of the flower will end up as oil, LED fixtures are a logical choice when it comes to energy consumption. For example, in Oregon, the state has attractive financial incentives to encourage the installation of LED light fixtures. The initial cost may be higher, but over time the decreased electrical consumption and subsequent reduced heat loads make the total cost over time cheaper versus HPS.
Our advice to any new facility owner is to start by building your design foundation around LED light fixtures. If you want to mix up the lamps with a few comingled HPS or CMH lamps, go for it, but we encourage the primary lighting to be LEDs. A recent cost comparative study we performed for a client between various LED manufacturers had wide ranging results in terms of simple payback. However, the net result was that LED, while more expensive on the initial per-fixture basis, was cheaper than HPS lamps due to reduced HVAC equipment and reduced electrical infrastructure cost in new construction. Follow that with annualized electrical savings and reduced fixture maintenance (LEDs generally last four times longer than HPS) and most companies find themselves in a more profitable position for the long game.
Part 2C - HVAC Options
As we mentioned in the lighting discussion, the HVAC system sizing for each of your rooms follows the selection of your lighting with secondary sizing input from the type of building and your growing methods. Sizing of heating, cooling or dehumidification loads is a relatively easy exercise. However, the selection of equipment that balances initial costs with longer term operational costs and crop risk is a much more complex effort and is not something easily explained in a quick blog post.
It’s no secret that what we commonly see in the indoor grow market is an overabundance of small mini-split HVAC systems (less than 5-ton capacity) from Daikin, Mitsubishi, Sanyo or other brands. In the design world, we classify this equipment as residential or light-commercial grade. They are appealing for lower price point and relatively efficient, but they are not meant for the duty cycle of a commercial or industrial grade grow facility. In conjunction with this, we see multiple individual cooling units in each grow room which increases overall equipment counts and electrical points of connection. Each of these pieces of equipment will require maintenance at some point and generally are not easy to clean and sanitize. They also represent points of potential and expensive failure lacking significant capabilities for industrial filtration to control and mitigate the spread of molds, mildews and pests.
As a general rule of thumb, in a grow facility that is less than 2,500 square feet, a mini-split system with supplemental dehumidification and hygienic filtration equipment is entirely acceptable and potentially one of the options that we would offer to our clients as a low level FDA-compliant facility. A facility that is over 2,500 square feet should be looking at a centralized cooling or combined cooling and dehumidification used in conjunction with industrial filtration systems serving multiple rooms and equipment that is rated for commercial or industrial-duty loads. The reasoning comes down to economies of scale and access to more robust and affordable equipment when we cross over into larger equipment sizes. Less costly electrical connections and sharing of equipment cooling or dehumidification capacity from one flower room to another lends itself nicely to lower construction and long term operational costs.
Any facility over 15,000 square feet should strongly consider a modular, panelized clean grow facility. Think of this as a ‘building within a building’ which allows you to access low cost warehouse or industrial park space and construct your multiple modular veg, clone/seed or flower rooms within the building at a significantly lower cost than a standard construction stick-built facility. To be honest, our clients have not had luck with containerized buildings (i.e. converted cargo containers). Their width often prohibits adequate space to grow in a cost effective manner. The benefit of these modular facilities is that they include everything - walls, electrical, lighting and HVAC - as a fully factory integrated, tested and optimized system. This makes them appealing when time to market is the core need of delivery. These modular buildings are commonly developed for high tech or pharmaceutical facilities that require clean environments that can be regularly sanitized, which is a strong parallel to the need of an indoor grow operation.
One item that is regularly overlooked in most existing or new designs is the application of industrial grade, hygienic air filtration. What we mean by hygienic air filtration is a piece of equipment that can be regularly sanitized and washed down and has two or more stages of air filters. This is very important with indoor grows since powdery mildew spores are primarily spread via the air. A means to capture these spores in your grow environments or to filter molds, spores and pollen from outside air should be one of the cornerstones of an integrated pest management program. What is often overlooked is the ability to sanitize and clean equipment inside and out, which is very important in preventing carry over of an outbreak or cross contamination from one harvest to another.
We hope that the importance of thinking long term in regard to the long term success of your grow operation is becoming clearer. In the third and final part of our Grow Facility Compliance blog posts, we will discuss best practices we have developed from industry experience, water management, and networking and monitoring.
- Jason Dubose
Jason is a 15-year mechanical engineering industry veteran with an extensive background of designing a wide range of high tech, ultra-clean and hazardous critical facilities and processes across the US and worldwide.
His design specialty has translated into energy efficient, cost effective, safe and secure cannabis grows and extraction facilities that consistently outperform expectations. He puts customers success ahead of personal profits and is passionate about helping guide and support the recently legalized hemp industry and the cannabis industry as it heads towards a legalized future.
Read more about Jason on his LinkedIn profile.