Design for Compliance Part 3: A Sustainable Future Cont'd
Part 3A - Building Construction: Best Practices in Action
Of all the things that can make or break a potential grow operation, the most passive piece of equipment is the building. There are many factors to consider when evaluating a new facility and too many to cover in this blog post alone. However, there are a few recommendations we would like to share that are inline with what you need to be a FDA-compliant facility:
In new and used buildings, work hard to avoid wood framed buildings. In high humidity environments such as indoor grows, wood is most at risk for developing mold or hosting pests. Steel or concrete structures can be sealed and easily sanitized.
In used buildings, get mold tests done for airborne mold, samples from the walls, and samples from the floors before signing a lease or buying the building. If it’s already there, it will cost you greatly in the long run as you continuously battle against it.
Every surface - floor, ceiling, walls, lights and HVAC fixtures - needs to be capable of being washed down and sanitized after an outbreak or harvest. This generally translates into using materials that are more costly up front, but will reduce your risk (and increase your bottom line) considerably in the long run. Laird/Duraclad PVC wall material, green-drywall with multiple coats of epoxy paint, or structurally insulated panels (SIP’s) are highly recommended.
As a design consultation group, Rogue Sky has seen a great variety of grow facilities. Some very impressive in their design and operating at continual low risk.Some that pose substantial risk to their own sustainability. The recommendations in this blog, while not hardlined, are things we commonly seen in the most cost effective, efficient, and safe grows.
Part 3B - Water Management
In an indoor grow, water is the source of life and profit to your plants. Good management of water quality can have an even greater impact than fertilizer. Realistically, water in your facility comes from one of four sources: utility provided, ground well, rainwater collection, or delivery. All four of these sources can have a wide range of qualities that fluctuate over the course of a year. In all cases, if water is untreated it will create inevitable challenges when trying to standardize your crop health and quality. Individual variables such as pH, dissolved minerals, solids and oxygen, if converted to constants, can assist a grower in gaining steps towards reproducible and positive results.
The first step of any water management plan is to source a high quality water test which will give a complete panel breakdown of all waterborne elements in parts per million (PPM). This piece of information is very valuable and will help you identify your actual water treatment needs (if any). This is also a test that should be repeated every 4-5 months if from a source or every month if from rainwater collection to ensure that you’re removing or supplementing your water source appropriately.
Water treatment and the applicable equipment is not something that can be given the detail it requires in a few paragraphs and Rogue Sky will discuss this in future blogs. As a producer of a highly valuable product, the ability to reproduce the same product over and over again requires that all crop inputs remain the same and consistent, which is especially true of the water quality. Watch for more about this in future blogs to help understand what water quality you want to standardize and recommendations for contacting a professional water filtration company to determine what equipment is best for your grow.
Part 3C - Network and Monitoring
All legal indoor and outdoor grows have requirements for security and internet-connectivity. In a fully legal regulatory environment that requires Current Good Manufacturing Practices (CGMP), a very involved level of networking and monitoring to ensure crop safety and integrity will be (and already is in some states) required. Additionally, under the most recent U.S. Food Safety and Modernization Act (FSMA), monitoring of food product production has become more stringent and the requirements have been applied to small farms just as much as big farms. For CGMP recommendations to be followed in most manufacturing facilities, at a minimum, temperature and humidity will need to be monitored and that data logged along with equipment statuses. (i.e. has the unit been in alarm, not running, etc.)
Depending on what kind of CGMP or International Organization for Standardization (ISO) standards are created around cannabis or industrial hemp production and processing, other monitoring needs may potentially be:
Water quality and usage.
Outside air temperature.
Air filter replacement.
CO2 levels (if used).
Air pressure in each production space.
Air Quality (particle size and counts - PM1.0, PM2.5 and PM10).
There may be other factors that require monitoring depending on the end product being developed. When budgeting for a new or existing grow or processing facility, costs needs to be allocated for installation of both networking and the future sensor matrix.
Rogue Sky will be expanding on some of the individual items for successful grows in future blogs. We are starting to see future federal compliance pathways expanding and taking shape with the recent legalization of industrial hemp. If we have to leave you with one parting note, it is that compliance with federal CGMP requirements is real. It is coming and will be the rule, not the exception as we move forward for the next few years. Our goal is to enable you, as the grower, to be successful in your ventures. If you would like to learn more about facility design for compliance or have any other questions, please contact us, we would love to chat.
- 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.