If you’re involved in designing, planning, or managing a cannabis processing facility, there’s a good chance that you’ve heard a thing or two about “UL 1389” over the past couple of years. But what is it exactly? What does it apply to, and why is it important? This article will provide a brief overview of the history and content of the standard, with a look to its implications for the future of the cannabis processing industry in North America.
What is UL 1389?
The full title of the standard is “Plant Oil Extraction Equipment for Installation and Use in Ordinary (Unclassified) Locations and Hazardous (Classified) Locations”. A bit of a mouthful, but the standard itself is actually less than 60 pages long. If you feel like reviewing it yourself, you can access it for free through UL’s online catalog (registration is required).
It was first published in November 2019, and was developed in response to pressure from Authorities Having Jurisdiction (AHJs) in legal states who needed clearer guidelines on how to assess the safety of new processing facilities. Processing equipment varied greatly in quality and safety, was frequently repurposed from other industries and was often not well-suited to the particular demands of cannabis processing. Several high-profile fires and explosions threatened to undermine the public’s trust in the cannabis industry and legalization as a whole. Clearly, there was a great need for standardization and a basic set of design rules.
The standard applies to pretty much any equipment that’s used to process cannabis post-harvest: trimmers, deseeders, dryers, extraction equipment using organic solvents or CO2, processing booths, post-processing equipment like wiped-film distillation units and vacuum ovens, and more. The standard specifically does not apply to solventless mechanical extraction devices, like rosin presses and cold-water trichome separators. It is a joint national standard, meaning that it applies to both the USA and Canada.
The UL 1389 standard includes references to dozens of other existing standards for other equipment and industries; many of the hazards and challenges faced by cannabis processing equipment designers have already been faced by people working in other industries. These referenced standards cover subject areas including motors for hazardous locations, electrical installations, industrial control panels, fire code, sprinkler systems, compressed gases, and numerous others.
UL 1389 also defines best practices for design and construction, as well as specific tests for verifying that equipment conforms to the standard. The intention is to make it as easy as possible for equipment manufacturers to understand and adhere to this set of best practices, while protecting the public by providing a resource that engineers and other professionals can use to verify equipment safety.
Why is it important?
Any time a piece of industrial equipment is installed in North America, the installation must be inspected and approved by the local Authority or Authorities Having Jurisdiction (such as an electrical authority, fire marshal, or building inspector). This is critical for a number of reasons: it ensures the safety of the people who interact with that machine or frequent the building; it ensures the security of the facility; and it gives the facility operator the documentation they need to justify insurance claims in the event of an incident. Equipment listings or certification from accredited testing laboratories can help expedite this process.
When a piece of equipment arrives at your facility with a “Listed” or “Certified” mark from a recognized testing body, it proves to the AHJ that the equipment has been investigated thoroughly by professional engineers, who confirm that it has been designed and built to the standard specified on the label. The AHJ can then confidently approve the installation without further specialized tests or inspections - it is a very cut-and-dried process from a facility operator’s perspective. Sounds easy, right? So why settle for anything less?
Well, the cannabis industry moves quickly, but not that quickly. Since the first publication of the UL 1389 standard just over a year ago, only a small handful of machines have been investigated and certified to this standard. Having a product listed or certified by a recognized testing body can be an onerous, lengthy, and expensive process, and it is geared towards mass-production equipment. Typically, an equipment manufacturer sends an entire machine, or a few representative pieces or samples from the machine, to a recognized testing laboratory to be subjected to (sometimes destructive) testing. Then, they either have each and every piece of equipment inspected as it’s installed, or they enter an agreement with the testing laboratory to a predetermined number of surprise inspections every year to verify that they are building the equipment precisely as described in their documentation. This represents a significant up-front expense, and a smaller ongoing expense to maintain the certification, but with a high sales volume it is very cost-effective and the savings can be passed on to the customer.
The most common alternative to having a product listed or certified is to have a third-party engineer peer review the equipment. If a company is only manufacturing a piece of equipment once, for a custom application, it might make most sense to have an engineer with relevant expertise peer review the machine and/or perform a field evaluation to verify its safety. The consulting engineer should be aware of the UL 1389 standard and other relevant standards, but they can also use their own professional judgment to determine if the equipment is safe as built. In this sense peer reviews are understood to be more flexible than listing or certification, while also being deemed legally equivalent. Engineer peer reviews aren’t cheap either, but in a fast-changing industry, they can be a safer bet and shorter-term commitment for equipment manufacturers whose designs are rapidly evolving.
What does the future hold?
Over the next few years, expect to see many more manufacturers offering equipment that is Listed or Certified under the UL 1389 standard. The next editions of the Canadian Electrical Code and the National Electrical Code are both expected to include references to the UL 1389 standard. Other standards like the International Fire Code (IFC) will follow. The cumulative effect of this adoption will be increased awareness of the standard, greater customer demand for listed or certified equipment, and increased scrutiny of equipment that is not listed or certified. UL 1389 is also still being refined as the industry grows, and it will likely be expanded to include equipment that is currently not covered.
Yellowstone Extraction Co. already uses UL 1389 as a design input, and is currently working on an even more functional falling film evaporator which will be certified to the standard. In the meantime we continue to rely on engineer peer review and field verification when required.
There are as many ways to process cannabis as there are processing facilities, but they should all be safe. A reputable equipment manufacturer will let you know up front exactly what the approvals process for their equipment will look like, along with approximate costs and timelines. Hopefully this article will help you make an informed decision when it comes time to invest in your facility. Stay safe out there.
Yellowstone uses UL 1389 as a design input for all of its machines.
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