Impacts and Actions Resulting from the Recent Enforcement of Electrical Equipment Interlocks with the HAL Extraction Booth by Authority Having Jurisdictions and Third-Party Professional Engineers
Summary of Code Enforcement
As of June 2021, HAL Extraction Technology received approval for and implemented over 300+ Extraction Booths into licensed cannabis manufacturing facilities throughout the United States, Canada, and Puerto Rico. Successfully navigating the Fire and Building Code approval process is instrumental to HAL Extraction’s mission to deliver code-compliant solutions to an ever-evolving regulatory landscape. Within the last year, there has been a stronger push from Plan Checkers and Professional Engineering firms to enforce the requirements detailed in International Fire Code 2018 Chapter 3905.1.5 which states:
IFC 3905.1.5 Electrical components within the extraction room shall be interlocked with the gas detection system. Activation of the gas detection system shall disable all light switches and electrical outlets.
A common electrical configuration within the Extraction Booth is to connect an electrical refrigerant compressor for the extraction system through an outlet rated for hazardous locations. According to IFC 3905.1.5, proper installation of this device requires the electrical outlets in the Booth shall be disabled upon activation of the gas detection system, thereby preventing electricity from being supplied to the refrigerant compressor. The electrical equipment inside the booth is disabled for any Booth state that is considered unsafe for electric operation. The following instances below describe the states of the Extraction Booth in which the Interlock Relay is powered ON/OFF:
- Stand-By State (Fans Off): Interlock Relay OFF
- Base State (0% - 10% LEL): Interlock Relay ON
- Purge State (10% - 25% LEL): Interlock Relay ON
- Emergency State (25+% LEL): Interlock Relay OFF
- Equipment Fault State (NO SIGNAL): Interlock Relay OFF
The HAL Extraction Booth’s B30 Control Panel comes standard with a 4-pole relay that has (4x) sets of dry contacts for interlocking the equipment inside of the Booth. The dry-contacts will allow a signal to be sent to a near-by motor contactor that controls when power can be supplied to the electrical components within the booth. This motor contactor can be designed as a latching or non-latching interlock, as required by certain AHJ’s.
Impact to existing HAL Extraction Customers
HAL Extraction Customers who purchased booths prior to November of 2019 received a Control Panel that did not come standard with the Equipment Interlock Relay. HAL Extraction developed and re-engineered the standard Control Panel throughout the 2019 year in response to code changes resulting from the release of IFC 2018, which included the IFC 3905.1.5 requirement. As a result, revisions of our first-generation Control Panel prior to this development did not include the hardware with the functionality to meet the interlocking requirement.
As cannabis legalization efforts continue to unfold in new states throughout the US and abroad, national standards will begin to converge amongst all AHJ’s across the country. HAL Extraction, and other well-respected Engineers, Industrial Hygienists, and public officials agree that electrical interlocks within plant oil extraction operations will become a widely enforced rule. For customers seeking compliance beyond federal legalization, it is heavily advised that all plant oil extraction operators consider installing the components necessary to achieve the functionality required to meet IFC 3905.1.5.
Actions to consider for existing HAL Extraction Customers
If you are a HAL Extraction Booth Customer that purchased your Booth before November of 2019, or you have received a Control Panel that does not have a touchscreen Human Machine Interface (HMI) on the front door, you may need to consider a means for interlocking the electrical components within your Booth. See image below for an example of the Control Panel lacking the interlocking hardware:
HAL Extraction has engineered solutions ready to resolve the issue for customers that may need to implement an interlock into their pre-existing Extraction Booth. If your facility is subject to annual inspections by your AHJ or Field Verifications by Professional Engineers, it is likely that a future inspection will fail because of the requirement for equipment interlocks.
To get ahead of this issue, HAL Extraction can provide Booth Upgrades that will provide the necessary functionality for interlocking and also greatly improve the quality of your booth for future operation. The latest version of the Control Panel features an HMI touchscreen giving you advanced control and clear insight into the functionality of the Booth’s Control System. HAL Extraction also provides UL 508A constructed Equipment Power Interlock Panels that can be custom sized for your specific electrical extraction application.