What’s That Smell?
The prevalence of cannabis odour has been a concern for municipalities and their residents. Metro Vancouver has seen an influx of complaints and has moved to address this issue.
Odour is one of the top municipal concerns when new licence applicants are trying to get a jurisdiction on board with their build plans, as such, odour control is often included in the applicant’s presentations to municipalities, and is also often the subject of spirited Q&A sessions with the public.
Terpenes, the aromatic component of cannabis that connoisseurs appreciate – can also get a cannabis company in trouble.
Odour control is a regulatory requirement
Cannabis Regulations have always included the requirement to ensure odour doesn’t escape the facility. Section 85 of the Regulations states “The building or part of the building where cannabis is produced, packaged, labelled and stored must be equipped with a system that filters air to prevent the escape of odours.”
Does that brief requirement ensure communities aren’t left dealing with smells from a cannabis cultivator? Clearly not, or there would be fewer issues cropping up.
Odour control and air filtration systems are complex and expensive. They are particularly challenging in retrofitted buildings which weren’t purpose-built for substances that emit odour, like cannabis. The main physical components of a good air filtration system are HVAC (heating, ventilation, air conditioning), filtration, and an odour atomizing system.
That just covers the equipment. More important is operational experience with your HVAC system, and regular monitoring to ensure your maintenance program is adequate for your facility’s production volumes. Off-the-shelf equipment, correctly installed, is only effective when combined with a custom preventive maintenance program. And such a program must be verified regularly with real-world experience.
Systematic monitoring is expected
The newly published “Good Production Practices (GPP) for Cannabis” guide (May 2019), from Health Canada, adds more clarity about licence holders’ responsibilities. Section 184.108.40.206, for Air Filtration includes the following requirement: “The presence of odours surrounding the facility is monitored in accordance to a schedule and responded to if necessary.”
The onus on the Licence holder is clear – they should have a proactive odour monitoring system in place. Monitoring should be more frequent in the first year of operations, and whenever production volumes change significantly. Ideally this system would also include a formal arrangement to track and respond to neighborhood complaints.
While odour control has always been a requirement, Health Canada has taken it one step further, clarifying that the expectation is for the Licence Holder to respond to odour issues. It remains to be seen if this is will be backed with any of the enforcement measures at Health Canada’s disposal.
Beyond the fear of enforcement action, cannabis companies have a responsibility to be good neighbors, by ensuring their operations aren’t making life difficult for those around them.
Municipalities are usually very supportive of cannabis operations, as they often bring jobs and prosperity back to places that have otherwise struggled. As good corporate citizens, Licence holders should ensure odour is never so bad that Health Canada feels the need to act and enforce the regulations.
Written by Karina Lahnakoski, VP Quality and Regulatory at CCI
Cannabis Compliance Inc. has been consulting on operational issues for licence holders across Canada, including remediation plans for sites, cultivation planning, and quality assurance auditing.