Hey all! Just a heads up and a bit of clarification. The LPG board requires fresh air intake for extraction rooms. Basically, they will not allow the air from the building or room the C1D1, C1D2 is located to pull air from that space. They require the air coming into the room be from outside. However, I did get clarification that if the ventilated room is not used for extraction purposes it does not require fresh air intake. For example, if you are using a C1D2 room for post extraction you are not required to have fresh air intake. This came from a city building inspector. Seems like they are all on the same page of new requirements. Hope this helps those in Oklahoma with more inspections coming up.
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That seems bizarre given the temp range the outside air in OK can achieve.
Do they have code they are pointing to?
National or local?
I can see implementing the PANIC airflow without conditioning, but requiring the normal airflow be maintained from outdoor air puts significant hx requirements on that air exchange, or leaves the process that should be temperature controlled open to huge fluctuations in room conditions.
I’ve worked in labs at 3C and 35C both suck!
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Very bizarre. 100+ temp hot air from a roof?
Definitely not making sense.
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Oh it’s terrible, the temperature fluctuations and humidity will make it difficult. I spoke with Chandra Heitzinger and Nicholas with the LPG Board and a good contact at the state fire marshal office is Angela Aguilar. Chandra and Nicholas confirmed this is a requirement.
Chandra Heitzinger Chandra.Heitzinger@lpgas.ok.gov
I have yet to have them email me the information. I have had three clients so far have building inspectors inform them it is a requirement. Unfortunately they aren’t helpful in pointing out where it says this requirement. They also state back up power required but don’t know what for, for how long, and what type of backup power and have never gotten the same answer from anyone. Wish I had clarity. We have presented information why this would not provide any safer environment and their claim is that if there is post processing outside the extraction room, and any potential solvent could be drawn into the C1D1 space it could be dangerous. So yeah. LOL
The back up power is listed on IFC Chapter 39 Section 3905.3
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You’d think they would at least try to understand the implications of their regulations, eh? I called the OMMA compliance center yesterday and after asking a couple questions was asked to be placed on hold so Julia could go read the FAQ sheets on the OMMA website, which I had already read before calling. The whole OMMA system out here is and will be a joke until they incentivize people in the industry with actual living wages or hire consultants to help structure the regulations themselves. Otherwise, it’s lobbyists working with old white republicans that are about 2 generations out of touch from the house and senate bills they pay for.
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The C1D2 at my work has an outside air intake also, per AZ fire marshall. I blocked it off and opened a baffle to the lung room (temp controlled warehouse) because it gets up to 120F in the summer here. It’s already over 90 outside at 10am today and it’s still Spring!
All the alcohol would be evaporating and nobody could comfortably/safely work in there before. Not the best solution, but what else can be done?
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They made me do this in Portland. As everyone says, say goodbye to AC!!!
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Common sense approach doesn’t seem to fit with regulations. I spoke with Adria Berry about ways to help companies be in compliance and having information available. Not sure if it will help at all. As of Nov. 1 the OMMA will no longer be under the health dept. so maybe there will be some positive outcomes for business owners? Not holding my breath but we shall see. They have several job openings for training etc.
Edited to add:
Good luck getting through to the state fire marshals office too. Extremely difficult. It should not be this hard.
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I lived in AZ for a while, loved it! There are ways to connect your a/c into the room but modifying so there is no risk of potential “backflow” (for lack of a better word) of any potential solvents. Again, common sense says that much butane can’t rise into a roof duct blowing air into the room, but what do I know, lol. Problem is all that bought air is being exhausted out and the size of unit needed gets pricey.
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We had to do this in lancaster and it sucks so bad. They will not let us take air from anywhere in the building. Very hot in the booth in summer and very cold in the winter. Makes chillers work overtime in the summer forsure.
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Does anyone here that have fresh air requirement implemented in their area know where they are getting this? Any national codes or references?
Can you guys put a water cooled or geothermal heat exchanger outside the building? Should cool the intake air down a bit no?
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Just want to mention, you can still have an AC feeding directly to the booth and only inputting fresh air from outdoors that has been conditioned.
It’s energy intensive because you’re exhausting every single bit of air you condition… but it works
Edit: I might add that this AC has to be dedicated to the booth it cannot service any other zones in the building.
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You put that way better than I attempted to!
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Unfortunately we have people without common sense running the show and changing the rules along the way while we are all trying to comply here in Oklahoma.
I would understand if it was in a very small place with little excess air for intake, but their ideas are beyond lacking in the intelligence department.
Thank you for sharing your findings with everyone. There’s a lot of mistakes being made by poor information getting passed around from all of my discussions with other processors here around Oklahoma.
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Geothermal sounds better than ac in my opinion
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This is the (expensive) answer right here.
This is a similar problem that we run into in GMP Cleanroom applications. The clean space has tight environmental parameters that have to be met for compliance purposes, and often times we’re pulling air from non conditioned industrial space or outside and have to make sure to provide sufficient HVAC on the inlet to ensure a ~68 degree environment on the inside. That being said, a properly sized HVAC on the inlet costs a pretty penny and typically this is paid for with deep pharma pockets because they have to to maintain compliance. Add in the fact, like Phil said, that you’re exhausting every bit of conditioned air that you put into the space and your HVAC requirements go WAY up.
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The Biologics manufacturer I worked with would exhaust air into a a return through HEPAs, exhaust a portion of that and then mix the remainder with outside air from a blowdown fan.
This was for ISO 7 and ISO 8 environments
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Definitely hate being the barer of bad news, but rather companies have a heads up before an inspector has to tell them.
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