Washington State Emergency Rules on Flammable Solvent and CO2 Extraction

OK ya’ll, here are copies of the “emergency rules” that Washington State has adopted in the face of the 2013 explosions, fires, and Bellevue fatality.



Well Intended Closed Loop Explosion

I’ve been expecting a closed loop explosion, and per O Toole’s Law, here is a splendid example of an ostensibly well intended, but woefully ignorant brother blowing himself up with a modified Lil Terp passive design.  It’s unclear whether he purchased it as is or assembled it himself, but he is clearly ignoring or ignorant of  the most basic of the rules.


For starters, he was extracting indoors, in a residence, which is not ever safe, because things can and do go wrong, go wrong, go wrong…………….

He is clearly in violation of the first, second, and third rules of CLS extraction, which are never extract indoors in a residence, never extract indoors in a residence, and never extract indoors in a residence.

The forth rule is only extract indoors in a commercial setting, in an adequately protected and ventilated enclosure, as approved by the fire marshal.

Regardless of where he was, he was demonstrably without adequate ventilation for the size leak that occurred.  In industrial settings, the fire marshal would never issue a permit with out proper safety precautions like ventilation.

The operator was wearing clothing that was not static free.  Some of you have noted attacks on my credibility and sanity on line, by extractor manufacturers like Mr Extractor, when I called them on a demonstration where his demonstrator was burping a passive system indoors wearing a synthetic dress.  Please note this incident appears to vindicate me and the NFPA guidelines, while flying in the face of  Mr Extractors defensive argument that my claims were  ludicrous .

As you can see from the picture below , the Lil Terp design was modified with the addition of sight glass under the column, so that when flooded, it was locked between two valves.

That subjects it to hydraulic forces as the butane warms and expands, which are measured in KSI as opposed to the 50 to 150 PSI  they are rated for.

That is why even 3X tanks designed to store butane, only allow an 80% fill, so that the system only sees vapor pressure.

Though the operator said a valve leaked with a pop, valves typically leak by weeping or peeing past a seal, while a sight glass over pressure failure definitely makes a pop.  Leaky seals don’t suddenly release enough butane to blow up a house, but ruptured sight glasses do.

In its current position, it isn’t possible to see whether the glass is broken, but there is clearly no evidence of the three piece valve separating far enough for a release and a leaky valve seal is a  jet, not a sudden release with a pop, not to mention it is visible and doesn’t show evidence.

The operator was also under the impression that his setup was legal in a residence, was safe to run indoors, and met CO regulations for a CLS.  There is no reason that it shouldn’t meet CO’s regulations as the Lil Terp was originally designed without sight glass, but with it in the configuration below, there is no way it would meet the 3X requirements of ANSI and ASME.

Hats off to this operator for attempting to extract safely, but a failing grade for pre-research.  Part of that research was the safety and legal ramifications of extracting in a residence and locale, so in addition to burn treatment, he is facing a day in court on charges that can lock him up for a long time.

Even if it is his house, I’ll bet the insurance doesn’t cover indoor extraction, and if it isn’t paid for, the mortgage holder will no doubt have some thoughts on repairs.

Close your eyes for a moment and imagine the changes it would bring to your life if suddenly you were badly burned, and were facing civil action for the damage, as well as high legal costs and prison time……………………………………


exploded CLS


Some of the comments suggest a lack of understanding of the laws for concentrate extraction in CO.  I’m not a lawyer, so here is a link to what the CO Attorney General thinks on the subject, as well as a link and summary clip from CO’s regulations on flammable solvent extraction:



D. Solvent-Based Medical Marijuana Concentrate.

A Medical Marijuana-Infused Products Manufacturer that engages in the production of Solvent-Based Medical Marijuana Concentrate must:

1. Obtain a report from a Certified Industrial Hygienist or a Professional Engineer that certifies that the equipment, Licensed Premises and standard operating procedures comply with these rules and all applicable local and state building codes, fire codes, electrical codes and other laws. If a local jurisdiction has not adopted a local building code or fire code or if local regulations do not address a specific issue, then the Certified Industrial Hygienist or Professional Engineer shall certify compliance with the International Building Code of 2012 (http://www.iccsafe.org), the International Fire Code of 2012 (http://www.iccsafe.org) or the National Electric Code of 2014 (http://www.nfpa.org), as appropriate.

Note that this rule does not include any later amendments or editions to each Code. The Division has maintained a copy of each code, which are available to the public;

a. Flammable Solvent Determinations. If a Flammable Solvent is to be used in the
processing of Medical Marijuana into a Medical Marijuana Concentrate, then the Certified Industrial Hygienist or Professional Engineer must:

i. Establish a maximum amount of Flammable Solvents and other flammable
materials that may be stored within that Licensed Premises in accordance with
applicable laws, rules and regulations.

ii. Determine what type of electrical equipment, which may include but need not be
limited to outlets, lights, junction boxes, must be installed within the room in
which Medical Marijuana Concentrate are to be produced or Flammable Solvents
are to be stored in accordance with applicable laws, rules and regulations.

iii. Determine whether a gas monitoring system must be installed within the room in
which Medical Marijuana Concentrate are to be produced or Flammable Solvents
are to be stored, and if required the system’s specifications, in accordance with
applicable laws, rules and regulations.

iv. Determine whether fire suppression system must be installed within the room in
which Medical Marijuana Concentrate are to be produced or Flammable Solvents
are to be stored, and if required the system’s specifications, in accordance with
applicable laws, rules and regulations.

Refrigerant Recovery Pump Updates

Some excitement for closed loop extractors looking for an electric refrigeration recovery pump rated for R-600 refrigerant and more good stuff from Haskel!

We are testing a electric new pump named the CMEP-OL that was designed specifically for our cannabis market, which is certified for use with flammable solvents, meets our process requirements, and has so far stood up to our field testing.

We just moved it to the third production lab for continued field beta testing, with a thumbs up from the first two, a note that they are quieter than either the Appion or the TR-21, and faster than two TR-21’s in both of their applications.

We are currently running it in the field in as continuous service as possible, to rack up hours and tests its ability to stand up to our use and abuse, and so far, so good.

We of course continue to recommend and rely on the pneumatic Haskel 59023 double stage and EXT420 single stage, which Haskel will now offer in a -2 configuration that is switchable from single to double stage using a single two way valve and two check valves.

WolfWurx already converts both of the existing pumps to selectable single or double stage, using two three way valves, which is more complicated, though ostensibly with less back pressure without check valves. At least one other operator I know has converted his to selectable stages, using four two way valves.

The Haskel’s single drawback is its air consumption, but we have exciting news! The first, but old news, was that the Haskel performs most of our tasks single stage, so we almost double the output, and now the new news is that we’ve also determined that the Haskel never requires its full rated 100 psi pressure or 40 scfm air flow to meet our performance requirements at their recommended 60 strokes a minute.

We don’t have enough back pressure on a Mk VB installation to require more than 50 psi even running single stage, so we end up needing only about 25 scfm at 50 psi, or about a 6.25 hp (7 1/2 hp) screw compressor, rather than the 10 horse required for full pump capacity.

The big difference that makes, is the selection of single stage screw compressors increases at 7 1/2 hp, and they use less electricity.

For smaller installations, many of us have searched for an electric oil less refrigerant recovery pump that is rated for flammable refrigerants, and many use the non NEMA 7 rated electric Appion G-5, the ProMax-6000, the CPS-TR-21, and TRS-21, simply because they work.

CPS delighted us recently with their offering of the TRS-21 sparkless, influenced by our markets needs, but not certified for use with R-290/600/600A. It currently appears to be struggling with infant mortality with the new pumps seals, and we await their solution.

Here at the Pharm, we’ve also tested the R-290/600/600A rated CMEP loaned to us by Ecogreen, which performed well testing machines, but alas was not oil less, and are now testing a CMEP-OL, NEMA 7 oil less refrigerant recovery pump on loan from Sanitarysteel.com.

Here is a picture of four pumps, left to right, the Appion G-5, the CPS-TR-21, the CMEP-OL, and the CMEP.

The Haskel that follows, is on WolfWurx, Inc Mk V waiting to be converted to selectable single or double stage, with a picture following of a unit converted using two three way valves.

Zee Pumps-1-2zee pumps 001Haskel 59025-3

Haskel plumbed selective stage

Haskel 59025-3 converted to selectable single or double stage using two three way valves. Haskel offers the EXT420 single stage and soon will offer their EXT420-2, which is selectable single or double stage, using one two way valve and two check valves, engineering test sled picture below:

Haskel EXT-420-2 prototype test sledHaskel EXT420-2 prototype:

Sorry, but just too too much has pushed us’ns over the edge on open blasting!

I’m sorry to say that I just removed our instructions on how to do BHO extractions using an open tube, after us’n three SPR partners unanimously agreed that too many brothers and sisters are ignoring all warnings against indoor open blasting, and the havoc they are wreaking is causing us to all be painted with the same brush as sociopathic idiots.

I left the parts not relating to open blasting, including butane safety, which is applicable to both open and closed loop extraction.

There are ample sites demonstrating how to open blast, so ours is not needed.

Sorry it came to this!  I note it is always the few that ruin things for us’n masses, but don’t know how to fix it.


Domestic Butane

Whoop, whoop, lu lu lu lu lu lu lu lu lu, awhooooooooooooooooooooooooooooooooo!!!!!!!!1

Medical extractors looking for a domestic source of 99.5% Instrument grade n-Butane will be gladdened by the latest gas supplier to announce a domestic source at competitive prices, replete with Praxair tests and certifications.   99.99% scheduled next.

You have to buy to own your first LP5 (24lb) or FX1 (120lb) tank, and then continue to swap it out.

Contact J Coltrane for pricing and delivery, at coltrane422@gmail.com.


We sent a sample of  Coltrane/Praxair 99.5% Instrument Grade n-Butane to a third party analytical lab to determine the contaminant levels of molecules larger than C-4, ignoring molecules smaller than C-4 because they are not of concern to us for our process.

The lab determined that the parts per million contamination was below their test cut off of 0.2 ppm, so this information was minimally useful.

We subsequently distilled off 10# of it into a new Lp-5 tank, and passed it through a VICI Metronics polishing filter.  We noted that after distilling 10# in a 12″ X 12″ recovery pot, that there was only a light film on the inside of the pot, with no droplets or puddles.  Sadly, the weight of the oil would be minuscule compared to the weight of the cold trap, so simple weighing is not possible, so we will again rely on a state certified third party forensic lab.

Dropping those off this morning and this time, we will have the remaining virgin n-Butane analyzed using a GCMS to the PPB level, and test the distilled and polished butane to glean empirical results on the efficacy of our process.



Free Open Source Dosage and Pricing Software!

Hee, hee, hee, here is a good idea at the right price!

Periodically brothers and sisters send us stuff to try out and comment on. Leblanc CNE is one whom just sent us some free open source software that they’ve written for calculating individual dosages, as well as software for establishing pricing, based on costs and markups.

The joy of both is that you can change any number and it will update the rest, so it makes it easy to also play, “What if?”

I think it’s cool, and suggested posting it on SPR for more people to try and provide feedback to, which they agreed to, so here it is folks:

First we have the dosing software:


Here is the pricing software:


Here is where to leave direct feedback to the fine mind that created the software and provided it for your whim and pleasure free:


Poisoning the well!

Joe and I have both spoken out against sub standard and unsafe extraction devices, but how about those suppliers whose marketing plaudits, include poisoning the well for their competition with exaggerations and untruths?

Suppliers with such a low opinion of their own product, that they don’t feel up to competing based on their own products attributes, so they make a concerted effort to shoot down the competitors product using a tapestry woven of truths, half truths, and untruths.

Joining MO in that regard, we now have Connoisseur Concentrates with Mr Extractor, whom paint their competitors as intentionally poisoning the public.


They present their machine as the safer alternative, yet publish a video demonstrating extracting indoors, with out a properly ventilated extraction enclosure, a never, under any circumstances NO NO.

If they are the safer alternative, what does that make the rest of us?

Compounding the egregious blunder, they also didn’t first vacuum the oxygen from the extractor before injecting the butane.  They instead floated the oxygen laden atmosphere out and burped it out into the room.

Please ask your local fire marshal’s views on how safe he thinks that is.

In point of fact their “safer” machine didn’t even have a vacuum connection for a pump, as do both the Tamisium and Lil Terp they present as inferior.

We touched swords on IC MAG forum, (https://www.icmag.com/ic/showthread.php?t=298826)but Drew left the field to avoid answering the questions listed below.

I see them germane to the question of whether Mr Extractor is indeed safer and ahead of the industry, or whether they are just a rip off of the Tamisium and Lil Terp, adding a glass sight glass unlikely to meet ANSI/ASME in this application.

Certainly the jackets are handier than buckets, but are they safer and what in Earth justifies the $6000 markup over the cost to assemble a Lil Terp?   Is it the attached jackets to avoid using buckets.

What justifies the added cost over the Tamisium TE-175 at about $1800?


The questions begging an answer, and being avoided, are as follows:

(1) A yes or no question. Do you have a ME PE stamped document certifying Mr Extractor to meet ANSI and ASME?

(1.1) May we see a copy?

(2) Now may we talk about finishing. Would you share with us how you recommend finishing the material from your recovery pot to meet current residual solvent standards?

(3) Do you have any reputable third party lab analysis of product demonstrating the common deposits of metal and PTFE piston ring material in extractions and if so, would you please share?

(4) I am most curious about your use of 9mm borosilicate tube for the extraction tube, which we too looked at because it is so obvious, but decided to not pursue it after considering the effect of shock sensitivity during sharp temperature gradients.

We even looked at having the glass coated inside and out with clear PTFE for the added safety, but decided it wasn’t a good idea to have a pressurized glass vessel with flammable gas inside.

Sort of along the same lines of why the gas station won’t fill your glass jug for you.

(4.1) That leads me to the subject of liability insurance. May we see a copy of your product liability policy and contact information to your carrier?

Drew also claims superior performance, but has failed to address the following observations:

1.0 The pumped system is considerably faster.

2.0 The pumped system evacuates the oxygen before injecting butane, so that there is never an explosive mixture.

2.1 Since Mr Extractor uses no vacuum, the passive system mixes the butane with atmosphere as it is injected and floats the explosive mixture out. It is vulnerable to ignition and explosion during that process.

3.0 The system is recovered to -22″ in a pumped system, so only 25% of its volume in vapor is lost.

3.1 100% of its volume in vapor is lost when opening a passive system.

4.0 An active system recovers most of the butane soaked into the material in the columns, by vacuuming to -22″Hg. The pumps are unable to achieve that level until most of the butane is gone.

The last 25% between -22″ Hg and -29″ Hg, is subsequently pumped off using a vacuum pump, so when the columns are opened, there is not an explosive mixture.

4.1 The passive system not only doesn’t recover the butane soaked into the material to the same levels as the active systems, but when opened the columns are definitely within explosive limits.

Because it leaves the butane in the material, losses are greater.

5.0 A pumped system can pass more fresh clean butane through the material faster, and in both directions, so ergo it extracts faster and more completely.

6.0 You can recover a pumped system recovery pot at 31.9F, so as to preserve more carboxylic acids and aromatics.

6.1 Even using dry ice, you are still using a hot water bath with the meds in it, utilizing passive techniques.

7.0 An active system easily pre-distills butane at 85F, to remove residuals including Pentane, which boils around 100F.

7.1 Recovery at 85F using a passive system takes much longer.

8.0 An active system offers more latitude for propane mixes.


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