Cannabis and Occupational Health and Safety

How do you keep cannabis workers safe on the job?

Occupational health and safety is something that every business and licensed cannabis producer needs to consider. When it comes to occupational health and safety for cannabis businesses, the steps that need to be taken are similar to the steps taken in other agricultural industries. Each province will have different local requirements, but there are some general cannabis worker safety steps that should be taken regardless of location.

Because of its history as an illegal drug, there has been limited scientific study of occupational health hazards within the cannabis industry. …there is accumulating evidence that some of these exposures may be associated with adverse health effects in workers exposed to cannabis.

Christopher Simpson, Occupational Health and Safety in the Cannabis Industry

Identifying Workplace Hazards for Cannabis Growers

In the cannabis cultivation space, there are many workplace hazards that employers need to address. Using procedures for Hazard Analysis Critical Control Points (HACCP) and Risk Assessment will enable you to identify workplace hazards, grade the severity of the hazard, and create a plan to control or eliminate the hazard. HACCP and Risk Assessment SOP templates are available from GrowerIQ and are important procedures to include in your Quality Management System.

Just some of the major workplace safety concerns for cannabis businesses include allergens (to cannabis and other materials), dust particles and aerosols, pesticides, ergonomic hazards, noise, and physical hazards like cuts, slips, and trips. On-the-job cannabis use is also concerning. While there is not currently a good method to discern short-term versus long-term cannabis use, any employee that is exhibiting observable signs of impairment (regardless of reason/source of impairment) should not be allowed to remain at work.

What is HACCP?

HACCP has seven principles that allow workplace safety hazards to be identified, controlled, and monitored. HACCP needs to be used in GMP-regulated environments but can benefit environments that are not GMP-regulated as well. Here are the seven principles of HACCP to give you an idea of what is involved in this systematic approach to workplace safety:

1. Conduct a hazard analysis
2. Determine the critical control points (CCPs)
3. Establish critical limits
4. Establish monitoring procedures
5. Establish corrective actions
6. Establish verification procedures
7. Establish record-keeping and documentation procedures

PSHA and OSHA for Cannabis Businesses

In “Occupational Health and Safety in the Cannabis Industry,” Christopher Simpson points out that dermal and respiratory health effects along with increased injury rates have been observed in cannabis workers. Personally, I recall that I encountered many health and safety issues when I worked in a hemp greenhouse. I developed a skin allergy to cannabis, had to battle the heat of the work environment, was bitten by insects that infested the nursery, and the work conditions were concerningly unsanitary.

Needless to say, I did not keep this job for long and that company was not upholding its duty to comply with Colorado Cannabis Worker Safety Guidelines. Be sure to follow this link and view the Colorado Cannabis Worker Safety Guidelines and California Guidelines linked below because they provide great examples, resources, and great information!

In the US, both Colorado and California have established cannabis worker safety programs that are based on Occupational Safety and Health Administration (OSHA) requirements. In Canada, Public Services Health and Safety Association (PSHA) serves the same purpose as OSHA. Neither OSHA nor PSHA weighs in specifically on how to protect workers in cannabis businesses. They will both address cannabis intoxication as being of concern, but don’t go into the specific detail of the California and Colorado plans for cannabis worker safety.

In “Safety Lessons for Cannabis Growers,” Kelly Fernandes points out that Health Canada’s safe operating requirements aim to protect the safety and quality of the cannabis product. Provincial occupational health and safety requirements supersede safe operating and GMP requirements. She explains that PSHA has a general duty clause that requires employers to take every reasonable precaution to protect their workers, even when there is no specific legislation directing specific worker protections.

Remember, when creating your safety plans and working through the Health Canada licensing process you will need to consult PSHA and provincial law in addition to Health Canada regulations. Since cannabis workplace safety is so new, you’ll benefit from checking out additional resources as well.

As the cannabis workforce increases, there is a growing need to identify the hazards present in this industry, evaluate the associations between these potential hazards and the health of cannabis workers, and to develop appropriate control strategies to mitigate those exposures.

Christopher Simpson, Occupational Health and Safety in the Cannabis Industry

How to Control Cannabis Workplace Hazards

There are three types of hazards- biological hazards, chemical hazards, and physical hazards. The first step in controlling cannabis workplace hazards is to identify all of the potential hazards that fall into these three categories.

Once the hazards of your cannabis work environment are identified, plans and procedures can be developed to keep workers safe. At a minimum, these safety plans should include the following:

• Hazard communication plan
• Hearing conservation plan
• Personal protective equipment (PPE) assessment
• Respiratory protection plan
• Chemical hygiene plan
• Lock-out/Tag-out

Chemical Hygiene Plans

One of the most important safety plans you’ll need is a chemical safety plan. You’ll need to document what chemicals you use, the quantities of them, their use, and their storage. Chemical safety and chemical hygiene are critical because they carry many risks. Not only can chemicals harm workers through skin, eye, and respiratory exposure, they can also interact in improper storage conditions and lead to explosions and fires. Chemicals require proper PPE, proper storage, controlled use, and you must keep all SDS (safety data sheets) in a binder where the chemicals are stored and where they are used/mixed.

Personal Protective Equipment (PPE)

PPE is really important in cannabis businesses. Workers need to protect their skin from contacting cannabis plants and chemicals. Captive clothing that is worn only in the workspace is recommended for personal protection and for sanitation purposes. Workers need eye protection in spaces with grow lights and where any spraying or dust is prevalent. Disposable gloves and cut-resistant gloves are needed to protect hands.

When it comes to respirators, half-face or full-face respirators are needed where chemicals are sprayed (such as pesticide application). In order to use respirators properly, your employees will need to undergo respirator fit testing by an accredited agency. Disposable surgical masks can be used by anyone to protect from general dust and debris (and should be required due to the current COVID-19 situation).

Hazard Communication Plans

Having a plan of how to communicate workplace hazards to employees is also very important. Employees need to be given regular training to make them aware of what hazards are present in their workplace. They also need to be trained on how to avoid those hazards by following safety plans and using PPE properly. Documenting safety training is also very important. If you do have an inspection from PSHA (or OSHA), you’ll need to show them that you are working hard to keep employees safe and control workplace hazards.

Final Thoughts on Cannabis Worker Safety

There are three main lessons to take away with regard to cannabis worker safety. First, learn everything you can about cannabis workplace safety laws and have a thorough understanding of the risks, hazards, and controls at your facility.

Second, use the HACCP system to eliminate as many hazards as possible. Remember that PPE is considered to be a “last resort” when it comes to the hierarchy of hazard control. You should aim to eliminate hazards first, then to control them through procedures and engineering/design.

Third, document everything! If it is not documented it does not exist (and it is not good when records are missing). Remember that safety plans need to be continually improved and employees need good training. Good documentation and good safety plans will help your cannabis business stay productive and ensure workers are safe and healthy.

Find Out More

Consult with GrowerIQ to ensure that your business has the best health and safety practices. Click the button below to get in touch with one of our experts, and find out how GrowerIQ can help your business reach its maximum potential.

References

1. Fernandes, K. 2020. Safety lessons for cannabis growers. OHS Canada.
2. Simpson, C. 2020. Occupational Health and Safety in the Cannabis Industry, Annals of Work Exposures and Health, Volume 64, Issue 7, Pages 677–678.