Safety and Health Plans for Cannabis Facilities: Occupational Safety
Guest Writer - Alex Hearding Chief Risk Management Officer at National Cannabis Risk Prevention Services (NCRPS)
Each company should have a Safety and Health Program, with employee training procedures, hazard identification and assessment, and safety and health plans/programs. This is sometimes referred to as the company’s safety manual. The manual is site-specific with the applicable OSHA standards for that workplace. This blog will identify most of the common topics in a cannabis facility safety manual.
Hazard Communication Plan (HAZCOM)
The Hazard Communication Standard requires employers to inform employees of the hazards and chemicals they are exposed to, and the protective measures available. All workplaces must have a written plan describing how the Hazard Communication Standard will be implemented in that facility. The steps for implementing an effective hazard communication plan are
- Obtain a copy of the standard from OSHA and designate an individual responsible for implementing this standard.
- Prepare and implement a written plan which includes how the facility will meet the standard for each chemical in the workplace
- Ensure ALL containers are labeled correctly. The original manufacturer's label will identify the material and contain appropriate hazard warnings. These labels must be kept and remain on the container. If the manufacturer’s labels are removed or if materials are transferred into other containers, employers must create their own labels with specific information regarding chemical hazards. Unknown substances are not allowed.
- Maintain Safety Data Sheets (SDS). SDSs have information about hazardous chemicals including, identification, hazards, first-aid, and handling and storage requirements. Manufacturers are required to provide SDSs and employers are required to provide them and provide easy access to them.
- Inform and train employees in the hazardous chemicals before their initial assignment, and whenever new hazards are introduced. Employees must understand SDSs and labeling.
- Evaluate and assess your program. These plans must remain current so periodically reassess the program to make sure it meets objectives, new hazardous chemicals have been added, and employees are aware of the changes.
Emergency Action Plan (EAP)
An Emergency Action Plan spells out what should happen at a specific workplace during an emergency, per OSHA (1910.38). The minimum elements of a written emergency plan include:
Procedures for reporting a fire or other emergencies
- Procedures and exit routes for emergency evacuation
- Procedures to be followed by employees who remains to operate critical plant operations before they evacuate
- Procedures to account for all employees to obtain more information about the plan.
- Explanation on how the company will notify employees in case of an emergency.
Fire is the primary emergency planned for, but facilities should also consider preparing for natural disasters and live-active shooter scenarios. First-aid plans can stand on their own or be included in the EAP.
- Each shift should have a first-aid trained employee who can perform CPR and operate an AED.
- The facility should have a first aid kit that meets minimum standards of ANZI Z308.1-2015.
- Employers should provide automated external defibrillator (AED) and have eye wash stations.
- All employees should be aware of universal precautions for exposure of blood or bodily fluids and designated first-aid workers should be able to mitigate the risks of bloodborne pathogens.
Pesticide Application Program
This program should defer to the Worker Protection Standards and their State’s pesticide application rules, including
- WPS training for Agricultural Workers and Pesticide Handlers before they operate in a cultivation.
- A list of all pesticides and their SDSs.
- Proper PPE training, storage, and maintenance, including a Respiratory Protection Program.
- Proper pesticide storage in a lockable cabinet placed on a solid surface
- Spill clean-up operations and material
- Decontamination procedures
- Extra clothes if needed for applicators
- Proper response to pesticide exposure
- Right-to-know information and/or posters required by WPS
- Compliance requirements for Return Entry Intervals (REI)
- Emergency procedures
- Pesticide application reporting requirements: date, time, applicator’s name, badge and/or license, plants or area applied with pesticide, EPA-registration number and REI
Respiratory Protection Program
OSHA requires a written respiratory protection program with worksite specific procedures for workplaces where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer.. It must detail worksite-specific tasks and hazards for which respirator use is required and must be updated if there are changes in workplace conditions that affect respirator use. There must be a designated program administrator suitably trained to administer the program.
OSHA notes the following components may be necessary for a written program:
- Procedures for selecting respirators
- Medical evaluations of employees required to use a respirators
- Fit testing procedures
- Procedures for proper use of respirators in emergency situations
- Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and/or maintaining respirators
- Special requirements for atmosphere-supplying respirators
- Training in potential respiratory hazards
- Updating program for changes in workplace, i.e. new chemicals, different processes
While not required, a log should be used to determine duration of use and need for disposal and cartridge replacement if using a cartridge without an end-of-life indicator.
Lockout/Tagout or Energy Control Program
Lockout/Tagout refers to specific practices and procedures to safeguard employees from unexpected energization from machinery and equipment or the release of hazardous energy during service or maintenance activities. The program should include procedures that establish energy control, procedure for removing the energy supply from machines and the use of appropriate lockout or tagout devices to prevent unexpected re-energization. This program must outline
- How to implement the procedures
- How to shut down, isolate, block, and secure machines
- Specific steps for safe placement, removal, and transfer of lockout/tagout devices
- Naming who has responsibility for the lockout/tagout devices
- Specific testing requirements for the effectiveness of the lockout devices, tagout devices, and other energy-control devices
- Inspection procedures (at least annually) for effectiveness
The employer must provide training before starting service and maintenance activities, and retraining as necessary. In addition, the employers must certify the training has been given to all employees covered by the standard.
Hearing Conservation Plan
OSHA has set an action level of 85 decibels (dBA) as a time-weighted average (TWA). When workers are exposed to noise levels at or above that level, employers are required to implement a hearing conservation program. Examples of high noise levels in cannabis facilities are power tools, woodchippers, landscaping equipment, heavy machinery, and extraction equipment.
The best solution, as always, is to eliminate hazards and then to engineer solutions. An effective hearing conservation program can prevent hearing loss, improve employee morale, promote a general feeling of well-being, increase the quality of production, and reduce the incidence of stress-related diseases. The steps to implement a successful plan are:
- Employers must monitor noise exposure to noise at or above 85 dBA TWA and repeat monitoring when noise exposures increase or more employees are affected.
- Employers must provide hearing protection devices to all workers exposed to the actionable noise level and exposed employees must wear hearing protectors.
- Employers must provide a choice of at least one hearing plug and one muff. Employees should choose which size and type protector is best for comfort and protection.
- Employers must train affected employees at least annually: on the effects of noise, hearing protection, and audiometric testing.
- Employees who are a part of a hearing conservation program should be tested both at hire and annually to determine if they have experienced any hearing loss. Audiometric tests must be performed by a licensed professional, within six months of the employee’s first exposure above the actionable level.
- Employers must retain data on exposure measurements for at least two years, and audiometric test results must be maintained for the duration of the employee's employment.
Fire Prevention Plan (FPP)
A fire prevention plan must be written, kept in the workplace, and made available to employees for review. An employer with ten or fewer employees may communicate the plan orally. Local municipalities may have different guidelines for marijuana facilities. At minimum, the fire prevention plan must include:
- A list of all major fire hazards
- Proper handling and storage procedures for hazardous/flammable materials
- Potential ignition sources
- Protection equipment necessary to control each major hazard
- Procedures to control the amount of flammable and combustible material stored in the facility
- Procedures for regular maintenance of safeguards on potential ignition sources
- Name of employee maintains fire prevention equipment
- Name of employee operates fire control equipment
- Anything necessary for an employee’s self-protection
- Procedures for clean-up and removal of combustible material
The PPE standard prescribes a hazard assessment for the entire workplace and each individual job or task. If a process or work practice changes the employer should re-evaluate PPE needs to determine if the existing PPE program remains suitable and protective for employees. The steps in a PPE Assessment are:
- Assessing the workplace for hazards
- Implementing engineering and administrative controls to control or eliminate or minimize these hazards Selecting appropriate PPE for hazards that cannot be eliminated or controlled through engineering and work practices
- Informing employees why the PPE is necessary and when it must be worn
- Informing employees of proper use, the limitations, and how to care for, maintain, clean, and dispose of the PPE.
- Demonstrating understanding of the program by employees
Permit-Required Confined Space Program
OSHA uses the term "permit-required confined space" (permit space) to describe a confined space as one that
- Contains or has the potential to contain a hazardous atmosphere
- Contains material that has the potential to engulf an entrant
- Has walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant
- Contains any other recognized safety or health hazard, such as unguarded machinery, exposed live wires, or heat stress
One example of such a space is a water storage tank that must be entered to perform cleaning tasks using chemical cleaners. Another example would be a storm sewer. If an employer determines his/her workplace has a permit required for a confined space, then the employer must inform employees of its existence, location, and hazards. This can be done by placing danger signs such as 'DANGER – PERMIT REQUIRED CONFINED SPACE – AUTHORIZED ENTRANTS ONLY.’ Facilities can transfer the risk of entering such a space by hiring a qualified third party or adhere to OSHA’s extensive standards and requirements found here.
Fall Protection Program
Falls from portable ladders (step, straight, combination and extension) are one of the leading causes of occupational fatalities and injuries. There are a number of ways employers can protect workers from falls, including conventional means such as
- Safety nets
- Personal fall protection
- Safe work practices and appropriate training
Think pro-actively! Whether conducting a hazard assessment or developing a comprehensive fall protection plan, thinking about fall hazards before the work begins will help the employer manage fall hazards and focus attention on prevention efforts.
If personal fall protection systems are used, particular attention should be paid to identifying attachment points and ensuring employees know how to properly use and inspect the equipment. These programs should be designed for individual facilities. You can find an OSHA sample fall protection plan here. This is not a complete list of safety plans but they are the ones most commonly found and useful in cannabis facilities.
Take the time to do a proper hazard identification and assessment of your facility before you decide which safety plans are applicable, and visit osha.gov for more safety plan specifics. For further hazard identification and assessment support, visit NCRPS.com.
ICS Consulting specializes in Compliance based services, such as Third-Party State Regulatory Audits, State and Local License Application Support, Technical Writing, Standard Operating Procedures Development, Compliance Operations Training, Employee Retention Solutions, and Employee Onboarding. For more information on how ICS Consulting Service can help your Cannabis Business, book a free 30-minute consult and we'll help you map out your next steps to be successful in the Regulated Cannabis Industry.