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Cannabis Industry Health & Safety Compliance Solutions
RHP offers occupational health and safety consulting services to both start up and existing cannabis businesses (lab, retail, grow facilities). RHP’s Board-Certified Industrial Hygienists (CIHs) and Safety Professionals (CSPs) can provide solutions for solving your health and safety needs, including cannabis worker safety, auditing, design and implementing custom OSHA required health and safety program & training, assessments of occupational exposures, air monitoring, ventilation assessments, and cannabis lab and processing chemical management and waste assessments.
RHP professionals have extensive experience in developing, modifying, and auditing OSHA compliant programs specifically designed for the cannabis industry. RHP partners with our clients to keep them up to date with the changing regulatory environment (local, state and federal), and as a resource to maintain compliance and effectiveness with difficult-to-maintain programs such as LOTO, Respiratory Protection, and Hearing Conservation. Further, RHP can customize and help implement site-specific programs and training for topics such as HazCom, LOTO, electrical safety, and walking/working surfaces for your workplace.
Our Cannabis Health and Safety Consulting Services
RHP’s Board-Certified Industrial Hygienists (CIHs) and Safety Professionals (CSPs) can provide solutions for solving your health and safety needs. Below is a list and description of specialized occupational health and safety services in the cannabis industry that RHP can provide:
Indoor Air Quality Assessments
RHP professionals perform indoor air quality assessments to better understand the quality of air that is present in a cannabis cultivation and processing facility. OSHA requires employers to know what chemicals and the concentrations of these chemicals that employees may be exposed to in a work environment. This information is important for understanding if additional ventilation equipment is needed, or if employees need to wear respiratory protection for certain tasks. Additionally, mold and other contaminates can cause devastating damage to crops and significant losses of revenue if left unchecked.
RHP professionals perform ventilation assessments to determine if a ventilation system is operating effectively in removing contaminated air and replacing that air with clean air. RHP professionals perform ventilation assessments of laboratory fume hoods, extraction booth ventilation, gas cabinet ventilation, and general exhaust ventilation to determine if the systems are operating as designed and are performing effectively in removing contaminates from the air.
RHP professionals perform hazard assessments of cannabis industry processes in order to identify potential hazards and look at ways to control hazards and reduce risk for cannabis employees.
RHP professionals can help your business develop a hazard communication plan, evaluate and audit your plan, and assist in training your employees so that your business is OSHA compliant when it comes to hazard communication. Failure to have a compliant Hazard Communication plan in place can result in costly OSHA violations that are completely avoidable.
RHP professionals can help your business fully understand your respiratory protection needs to protect against potential workplace airborne hazards, shielding against particulates and chemical vapors. RHP professionals can help navigate the extensive OSHA respiratory protection regulations so your company is fully compliant and offering the best protection for your workers.
Personal Protective Equipment
RHP professionals perform assessments for the need of personal protective equipment for the different cannabis processes and can help you choose the proper type of PPE. RHP professionals can also design and draft your OSHA compliant PPE program and training.
Electrical Safety & Lock-Out/Tag-Out (LOTO)
Cannabis cultivation and processing facilities utilize large scale ventilation systems, water and nutrient delivery systems, lighting systems, and extraction systems that utilize vast amounts of energy. OSHA compliant LOTO programs are difficult to design and implement. RHP professionals can review your specific LOTO needs and develop equipment specific procedures, training, and draft your OSHA compliant program.
Confined Space Identification & Training
OSHA regulations regarding confined spaces are often difficult to fully understand. What is a confined space? What are permit required confined spaces? RHP professionals can help you identify if you have confined spaces and if would be classified as permit required. RHP professionals can then develop specify entry procedures and draft your OSHA compliant program and training.
Illness & Injury Notification & Reporting
OSHA requires employers to document workplace illnesses and injuries, and in some cases, report major illnesses and injuries in a time sensitive manor. Additionally, OSHA requires employers to maintain certain records for years. RHP professionals can help you draft an OSHA compliant program and to help you better understand what records must be maintained and for how long.
Emergency Response/Fire Prevention Program
RHP professionals can help you audit your current emergency response/fire prevention plan or draft a custom plan for your new business. ERP/FPP are extremely important for all businesses so occupant know what to do during an emergency. These programs can mean the difference between life and death.
Pandemic Plan and Processes (COVID-19) — COVID-19 has added another set of hazards for all employers and employees. OSHA requires employers to develop a pandemic plan that addresses procedures for mitigating COVID risks and safe work practices. RHP professionals have been working extensively during the pandemic to research current scientific knowledge available concerning COVID safe work practices and process needed to keep your employees safe during these difficult times.
Hazardous Material Handling
RHP professionals can audit current work practices and procedures related to the handling, storage, and waste of hazardous materials and help you understand the hazards, risks associated with the hazards, areas of non-compliance, and solutions to better create a safer, regulatory compliant workplace.
Hiring Experienced and Knowledgeable Consultants
RHP professionals partner with employers in the cannabis industry to develop programs, training and S&H needs that are unique to the business and location to protect employees and comply with H&S regulations. Thinking about and initiating a strong, comprehensive and compliant H&S program during your planning and construction stages can save time, effort and expense later when controls may be determined to be needed. H&S programs and procedures should be included in your SOPs and all employers should be aware that H&S is as important to healthy and sustainable working environments as the security systems typically required under state application processes.
Benefits of Our Consulting Services
Health & Safety professionals like the CIHs and Certified Safety Professionals (CSPs) at RHP have the experience and knowledge to navigate all of the H&S regulations. Compliance will lead to a happier, healthier, more safe work environment and help mitigate risks and liabilities.
Occupational Hazards in the Cannabis Industry
The cannabis/CBD/hemp marketplace is expanding exponentially in states that allow the sale of medical, adult recreational and CBD. With the speed and intensity within this huge marketplace for new entry and expansion coupled with the fact that cannabis markets are isolated within each state due to federal prohibition, the pre-pandemic employment has been estimated over 200,000 cannabis workers.
Cannabis businesses range in size from small, local operations to large multistate corporations. With the momentum at which the cannabis industry is developing, it is not uncommon for a small operating business with only a handful of employees to expand to over a hundred employees in just a calendar year.
Employers have a duty, both legally and ethically, to provide a healthy and safe work environment, and the cannabis industry is no different, regardless of the federal legality posture.
At RHP, we understand the unique hazards and risks that come with the growing, processing, extraction and distribution that makes up the cannabis market. And further understand that the issues the cannabis industry faces with health and safety (H&S) compliance are no different than any other business. Under both federal and state OSHA, a company designee holds the responsibility for implementing and maintaining H&S programs and procedures.
Based upon RHP’s experience, the working H&S and OSHA compliance issues related to safety in the cannabis industry include:
(1) A lacking or absence of OSHA required programs and employee training.
(2) The use of and storage of flammable and irritating chemicals.
(3) A lack of employee occupational exposure data and record keeping; and
(4) Improper fit, training and use of respirators.
Occupational Exposure Risks for Cannabis Workers
OSHA Required Programs & Employee Training
OSHA requires that all businesses develop and implement certain H&S programs, depending on the nature and the hazards both general and unique to that business. For cannabis businesses, these include: Illness & Injury Prevention and OSHA Recordkeeping, Emergency Response/Fire Prevention, Electrical Safety and Control of Hazardous Energy (LOTO), Confined Spaces, Hazard Communication, Laboratory Chemical Hygiene, Respiratory Protection, and Personal Protective Equipment (PPE).
Employees should be trained to respond to emergencies efficiently and effectively, to know and understand the hazards (both chemical and physical) they may be exposed to, how to handle and dispose of the chemicals used by or stored the business, and the selection of proper personal protective equipment (PPE) for their respective work. Employees who wear respiratory protection must be trained on the proper use, inspection, storage, and care of their respirators. Maintenance staff should have a basic understanding of electrical safety, including lock out tag out (LOTO), hazardous materials and confined space training.
All training information and program specific requirements are spelled out in an OSHA compliant, written program, and as one program “does not fit all”, it is important that programs be specific to your business and location of operation.
Use of Flammable and Irritating Chemicals
Within cannabis grow, cultivation, and processing facilities, the wide-spread use of and storage of flammable and irritating chemicals is very common. Cleaning and extraction processes commonly include flammable organic solvents such as ethanol, isopropyl alcohol and acetone and flammable gases – butane and propane. The improper use and inadequate ventilation of such substances could lead to workplace injury and life-threatening fires and explosions.
Additionally, irritating chemicals containing bleach or peracetic acid solutions may be on hand and used for cleaning and disinfecting surfaces and cleaning rooms after cultivation to prevent microbial growth. These chemicals may cause adverse responses such as difficulty breathing and skin and eye irritation and damage.
Employee Occupational Exposure Data
OSHA has established Permissible Exposure Limits (PELs) for nearly 500 chemicals. The definition of an OSHA PEL is an 8-hour Time Weighted Average (TWA) concentration that represents the highest level of occupational exposure an employee may be exposed to without incurring the risk of adverse health effects. Most PELs were established shortly after OSHA was adopted as law in 1970, and have not been updated, updates require legislative approval. Therefore, PELs may be found to be outdated and not adequate protection, however as the prevailing law and employers are required to protect employees from exposure exceeding these limits. In order to control employee exposure risk to a level below PELs, an employer must understand (1) what chemical or physical hazard their employees may be exposed to; and (2) what concentrations or levels of these chemical and physical hazards employees may be exposed to. Although there are occupational exposure data resources which may provide insight for prioritization and decision making on of controls it is important to have your business evaluated and audited by a trained and knowledgeable safety and health professional, a certified industrial hygienist.
RHP Certified Industrial Hygienists (CIHs) are professionals who carry extensive training and experience in conducting exposure monitoring and exposure assessments, including personal employee exposure monitoring. The exposure monitoring data from both area and breathing zone of an employee can be used to compare with PELs or other occupational exposure limits (OELs) to determine compliance and risks and may be informational in effectiveness or ineffectiveness of controls such as ventilation. Once the CIH has inspected the site, collected the samples, and evaluated, the data can the occupational exposures risk be completely understood and precise decisions may be made regarding controls, manipulation of controls or other mitigation measures to provide a safe workspace.
Use of Respirators in the Cannabis Industry
From RHP’s experience, the reasoning behind cannabis workers wearing respirators fall into four categories:
(1) the employer has done occupational exposure monitoring and results have demonstrated the need to use respirators to protect a cannabis worker to concentrations above PELs or other OELs;
(2) The employer has done occupational exposure monitoring and results indicate respirators are not needed; however, the cannabis worker still wants to voluntarily use the respirator for comfort or ease of mind.
(3) No occupational exposure monitoring has taken place but the employer and maybe cannabis workers believe they should be wearing a respirator and the employer just hands them out.
(4) No occupational exposure monitoring results and the cannabis worker brings in their own because he feels he needs to wear something for ease of mind and maybe comfort. The first two scenarios are the only proper and legal scenarios that any cannabis worker should wear a respirator. Respirators should never be handed out without knowing if they are required or voluntary; thus, occupational exposure monitoring.
Additionally, cannabis workers must be medically cleared to wear a tight-fitting respirator; and, all tight-fitting respirators need to be fit-tested on the cannabis worker annually. Also, employers must have an OSHA compliant, written Respiratory Protection Program with employee training, both voluntary use and required use.
Learn More About Our Health and Safety Services for Cannabis Facilities
Contact RHP for an initial consultation and learn more about our professional services.
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