As of May 2019, the District of Columbia, Puerto Rico, Guam, the US Virgin Islands and 34 states have legalized marijuana under state law, typically for medical reasons and/or recreational use. There are 12 other states that have decriminalized certain levels of possession. South Dakota, Nebraska, Kansas and Idaho are the four remaining states that do not have any type of public marijuana access program.[i]
As the legalization of and demand for cannabis and cannabidiol (CBD) products increases, cannabis farming, nutraceutical production and the retail industry associated with hemp and other forms of cannabis goods also continues to grow.[ii] As a result, the cannabis industry is estimated to now support 125,000 to 160,000 workers throughout the United States.[iii] That is a lot of workers, exposed to a wide range of hazards associated with growing, harvesting, extracting, processing and selling all types of cannabis, hemp and CBD products, who may need personal protective equipment (PPE).
For instance, there have already been reported incidents involving fires from trying to extract CBD oil from plants.[iv] Inspections of facilities always bring the potential for fines and other sanctions – for example, there have been reports of state OSHA citations due to lack of adequate communication of hazards, respiratory protection violations as well as the absence of eyewash or safety shower stations where employees may be exposed to corrosive or injurious materials.
Certain states, such as Oregon, Washington and Colorado, are trailblazers when it comes to trying to monitor marijuana grow operations (MGO) and cite them for health and safety violations when appropriate. These states are also providing detailed public guidance on how companies can help protect their workers. The following summary relating to hazards that may arise while doing business as an MGO comes from Washington’s Department of Labor & Industries and Colorado’s Department of Public Health and Environment (full document located at: https://www.colorado.gov/pacific/cdphe/marijuana-occupational-safety-and-health).[vi] Please note, the reader should always consult and follow all applicable worker health and safety regulations.
While safety and health risks continue to evolve as operations become more advanced from when MGOs first started to really take root legally throughout the US, here are some of the most common hazards that the Washington state and Colorado agencies point to for workers in this industry:
- Biological hazards: mold exposures for indoor growing operations caused by improper ventilation, as well as dermal exposure to sensitizers or allergens while handling plant buds, including exposure to THC
- Chemical hazards: pesticides, fertilizers, nutrients exposure for maximizing plant growth; excessive carbon dioxide (CO2) exposure in greenhouses being used to optimize growing environments; accidental carbon monoxide (CO) and exposure from CO2 producing devices; disinfectant/cleaning chemical agents or corrosive chemicals that may be used to keep a facility clean
- Physical hazards: flammable, combustible liquids, compressed gas for facility power and CBD extraction; excessive ultraviolet (UV) exposure from grow lamps; walking/working surface risks; forklift incidents; confined space work; working at heights; noise
- Occupational injuries: electrical shocks from poor wiring; cuts, pinches, and ergonomic injuries; sprains from harvesting or processing operations; noise; workplace violence; machine and hand tool usage; extraction equipment dangers
Because of this wide variety of potential hazards, compliance with state OSHA standards requires continual oversight, planning, review and training, in addition to a comprehensive company safety program.
Hazard Communication Requirements
MGO’s must have a hazard communication plan that is in accordance with OSHA standard CFR 1910.1200 Subpart Z. Employees must be properly trained on the company’s specific program. Any employee who may come in contact with any hazardous materials at the workplace must be given proper training to do his or her job safely and must have access to information about the hazardous materials in the form of clearly posted Safety Data Sheets (SDS).
This also includes keeping careful inventory of all materials that come through and are used in the dispensary or processing facility, ensuring they are clearly and properly labeled. Businesses must be vigilant and continually modify or update their policies, procedures as well as what protective equipment they offer to employees because of changing workplace conditions and needs.
Personal Protective Equipment Suggestions for Marijuana Growth Operations
The following PPE suggestions are based on the Colorado Department of Public Health and the Environment’s comprehensive “Guide to Worker Health and Safety in the Marijuana Industry” and related federal OSHA standards.[vii] These PPE recommendations also serve as an expansion on the initial guidance provided in this previous blog. MGO’s should consult with food and beverage industry specialists for help selecting the right PPE for their company’s workers.
Note: As with all PPE selections, it remains the responsibility of the employer to conduct a full hazard assessment and to select the appropriate PPE needed to address the hazards present.
First, MGO’s should make sure that proper ventilation and gas detection is in place and being maintained to avoid overexposure to hazardous gases such as CO, CO2, and NOx. Respiratory protection may also be required during normal growing operations to help reduce exposures to mold, dusts, pesticides, cleaning agents or other chemicals being used onsite. Respiratory selection and use should be based on results of air monitoring, in compliance with the assigned protection factors (APFs) outlined in the US OSHA Respiratory Protection Standard 29 CFR 1910.134, state or local pesticide application regulations, and pesticide manufacturers’ recommendations.
Based on the exposure assessment, an N95 or higher rated disposable respirator, or half facepiece or full facepiece respirator with a combination organic vapor cartridge/P100 filter or organic vapor cartridge with N95 prefilter, may provide appropriate protection. Half facepiece respirators have an APF of 10. Full facepiece respirators, when quantitatively fit tested, have an APF of 50. If workers need to use respiratory protection for a prolonged period of time or they have limited facial hair, they may want to consider a powered air purifying respirator (PAPR) with headgear and blower that circulates fresh air. State and local pesticide regulatory agencies should be consulted for any additional respirator selection requirements based on the pesticide to be used.
Per US OSHA regulations, a site-specific cartridge change-out schedule may need to be developed. Respirators must always be used in accordance with all procedures, cautions, and limitations specified in the respirator manufacturer’s User Instructions in order to receive the assigned level of protection. Per OSHA 29 CFR 1910.134, OSHA requires employers to implement a written respiratory protection program meeting all the requirements of the standard when respirators are used. A health and safety professional should be consulted if there is any question regarding respirator selection and use. Misuse of the respirator may result in sickness or death.
Skin contact must be prevented during cutting and harvesting operations to reduce the risk of dermal exposure to THC, pesticides and fertilizers. Protective coveralls, lab coats, aprons, footwear, and especially gloves should be considered during cutting and harvesting operations, and during the application of pesticides or fertilizing chemicals. Refer to coverall, glove, and pesticide manufacturers recommendations for specific products. In outdoor operations, the potential for increased risk of heat stress should be considered when selecting worker protective clothing, Likewise, protection selection should take into account UV light and heat for indoor/greenhouse operations as well.
Eye and Face Protection
Eyes must also be protected from contact with THC, pesticides and chemicals. Some operations may also result in flying debris and projectiles from the harvesting and processing aspects at the MGO. Employers should consider the need for eyewear, combination eyewear and face shield, or a full facepiece respirator.
If not required to wear a full facepiece respirator for pesticide spraying, indirect venting goggles meeting the ANSI Z87.1 D3 Splash/Droplet rating are recommended. Where flying debris is possible, OSHA requires eye and face protection meeting the impact rating in ANSI Z87.1-1989 or later. Consult the ANSI Z87.1-2015 selection guide for more information.[viii] Some exposures may require a combination of face shield and spectacle or goggle.
Lamps used in indoor growing operations may overexpose workers to UV. Ensure that the eyewear selected is rated for the expected light spectrum of the lamp.[ix]
Chippers, moving equipment, compressors and conveyors are examples of equipment that may result in overexposures to noise. If workers will be exposed to a time-weighted average (TWA) noise level of 85dBA or higher over an 8-hour shift, OSHA 29 CFR 1910.95 requires a written hearing conservation program be a part of the company’s safety program. Per OSHA 29 CFR 1910.95, employers must provide a variety of suitable hearing protectors which may include in-ear and over-the-ear protection. Employers must also provide training and ensure initial proper fit.
The EPA specifies the Noise Reduction Rating (NRR) as the measure of hearing protector noise reduction, and 3M strongly recommends the fit testing of hearing protectors to validate expected levels of protection. Research suggests that many users will receive less noise reduction than indicated by the NRR due to variation in hearing protector fit, hearing protector fitting skill and motivation of the user. It is recommended that the NRR be reduced by 50% to better estimate typical workplace protection. A recent OSHA interpretation states that fit testing may be used to help fulfill the initial proper fit and training requirements of the standard.[x]
To read more about protecting the workforce in the cannabis industry, please check out this piece and download our handy infographic. We also invite you to consult with our food and beverage technical safety specialists for help with how to select the right PPE for your workers.
[vi] Lni.wa.gov. (2019). Cannabis Industry Safety & Health (Marijuana). [online] Available at: http://www.lni.wa.gov/Safety/Topics/Industries/Marijuana/default.asp and https://www.colorado.gov/pacific/cdphe/marijuana-occupational-safety-and-health
[viii] American National Standards Institute (2015). Eye and Face Protection Selection Tool. International Safety Equipment Association, pp.1-3. https://safetyequipment.org/wp-content/uploads/2015/06/Eye-and-Face-Selection-Guide-tool1.pdf