PDF Guide to Worker Safety and Health in the Marijuana Industry

Guide to Worker Safety and Health in the Marijuana Industry

Marijuana Occupational Health and Safety Work Group January 2017

cdphe/marijuana-occupational-safety-health

Guide to Worker Safety and Health in the Marijuana Industry: 2017

About this guide

This guide is intended to help assist employers in the marijuana industry build occupational safety and health programs. While the foundation of this guide includes existing Colorado state and federal regulations, it is not a comprehensive guide to all of the regulations pertaining to occupational safety and health. It should be noted that this guide does not present any new occupational safety and health regulations for the marijuana industry. Marijuana cultivators, extractors, labs and retailers are required to adhere to all regulations established by the Colorado Department of Revenue's Marijuana Enforcement Division (MED) . The marijuana industry in Colorado falls under federal OSHA jurisdiction and businesses must comply with OSHA regulations and recordkeeping requirements. In addition to OSHA regulations, marijuana businesses are required to comply with other state regulations including Colorado labor laws, Colorado workers' compensation laws, Colorado hazardous waste laws, Colorado Pesticide Applicator's Act, local fire codes, and other regulations that are specific to employment and labor as well as the production of retail and medical marijuana.

Guide to Worker Safety and Health in the Marijuana Industry: 2017

About the Colorado Marijuana Occupational Health and Safety Work Group

The Colorado Marijuana Occupational Health and Safety Work Group is a multidisciplinary group that was convened to draw on expertise and experiences of many professionals in the Colorado community. The committee included professionals with a variety of skill sets, including epidemiologists, medical doctors, industrial hygienists, safety professionals, and regulatory specialists, which resulted in a thorough review of the potential occupational safety and health issues in the industry. The larger committee had several subcommittees that contributed to the production of this document. As the committee continues to meet, it is the intention that this guide will continue to grow to add information on how the industry can continue to address safety and health issues. We would like to thank the following people and their respective organizations for their participation in the Colorado Marijuana Occupational Health and Safety Work Group:

Associates in Occupational and Environmental Health, LLC Cynthia Ellwood, Ph.D., CIH, FAIHA

Boulder County Department of Public Health

Bill Hayes Mike Richen, CIH Ambra Sutherlin

Center for Health, Work & Environment, Colorado School of Public Health, University of Colorado Anschutz Medical Campus

Lee Newman, MD, MA Liliana Tenney, MPH

C&IH Ventilation Engineering Bill Mele, CIEC

Colorado Department of Public Health and Environment Dara Burris, MPH Mike Van Dyke, Ph.D.,CIH Roberta Smith, RN, MSPH, CIH Shannon Barbare Chris Lane Megan Snow, MS, CHES Elyse Contreras, MPH Edward Smith Meredith Towle, MPH

City of Aurora Dave Jeary, MS, CSP

City of Longmont Michelle Cogswell

Guide to Worker Safety and Health in the Marijuana Industry: 2017

Colorado Department of Agriculture Mike Rigirozzi Laura Quakenbush, Ph.D. John Scott

Colorado State University Gwenith Fisher, Ph.D Joshua Schaeffer, Ph.D, MS Kevin Walters, MS

Colorado State University- OSHA Consultation Program Casey Barnes, MS, CSP Del Sandfort, CIH Layne Sargent, MS, CIH

Denver Environmental Health Emily Backus Janet Burgesser Kirk Whitehead

Good Chemistry

Laura Davis

Green Hygiene, LLC

Sarah Kaiman, CIH, CHMM

Integrated Occupational Health and SafetyDoug Herrick, CIH, CSP

Jeff Pothast & Associates INC. Jeff Pothast, CIH

Marijuana Industry Group

National Jewish Health Lisa Barker, CCRC, MPH Alison Welch, MS

NIOSH Western States Office Elizabeth Dalsey Max Kiefer, MS, CIH Bradley King, Ph.D., MPH, CIH

The OSHA Connection, LLC Jolene Donahue, CSHS, OT

Pinnacol Assurance Allison Hoskins, AINS

Guide to Worker Safety and Health in the Marijuana Industry: 2017

TriCounty Health Department Michele Kinshella, MS, CIH

University of Colorado- Department of Environmental & Occupational Health John Adgate, Ph.D., MSPH

University of Colorado- Occupational Health Residency Brian Williams, MD

University of Colorado Denver Marty Ota?ez, Ph.D.,

Contributing Authors

Elyse Contreras, Laura Davis, Jolene Donahue, Mike Elliott, Cynthia Ellwood, Allison Hoskins, Bradley S. King, Michele R. Kinshella, Chris Lane, Marty Ota?ez, Layne Sargent, Joshua Schaeffer, John Scott, Roberta Smith, Alison Welch, and Mike Van Dyke.

Guide to Worker Safety and Health in the Marijuana Industry: 2017

Executive Summary

Executive Summary

At the time of this writing, 28 states and the District of Columbia currently have laws legalizing marijuana in some form. While many studies have focused on health outcomes and public safety issues, little attention has been focused on occupational safety and health associated with this industry. Prior to its legalization, occupational safety and health hazards associated with producing illegal marijuana were documented in published literature and law enforcement reports.1 Washington was the first state to develop formal guidance for the industry, such as the Regulatory Guidance for Licensed I-502 Cannabis Operations (). Our workgroup sought to identify various types of occupational hazards encountered in this industry and build a document to assist the industry and its workforce in building effective safety and health programs for their businesses. Our team included professionals with a variety of skill sets, including epidemiologists, medical doctors, industrial hygienists, safety professionals, and regulatory specialists, which resulted in a thorough review of the potential occupational safety and health issues in the industry. The State of Colorado Marijuana Enforcement Division's (MED) Retail Marijuana Code, 1 CCR 212-1 and CCR 212-2, have specific regulations written for the marijuana industry in Colorado. This document is informational only and is not intended to replace or supplement regulations from Colorado's MED Retail Marijuana Code or from the U.S. Occupational Safety and Health Administration (OSHA). The best practices in this document are suggestions and do not establish any new enforceable regulations by the State of Colorado. Furthermore, this guide is not intended to provide a comprehensive list of existing federal, state, and local regulations that may apply to the marijuana industry.

Purpose, scope, and users of the guide

The complicated nature of the hazards present in the marijuana industry highlights the need for careful attention to safety and health at all types of marijuana businesses. The purpose of this guide is to provide an overview of the safety and health hazards that may be present in the cultivation, processing and sale of marijuana. Not all hazards listed in this guide may be present at a given facility. Conversely, there may be additional hazards not listed within the scope of this guide that may be present at a given facility. This guide is intended to provide a starting point for the assessment and evaluation of occupational health hazards. This guide also provides abbreviated guidance and a list of resources to help employers in the marijuana industry develop an occupational health and program.

Guide objectives

The objectives of this guide are to:

Assist in the recognition of occupational health hazards that might be present within the marijuana industry.

Identify specific existing federal, state, and local safety and health related regulations that may apply to the marijuana industry.

Provide initial recommendations for engineering, administrative and personal protective equipment controls that can be used to help eliminate or reduce hazards in the marijuana industry.

Provide information and resources to assist employers in developing written workplace safety and health programs.

Provide information to help develop marijuana worker safety training programs.

1 Martyny JW, S. K. (2013). Potential Exposures Associated with Indoor Marijuana Growing Operations. Journal of Occupational and Environmental Hygiene , 622-639.

Guide to Worker Safety and Health in the Marijuana Industry: 2017

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Executive Summary

Guide roadmap

Part 1 of the guide begins with the initial steps that can be performed to establish a safety and health program within a facility. Given this initial background in Part 1, Part 2 provides more detail in two separate sections.

Section I Outlines the hazards for the industry by category (biological, chemical, and physical). For each hazard a general description is given followed by: o Information on the job role that might be specifically affected by the hazard o Considerations for a hazard assessment o Best practices for eliminating or managing the hazard o Federal, state, or local regulations that may apply to that hazard o Additional resources to assist in hazard recognition and management.

Section II Outlines broader safety and health programs that should be implemented within the industry and provides examples and tools to help develop these programs. The programs in Section II are broader programs (e.g. hazard communication and hearing conservation) in which, if needed, have a written plan component that is required for compliance.

The final appendix that is included in this guide includes a table of OSHA regulations that may be applicable to the marijuana industry.

Guide to Worker Safety and Health in the Marijuana Industry: 2017

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