During cannabis cultivation and extraction, employees may be subject to chemical exposure from fertilizers, wetting agents, insecticides and herbicides. Not to mention the additional hazards from gasoline, diesel fuel, propane, butane, isopropyl alcohol, aerosol spray cans and more.
These chemical substances can pose a threat to the environment and/or the personal health of employees if unintentionally released or misused. Therefore, the OSHA Hazard Communications Standard (HCS) (29 CFR 1910.1200), or HAZCOM for short, should be the basis for all cannabis business training programs.
OSHA's HCS promotes chemical safety in the workplace by mandating that cannabis businesses make information about the identities and hazards of the chemicals available and understandable to workers. HCS requires the development and dissemination of such information.
The key elements to the HAZCOM standard include:
- Safety Data Sheets. A Safety Data Sheet (SDS) is a document created by each chemical manufacturer, listing its characteristics and attributes. There are 16 sections to every SDS, including first aid and firefighting measures. If your SDS does not have 16 sections, it is out of date and needs to be updated as soon as possible. Every business must maintain an SDS for all current and former chemicals on site. Most businesses keep a binder of safety data sheets near their production location. SDSs may be kept electronically and all employees must have unrestricted access to them. An employee must be assigned the task of maintaining the SDS database or binder.
- Training. Hazard training is critical and required under the HAZCOM standard. Once employees understand what hazards they face, they can then be taught how to protect themselves and what personal protective equipment (PPE) to use. All employees must understand how to read an SDS and understand the Globally Harmonized System (GHS) for the classification of chemicals. Training should begin during employee onboarding so that new employees are aware of all potential hazards before they have a chance to harm themselves. Hazard training should continue annually, thereafter. When creating training plans, remember to consult your state OSHA plan as well as any additional local municipal rules.
- Globally Harmonized System or Labeling. The Globally Harmonized System (GHS) was created by the United Nations for the unified classification and labeling of chemicals and has been in effect since 2017. The most noticeable change is the addition of pictograms to communicate hazards. The pictograms are universal and intended to be self-explanatory. Along with the pictogram, there are “signal words,” precautionary and hazard statements as well as manufacturer information. All employees using chemicals need to know how to understand the pictograms and warning statements.
- Chemical Labeling. A written Hazard Communication Program (HCP) is a requirement. The written document must detail how the company will achieve all the requirements of OSHA’s HAZCOM standard. An inventory of all chemicals on site should be listed alphabetically and kept in the front of the SDS three-ring binder, making locating the SDS more efficient.
Meeting the above requirements is critical to not only maintaining OSHA compliance, but also to safeguarding the health and safety of your employees who are interacting with hazardous chemicals and extraction processes daily.
Contact your HUB Cannabis expert for more information on safeguarding your workforce during cannabis cultivation and transferring risks to insurance.
