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Cannabis Enterprises: EH&S Compliance You Need to Know!
The document discusses environmental health and safety (EH&S) compliance for cannabis enterprises, emphasizing the importance of understanding regulatory requirements from various agencies like OSHA and EPA. It covers industry-specific hazards, best practices for disposal and safety, and the significance of maintaining a safe work environment within the cannabis industry. Additionally, the document highlights employment statistics and the health effects associated with cannabis exposure.
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Cannabis Enterprises: EH&S Compliance You Need to Know!
- 1. Cannabis Enterprises: EH&S ComplianceYou Need to Know! Mike Albert, Consulting Operations Director Triumvirate Environmental Greg Rosinski, Strategic Business Manager Triumvirate Environmental
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- 3. 3 During this Webinar ✓All lines will be muted. ✓ Communicate via the questions tab in your webinar panel. ✓ Unanswered questions will be responded to personally after the webinar. ✓ Webinar recording and slides will be emailed to you tomorrow.
- 4. Mike Albert Consulting OperationsDirector Triumvirate Environmental 4 Meet Your Presenters Greg Rosinski Strategic Business Manager Triumvirate Environmental
- 5. Cannabis Control Commissionand Environment, Health, and Safety 5
- 6. Environmental Regulations, HealthRegulations & Safety Regulations 6 Industry Jobs Administration Budtender Cultivator Edible Producer Extraction Tech Laboratory Tech Maintenance Trimmer Transportation
- 7. Number of Full-TimeWorkers in the Cannabis Industry: Employment Comparisons to Mainstream Professions 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 Legislators Veterinarians Flight Attendants Cannabis Industry (2018) Web Developers Cannabis Industry (2019) Clergy Chief Executives 7 Note: Cannabis industry employment figures calculated using number of full-time equivalent workers that support the marijuana industry. Source: US Bureau of Labor Statistics Employment Projections: 2016-2026. Projections includes both full- and part-time workers in 2019. Set the culture!
- 8. Agenda 8 Environmental Health &Safety: Why It Is Important Compliant & Best Practices: What You Need to Know Disposal: Safe, Compliant, & Effective Real-Life Examples in the Industry Q&A
- 9. Environmental Health &Safety • Environmental protection & safety at work • Cannabis regulations: ▪ Food and Drug Administration - 21 CFR Federal Food, Drug and Cosmetic Act ▪ Drug Enforcement Administration - Schedule I - drugs, substances, or chemicals are defined as drugs with no currently accepted medical use and a high potential for abuse. ▪ State regulatory agencies - California Bureau of Cannabis Control, Illinois Department of Financial and Professional Regulation, Massachusetts Cannabis Control commission, New York Office of Cannabis Management, etc. • EH&S exists because of the law ▪ Environmental Protection Agency (EPA) ▪ State-run environmental agencies ▪ Occupational Safety & Health Administration (OSHA) 9
- 10. Why Are WeHere Today with EH&S? OSHA General Duty Clause & Environmental Regulations for Disposal: “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees." (OSHA - 29 U.S.C. § 654, 5(a)1) 10
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- 12. Agenda 12 Environmental Health &Safety: Why It Is Important Compliant & Best Practices: What You Need to Know Disposal: Safe, Compliant, & Effective Real-Life Examples in the Industry Q&A
- 13. OSHA and EPAPrograms • Ergonomics • Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) • Fire and electrical safety • Flammable liquids storage • Hazard communication • Respiratory protection • Security • Worker readiness (Drug policy) • Wastewater • Reporting and recording • Indoor air quality/mold • Hazardous waste (RCRA) 13 Not an exhaustive list!
- 14. Industry Facts & Exposure •Cannabis genus of flowering plants • Cannabidiol (CBD) ▪ 40% of plant extract ▪ NOT psychoactive ▪ Studies regarding the treatment of epilepsy, anxiety, pain management, mental disorders • Tetrahydrocannabinol (THC) ▪ Psychoactive component ▪ “No currently accepted medical use” ▪ Lipid – easily moved through the body • Routes of exposure: ▪ Inhalation ▪ Ingestion ▪ Absorption 14
- 15. Fitness for Duty •Physical impacts ▪ Increased heart rate, dry mouth, reddening of the eyes, muscle relaxation and a sensation of cold or hot hands and feet and/or flushed face ▪ Movement and coordination issues • Behavioral effects ▪ Short-term memory loss ▪ Lower cogitative functions • Cannabinoid receptors triggers ▪ Dopamine – feel good hormone ▪ Norepinephrine – fight or flight hormone; anxiety 15
- 16. Fitness for Duty •Yes, your employer can still have a fitness for duty policy • Safety sensitive positions ▪ Drivers ▪ Heavy equipment operators ▪ Medical providers • Stored in fat tissues → long half life ▪ 3-10 days in infrequent users ▪ 2-3 months in habitual users • Testing – blood, urine, hair, saliva, and sweat ▪ New hire, and periodically ▪ Reasonable suspicion (DOT) 16
- 17. Industry Workplace Hazards 17 JobHazards Administration Ergonomics, workplace violence Budtender Ergonomics, sensitizers/allergens, workplace violence Cultivation (owner/operator) Ergonomics, sensitizers/allergens, mold, pesticides/fungicides, high pressure machinery, noise, chemicals, workplace violence Cultivator Ergonomics, sensitizers/allergens, mold pesticides/fungicides, walking/working surfaces, lighting hazards, chemical exposures
- 18. Industry Workplace Hazards 18 JobHazards Edible producer, infused product confectioner/artisan/chef Ergonomics, occupational injuries (burns), noise, chemicals Extraction technician Ergonomics, machinery, allergens, noise, chemical exposures, use of explosive/ flammable chemicals such as butane Laboratory technician Ergonomics, solvents Maintenance Ergonomics, elevated heights, electrical hazards Transportation Ergonomics, occupational injuries, workplace violence Trimmer Ergonomics, mold, sensitizers/allergens, pesticides, occupational injuries (cuts), chemical exposures, machinery
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- 20. Engineering Elements • HVACsystems & air purification • Environmental controls/environments • Heating/Cooling of products – fume hoods/exhaust • Grinding machines • Ethanol processing • Water discharge • Packaging • HPLC machines 20
- 21. Extraction Process • Ethanol •Halogenated solvent • CO2 21
- 22. Design & ProgramSet-Up 1) Regulation requirements met 2) Industry specific applicability 3) Adaptable to your environment 4) User friendly 5) Sustainable for long-term solutions 22
- 23. Agenda 23 Environmental Health &Safety: Why It Is Important Compliant & Best Practices: What You Need to Know Disposal: Safe, Compliant, & Effective Real-Life Examples in the Industry Q&A
- 24. Manufacturing (Cultivation/Harvest/Products) • Biomass ▪ Saturatedor unsaturated ▪ Contaminated • Soil ▪ High metal contamination ▪ Pesticides ▪ PCBs • Solvents ▪ Off-specification ▪ Reused too many times • Trim ▪ Cleaning/disinfecting ▪ Contamination ▪ Unused or aged-out plants • Off-specification products ▪ Returns ▪ QC test problems ▪ Harvest/lots 24
- 25. Quality Control Laboratories •Sample control ▪ Storage ▪ Security • Solvents ▪ Methanol/ethanol/acetonitrile • Corrosives ▪ Amines ▪ Sulfuric/hydrochloric/phosphoric/ nitric • By-products ▪ THC collection ▪ Mold/bacteria ▪ Pesticides ▪ Heavy metals • Denatured cannabis 25
- 26. Collection and Storageof Waste • Solvents (liquid) or biomass (trim with solvents) ▪ Properly sized containers ▪ Storage in a safe space (flame cabinet, sprinkler systems, etc.) • Corrosives ▪ Properly sized, non-metal containers ▪ Storage in a dry space & safe • Off-specification pesticides or fertilizers or products ▪ Properly sized containers ▪ Ingredients are important! (reactivity) 26
- 27. Transportation and Disposal •Federal regulations require disposal of contaminated cannabis to be denatured before going off-site • Shipped in Department of Transportation approved containers • Destruction by incineration and landfill • Sustainability 27
- 28. Agenda 28 Environmental Health &Safety: Why It Is Important Compliant & Best Practices: What You Need to Know Disposal: Safe, Compliant, & Effective Real-Life Examples in the Industry Q&A
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- 36. Agenda 36 Environmental Health &Safety: Why It Is Important Compliant & Best Practices: What You Need to Know Disposal: Safe, Compliant, & Effective Real-Life Examples in the Industry Q&A
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- 39. References • NIOSH HealthHazard Evaluation “Evaluation of Potential Hazards during Harvesting and Processing Cannabis at an Outdoor Organic Farm” April 2017 HHE Report No. 2015-0111-3271 • Guide to Worker Safety and Health in the Marijuana Industry. Marijuana Occupational Health and Safety Working Group. January 2017 Colorado Department of Public Health and Environment • California Cannabis Portal • OSHA • EPA • Cannabis Control Commission 39