Cannabis growers, cultivators, and distributors face unique compliance challenges when navigating federal and state regulations, managing hazardous and non-hazardous waste streams, and ensuring your facility runs safely and compliantly. This webinar will help early-stage and fast-growing cannabis companies understand the state and federal regulatory environment, obtain permits and licenses, and build environmental, health, and safety (EH&S) programs. Whether your cannabis organization is new to the compliance world or has some safety programs in place, this webinar will provide guidance on how to reach operational excellence.
Cannabis Enterprises: EH&S Compliance You Need to Know!
1. Cannabis Enterprises: EH&S
Compliance You Need to
Know!
Mike Albert, Consulting Operations Director
Triumvirate Environmental
Greg Rosinski, Strategic Business Manager
Triumvirate Environmental
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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 Operations Director
Triumvirate Environmental
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Meet Your Presenters
Greg Rosinski
Strategic Business Manager
Triumvirate Environmental
6. Environmental Regulations, Health Regulations & Safety Regulations
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Industry
Jobs
Administration
Budtender
Cultivator
Edible
Producer
Extraction
Tech
Laboratory
Tech
Maintenance
Trimmer
Transportation
7. Number of Full-Time Workers 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
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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
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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)
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10. Why Are We Here 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)
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12. Agenda
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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 EPA Programs
• 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)
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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
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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
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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)
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22. Design & Program Set-Up
1) Regulation requirements met
2) Industry specific applicability
3) Adaptable to your environment
4) User friendly
5) Sustainable for long-term solutions
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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
▪ Saturated or 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
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26. Collection and Storage of 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)
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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
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28. Agenda
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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
36. Agenda
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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
39. References
• NIOSH Health Hazard 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
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