Cal/OSHA Cannabis Industry FAQ

Injury Protection

Cal/OSHA requires a written Injury and Illness Prevention Program (IIPP) with employee training on facility hazards etc. Business owners should delegate responsibility within the company to a safety manager, officer, or even a safety committee.

Injury Reporting

Cal/OSHA requires that an employer immediately report worker injuries. Having a reporting procedure in place before something happens is extremely important.

Hazard Communication Program

Operators must maintain a list of all hazardous chemicals, safety data sheets associated with those chemicals, proper labeling of all chemicals and employee training on how to use the chemicals.

Emergency Action and Emergency Evacuation Plans

Cal/OSHA mandates that a facility have, at a minimum, an Emergency Evacuation Plan which can fit into a larger Emergency Action Plan. The Emergency Evacuation Plan maps exit routes to take in the event of an emergency. Employees must be trained on the plan through regular fire drills, and one employee must be accountable for head counts once everyone is evacuated. A more inclusive Emergency Action Plan includes workplace violence prevention and steps to take in the event of a live shooter.

First Aid

It is helpful to have first aid readily available in your facility. Ideally there is at least one employee that is first aid certified on every shift.

Training and Record-Keeping

Cal/OSHA outlines requirements for employee training, pesticide storage, signage and record-keeping.

Hearing Conservation Program

All personnel who are exposed to occupational noise levels equal to or exceeding an 8-hour time-weighted average of 85 dBA shall be included in a hearing conservation program

Personal Protective Equipment Assessment

Cal/OSHA outlines regulations on the use of respirators. If an employee is using a pesticide that requires wearing a respirator, the employee is legally required to use one and the employer is legally required to have a Respiratory Protection Plan. A plan is also required if an employee voluntarily chooses to use a respirator. The key elements of a Respiratory Protection Plan include a medical evaluation to determine if the employee is healthy enough to wear a respirator, proper fitting of the respirator and the proper storage and maintenance of the equipment. This includes knowing when cartridges reach the end of their usable life.

Heat Illness Prevention for Outdoor & Indoor (Proposed) Places of Employment

California employers are required to take these four steps to prevent heat illness:

• Train all employees and supervisors about heat illness prevention.
• Provide enough fresh water so that each employee can drink at least 1 quart per hour, or four 8 ounce glasses, of water per hour, and encourage them to do so.
• Provide access to shade and encourage employees to take a cool-down rest in the shade for at least 5 minutes. They should not wait until they feel sick to cool down.
• Develop and implement written procedures for complying with the Cal/OSHA Heat Illness Prevention Standards for High Heat Procedures

Other Regulations that May Apply:

• Electrical Hazards
• Exposures to Airborne Contaminants
• Flammable Liquids and Gase
• Pressure Vessels
• Prohibition of Smoking in the Workplace
• Repetitive Motion Injuries
• Sanitation and Pest Control
• Slips, Trips, Falls, and Use of Ladders

The Top 5 OSHA Infractions for Cannabis Businesses

1. The facility does not have a written Hazard Communication Plan that describes how it achieves compliance with: 1) labels on hazardous containers; 2) MSDSs for all chemicals and pesticides, and 3) hazardous chemical training for employees.
2. All relevant employees have not been trained on hazardous materials in use at the facility prior to their initial work assignment and when new hazards are introduced and documented as required.
3. The facility does not have a formal fire prevention plan (written with more than 10 employees) that addresses major hazards in the facility, accumulation of waste material, maintenance of heat-producing equipment and names and titles of employees responsible for various parts of the plan.
4. Required Personal Protective Equipment (PPE) has not been evaluated and documented, along with associated training plans and verification for employees.
5. The facility does not have required OSHA documentation related to workplace injury, OSHA Form 300, or Form 301 if injuries have occurred, on file.

EPA’s Additional Worker Protection Standards

Additional Cannabis Worker Protection Resources

Washington State WPS Requirements for Cannabis Employers

Colorado State WPS Requirements for Cannabis Employers

Colorado State WPS Requirements for Cannabis Employers Video Part I and Part II

EPA WPS Checklists

EPA WPS Pesticide Compliance Manual

PERC WPS Pesticide Training Materials

Workplace risks for Cannabis Operations

Marijuana Workplace Hazards