Roberta Smith, occupational health program manager at the Colorado Department of Public Health and Environment, hasn't heard of anyone dying in an industrial accident at a Colorado marijuana business. But she says dispensaries, grows and the like present unusual safety risks, including the possibility of fires and explosions from hash-oil extraction, in addition to the sort of everyday dangers that hover over virtually every workplace. That's why the CDPHE has produced "Guide for Worker Safety and Health in the Marijuana Industry," which Smith believes is the first-ever document of its kind.
"We wanted to make sure we put something comprehensive together outlining some of the hazards that may exist and give businesses some best practices for how to build a health-and-safety program," Smith says.
The guide, on view below in its entirety, was put together with "input from the industry itself, epidemiologists, health professionals and a variety of other partners," Smith reveals. Also involved were state officials who consider the guide a necessity in part because of the way inspections of dispensaries and grow facilities in Colorado are handled.
"In Washington, Oregon and California, the states come in and do inspections," Smith explains. "But in Colorado, inspections are done by OSHA [Occupational Health and Safety Administration], a federal agency that oversees worker safety. So OSHA requirements need to be heeded by the marijuana industry, just like any other industry in the state."
High-intensity lighting is common at marijuana grow facilities.
Photo by Lindsey Bartlett
Because state-legal marijuana is so new, Smith continues, "people may not be aware of the need to not only follow federal occupational health and safety standards, but also Colorado standards that need to be followed as well. We outline those and put best practices in place. The guide doesn't introduce any new regulations; it's based on existing codes and standards. But it also looks at some of the things that are unique about the marijuana industry."
Here's an example from the guide — an excerpt from the section about extraction equipment:
High heat and pressure may be combined to make products like rosin. High-pressure machinery poses a hazard both from the pressing and high pressure build-up to extract oils and from explosion hazards and burns.... Extraction using butane is the most cost effective yet the most dangerous method of extraction used. Open releases of butane to the atmosphere during extractions is prohibited by Denver Fire Code. Extraction equipment that use hazardous materials (i.e. flammable/ combustible liquids, Carbon Dioxide (CO2), liquefied petroleum gases (i.e. butane)) are required to be listed or approved per the Denver Fire Code. Only closed-loop type liquefied petroleum gas extraction equipment is permitted. This equipment must further be approved by the Denver Fire Department before use.
Smith feels extraction-related explosions present "the biggest risks for people working in the industry. When you're extracting oils, a lot of times compressed gases and high heat can be used. The state regulates a lot of the extraction processes; they have to be inspected before they're put in place. But from a safety standpoint, explosions can happen and can lead to fatalities."
She sees similar reasons to worry due to "the high use of electricity at cultivation facilities. There can be a lot of standing water, and many of them are operating 24/7. That can create a lot of electrical hazards."
Additional concerns surround the possibility of mold developing at marijuana facilities, as described here:
Marijuana production requires increased levels of humidity, which have been found to be as high as 70 percent. This increased humidity in the presence of organic material promotes the growth of mold. Previous studies of illegal indoor growing operations have reported elevated levels of airborne mold spores, especially during activities such as plant removal by law enforcement personnel. In this study, law enforcement personnel were exposed to levels of mold equivalent to a small to medium-sized mold remediation project. To date, there have not been similar studies of legal growing operations to determine the risk for mold exposure in the more controlled cultivation facility environments. Scientific reviews by the Institute of Medicine (IOM) and WHO [World Health Organization] have indicated strong associations of exposure to indoor dampness related agents such as mold with health issues including wheezing, coughing, increased asthma symptoms, shortness of breath, and respiratory infections. A trained industrial hygienist can perform air monitoring to determine spore levels within the work environment. Special considerations may be needed for susceptible or immunosuppressed individuals. More research is needed to characterize and reduce potential exposures to mold and powdery mildew, including adverse effects on workers’ respiratory and lung functions.
The prevalence of hoses and wires at marijuana facilities can increase the risk of slips and falls, according to the guide.
Photo by Lindsey Bartlett
Expanding on this topic, Smith notes that "indoor air quality and potential mold issues can certainly present respiratory problems or create sensitivities in the workplace — not just with mold, but with pesticides, too. The Department of Agriculture is the group that regulates pesticide use, but with some of the pesticides, depending on their label, respiratory protection might be required. We highlight that in the guide, and we also have a little section in the back that describes how to develop a respiratory-protection program. Under OSHA, if you have employees using respirators for respiratory protection, and there are known hazards, you've got to have a written plan to make sure the respirators fit and protect them adequately."
Also included in the guide is a (potentially controversial) section on workplace violence tailored to the marijuana industry:
There may be a false sense of security or general lack of awareness regarding workplace violence in the marijuana industry. The most obvious opportunity for violence is in growing operations and retail stores, due to the presence of large quantities of cash and product, the possibility of disgruntled employees, angry terminated employees, and a high-stress environment. Other routine activities such as moving large quantities of product between stores, transporting product in personal vehicles and making trackable movements (times and routes) create opportunities for a violent offender to attempt robbery. Workplace violence can take many forms including verbal threats, threatening behaviors or physical assaults. Violence can be committed by strangers, customers or clients, co-workers, or by personal relations.
And then there are more run-of-the-mill issues.
"In this industry, like any industry, you can have slips, trips, falls, cuts and ergonomic injuries, like overuse of certain muscles if you're doing a trimming process," Smith points out. "We put them in the guide because they might not be as recognized as some of the other hazards, but they're all things you want to look at when it comes to the health and well-being of employees."
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Because the CDPHE doesn't collect injury data, Smith lacks hard numbers about how many people have been hurt working in the Colorado marijuana trade. But based on anecdotal conversations with industry professionals, Smith says the slip-and-trip sorts of injuries are by far the most common taking place at cannabis facilities, just as they are pretty much everywhere else.
With the help of the guide, let's hope no one blows up or catches on fire, either. Continue to read the document.