Core requirements for Oregon cannabis growers, processors, and retailers

A workplace hazard is anything that puts your employees' health or safety at risk.

Identifying hazards is something that you and all of your employees can do. Require employees to immediately report hazards to you or someone else who can act on the report. Employees who report hazards also need to know when and how the hazards will be fixed.

Reporting workplace injuries

If your workplace has a serious workplace injury or death, you must promptly report it to Oregon OSHA.

Report to Oregon OSHA within eight hours:

• The death of an employee.
• A catastrophe (two or more employees are fatally injured, or three or more employees are admitted to a hospital or an equivalent medical facility).

Work-related deaths include those caused by a motor vehicle crash that happens during an employee's work shift. Deaths caused at work by heart attack or other medical conditions must also be reported.

Report to Oregon OSHA within 24 hours:

An in-patient hospitalization. Do not report emergency room visits unless they involve:

• Loss of an eye.
• An amputation or avulsion that results in bone loss. (An avulsion is the tearing away or forcible separation of any body part by trauma.)

Failure to report these incidents within the required time limits can result in a mandatory penalty.

How and where to report

Recording workplace injuries

Cannabis growers, processors, and retailers with 10 or more employees must:

• Record their injuries and illnesses on a form called the OSHA 300 Log
• Summarize that information on a form called the OSHA 300-A

Cannabis, growers, processors, and retailers with more than 25 employees must annually submit the OSHA 300-A to federal OSHA. The forms and instructions on how to complete the OSHA 300-A and OSHA 300 Log are in the publication OSHA forms for recording work-related injuries and illnesses.

You must post the OSHA 300-A where employees can see it, no later than Feb. 1 each year.

You must display Oregon OSHA's It's the law! poster where your employees can see it. The poster summarizes the rights and responsibilities you and your employees have under the Oregon Safe Employment Act. The poster also comes in Spanish. If you have employees who speak English and others who speak Spanish, display both versions.

If someone offers to sell you the poster, don't buy it. You can print it yourself or order it from Oregon OSHA. The Bureau of Labor and Industries' (BOLI) Technical Assistance for Employers Program also offers free online access to all required posters, as well as nine-in-one and seven-in-one composite versions that are available for a nominal charge.

Most Oregon businesses must have a safety committee or hold safety meetings. There are different requirements for general industry and agricultural employers. If you have fewer than 11 employees, you may hold monthly safety meetings or choose to have a safety committee.

• If you are a cannabis processor or retailer: The best way to determine if you need a safety committee or hold safety meetings is to read Oregon OSHA's Quick guide to safety committees and safety meetings, which covers the requirements.
• If you are a cannabis grower: Oregon OSHA's Quick guide to safety committees and safety meetings for agriculture covers the requirements.

Your employees must know their safety responsibilities, what hazards they could be exposed to, and how to eliminate or control their exposures. New worker orientations, emergency drills, refresher training, classroom sessions, and hands-on practice are good ways they can learn. Don't forget that managers and supervisors need training, too.

• Ensure that employees are trained to safely do their jobs before they begin work for the first time. They should have orientation training that covers your business safety policy, workplace safety rules, hazards, and procedures for responding to emergencies. This includes employees rotated into new positions or job tasks.
• Create a training outline that identifies the hazards for each job task.
• Ensure that employees know the Oregon OSHA requirements that apply to their jobs, their safety responsibilities, what hazards they could be exposed to, and how to prevent exposures. They must be retrained whenever there are changes in the workplace that create new hazards.
• Ensure that employees are knowledgeable about the hazards of the chemicals in their work areas.
• Review safety data sheets for each chemical to identify the hazards associated with the chemical. Training should cover hazards, appropriate controls, and emergency procedures. 
• Create written operating procedures for cannabis and hemp extraction equipment to simplify employee training.
• Ensure that employees who operate extraction equipment know about emergency procedures for shutdown and maintenance requirements based on the manufactures' guidelines.
• Keep a record of each employee trained, the type of training, the training date, and the trainer.

Some Oregon OSHA rules require you to develop procedures, policies, or plans to protect your employees. These are typically referred to as “programs" and must be available for employees to review – either on paper or on a computer. The programs that your workplace needs depend on the hazards that your employees may be exposed to. Programs that may be required for cannabis growers, processors, and retailers include.

Programs for growers

• Respiratory protection program – 437-004-1041, Division 4, Subdivision I
• Lockout/tagout program – 437-004-1275, Division 4, Subdivision J
• Pesticide safety training program for workers – 170.401, Division 4, Subdivision W
• Pesticide safety training program for handlers – 170.501, Division 4, Subdivision W
• Personal protective equipment program – 170.507, Division 4, Subdivision W
• Hazard communication program – 437-004-9800, Division 4, Subdivision Z

Programs for processors and retailers

• Assured equipment grounding conductor program for use of flammable liquid and gases – 1910.304, Division 2, Subdivision S
• Emergency action plan – 437-002-0042, Division 2, Subdivision E
• Emergency medical plan – 437-002-0161, Division 2, Subdivision K
• Fire prevention plan – 437-002-0043, Division 2, Subdivision E
• Hazard communication program – 1910.1200, Division 2, Subdivision Z
• Lockout/tagout program – 1910.147, Division 2, Subdivision J
• Powered industrial trucks training program – 1910.178, Division 2, Subdivision N
• Respiratory protection program – 1910.134, Division 2, Subdivision I

Your workplace should have a plan that ensures your employees will respond properly in an emergency. But, if you have not responded to a workplace emergency before, how do you begin? Start by identifying emergencies that could affect your workplace and developing emergency response procedures.

Examples include:

• Earthquake
• Explosion
• Fire
• Hazardous-substance release
• Medical emergency
• Threat of violence
• Weather-related event

Oregon OSHA also has rules to ensure your employees can respond properly to fires and medical emergencies. These include emergency action plans and fire prevention plans.

Emergency action plan

If your workplace has 11 or more permanent, year-around employees, the plan must be in writing and include:

• Procedures for reporting a fire or other emergency
• Procedures for emergency operation or shutdown of critical equipment
• Procedures for rescue and medical duties
• Names or job titles of employees to contact to get more information about the duties of employees under the plan

Workplaces with 10 or fewer employees don't need written plans, but employees must know what procedures to follow during an emergency.

There must be a communication system to alert employees about an emergency or an alarm system with a distinctive signal for each type of emergency.

You must review the emergency action plan with each employee:

• When the plan is new or the employee is new to the job
• When the employee's responsibilities under the plan change
• When the plan changes

Fire prevention plan

If your workplace has 11 or more permanent, year-around employees, the plan must be in writing and include:

• Procedures to control accumulations of flammable waste
• Procedures for maintaining safeguards installed on heat producing equipment to prevent accidental ignition of combustible materials
• Procedures for reporting fire-related hazards

Workplaces with 10 or fewer employees do not need written plans, but employees must know what procedures to follow during a fire emergency.

You must inform employees about fire hazards in their work areas and review with each employee, who is new to a job, the parts of the fire prevention plan necessary to protect them.

Exits and exit routes

Each work area must have at least two permanent, unobstructed exit routes. A single exit route is acceptable only if all workers can safely move through it during an emergency.

There must be unobstructed access to exit routes. Exit routes must not pass through or into lockable rooms or dead ends and must be mostly level or have stairs or ramps.

Exit routes must:

• Be able to handle the maximum number of people allowed in the area it serves
• Be at least 6 feet, 8 inches high at all points
• Be at least 28 inches wide between handrails or wider if needed to handle the expected occupant load
• Be free of objects that reduce its minimum height or width
• Minimize danger to workers during emergencies
• Have adequate lighting

There must be a clear and unobstructed access and exit by a ladder, stairs, or ramp to any location more than four feet above or below the floor.

Exit doors must open from the inside without keys or special tools and there must be nothing on an exit door that could hinder its use during an emergency. Doors that lock only from the outside are acceptable.

Exit signs

• There must be exit signs at all emergency exits, except those that are obvious and clearly identifiable.
• Identify doorways or other passage ways that could be mistaken for exits with a sign that says “Not an Exit" or indicate its real use.

Hazardous areas

• Exit doors serving hazardous areas must swing in the direction of exit and open in a way that does not obstruct exit passageways.
• Do not allow anything to obstruct or prevent the use of an exit. All escape exit doors and windows must be easy to open from the inside.
• Rooms subject to extremes in temperature or toxic atmospheres must have at least one door that opens from the inside. If this door is lockable from the outside, lighting and a set of instructions for opening the door must be inside the room on or near the door.