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Information for cannabis growers

simple green graphic of cammabis leaf in a flower pot  

Cannabis growers include employers who plant, cultivate, grow, or harvest cannabis.

Cannabis growers covered in this section are in these 2017 North American Industry Classification System (NAICS) codes:

  • 111998 (All Other Miscellaneous Crop Farming) Marijuana, grown in an open field
  • 111419 (Other Food Crops Grown Under Cover) Marijuana, grown under cover

Oregon OSHA rules that apply to growers

  • Cannabis growers (indoor, outdoor, and greenhouse) are covered by Oregon OSHA's Division 4, Agriculture rules.
  • An extraction facility located on an agricultural grow site that processes at least 51 percent of the crop on that site is also covered by Oregon OSHA's Division 4, Agriculture rules.
  • Oregon OSHA's rules do not apply to corporate family farms that employ only family members.

Agricultural labor housing

Oregon OSHA's agricultural labor housing rules apply to any place where there are living areas or other housing provided by someone who recruits workers to work on an agricultural establishment. These rules cover:

  • All housing provided by a farmer, farm labor contractor, agricultural employer, or other person who recruits workers on an agricultural establishment.
  • Any type of labor housing and related facilities, together with the tract of land, established, operated, or maintained for housing workers, with or without families, whether or not rent is paid or collected.
  • All housing given, rented, leased, or otherwise provided to employees while employed and provided or allowed either by the employer, a representative of the employer, or a housing operator.

Agricultural labor housing for workers who produce or harvest farm crops must be registered with Oregon OSHA, except when the housing is occupied by members of the same family or by five or fewer unrelated people.

After housing is registered with Oregon OSHA, the operator will receive a certificate that must be displayed in a location frequented by employees. The operator of the agricultural labor housing must also provide and display a translation of the certificate in the language or languages used to communicate with the employees.

Agricultural seasonal workers

Agricultural seasonal workers are employed in a job tied to a certain time of year by an event or pattern and for not more than 10 months in a calendar year – for example, harvesting cannabis in October.

Safety awareness information

Give seasonal workers safety awareness information at their orientation meeting before they begin work for the first time and when work conditions or locations change, affecting their safety or health.

Safety awareness information includes:

  • Your safety and health rules for their work
  • How workers should contact supervisors or managers to report an accident or illness
  • What workers should do if someone is injured or sick and needs help
  • Where safety and health information is posted at your site

If you have workers who do not speak or read English, you must provide this information in a way they can understand – for example, in the language they speak, pictures, or other visual aids.

"Safe Practices When Working Around Hazardous Agricultural Chemicals"

Give a copy of the Oregon OSHA publication Safe Practices When Working Around Hazardous Agricultural Chemicals (440-1951) to workers at their initial training. The publication is also available as a mobile app in English and Spanish.

Training

Provide initial Worker Protection Standard (WPS) training to seasonal workers if you use pesticide products that have an "Agricultural Use Requirements" designation on the label.

Give seasonal workers initial WPS training if the products are used during the 30 days before their first day of employment or at any other time during their employment. Safe Practices When Working Around Hazardous Agricultural Chemicals has the information you need to provide the training.

Additional WPS training is required on the worker's sixth day of employment and for pesticide handler work. See WPS paragraph 170.130(a)(3), Pesticide Safety Training for Workers, for these requirements.

Safety orientation meetings

Oregon OSHA requires that all workers be included in a safety orientation meetings for agricultural seasonal workers.

All agricultural seasonal workers must receive at least the following information in their orientation meeting before beginning work for the first time or when work conditions or locations change in a way that could affect their safety or health:

  • Information and training on the chemical they are using or are exposed to. Employers must review with all workers, the information in the Oregon OSHA publication, Safe Practices - Working With Hazardous Chemicals.
  • Your safety and health rules for the work employees will do.
  • Your procedures to contact supervision in case of accident, illness, or safety or health problems.
  • Your procedures for treatment of sick or injured workers and the summoning of emergency assistance.
  • The location of posted safety and health information.

Hand-labor operations

Hand-labor operations are agricultural activities performed by hand or with hand tools, including:

  • Hand cultivation, hand weeding, hand planting, and hand harvesting of vegetables, nuts, fruits, seedlings, mushrooms, or other crops
  • Hand packing or sorting, whether done on the ground, on a moving machine, or in a temporary packing shed in the field

Provide the following to seasonal workers who do only hand-labor operations:

  • The Safe Practices When Working Around Hazardous Agricultural Chemicals publication.
  • Safety awareness information required by 437-004-0240.
  • Access to safety data sheets (SDS) for any hazardous chemicals to which they may be exposed.

Cannabis allergens

An allergen is a substance that can trigger the immune system and cause an allergic reaction. People can have allergic reactions to cannabis just as they do with many other plants. Symptoms vary from mild to severe. Initial exposures may show no symptoms, but exposures over time can lead to progressively stronger reactions.

Handling cannabis has been associated with hives, itchy skin, and swollen or puffy eyes. Breathing or inhaling cannabis allergens can result in shortness of breath, runny nose, sneezing, itching, and swelling and watering eyes.

Less commonly, cannabis can cause a severe allergic reaction called anaphylaxis. This condition can be life-threatening and occurs within seconds or minutes of exposure.

There have also been cases of cross-reactivity between cannabis and certain foods, including tomatoes, peaches, grapefruit, apples, eggplant, bananas, and hazelnuts. Cross-reactivity happens when proteins in the cannabis plant, such as pollen, resemble the proteins in another plant. A person who comes into contact with a plant that has a similar protein could have an allergic reaction.

Currently, there is no standard way to test for a cannabis allergy; however, skin testing could be considered for patients who have experienced allergic reactions to cannabis. Typically, a doctor applies diluted cannabis to the skin's surface with a needle. If a red bump, itching, and redness develop within 15 minutes, a person may be allergic to cannabis.

There is no treatment currently available for a cannabis allergy, though antihistamines may help people manage symptoms and reduce discomfort. People who think they might be allergic to cannabis should avoid smoking, eating, or touching the plant.

Workers who handle cannabis should use impervious coveralls, nitrile gloves, and N95 or N100 filtering face-piece respirators (dust masks) to reduce symptoms. Employees experiencing allergic reactions should seek medical attention. Allergic reactions are recordable on the OSHA 300 log.

Carbon dioxide

Carbon dioxide (CO2) can be used as a liquid compressed gas to increase plant growth in grow rooms. Solid carbon dioxide, or dry ice, can be also used in cannabis extraction processes. Dry ice converts directly to carbon dioxide gas and can be hazardous to workers if not handled properly.

Under normal atmospheric concentrations, carbon dioxide does not pose a health hazard. However, at levels exceeding 5,000 parts per million (ppm) averaged over eight hours, carbon dioxide displaces oxygen and can be toxic, causing respiratory acidosis – a serious medical condition that happens when there is too much carbon dioxide in a person's blood. Oregon OSHA has found carbon dioxide levels as high as 18,000 ppm in rooms where dry ice is used for extraction.

Symptoms of overexposure to carbon dioxide include headache, dizziness, rapid breathing, and increased heart rate; continued overexposure can cause unconsciousness and death.

Facilities that use carbon dioxide and dry ice must be equipped with a carbon dioxide detector that will sound an alarm when carbon dioxide exceeds 5,000 ppm. Carbon dioxide detectors must be properly maintained, calibrated, and used in accordance with the manufacturer's guidelines. Auto-calibrating and self-zeroing detectors must not be used.

Rooms where carbon dioxide or dry ice are used must also be properly ventilated. Carbon dioxide concentrations should be kept below 1,400 ppm. Typically, one cubic foot of fresh air per square foot of solid floor space will provide proper ventilation. However, a ventilation engineer should be consulted to determine the appropriate ventilation design.

Safe practices

  • Train employees about the health effects associated with carbon dioxide so they are able to recognize symptoms of overexposure, know the methods for controlling their exposure, and know how to respond to an emergency involving carbon dioxide.
  • Require employees to use cryogenic gloves and safety glasses (or a face shield for liquid carbon dioxide) when they handle dry ice or liquid carbon dioxide to avoid contact with their skin or eyes.
  • Secure carbon dioxide compressed-gas cylinders to a fixed object to prevent them from falling, and use transportation carts to move cylinders.
  • Cylinder safety caps must be in place when the cylinder is not attached to an extraction system.
  • Ensure that pressure relief devices on high-pressure carbon dioxide extraction equipment and blow-off valves are piped to the exterior of the facility.
  • Ensure that a carbon dioxide safety data sheet is accessible to employees and part of the facility's hazard communication plan.
  • Do not use or store dry ice in confined areas, walk-in refrigerators, environmental chambers, or unventilated rooms.

Carbon monoxide

Carbon monoxide (CO) is a colorless, odorless, and tasteless poisonous gas produced by the incomplete burning of any material containing carbon – gasoline, natural gas, oil, propane, coal, or wood. It is harmful because it displaces oxygen in the blood and deprives the heart, brain, and other vital organs of oxygen. It is one of the leading causes of poisoning by inhalation and is a common workplace hazard.

Mild exposure to carbon monoxide can cause nausea, dizziness, or headache. Prolonged or high exposure may worsen symptoms, which include vomiting, confusion, collapse, loss of consciousness, and muscle weakness. Symptoms vary from person to person. Severe exposure can result in permanent brain and heart damage or death.

People can die from carbon monoxide poisoning while using fuel-powered tools and equipment indoors and in poorly-ventilated spaces. Typical examples include fuel-powered generators, compressors, forklifts, floor buffers, space heaters, and pumps.

Safe practices

  • Train workers about the sources of carbon monoxide, the symptoms of overexposure, and the methods for controlling their exposure.
  • Do not use fuel-powered generators, engines, or heaters indoors or in enclosed spaces; instead, use tools and equipment powered by electricity or compressed air.
  • Use carbon monoxide detectors with audible alarms set at 25 parts per million (ppm) in areas where potential sources of carbon monoxide may be present.
  • Install a ventilation system that will remove carbon monoxide from work areas.
  • Establish a preventive maintenance program that includes all natural gas, propane, and gasoline-powered equipment.

Confined spaces

A confined space is a space that:

  • Is large enough and so configured that an employee can fully enter the space and perform work
  • Has limited or restricted means for entry, exit, or both
  • Is not designed for continuous human occupancy

When workers enter a confined space, they can encounter toxic gasses, corrosive chemicals, flammable solvents, or machines that start unexpectedly. If something goes wrong, a confined space can be difficult or impossible to exit. Would-be rescuers can die as quickly as those they are trying to rescue.

Oregon OSHA has confined space rules for general industry and agriculture. The general industry rule (437-002-0146) applies to most cannabis processors and retailers. The agriculture rule (437-004-1250) applies to most growers. Examples of confined spaces include water tanks, cold storage areas, and manholes.

Employers must identify all confined spaces at their workplaces and determine if they contain safety or health-related hazards.

Oregon OSHA uses the term “permit-required confined space" (and “permit space") to describe a confined space that has one or more of the following hazards:

  • Contains or has the potential to contain a hazardous atmosphere
  • Contains material that has the potential to engulf an entrant
  • Has walls that converge inward or floors that slope downward and taper into a smaller area that could trap or asphyxiate an entrant
  • Contains any other recognized safety or health hazard, such as unguarded machinery, exposed live wires, or heat stress

Employees must be notified about the existence and location of hazards in permit-required confined spaces. Employees who enter permit-required confined spaces must follow comprehensive entry and rescue procedures.

Safe practices

  • Inspect the workplace to determine if confined spaces exist.
  • Consider procedures that eliminate the need for employees to enter confined spaces.
  • Notify employees that they must not enter a confined space unless they are authorized to do so.
  • If confined spaces are entered, establish an on-site rescue plan that includes necessary rescue equipment.
  • Call 911 to report a confined space emergency; only trained emergency responders can enter the space.
  • Develop and implement a comprehensive entry program if employees are required to enter a permit-required confined space.

Corrosive chemicals

Corrosive chemicals can burn and destroy body tissues; respiratory damage can occur from breathing in corrosive vapors or particles that irritate or burn the inner lining of the nose, throat, and lungs. The more concentrated the chemical and the longer it contacts the body, the more severe the damage can become.

Most corrosive chemicals are acids or bases. Corrosive chemicals used in the cannabis industry include chlorine bleach (a base), hydrogen peroxide (an acid), and peracetic acid.

Corrosive chemicals used in liquid and solid forms must be included in your hazard communication program's list of hazardous substances and must be properly stored.

Workers may also be exposed to corrosive chemicals when they mix plant nutrients; when mixed improperly, the nutrients can cause severe respiratory, skin, or eye irritation.

Safe practices

  • Substitute corrosive chemicals with a less hazardous substances when possible.
  • Ensure that safety data sheets for corrosive chemicals are readily available to workers.
  • Provide worker training on corrosive chemicals that covers use, storage, and emergency procedures for containing spills.
  • Maintain ventilation to help remove corrosive vapors, fumes, mists, or airborne dusts.
  • Inspect all incoming containers of corrosive chemicals to ensure they are undamaged and properly labeled before storing them.
  • Store corrosives in containers recommended by the manufacturer or supplier. Corrosives can destroy containers made of incompatible materials.
  • Segregate acids from bases when storing corrosive chemicals. Segregate inorganic oxidizing acids (such as nitric acid) from organic acids (such as peracetic acid), flammables, and combustibles.
  • Segregate acids from water-reactive metals such as sodium, potassium, and magnesium.
  • Store corrosive chemicals on lower shelves at least below eye level and in compatible secondary containers.
  • Do not store corrosive chemicals on metal shelves.
  • Ensure that personal protective equipment will protect workers from the chemicals they use.
  • Ensure that workers are trained how to use their personal protective equipment.
  • Provide areas where workers can wash up after using corrosive chemicals.
  • Provide ANSI-approved eyewash stations in areas where corrosive chemicals are handled.

Electricity

We are more conductive than the ground we stand on, which means that if there is no other easy path, electricity will make a path through our bodies to return to its source. When we become part of the electrical circuit, the consequences are never good for us.

Electricity is a serious workplace hazard that can cause falls and burns, and do major damage to our internal organs. It should come as no surprise that the word electrocution is derived from “electro" and “execution" – electrocution is death caused by electric shock.

It is not necessarily the number of volts that will electrocute you, but the amount of current, its path, and the time it takes to pass through your body.

Common electrical hazards include:

  • Improper use of extension cords
  • Missing breakers
  • Blocked electrical panels
  • Damaged electrical cords
  • Improper wiring
  • Improper use of electricity in high-humidity and watering areas

Do a workplace hazard assessment and create a list of potential hazards associated with electrical systems. Safety committee members should also be trained to identify and report electrical hazards during regular workplace inspections.

Safe practices

  • Use equipment only if it is approved by a nationally recognized testing laboratory.
  • Do not modify extension cords or use them incorrectly.
  • Use only factory-assembled extension cord sets and three-prong extension cords.
  • Use extension cords and fittings that have strain relief.
  • Do not use extension cords as a substitute for permanent wiring.
  • Use ground-fault circuit interrupters on all 120-volt, single-phase, 15- and 20-ampere receptacles, or have an assured equipment grounding conductor program where electrical outlets are located in damp or potentially wet areas.
  • Do not stand in wet areas when using portable electric power tools.
  • Use distinctively marked double-insulated tools and equipment.
  • Inspect electrical equipment to confirm it is safe before using it.
  • Remove from service any equipment with frayed cords, missing ground prongs, and cracked tool casings.
  • Develop a written program for controlling hazardous electrical energy and ensure that workers follow its requirements. Note: Cord-and-plug connected equipment is not covered by Oregon OSHA's hazardous energy requirements if the equipment is unplugged, the plug is under the exclusive control of the operator, and electricity is the only form of hazardous energy.

Flammable liquids

A flammable liquid is any liquid that has a flashpoint at or below 199.4 degrees F. A flashpoint is the lowest temperature at which a liquid gives off enough vapor to ignite at the surface. However, many flammable liquids will ignite and burn easily at temperatures below 100 degrees F.

Flammable liquids are present in almost every workplace. Examples include ethyl and isopropyl alcohol, fuels, solvents, thinners, cleaners, adhesives, paints, waxes, and polishes.

Flammable liquids are divided into four categories, based on their flashpoints and boiling points:

  • Category 1 includes liquids that have flashpoints below 73.4 degrees F and boiling points at or below 95 degrees F.
  • Category 2 includes liquids that have flashpoints below 73.4 degrees F and boiling points above 95 degrees F.
  • Category 3 includes liquids that flashpoints at or above 73.4 degrees F and at or below 140 degrees F.
  • Category 4 includes liquids that flashpoints above 140 degrees F and at or below 199.4 degrees F.

Flammable liquids may be used only where there are no ignition sources within 50 feet; this includes electrical equipment and open flames.

Personal protective equipment (PPE) hazard assessments

PPE hazard assessments for work involving flammable liquids should address proper use and handling, fire safety, chemical toxicity, storage, and response to spills. Conduct a chemical inventory and review the safety data sheet for each chemical to determine proper use, handling, and procedures to follow after a spill or chemical release.

Safe practices

  • Eliminate flammable liquids, substitute less flammable liquids, or reduce the quantities of flammable liquids used, if possible.
  • Ensure that safety data sheets for flammable liquids are included in your hazard communication plan.
  • Understand the bonding and grounding requirements for storing and transferring flammable liquids.
  • Always work with flammable liquids under a chemical fume hood.
  • Keep flammable liquid containers closed when the liquids are not being used.
  • Keep flammable liquids at least 50 feet away from electrical outlets, electrical equipment, and other ignition sources.
  • Use only enough flammable liquid to accomplish a task.
  • Develop an emergency action plan and a fire protection plan and know the locations of emergency equipment, including fire alarms, fire extinguishers, and safety showers.
  • Label all containers to identify contents that are flammable.
  • Do not put flammable liquids in “food-like" containers.

Hazard communication

We use thousands of chemical products throughout our lives, at home and at work, but most of us would not be able to distinguish safe products from hazardous ones without information and training.

Oregon OSHA's hazard communication rules – there are rules for general industry, construction, and agriculture – require employers to train their employees to recognize chemical hazards and to take the necessary precautions to protect themselves.

Most cannabis growers will follow the hazard communication requirements for agricultural employers.

Oregon OSHA requires employers to inform employees of hazards and identities of chemicals they are exposed to in the workplace, as well as protective measures that are available. Workplaces where employees may be exposed to hazardous chemicals must have a written hazard communication program that is specific to their workplace and includes:

  • A list of all the hazardous chemicals in the workplace
  • A description of the procedures for meeting the requirements for labels and other forms of warning, safety data sheets, and employee information and training
  • A description of the methods for informing their employees about the hazards associated with nonroutine tasks and the hazards associated with chemicals in unlabeled pipes in their work areas

How to implement an effective hazard communication program:

  • Review the hazard communication rule for agricultural employers (437-004-9800), and designate a person responsible for implementing the rule.
  • Determine how you will meet the requirements in 437-004-9800 and prepare a list of all hazardous chemicals in the workplace.
  • Ensure that the primary (shipped) labels on containers of hazardous chemicals are legible, in English, and prominently displayed on the container in the work area.
  • Have and review the safety data sheet (SDS) for each hazardous chemical that is used in the workplace, including residual pesticides encountered by workers doing field hand-labor operations. The SDSs must be readily accessible to all employees on all shifts. Where employees work at more than one workplace, the SDSs may be kept at the primary workplace.
  • Train employees about hazardous chemicals in their work area at the time of their initial assignment, and when a new physical or health hazard is introduced into their work area.
  • Evaluate the program. The hazard communication program must remain current.
  • Periodically reassess the program to make sure it is meeting its objectives and includes all hazardous chemicals in the workplace.

Hazardous energy and lockout/tagout

Most accidents that involve hazardous energy happen when workers release that energy on themselves or an unsuspecting co-worker. Energy exists in many forms, all of which are associated with motion, and it is motion that makes energy hazardous. Energy can harm you in different ways, depending on its form. The first step to control hazardous energy is to know the forms of energy that power the equipment you use and how that energy can harm you if you do not properly control it.

Lockout/tagout

Lockout/tagout refers to specific practices and procedures that safeguard employees from the unexpected energizing or starting of machinery and equipment, or the release of hazardous energy during service or maintenance activities. Most cannabis growers will follow the lockout/tagout requirements for agricultural employers (437-004-1275).

Lockout/tagout requires, in part, that an authorized employee turns off and disconnects the machinery or equipment from its energy sources before performing service or maintenance and either locks or tags the energy-isolating devices to prevent the release of hazardous energy. Authorized employees also should take steps to verify the energy has been isolated effectively.

Lockout devices hold energy-isolation devices in a safe or “off" position. They provide protection by preventing machines or equipment from becoming energized. They cannot be removed without a key or other unlocking mechanism. Tagout devices are prominent warning signs that fasten to energy-isolating devices to warn employees not to re-energize the machine while it is being serviced or repaired.

Lockout/tagout procedures

Employers must develop, document, and use lockout/tagout procedures for controlling hazardous energy. Documenting the required procedure for a particular machine or equipment is not necessary, however, when all of the following are true:

  • The machine or equipment has no potential for stored or residual dangerous energy or accumulation of stored dangerous energy after shutdown.
  • The machine or equipment has an easily identified and isolated single energy source.
  • The isolation and locking out of the energy source will eliminate all energy-related hazards.
  • The machine or equipment is isolated from that energy source and locked out during servicing or maintenance.
  • A single lockout device will achieve a locked-out condition.
  • The lockout device is under the exclusive control of the authorized person doing the servicing or maintenance.
  • The servicing or maintenance does not create hazards for other employees.
  • No incidents have happened that involved the unexpected activation or energizing of the machine or equipment during servicing or maintenance.

Training

Authorized persons must be trained to recognize of sources of hazardous energy, the type and amount of energy in their workplace, and methods to isolate and control the energy.

Other employees who work where energy control procedures are used must be trained about those procedures and not to restart or energize locked out or tagged out machines or equipment.

Indoor air quality and inhalation hazards

Cannabis growers can be exposed to a variety of organic solvents, cleaners, and disinfectants that can contribute to poor indoor air quality. These so-called inhalation hazards can affect the lungs, respiratory tract, and mucous membranes. They can also be absorbed into the bloodstream in the lungs and then distributed throughout the body.

The best way to find out if workers are overexposed to inhalation hazards is to sample the air they breathe – called air monitoring or exposure monitoring. An industrial hygienist, your workers' compensation carrier, or Oregon OSHA Consultative Services can perform air monitoring to determine employee exposure to possible inhalation hazards.

Ozone

Some indoor cannabis growers use ozone generators for odor control and high-intensity germicidal lights that can generate ozone. Ozone can decrease lung function and exacerbate pre-existing health effects, especially in workers with asthma or other respiratory problems. Where ozone exposure is possible, air monitoring should be done to ensure ozone levels are within Oregon OSHA's 0.1 parts per million (ppm) exposure ozone limit.

Ethyl alcohol and isopropyl alcohol

Growers frequently use ethyl alcohol and isopropyl alcohol for disinfecting. These chemicals are inhalation hazards and also flammable. Where ethanol or isopropyl exposure is possible, air monitoring should be done to ensure levels are within Oregon OSHA's exposure limits: 1,000 ppm for ethanol and 400 ppm for isopropyl alcohol.

Terpenes

Workers may also be exposed to terpenes and other volatile organic compounds from the cannabis plant. Terpenes are among the most common compounds produced by cannabis plants and are responsible for the fragrance of nearly all the flowers. Cannabis produces over 140 different terpenes, which can cause reactions ranging from eye, nose and throat irritation to headaches, vomiting, and dizziness.

Decarboxylation processes – heating cannabis to create the psychoactive component, THC – should use local exhaust ventilation to minimize workers' exposure to terpenes and the THC. NIOSH is currently evaluating the hazards of terpenes in the cannabis industry.

Safe practices

  • Train workers about the sources of inhalation hazards, the symptoms of overexposure, and the methods for controlling their exposure.
  • Complete air monitoring to determine employees' exposure to inhalation hazards.
  • Ensure adequate ventilation when chemicals are used indoors and HVAC systems are working effectively.
  • Establish a procedure for reporting indoor air quality complaints and determining how they will be addressed.
  • Eliminate possible ignition hazards within 50 feet of flammable liquids, including electrical equipment, open flames, spark producing equipment, and static discharge.

Ladders

Ladders are essential tools, yet more workers are injured in falls from ladders than from any other elevated surface – roofs, scaffolds, balconies, and even stairs. Most falls happen because workers select the wrong type of ladder for their job or they improperly set up the ladder and the ladder unexpectedly shifts or slips.

If you have employees who use ladders, make sure that you train them. Training should cover ladder hazards, how to use ladders, ladder capacities, and Oregon OSHA's requirements for the ladders they use.

Safe practices

  • Use ladders only for purposes approved or recommended by the manufacturer.
  • Do not load ladders beyond their working load rating.
  • Do not allow more than one person at a time on a ladder unless the manufacturer permits it.
  • Do not use ladders in front of doors that open toward the ladder without blocking, locking, or guarding the door.
  • Do not use ladders on boxes, barrels, or other unstable bases.
  • Do not use ladders with broken or missing steps, rungs, or cleats, broken side rails, or other faulty parts.
  • Do not splice sections of short ladders together to make a long one.
  • A ladder used to access a roof must extend at least three feet above the top support point at the eave, gutter, or roof line.
  • Secure ladders when they are used on surfaces that may allow them to slip or move.
  • Use portable ladders only on a surface that is stable and level.
  • Face the ladder and use both hands when climbing up or down a ladder.
  • Do not step or jump between erected ladders.
  • Do not use ladders as planks or bridges between walking surfaces.
  • Do not use ladders to gain additional height from elevated surfaces such as scaffolds, truck beds, vehicle bodies, tractor scoops, or boom truck buckets.
  • Do not use metal ladders or wood ladders with vertical metal parts for electrical work or where they may contact electric conductors.

Lighting

Overexposure to ultraviolet (UV) light is known to cause skin cancer, premature aging, immune system suppression, and eye damage. What many cannabis growers don't know, however, is that they may also be exposed to harmful amounts of ultraviolet light on the job.

Metal halide lights

Metal halide lights used in grow rooms have an inner arc tube that is similar to a welder's arc and emits intense ultraviolet radiation along with visible light. Normally, an outer glass bulb reduces the ultraviolet radiation; but, if the bulb is broken, ultraviolet levels can be significant enough to cause photokeratitis – a painful eye condition that happens when the eye is exposed to ultraviolet light. Symptoms include tearing, blurry vision, and the feeling of a foreign body in the eye that typically peak six to 12 hours after exposure. Broken metal halide bulbs should be immediately removed from service to prevent photokeratitis.

Ultraviolet lamps

Many growers also use ultraviolet lamps in their grow rooms. The effect of overexposure from UV lamps, which can affect eyes and skin, depends on ultraviolet intensity and wavelength, the body part exposed, and the sensitivity of the person to ultraviolet light. Symptoms of overexposed eyes include painful inflammation, a gritty sensation, and tears within three to 12 hours. Overexposed skin can burn within one to eight hours. Some medications can also increase a person's sensitivity to ultraviolet light.

Ultraviolet-C lamps in particular – often referred to as germicidal lamps – can cause painful burns on the skin and temporary damage to the cornea if observed directly.

LED and fluorescent lights

LED and fluorescent lights are also used in grow rooms. Health hazards associated with broken fluorescent lamps include lead, cadmium, and mercury.

Safe practices

  • Choose grow lamps with lower ultraviolet intensities.
  • Position ultraviolet bulbs at least eight feet above the ground.
  • Train employees how to take proper safety precautions with ultraviolet bulbs.
  • Never use germicidal lamps when workers are present. Rooms containing germicidal lamps should be interlocked to prevent access while lamps are on.
  • Display warning signs where ultraviolet-emitting bulbs are used.
  • Provide eyewear that protects workers from the ultraviolet wavelengths emitted by bulbs in grow rooms.
  • Encourage workers to wear long-sleeved shirts to limit their exposure to ultraviolet light.
  • Consider substituting metal halide lights with safer alternative lighting such as LED.
  • Operate metal halide and high-pressure sodium discharge lamps with the appropriate ballast, rated fixture, and socket.
  • Ensure that workers follow safe electrical practices when they change bulbs.

Disposing of used and broken lights

Lighting that contains mercury, such as fluorescent, high-pressure sodium, mercury vapor, and mercury halide lamps, is classified as “Universal Waste" and covered by the Oregon's hazardous waste regulations and the Resource Conservation and Recovery Act (RCRA).

Immediately remove broken bulbs from service. If a bulb is broken, the room should be ventilated and central forced-air heating and air conditioning should be shut off while repairs are made. Ensure that used and broken bulbs are disposed of as hazardous waste.

Do not vacuum broken bulbs. Broken glass should be swept onto stiff paper or cardboard. Sticky tape can be used to pick up small glass fragments and powder. Put used tape in a glass jar or plastic bag. Put clean-up materials in a sealed container.

Label used and broken bulbs as “Waste Lamp," “Used Lamp," or “Universal Waste Lamp." If the bulbs are placed in a container, only the container must be labeled – not the individual bulbs. Take the contents of the container to an appropriate disposal facility.

Machines

Most machines do not discriminate between people and widgets – the task is all that matters. That can be a problem when a machine has moving parts and a worker inadvertently gets too close.

Because grinders, trimming, chippers, and similar machines are used at cannabis grow facilities, it is critical that machines are properly guarded and maintained.

Assess all machines to identify hazards such as pinch points and exposed rotating parts. Safeguards should prevent workers' hands, arms, and other body parts from contacting dangerous moving parts.

Removable and interlocked machine guards

An interlocked guard may use electrical. mechanical, hydraulic, or pneumatic power or any combination of these. When this type of guard is opened or removed, the tripping mechanism or power automatically shuts off or disengages; the moving parts of the machine are stopped and the machine cannot cycle or be started until the guard is back in place. Replacing the guard should not automatically restart the machine. To be effective, all removable guards should be interlocked; however, energy control procedures may also be necessary during service or maintenance work to ensure the hazardous energy is isolated.

Employees who use machines and power tools may also be exposed to hazards that cannot be controlled unless they are protected by personal protective equipment (PPE). If there are such hazards, you must:

  • Select the PPE that protects your employees from the hazards.
  • Communicate your selection decisions to each affected employee.
  • Ensure that the PPE fits each employee.
  • Require your employees to use their PPE when they are exposed to the hazards.

Safe practices

  • Machines such as grinders that are designed for a fixed location should be securely anchored to prevent the machine from “walking" or moving.
  • Ensure that employees who use any type of machine are properly trained and recognize the hazards associated with the machine.
  • Never remove guards that are part of the machine. If it is necessary to service or repair the machine, use appropriate energy control procedures.

Mold

Mold can grow on any substance as long as moisture, oxygen, and organic material are present. Sunlight is not necessary, which is why mold is often found growing where it is damp and dark. Mold is a concern in cannabis production because of the higher levels of humidity – as high as 70 percent – in grow rooms.

Mold can trigger allergic reactions or asthma attacks and irritate the eyes, skin, nose, and throat.

Mold, which reproduces by creating tiny spores that usually cannot be seen without magnification, continually floats through indoor and outdoor air. However, a trained industrial hygienist can perform air monitoring to determine spore levels within the work environment.

It is impossible to eliminate all mold and mold spores, but controlling moisture and temperature can control mold growth. Ensure that the grow room is well ventilated, keep relative humidity below 50 percent in the cannabis-flowering phase, and keep the temperature below 77 degrees F. Use local exhaust ventilation to control airborne spores during grinding and bud trimming operations.

Disinfect the grow room after harvesting every crop. Use an Oregon Department of Agriculture approved fungicide or a 5 percent bleach solution. The ODA prohibits the use of sulfur dioxide gas. Exposure to sulfur dioxide can cause serious injury to the lungs.

Proper hygiene is also an important factor in controlling mold. Consider having workers change their clothes when entering the grow room and using foot-wash stations containing a sanitizer to prevent spores from contaminating the area.

Conduct a PPE hazard assessment to determine the need for respiratory protection, skin and eye protection, and protective clothing. An N95 or N100 respirator may be used to protect workers where cannabis dust is a problem and for employees who report even mild respiratory symptoms. Consider nitrile or other impervious gloves for employees whose jobs require direct handling of plants.

Some fungicides are oxidizing chemicals, which can cause a spontaneous fire when they contact flammable liquids (such as ethyl alcohol). Examples are peroxides and peracetic acid, which are often used to control mold. Oxidizing chemicals can also be corrosive to the eyes and skin.

Musculoskeletal disorders

When workers' jobs involve awkward postures or excessive effort to complete a task, fatigue and discomfort are often the result. As those jobs are repeated over and over, muscles, tendons, ligaments, nerves, and blood vessels are damaged. The resulting injuries are called work-related musculoskeletal disorders (WMSDs). They are also known as overexertion injuries, cumulative traumas, and repetitive motion injuries.

Unless we give our bodies enough time to recover or we change the work so that it's less stressful, we're setting ourselves up for a work-related musculoskeletal disorder.

WMSDs are easier – and less expensive – to treat in their early stages, but if left untreated, they can quickly become disabling.

Symptoms of WMSDs include:

  • Pain from movement, pressure, or exposure to cold or vibration
  • Change in skin color from exposure to cold or vibration
  • Numbness or tingling in an arm, leg, or finger, especially in the fingertips at night
  • Decreased range of motion in the joints
  • Decreased grip strength
  • Swelling of a joint or part of the arm, hand, finger, or leg
  • Fatigue or difficulty in sustaining performance, particularly of small muscle groups

Work-related musculoskeletal disorders can happen when workers do tasks necessary to accomplish their jobs in ways that put too much stress on their bodies. Some jobs have only one task, but most jobs have many tasks. How do you know which tasks are causing a musculoskeletal disorder? One way is to identify the factors that create risks for musculoskeletal disorders.

Risk factors are the parts of tasks that stress the body and increase the possibility of injury. They include:

  • Awkward postures
  • Excessive force
  • Repetitive motion
  • Pressure points
  • Vibration
  • Hot and cold temperatures
  • Eyestrain

When you identify the risk factors your employees are experiencing, you will have a better understanding of how musculoskeletal disorders happen and then you can take steps to control them. Common tasks and risk factors associated with WMSDs in cannabis growing environments include:

  • Stooping to pick up heavy objects
  • Awkward repetitive hand work, especially above shoulders
  • Reaching above shoulders to hang plants for drying
  • Repetitive hand work during trimming
Manual lifting, heavy objects

Manual lifting, heavy objects

Awkward repetitive hand work, especially above shoulders

Awkward repetitive hand work, especially above shoulders

Hanging plants for drying above shoulders

Hanging plants for drying above shoulders

Repetitive hand work during trimming

Repetitive hand work during trimming

Personal protective equipment

Employers must assess their workplaces to determine if hazards are present, or are likely to be present, that would make the use of personal protective equipment (PPE) necessary to protect their employees. If hazards are present, employers must:

  • Select and ensure that exposed employees uses the PPE that will protect them from the hazards identified in the hazard assessment
  • Select the PPE and ensure that it properly fits each exposed employee
  • Ensure that all exposed employees know about the selection decision

Most cannabis growers will follow Oregon OSHA's PPE rule for agricultural employers (437-004-1005).

Employers must provide PPE at no cost to employees, except for:

  • Safety-toe protective footwear (including steel-toe shoes or steel-toe boots) and prescription safety eyewear that employees are allowed to wear off the job site
  • Shoes or boots that employees with for employer-provided metatarsal guards
  • Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots
  • Skin creams, or other items, used solely for protection from weather

Employers must also pay for replacement PPE, except when the employee has lost or intentionally damaged it.

When employees provide their own PPE, employers do not have to reimburse them for the equipment. However, employers must ensure that the equipment is appropriate for the job and the job-related hazards.

All PPE must be maintained in a sanitary and reliable condition. Employees must not use defective or damaged PPE.

Require employees to wear and use personal protective equipment according to the manufacturer's instructions.

Employees working where they might contact moving parts of powered machinery or live parts of electrical equipment must not be allowed to wear rings, watches, earrings, bracelets, or similar items.

Training

Provide training to each employee required to use PPE that includes:

  • When PPE is necessary
  • What type of PPE is necessary
  • How to properly put on, take off, adjust, and use the PPE
  • The limitations and useful life of the PPE
  • The proper care, maintenance, storage, and disposal of the PPE

Employees must demonstrate an understanding of their training and the ability to use their PPE before they use it on the job. Employees must be retrained when:

  • They do not demonstrate an understanding of the skills required by their training
  • When changes in the workplace make previous training obsolete
  • When changes in the types of PPE to be used make previous training obsolete

Pesticides

A pesticide is anything that kills or repels a pest. Pesticides can cause skin irritation, eye damage, nervous system damage, reproductive problems, and cancer.

The Oregon Department of Agriculture (ODA) controls the sale, use, and distribution of pesticides in Oregon and considers cannabis an agricultural crop.

In Oregon, there are currently no registered pesticides labeled for use on cannabis. ODA developed criteria for pesticides for the production of Oregon cannabis. ODA has compiled a guide list of pesticide products that meet those criteria. Cannabis growers must follow the pesticide label instructions and only use pesticides from the ODA guide list.

Some pesticides include the words DANGER, WARNING, or CAUTION.

  • DANGER means that the pesticide is highly toxic by at least one route of exposure. It may be corrosive, causing irreversible damage to the skin or eyes. It may be highly toxic if eaten, absorbed through the skin, or inhaled, in which case the word POISON must be in red letters on the front panel of the label.
  • WARNING means the pesticide is moderately toxic if eaten, absorbed through the skin, inhaled, or could cause moderate eye or skin irritation.
  • CAUTION means the pesticide is slightly toxic if eaten, absorbed through the skin, inhaled, or could cause slight eye or skin irritation.

Pesticides and the Worker Protection Standard

The United States Environmental Protection Agency wrote the Worker Protection Standard (WPS) to reduce the risk of pesticide poisoning among agricultural workers and pesticide handlers. The requirements cover agricultural workers (people involved in the production of cannabis plants) and pesticide handlers (people who mix, load, or apply cannabis pesticides).

The WPS requires that employers:

  • Provide protection to workers and handlers from potential pesticide exposure
  • Provide training on the safe use of pesticides and how to avoid exposures (the WPS also establishes training requirements for workers and handlers)
  • Identify symptoms of pesticide exposures and know how to respond to exposures if they occur

Oregon OSHA enforces the requirements in the Worker Protection Standard, which apply whenever a pesticide has the words “Agricultural Use Requirements" on the label.

Safe practices

  • Read and follow the requirements on the pesticide label. The label includes instructions from the pesticide manufacturer to the pesticide user. The label is the law.
  • Inform workers about pesticide applications. The Worker Protection Standard requires employers to display information about pesticide safety, emergency procedures, and recent pesticide applications at a central location.
  • Select, use, and maintain personal protective equipment properly. The pesticide label may require personal protective equipment, including clothing, gloves, footwear, respirators, and eyewear.
  • Store pesticides according to the instructions on the label or the pesticides' safety data sheets.
  • Make pesticide labels and safety data sheets available to employees. Pesticide labels must be available where pesticides are prepared, and safety data sheets must be readily available for every pesticide that employees may be exposed to at work.
  • Plan a safe response to clean up spills and leaks. Pesticide spills can happen during transportation, storage, mixing, and application. Follow the three C's – Control, Contain, Clean Up – to manage spills.

Powered industrial trucks

There are many types of powered industrial trucks and each type presents different operating hazards. Most cannabis growers will follow the requirements for forklifts and other powered industrial trucks (437-004-1700) in Oregon OSHA's Division 4 rules for agricultural employers.

Only trained workers may operate powered industrial trucks, except those under direct supervision as part of the behind-the-wheel training program. Training must include:

  • A test covering the requirements in 437-004-1700, the information provided by the manufacturer for operation of the equipment, and any special information determined by the operating environment.
  • A behind-the-wheel training program, supervised by a person competent in the operation of the particular equipment and familiar with the area and circumstances of its use.

Tailor training to the type of powered industrial truck, the material being handled, and the site where the truck will be operated.

Conduct annual refresher training for drivers or when their driving record indicates the need for additional training.

A new worker is not considered trained and qualified based on experience from a previous employer unless the previous experience was on the same type of equipment, under substantially the same operating circumstances, and the worker had a safe operating record.

Powered industrial truck tip-overs

When a powered industrial truck tips over, the initial reaction of many drivers is to jump off of the truck. Unfortunately, this is a leading cause of serious injury. To minimize the chance of a tip-over:

  • Slow down before turning. Maintain a slow speed throughout the turn and slowly turn the steering wheel.
  • Lower the forks and tilt them back to keep the load stable.
  • Keep loads low and make sure the mast is tilted back for stability.
  • Do not load the forks beyond their maximum lifting capacity.
  • Do not move unstable loads.

Horseplay

Horseplay should be immediately addressed by supervisors. Operators must understand that irresponsibly driving a powered industrial truck endangers themselves and other employees.

Pedestrians

Pedestrian traffic must be considered when powered industrial trucks are in use. Powered industrial trucks and pedestrians should be separated when possible. Pedestrians always have the right-of-way, even if they are walking in a powered industrial truck's driving path.

Powered industrial truck drivers should always look in the direction the vehicle is moving – forward or backward. Always honk the horn at blind spots and intersections. If visibility is blocked because of a high load, drive the truck backward. If this is not possible, use a spotter. Make sure that no one is near the path of travel, and drive slowly.

Never let a person walk under raised forks, even if there is no load. And never lift a load that requires another person to position or hold the load while the powered industrial truck is moving.

Safe practices

  • Ensure that only trained and competent operators are permitted to operate a powered industrial truck. All powered industrial truck operators must be trained and certified by their employer.
  • Ensure that operators know the major parts and accessories associated with the powered industrial trucks they use and their hazards.
  • Ensure that operators understand the hazards and safe practices for each step in load handling.
  • Develop a program that includes a procedure for inspecting and maintaining powered industrial trucks before their use.
  • Require operators to use seatbelts when they are operating powered industrial trucks.
  • Never use a powered industrial truck to lift a person on the forks or to create an elevated work surface.

Work surfaces

Most cannabis growers will follow Oregon OSHA's Division 4, Subdivision D (Work surfaces) requirements for agricultural employers.

Housekeeping

Floors, work areas, aisles, and passageways must be in good condition and must not have protruding nails, obstructions, debris, or loose boards that create a hazard.

Aisles, walkways, inclines, and passageways

  • Aisles and passageways must be kept clear and in good repair. There must be clearance for the safe operation of material handling equipment.
  • Aisles, passageways, and walkways must be at least 22 inches wide. Passageways more than four feet above the ground or a floor level must have standard guardrails.
  • Fixed inclined walkways must be at least 22 inches wide, incline at no more than 24 degrees, and be securely fastened at the top and bottom. There must be guardrails on each open side.
  • Inclined walkways that may be slippery must have anti-slip surfaces or cleats secured at uniform intervals of not more than 18 inches, and extending the full width of the walkway.
  • Inclines from floor to floor, without open sides and used instead of stairways, must have standard handrails.

Wall openings

Wall openings with a drop of more than four feet must have one of the following:

  • A rail or an equivalent barrier.
  • An extension platform to receive hoisted materials for handling that has guard rails or an equivalent barrier.

Window wall openings

Window wall openings with a drop of more than four feet, and where the bottom of the opening is less than three feet above the floor, must have slats, grill work, or a standard railing.

Open-sided floors or platforms

Open-sided floors or platforms four feet or more above an adjacent floor or ground level must have a standard railing on all open sides, except where there is entrance to a ramp, stairway, or fixed ladder.

Surface loads

Post the load capacities on overhead storage areas constructed after Dec. 1, 1997. Do not allow overloading.

Pits, tanks, vats, and excavations

There must be protective barriers or suitable guards for uncovered openings or excavations that are accessible to vehicle or pedestrian traffic. Each open side of pits, tanks, vats, and excavations must have guardrails.

Vertical clearances

There must be a vertical clearance of at least 6 1/2 feet over work areas. Where it is impractical to provide this clearance, use padding, contrasting paint, or a similar warning on overhead obstructions.

 


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