A Review of Current Occupational Safety and Health in the Washington Cannabis Industry
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1 A Review of Current Occupational Safety and Health in the Washington Cannabis Industry Sally Buckingham, M.S. Standards and Technical Services WA State Department of Labor and Industries Division of Occupational Safety and Health (DOSH)
2 Workplace safety and health is regulated by Labor & Industries Division of Occupational Safety and Health (DOSH). We are an OSHA State Plan state. As such, we apply the Washington Administrative Codes (WACs). We inspect any employer site with one or more employee; including municipalities and agriculture. Washington State Department of Labor & Industries 2
3 Our Cannabis Licensees Producers: 1,149 Processors: 1,517 Retailers: 1,854 Source: Washington State Liquor Cannabis Board Washington State Department of Labor & Industries 3
4 Growers Washington State Department of Labor & Industries 4
5 Our agriculture standard applies to any grower indoor or outdoors. The worker protection standard (WPS) contains provisions for pesticide-related safety and health requirements. The Washington State Department of Agriculture provides training for handlers and workers in agricultural establishments. Many producers grow cannabis alongside their fruit orchards. Washington State Department of Labor & Industries 5
6 Washington State Department of Labor & Industries 6
7 Washington State Department of Labor & Industries 7
8 Washington State Department of Labor & Industries 8
9 WSDA Maintains a List of Approved Pesticides For Use on Cannabis Washington State Department of Labor & Industries 9
10 Amputations Electrical Hazards Cylinder handling Do It Yourself Equipment Hazards Washington State Department of Labor & Industries 10
11 Washington State Department of Labor & Industries 11
12 Washington State Department of Labor & Industries 12
13 Washington State Department of Labor & Industries 13
14 Awkward Positions Bending Stooping Lifting Twisting Ergonomic Hazards Washington State Department of Labor & Industries 14
15 Pesticides Cleaning Agents Flammable Gas/Liquid Carbon Dioxide Any chemical product used in an occupational setting Washington State Department of Labor & Industries 15
16 Washington State Department of Labor & Industries 16
17 Confined Spaces Washington State Department of Labor & Industries 17
18 Plant Extraction Processes Not New to Washington State Washington State Department of Labor & Industries 18
19 Washington State Department of Labor & Industries 19
20 DOSH doesn t have vertical WACs directed at cannabis extractions, but applies existing rules to those employers. If we see conditions that warrant an inspection by the local building inspector, we refer the information to that authority. Washington State Department of Labor & Industries 20
21 Respirators Facemasks Gloves Safety glasses/goggles Personal Protective Equipment Washington State Department of Labor & Industries 21
22 Washington State Department of Labor & Industries 22
23 UV Eye Protection Wavelength-Specific Washington State Department of Labor & Industries 23
24 Washington State Department of Labor & Industries 24
25 Bacteria Endotoxins Vegetative Dust Fungi Molds Biological Hazards Washington State Department of Labor & Industries 25
26 Respiratory Disease Chest Tightness Shortness of breath Cough Farmer s Lung (Hypersensitivity Pneumonitis) Exists in conditions where organic antigens reside in optimal growth conditions. Farming, birdkeeping, etc. Washington State Department of Labor & Industries 26
27 Case Summary: Ventilation Issues at a Cannabis Grow and Extraction Business Labor dispute blamed for the complaint The pressure relief valves on the CO 2 equipment relieve to the room instead of outdoors CO 2 used for growth as well as extraction Ductwork intended to move CO 2 around had no fresh/outdoor return air, and leaked throughout the building. Not dissimilar to an anesthetic gas scavenger used in an operating room. Garage and front door opened once a day for ventilation Allegations: CO 2 levels too high in all areas of the facility Harvest rooms not properly ventilated PPE requirements not followed Washington State Department of Labor & Industries 27
28 Observations: Significant elevation of CO 2 but below the PEL No oxygen monitoring No/ineffective personal protective equipment No written hazard communication program No hazard communication training No emergency washing Washington State Department of Labor & Industries 28
29 Recirculating stale air with CO 2 throughout the building s HVAC system Harvest Room: 4 exhaust vents, 4 return air vents, and 14 fans Trimming/packaging area used to be a break room Washington State Department of Labor & Industries 29
30 Pressure relief valves should relieve CO 2 through enclosed equipment that safely routes it outdoors. Washington State Department of Labor & Industries 30
31 Washington State Department of Labor & Industries 31
32 One hospitalization for asthma-like symptoms Employer stated that they had 10 employees, thinking that DOSH couldn t enforce our rules with fewer than that (per OSHA). In Washington State, we enforce if there is one or more employee Water leaks/damage inside, mold and mildew present Observation of 1440 fpm at each exhaust intake in the extraction rooms CO 2 -laden air goes into the lobby area at around 800 ppm The employer was aware of these hazards Washington State Department of Labor & Industries 32
33 When informed of the CO 2 atmospheric hazard during the inspection, the employer acknowledged his understanding of the hazard, and stated, Carbon dioxide is a reasonable way to kill pests. During the closing conference, the DOSH inspectors were informed that the employer was dissolving the business and moving to New York The owners were a board-certified anesthesiologist and a registered nurse. In New York. Washington State Department of Labor & Industries 33
34 Looking Ahead Washington State Department of Labor & Industries 34
35 Developing a partnership with the State Building Code Council and State Fire Marshal s office Identify building code personnel in every county to contact for referrals Develop ongoing dialogue with stakeholders Participate in industry conventions and events Create specific worker health and safety outreach documents for growers and processors Offer consultation services prior to programmed enforcement action Washington State Department of Labor & Industries 35
36 Questions? Washington State Department of Labor & Industries 36
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Proposal and Contract for HOME BUILDING and HOME REPAIR;
Proposal and Contract for HOME BUILDING and HOME REPAIR; Date of Proposal: Attachments Comprising the Contract: [ ] General Conditions of Contract [ ] Plans and specifications [ ] Allowances Sheet [ ]
APPLICATION FOR INITIAL REGISTRATION FOR ASBESTOS-RELATED WORK
STATE OF CALIFORNIA DEPARTMENT OF INDUSTRIAL RELATIONS DIVISION OF OCCUPATIONAL SAFETY AND HEALTH APPLICATION FOR INITIAL REGISTRATION FOR ASBESTOS-RELATED WORK TABLE OF CONTENTS APPLICATION INSTRUCTIONS