Heather Despres – Patient Focused Certification Program, Americans for Safe Access
As more states and territories enact cannabis regulations, the need for comprehensive health and safety programs increases. Almost daily, news stories are published that cite health and safety violations by cultivators, manufacturers, and even laboratories. Many of these safety events could have been avoided by simply putting in place an environmental health and safety plan that is in compliance with state and other regulations. Examples of other relevant regulations include rules outlined by the Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), and the National Fire Protection Association (NFPA).
Not all states have health and safety requirements written into their regulations, so it is incumbent upon businesses to take the steps necessary to protect both their workers and the consumers of the products they are making. Worker safety should be factored into every process as it is developed, beginning in the application phase. When businesses are applying for a license, they should be factoring in how the construction of their facility and development of quality processes and standard operating procedures will play into the overall health and safety of their operation, their products, and the environment around them.
For example, electrical loads on older warehouses, buildings, and even residential homes are severely taxed when the electrical lines of these facilities are not updated and upgraded prior to plugging in equipment and machinery such as light ballasts, manufacturing equipment, and laboratory equipment. Access to these spaces also poses an issue for first responders since buildings that house cannabis operations tend to be harder to get into due to strict security requirements.
Another area of concern is the equipment being used, particularly when it comes to extraction equipment. Many state regulations include provisions for the type of solvents that can be used in the production of cannabis concentrates and the type of equipment that may be used. Solvents typically approved for use include carbon dioxide (CO2) and, in certain jurisdictions, hydrocarbons (e.g., butane, propane). The types of solvents used are of concern because of the potential for hydrocarbon residues to remain in the concentrates that would ultimately be consumed, though most states have taken steps to mitigate this by imposing strict limits on the amount of residual solvents that can remain in products. Additionally, given their explosivity, hydrocarbon solvents can pose a risk to employees and manufacturing operations if they are not stored and handled according to strict safety guidelines.
The methods of extracting cannabinoids also pose a safety hazard that should be thoroughly explored by all facilities engaging in this activity. Solvent extraction is done using equipment that is operated at high pressures – especially so when CO2 is being used as the solvent – and businesses should ensure that it meets the specifications required by state regulations and that all employees using this equipment are trained in its operation and maintenance. Explosions can result from improper usage and from attempting to use equipment that wasn’t designed to perform cannabis oil extractions.
Facilities must be prepared for emergencies. If a fire were to break out, do employees know where fire extinguishers are and how to use them? If someone is injured on the job, is there a first aid kit available? If a patient has a medical emergency inside a dispensary, do employees know how to respond appropriately? If a product is found to be contaminated, are there recall procedures in place to protect consumers?
The state boards that are in charge of implementing these programs are tasked with protecting workers and consumers alike, but many of these agencies lack the resources to adequately inspect each facility on a regular basis. As a result, things can slip through the cracks. What can businesses do to protect employees and consumers? They should start by making a commitment to the health and safety of the environment and their employees.
A robust environmental health and safety plan is the first step in ensuring that employees are safe and know what to do in the event of an emergency. The next step is training all employees to react to any situations that may arise, no matter the type of emergency. Third-party certification programs, like the Patient Focused Certification (PFC) offered through Americans for Safe Access, give consumers confidence that the certified business has undergone a thorough assessment, which includes verifying that equipment has been installed properly and that employees have been trained on correct usage. The PFC program also ensures consumer safety by checking that products are being tested to appropriate standards and that the laboratories performing the testing have implemented quality control procedures including method validation and equipment calibration. If your business does not have a quality training program or environmental health and safety policies, PFC can help with those as well.
Health and safety issues are present in every industry, and the cannabis industry is no exception. Until there is oversight at the federal level, businesses must take it upon themselves to operate in a manner that is consistent with the regulations in their state and the guidelines that federal agencies use for other industries. The PFC program and PFC-certified seal give regulators and consumers confidence that the certified business is operating according to the highest standards of safety and quality.
