Cannabis Resources
The following is a list of resources we have gathered to support the Cannabis growing and manufacturing. It is offered without guarantee and does not constitute legal advice. For additional support in any of the areas covered by this content, please use the form on our Cannabis Services page so we can connect.
Relevant OSHA Programs
“This standard is designed to ensure that employers and employees know about hazardous chemicals in the workplace and how to protect themselves. Employers with employees who may be exposed to hazardous chemicals in the workplace must prepare
and implement a written Hazard Communication Program and comply with other requirements of the standard.”GENERAL REQUIREMENTS:
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Site specific written program.
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Product labels:
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Ideally manufacturer’s labels remain on the product
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For transferred products, the label must identify the chemical’s identity and any appropriate hazard warning
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List of hazardous chemicals (e.g., bleach, isopropyl alcohol) and if applicable physical agents (e.g., radiation) or infectious agents.
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Safety data sheets for hazardous chemicals used and stored in the workplace. These can be stored electronically but should be easily accessed.
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Employee training provided prior to working with hazardous chemicals and repeated annually.
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GENERAL REQUIREMENTS:
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Assess the workplace to determine hazards present, which necessitate the use of PPE. The PPE hazard assessment must be documented.
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Provide PPE and employee training appropriate for the hazards present. For example, eye or face protection to protect against corrosive chemical splashing or chemical resistant gloves when handling substances that can be absorbed through
the skin. -
PPE must meet relevant standards, such ANSI Z87.1 for Safety Glasses.
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Ensure PPE is used and maintained in a sanitary and reliable condition, replace whenever necessary.
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There are significant additional requirements for each type of PPE, especially respiratory, fall, and electrical protection.
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Federal OSHA: 29CFR1910.37 – Evacuation Routes
Federal OSHA: 29CFR1910.38 – Emergency Action Plans
Federal OSHA: 29CFR1910.157 – Fire Extinguishers
Federal OSHA: 29CFR1910.151 – Medical Services and First Aid“OSHA recommends that all employers have an Emergency Action Plan. A plan is mandatory when required by an OSHA standard. An Emergency Action Plan describes the actions employees should take to ensure their safety in a fire or other emergency situation.”
GENERAL REQUIREMENTS:
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Exit routes must be free and unobstructed.
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Each exit route must be adequately lit so that an employee with normal vision can see along the exit route.
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Emergency action plans are required to be documented, and all employees must receive training regarding their implementation.
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Install, visually inspect monthly, and annually maintain fire extinguishers.
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Provide safety shower and/or eye wash station when body or eyes may be exposed to corrosive materials.
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MN OSHA: 182.653 Rights and Duties of Employers. (link)
“Employers engaged in certain specific industrial classification codes are required by this legislation to develop and implement a written safety and health program with specific actions designed to reduce the incidence of workplace accidents and injuries.”
GENERAL REQUIREMENTS:
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Required for employers with NAICS code listed here. Medicinal and Botanical Manufacturing (NAICS 325412) is NOT on the list.
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Written program describing hazard identification, communication of safety measures, investigation of workplace incidents, corrective actions, and enforcement of safe work practices.
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Review the workplace accident and injury reduction program annually, document how the procedures included in the program are being met.
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Safety Committee is required if the employer has more than 25 employees.
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For the purpose of small hemp and cannabis retail operations, the primary requirements are related to container construction, grounding, and size. Flammable liquids should be stored in closed containers. The volume of isopropyl alcohol stored outside of a designated storage cabinet, should not exceed 120 gallons.
GENERAL REQUIREMENTS:
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Applies to hazardous substances with flash point and boiling point.
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Designates container design, size, construction, and grounding.
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Defines storage requirements, which vary based on volume of flammable liquids stored.
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Volume and flammable liquid category may include additional fire suppression, ventilation, and different wiring.
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Defines waste disposal requirements.
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Additional requirements for tanks and piping, which are out of scope.
RESOURCES:
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For the purpose of small hemp and cannabis operations, segregate incompatible chemicals and have a spill response plan. Certain types of chemicals are reactive with other chemicals. For example, bleach is reactive with most other chemicals. If bleach and ammonia are accidentally mixed because of leaking containers, toxic gases can be released.
GENERAL REQUIREMENTS:
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Separate by hazard class, not alphabetically or by physical state alone.
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Use Safety Data Sheets (SDSs) and container labels to identify hazards.
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Prioritize physical and health hazards, especially for chemicals with multiple hazard classes.
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Avoid storing incompatible chemicals in the same cabinet, unless physically separated.
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Use secondary containment (e.g., trays with high sides) to prevent cross-contamination.
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Label storage areas clearly by hazard class.
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Ventilate storage areas and avoid direct sunlight or heat sources.
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Limit quantities and ensure containers are tightly sealed and in good condition.
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“This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy could cause injury to employees.”
GENERAL REQUIREMENTS:
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This standard does NOT apply to “work on cord and plug connected electric equipment for which exposure to the hazards of unexpected energization or start up of the equipment is controlled by the unplugging of the equipment from the energy
source and by the plug being under the exclusive control of the employee performing the servicing or maintenance.” -
If the equipment has multiple sources of energy (e.g., electricity and hydraulic power), then a written Lock out/Tag out program, training, and equipment specificprocedures are required.
RESOURCES:
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“Moving machine parts have the potential to cause severe workplace injuries, such as crushed fingers or hands, amputations, burns, or blindness. Safeguards are essential for protecting workers from these preventable injuries. Any machine part, function, or process that may cause injury must be safeguarded. When the operation of a machine or accidental contact injure the operator or others in the vicinity, the hazards must be eliminated or controlled.”
GENERAL REQUIREMENTS:
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One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks.
RESOURCES:
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There are extensive requirements related to electrical equipment, wiring design, and installation (29CFR1910.303 through 307, and Federal OSHA: 29CFR1910.332 through 334). Wiring and Electrical equipment should be installed and maintained by qualified professionals. This summary will not cover their scope.
GENERAL REQUIREMENTS:
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The path to ground from circuits, equipment, and enclosures shall be permanent, continuous, and effective.
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Flexible cords may be used only in continuous lengths without splice or tap. They may not be used as a substitute for the fixed wiring of a structure.
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Flexible cords and cables may not be run through holes in walls, ceilings, or floors.
RESOURCES:
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“Minnesota law requires employers to provide some notices to their employees and requires certain posters to be displayed in a location where employees can easily see them. The posters and notices are available at no cost and need to be updated only
when Minnesota law changes.”RESOURCES:
Relevant Safety and Health OCM Requirements
GENERAL REQUIREMENTS:
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Standard operating procedures
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Procedures for responding to an emergency, including fire, loss of electrical power, robbery, natural disaster, and workplace violence
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Training records
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GENERAL REQUIREMENTS:
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Comply with all applicable Federal and State OSHA regulations
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Equip the premise with functioning carbon monoxide detection system
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Prominently display emergency procedures, including evacuation and shelter in place
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Comply with Hazard Communication/Right-to-Know
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Provide workers with information about the procedures for safely handling and operating equipment or tools.
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GENERAL REQUIREMENTS:
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Ventilation and air-handling systems with temperature and humidity controls that are adequate for safe processing and sanitary operations.
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Safe flammable liquid storage.
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Cannabis Industry Health and Safety Hazards
Sprains, strains, and other soft tissue injuries are the most common types of injuries. These often occur when lifting heavy and/or awkward objects. Additionally, repetitive motions, improper posture, and frequent use of hand tools can also contribute to the development of soft tissue injuries.
Using adjustable workstations and anti-fatigue mats can help reduce strain. It is also important to provide training on safe lifting techniques and mechanical aids. Additionally, supporting regular breaks and implementing task rotation can prevent repetitive strain and promote musculoskeletal health.Cannabis industry workers face significant respiratory health risks, particularly work-related asthma, due to exposure to cannabis dust, plant material, and other irritants like ozone, mold, and pesticides. Most cases of asthma are linked to cultivation and processing tasks, especially activities such as grinding and sifting dried cannabis, which have the highest levels of dust exposure.
Controls include limiting dry sweeping, using HEPA vacuums, implementing local exhaust ventilation, providing respiratory protection, and training employees on signs and symptoms.