What safety training do cannabis workers need?
All employees who work in an area that has recently applied pesticides need to have Worker Protection Standards (WPS) training.
Pesticide Handlers are defined as those who mix, load, or apply agricultural pesticides; clean or repair pesticide application equipment; or assist with the application of pesticides.
Agricultural Workers are defined as: those who perform tasks related to growing and harvesting plants on farms or in greenhouses, or for nurseries.
These definitions would generally include all employees who work in a cultivation facility. The only exception would be if the trimmers were not involved in harvesting and were prevented from entering the grow areas. To be safe facilities should train all their employees.
The training for handlers is the same training as for agricultural workers but with additional information on personal protective equipment and on safe procedures for applying, cleaning, transporting, and disposing of pesticides. Many cultivation facilities train all their employees for pesticide handling, so they are not limited in the tasks they can partake in.
At one time there was a month’s grace period for this training, but that no longer exists. All employees need this training before they enter an area affected by pesticides, unless they are licensed pesticide applicator. This training can be done by a licensed pesticide applicator or someone who has completed an EPA-approved WPS Train-the-Trainer workshop. Employees who are not licensed pesticide applicators must have this training every 12 months.
The WPS training focuses on the pesticide hazards, but there are many other hazards in a cannabis facilities, that an employer must train their employees in. The OSHA General Duty Clause states ‘of the Occupational Safety and Health Act, requires that each employer to provide their employees a workplace free from recognized hazards likely to cause death or serious injury.’ No person should ever be injured, become ill, or die for a paycheck. OSHA believes that training is an essential part of every employer’s safety and health program for protecting workers from injuries and illnesses.
It is a best practice to keep a record of all safety and health training. Like most bureaucracies OSHA likes paperwork, and documentation can answer one of the first questions an incident investigator will ask: ‘Did the employee receive adequate training on the job?’ All employees should be trained in the facility's hazards when they are hired as a part of their onboarding process, but annual training is strongly recommended to prevent complacency.
Most but not all hazard training is up to the owner’s discretion. OSHA mandated training must be documented by the facility’s or company’s Safety Program. At a minimum, the Safety Program training should include Hazardous Communication Plan, and either an Evacuation Plan or Emergency Action Plan. Other common plans and training that may be required are:
- Respiratory Protection Program,
- Lockout-Tagout or Energy Control Plan,
- Hearing Conservation Plan,
- Working at Heights Training Program, and
- Confined Space Entry Program.
I will go deeper into these Safety Program plans in future blogs. If you have any questions please contact us.