Meeting Review: EHS and Security Concerns with the Cannabis Industry
Submitted by: Dennis Kelly, Pgh. AIHA Past-President
Safety Aspects of Cannabis Cultivation/Processing and Distribution
On Tuesday, December 10, the Pittsburgh Section of the American Industrial Hygiene Association hosted our monthly meeting at Ditka’s Restaurant in Robinson Township. Our guest speaker was Section Member Mr. Andrew Wright, CIH of ProTect-All Solutions, LLC.
Protect-All Solutions has recently expanded the scope of services to the emerging Cannabis industry. They are involved in health/safety/security issues for the growers, processors and dispensaries for the legal cannabis providers. Protect-All’s security group leader, Ms. Christina Wilson also discussed security concerns for cannabis facilities. Ms. Wilson’s full time position is Global Security Director for Alcoa, Inc.
While the focus of Mr. Wright’s presentation concerned health and safety issues in the production, processing and retail facilities, there was also an extensive discussion of the different products available in the market and their impact on the workplace.
A Nationwide Issue
Pennsylvania is now one of 33 states that have a medical marijuana program as of April 2016. In January 2018 the first dispensaries opened in the state. In addition in September 2019, Governor Tom Wolf announced that he was favorably disposed to legalizing recreational use of marijuana in Pennsylvania and urged the State Legislature to take up the issue.
In Pennsylvania 106,000 patients have been issued medical marijuana cards with some 1,600 physicians who have undergone certification to prescribe medical marijuana.
THC vs CBD – a Crucial Difference
Tetrahydrocannabinol (THC) is the primary psychoactive chemical component of marijuana and is responsible for the intoxication exhibited by users. Cannabidiol (CBD) is a related chemical with no (known) psychoactive properties. Both THC and CBD have important medical and therapeutic uses. CBD products are legal in all 50 states with various degrees of restriction. There is little to no Federal enforcement against CBD products. Almost all CBD products are marketed and sold as dietary supplements and NOT as drugs. The important difference is – the FDA regulates drugs, but NOT supplements. Thus, there is no comprehensive regulatory scheme for quality control of CBD products.
Per the FDA, the cutoff for classification of a cannabis product as THC-containing is a maximum concentration of 0.3% THC. Use of CBD products below 0.3% THC will theoretically not result in a positive drug test result. However, the problem for users of CBD products is that they can be contaminated, adulterated, or mislabeled due to the lack of regulatory control. A CBD product is ostensibly safe, but if it is contaminated with THC due to mislabeling or poor quality control, a user can potentially test positive for THC via urinalysis.
Occupational Safety Issues
Most cultivation of plants is done indoors under controlled conditions using various UV lighting and climate control. Harvesting the plants, especially in outdoor conditions, presents ergonomic issues such as repetitive stress disorders, fall hazards, and lifting/material handling issues. Exposure to UV light is an emerging issue, as is eye/dermal exposure to THC while handling buds and other plant parts.
Extraction of CBD and other components is a chemical process generally using some form of solvent extraction. Thus exposures to organic solvents, CO2, steam, and hydrocarbon extractants are considerations.
Operators, like many other businesses, are primarily concerned with producing and marketing their products, and have little to no familiarity with common safety issues such as confined spaces, LOTO, electrical safety and life safety issues such as fire extinguishers and means of egress.
Surprisingly to many in the audience, the legal marijuana business completely cash based. With so much cash on hand in the dispensary (dispensaries commonly have ATM machines installed right in the store) security considerations and identity verification of employees, visitors, delivery personnel and others become of prime importance.
With more and more states liberalizing the sale and use of CBD, medical marijuana, and legal recreational use of THC-containing products, the health and safety issues facing the industry are bound to increase in scope and complexity moving forward.
Extremely interesting meeting as you can imagine!
Thank you to the following attendees who participated in the event:
Andrew Wright, CIH owner and President of ProTect-All Solutions, LLC. He is an entrepreneur and is principle for Wright-Way Enterprises, Tigereye, Servus Group and Black Bottle. He has over 27 years of broad-based safety, health and environmental consulting, security and training experience in a variety of manufacturing, forging, metals, foundry, automotive, aerospace, transportation, oil/gas, instrumentation, chemical and pharmaceutical industries. He has provided process safety management and industrial hygiene expertise, facilitated preliminary hazard analysis and risk assessments, completed numerous third-party EHS, ISO 9001, and OHSAS 18001 audits. Developed audit protocols for a national software provider. In addition, Andrew has provided comprehensive EHS services including: development of energy isolations procedures, Extensive Third Party LTT audits, onsite health and safety training, facilityspecific written safety programs, compliance audits, machine guard assessments, ergonomic evaluations, work station/tool design, industrial hygiene surveys, PPE and exposure assessments, personal air monitoring, monitoring database development, process data calculations for air permits and Form R audits. He has developed a PSM data management for a web-based portal application. In addition, he has provided expert witness testimony for law firms in workers’ compensation cases. Mr. Wright is an experienced trainer who provides high-quality, highenergy presentations on a diverse range of topics. A passion for leadership and culture development, human element and reducing risk. His Company ProTect-All is a leader utilizing drone and ROV technology in reducing risk in confined spaces and elevation
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