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Committee Insights | 7.13.23 | Know Your Hazards – Occupational Health and Safety Considerations in Cannabinoid Ingredient Manufacturing

NCIA’s #IndustryEssentials webinar series is our premier digital educational platform featuring a variety of interactive programs allowing us to provide you timely, engaging and essential education when you need it most.

In this edition of our NCIA Committee Insights series, originally aired on July 13, we were joined by members of NCIA’s Cannabis Manufacturing, Scientific Advisory and Hemp Committees for an in-depth discussion highlighting the occupational health and safety considerations to make during the manufacture of cannabinoids and provide recommendations for mitigating risk.

There is no mistaking that manufacturing cannabinoids is here to stay. It is more and more prevalent to see historically plant/naturally derived bulk ingredients being manufactured in a controlled environment in the lab or through innovative processes like precision fermentation. It is likely that bulk ingredient manufacturing of cannabinoids will go this route too.

For cannabinoids like HHC, that do not exist naturally in the plant or in high enough quantities to be commercially viable for extraction, it is most certainly the case that manufacture of these compounds will occur in the lab. To produce these compounds safely, we can luckily look toward existing regulations and occupational health and safety guidelines for producing novel ingredients for use in foods and non-foods.

Learning Objectives:

• Recognizing common occupational safety hazards associated with manufacturing cannabinoids and recommendation to mitigate these hazards

• Learning the different occupational safety considerations between isolation and purification of naturally occurring cannabinoids and the manufacture (synthesis) of cannabinoids in the lab

• Understanding the special safety considerations that processes like hydrogenation and others have and why these are critical to mitigating liability for your business

Panelists:

Jacob Enslein
Consultant
AJ Cannabis Consulting

Rhiannon Woo
Co-Founder & CSO
TraceTrust

Tenay Woodard
Director of Safety & Security
KIVA Brands, Inc.

Tucker Holland
Co-founder, CFO and Processing Director
Entourage Cannabis

Keith Butler
CEO
OP Innovates / Naturia+™

This is the fourth of five in a multi-part series of #IndustryEssentials webinars. You can watch Parts I-V at the links below.

Defining the Conversation: Minor, Novel & Synthetic Cannabinoids (Part I): https://bit.ly/3D2LReB

Meet the Minors (Part II): https://bit.ly/3qUD8Ip

Safeguarding Consumers in the Cannabinoid Product Landscape (Part III):

Know Your Hazards – Occupational Health and Safety Considerations in Cannabinoid Ingredient Manufacturing (Part IV)https://bit.ly/3rEUeKP

Concepts for Regulatory Consideration – Shifting the Conversation from “Cannabis vs. Hemp” to “The Cannabinoids” (Part V): https://bit.ly/3P3r5AW

Member Blog: Common Sense and Not – Tips to Maintain Safe Extraction Processes

by Xavier Jaillet, HAL Extraction

After years of trial and error, the modern extraction equipment and standard operating procedures have removed a significant amount of risk from volatile solvent extraction processes. As more and more states are looking to adopt marijuana policies involving volatile solvent extractions, I wanted to share some insights about safety I have learned in my 5 years of working in and with various extraction labs. Some of this may seem intuitive and obvious, some of it may not. 

Employee Safety

Employee safety is the most important facet of safety in an extraction operation. Your employees are your greatest variable, but also the things you want to protect the most. Loss of life or limb is no joke and can often contribute to significant fines, license suspension, or even a total shut down – not to mention the emotional strain an injury-inducing incident can put on everyone. 

I like to simplify employee safety into two areas: preparedness and equipment. Although your employees are a large variable in your operation, proper training, protective equipment, and process expertise will keep them safe from all but the direst of situations. Proper training should cover equipment usage, company SOPs, and hazard responses. Hazard responses will include emergency exit strategies, process shutdown, flushing station use, and will generally cover what an employee should do if hazardous conditions become present. Consistent training for your entire team will ensure that employee groups can regulate each other – one employee may catch another employee doing something that violates a company code and can prevent further incidents from occurring. 

Equipment, in this case, means the personal protective equipment, or PPE. All extraction processes involve pressure, chemicals, or moving machinery and can cause bodily harm to your employees. At a minimum, employees should habitually wear goggles, gloves, and closed-toed shoes. Given that there are chances for chemical spills and irritation from fine plant matter particles, long sleeves and pants are also recommended – most labs are providing lab coats for their employees to fulfill this need. It is generally advised that you, the employer, should make protective equipment accessible to your employees and not require them to provide their own equipment. If your extraction processes involve hydrocarbons, make sure employees are aware of static build-up from their clothes. It is important to note that PPE generally doubles to prevent foreign materials from contaminating your product – hair and beard nets will provide added protection. 

Equipment Safety

I like to consider equipment safety as an extension of employee safety because equipment failure or incident can typically be directly attributed to misuse by employees. Proper training is going to have the greatest impact on equipment safety, but installation, maintenance, and inspections will also dictate the longevity of your product and safe usage by employees. After selecting the proper unit for your operation, you should make sure that the unit is installed by a certified source. Most equipment manufacturers (EM) will offer training for you to have one of your employees be certified, or the EM will have a traveling resource that can visit your facility to ensure that install is done up to their standards. Once your unit has been installed, you need to have a 3rd party inspection done on your equipment and its operating area. One option is Pressure Safety Inspectors (PSI) – most local authorities will be happy to see a PSI stamp of approval and it will likely speed up your inspection process. 

After initial equipment set up and approval, equipment safety largely boils down to maintenance and employee inspections. Most extraction units use components that will degrade over time: seals, gaskets, nuts and bolts, solvent lines and filters to name a few. You should implement a consistent replacement schedule, regardless of the appearance of these components, to ensure that they don’t become liabilities.

Beyond components, employees should also be performing regular integrity inspections of all unit vessels – if any damage is apparent, it is paramount that you contact the manufacturer to replace that component. Do not perform repairs on your own. 

Facility Safety

Finally, we have facility safety. Luckily, modern technology has largely made facility safety autonomous – smart sensors detect solvents to ramp up airflow, fire suppression systems are automatically deployed, and control spaces can react efficiently to hazardous situations. However, because employees are still present, I do want to point out some areas that may be overlooked when it comes to facility safety.

First, signage. Signage can be anything from exit signs to hazardous material signs to reminders that PPE must be worn inside operating areas. Humans can be lulled into a sense of false security or forget important steps to operating safely and visual reminders go a long way to ensure that your employees are approaching their day to day tasks with the appropriate level of preparedness. Signs will also help employees efficiently vacate a space if there is a hazardous situation present – make sure your doors have panic bars and open outwards!

Another seemingly obvious, but often overlooked area of facility safety is the removal of ignitions sources from areas that contain hazardous materials. You must ensure that all equipment and components in a control area meet the electrical rating specified for that space. For example, a heat gun should never be used to expedite off-gassing of volatile solvents… it still happens more often than you would expect. Static build-up can occur because of certain textiles used in clothes along with plastic trash bags in plastic trash receptacles. Even tools should be spark-proof if they are going to be used in a control area. 

Hopefully, some of the above information helps you ensure that your extraction processes are operating as safely as possible. As a parting thought, please listen to your employee’s feedback. If they feel unsafe or are questioning a process, do not write them off. They are on the front lines working in hazardous environments and will often see an issue before it becomes a catastrophe. As always, this is meant to be a guide, and you should always consult local authorities and follow regulations. 


Xavier Jaillet has been a part of the cannabis industry since 2013 and worked in both businesses that are plant-touching and those that provide ancillary services to plant-touching operations. A brief stint in the mining, construction and transportation safety sector gave him a unique appreciation for safe operating practices and led him to HAL Extraction. HAL Extraction focuses on improving safety for manufacturing operations by designing smart, efficient, and effective extraction booths.

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