Employment Safety and health play a central role in Germany. The fundamental law is on the implementation of employment safety measures to improve the safety and health protection of employees at work (Arbeitsschutzgesetz – ArbSchG) (1). This law and the rules and regulations impose more obligations on the employer than on the employee. Through cooperative collaboration, it is possible to significantly reduce the risks for employees and to optimize health protection in the corporation.
The industrial production of cannabis is quite new to Germany and it is, therefore, all the more important to consider which measures have to be taken to maintain the health of the employees. The production of cannabis is subject to the same requirements as all other work, depending on the work area and task, the spectrum of hazards can be quite broad.
The possible hazards can be roughly divided into the following categories:
Good quality and risk management is not only the basis for more informed decisions but also provides regulators with more reliable data on how professionally a company can manage potential risks. In principle, the employer must ensure that a risk assessment is carried out for each activity (2) The order of measures for employee safety is specified (Technical Rules for Industrial Safety TRBS 1111) and consists of the following levels S-T-O-P (3):
Substitution, i.e. replacing or defusing any cause of danger until the cause is no longer present. Hazardous substances e.g. non-hazardous substances and high voltage technology by low voltage technology.
• Technical measures
Avoiding danger e.g. by changing the working procedure or separating workers and danger by encapsulating dangerous machinery.
• Organizational measures
Limiting the exposure time of the worker to the hazardous conditions, e.g. through access controls.
• Personal measures
Personal protective equipment, such as safety shoes, safety gloves, protective goggles, dust masks, etc.
A hazard that cannot be eliminated by substitution must be eliminated by a technical solution. If this is also not possible, an organizational solution to the problem must be sought. Only when this does not lead to the desired result, should personal protective equipment (PPE) be used. The employer must instruct the employee with the correct information in how to use the personal protective equipment before it is used for the first time (4 & 5)
The risk assessment is the basis for the written workplace instructions (6, 7 & 8) which explains to the employee how the activity is to be carried out safely before the work equipment is used and in the event of relevant changes to the work procedure. For this purpose, an easily understandable color structure has proven to be useful for the documents (although this is not mandatory)9:
- blue for work equipment,
- orange for hazardous substances,
- green for biological agents and
- yellow for genetic engineering plants
If hazardous substances are used, employees must be given access to the safety data sheets on which the information for hazardous substances (“orange”) in the workplace is based.
Employers (or the delegated person) must at least once a year provide sufficient and appropriate training on employee safety and health (10) or authorized by an appropriate person (document, date, and content of the training!). Attention must always be paid to ergonomics (11) when setting up the workplace. Ergonomics ensures that the workplace and working conditions are well adapted to the characteristics and needs of the people. This is not only good for the health of the employees, but it will also help to improve their performance and protect against the long-term consequences of bad posture. Different components such as work equipment, work process, and work environments must be harmonized for an ergonomically healthy workplace.
Physical hazards can occur in many different forms. Here are a few examples:
Depending on the type of lighting used in a greenhouse, the source of danger is not only heat, radiation and bright light, but also a wide radiation spectrum from infrared to ultraviolet. Not only the eyes must be protected from UV radiation (risk of corneal inflammation) (12), but also the skin (risk of skin cancer) (13).
Depending on how the lamps are mounted, it may also be necessary to wear head protection to prevent injury from bumping into them (14).
The use of protective gloves may be particularly advisable when handling plants (working in damp environments), fertilizers, pesticides and cleaning agents. As with the handling of sharp objects (knives and scissors), the hazard analysis and operating instructions must specify the type of protective gloves to be used (15).
To prevent skin damage, suitable skin protection products must be selected and provided. A skin protection plan (16) must be drawn up for proper use in skin cleansing, skin protection, and skincare.
Stumbling, slipping and falling are the most common accidents. Therefore, appropriate foot protection is necessary on damp floors (17).
Compressed gases (18)
Physical problems with pressure and temperature can occur here (adiabatic cooling / Joule Thomson effect).
Electrical devices (19)
Must be tested before first use and regularly thereafter. The valid test seal must be applied visibly.
These may still occur even when a task as simple as cleaning rooms and objects has been carried out, as chemical cleaning agents and disinfectants could be used. Hazards could be also associated with the use of fertilizers and pesticides. The employees must have constant access to the safety data sheets.
Ozone is formed during cannabis cultivation by a chemical reaction of nitrogen oxides with volatile organic compounds (such as terpenes) emitted by the cannabis plants. Ozone can reduce lung functions or make those present worse.
Carbon monoxide can be produced when using generators. Even small concentrations of carbon monoxide in the air we breathe can cause serious symptoms of poisoning and become fatal after a short time.
Carbon dioxide is partly used to increase plant growth (and in some extraction processes). In high concentration, it is a choking agent and displaces oxygen. Symptoms can be headaches, dizziness, rapid breathing, difficulty in breathing and an increased pulse. In extreme cases unconsciousness and death. The workplace can be made safe with gas monitoring equipment because CO2 exposure must be detected quickly.
This could arise with the employees responsible for plant care. This activity could result in contact with pesticides, insecticides, fungicides, bacteria, and fungi. Particular attention must be paid to molds and their spores, which are given an ideal basis for life in the high humidity necessary for the plants. Mould (20) can lead to several clinical symptoms, such as shortness of breath, watery eyes, runny nose, hives, and other skin reactions. Adequate countermeasures for a healthy working environment would be appropriate ventilation or filtering of the air. There is currently no limit value for mold in Germany, but the limit values of other countries can be extremely helpful in analyzing the risk (21).
The examples of the hazards listed here are not exhaustive, but a small selection!
GMP (Good Manufacturing Practice) refers to guidelines for quality assurance of the processes and environment in the production of pharmaceuticals and foodstuffs. The guidelines of good manufacturing practices are intended to ensure that the quality of the products is right – at all times. Especially for employees who come into contact with the products, it must be ensured that they do not contaminate the products. Employment safety does not only concern the employees but is also intended to protect the products from possible contamination. The keyword here is personal protective equipment (PPE), which is mandatory in all companies in the pharmaceutical industry (22). Each step must be certified and validated before the start of production and is documented most accurately during production. It is important to have even the smallest change approved by the correct authority before use, including any changes in the equipment.
The various extraction processes with the associated employment safety precautions (fire and explosion protection) are deliberately not mentioned here due to their broad scope.
A risk matrix is helpful for the classifications in the hazard analysis. It represents a risk as to the combination of the probability of occurrence of a loss and the extent of that loss. The risk assessment is therefore carried out in the following stages
- Risk Identification
- Risk analysis
- Risk assessment
Ulrich Dahmen- Environment Health & Safety Expert
Dedicated, accomplished, multilingual EHS Specialist highly regarded for guiding EHS operations to ensure complete regulatory compliance for industry leaders. Out-of-the-box thinker who champions innovative solutions through in-depth data analysis, ensuring safety efforts match strategic company goals. Connect with him on LinkedIn
Cannabis Production and Employment Safety in Germany
Here the links to the regulations that I mentioned in the text:
- https://www.gesetze-im-internet.de/arbschg/ html
- http://www.gesetze-im-internet.de/psa-bv/ html
- https://www.gesetze-im-internet.de/betrsichv_2015/ html
- https://www.gesetze-im-internet.de/gefstoffv_2010/ html
- https://www.gesetze-im-internet.de/biostoffv_2013/ html
- https://www.gesetze-im-internet.de/arbschg/ html
- https://publikationen.dguv.de/regelwerk/regelwerk-nach-fachbereich/persoenliche- schutzausrustungen/fussschutz/1353/benutzung-von-fuss-und-knieschutz
- https://publikationen.dguv.de/regelwerk/regelwerk-nach-fachbereich/energie-textil-elektro- medienerzeugnisseetem/elektrotechnik-und-feinmechanik/1052/elektrische-anlagen-und- betriebsmittel
- https://umweltbundesamt.de/themen/gesundheit/umwelteinfluesse-auf-den- menschen/schimmel/haeufige-fragen-beischimmelbefall#textpart-1