Time to invest in several of those! I really appreciate the suggestion.
1 Like
Could you give me an example of what would be put under the Consultation subsection? I have completed all other areas, and I would like to post what I have for scrutiny but I did not want to leave it unfinished.
Edit: I assumed it meant having your processes validated by 3rd party individuals. I have had SO many people into my facility in order to audit our setup and processes. My papaw used to make RDX explosive back in the day and I felt that he had a pretty good bead on safety coming from facilities as such. Anyways, here is what I came up with for Safety Policies. I didn’t want to get too awful wordy but I feel that I have covered most of my bases. I would love feedback from individuals that are more knowledgeable in this area.
MMHC Safety Policy Statement.pdf (42.8 KB)
2 Likes
Don’t forget to actually got out in the parking lot and put stuff out with one.
They are not as effective as the chemical extinguishers…but if they’ve got what it takes, then the aftermath is not nearly as unpleasant.
3 Likes
We will definitely experiment! Thankfully, our bulk solvent is stored in a shipping container outside of the facility, and we only use <20L of solvent at a time. I know that is surely more than enough for a nasty mess, however. I couldn’t imagine running thru 1500L/hr like the Shyne facility. I just don’t understand why their fire suppression system failed! They took the time to implement it and explain it in their promo video, but it looks like the firefighters still had to wrestle it!
1 Like
I am so proud of you. That is really, really great work. I can tell that you have thought about it. I would think the next step is to print this for all employees and do a walk around to verify that reflects the situation on the ground.
I encourage people to use your verbiage keeping in mind that this is not a book report. The printed copy is there to define and reflect the actual practices which are drilled and refined continually.
2 Likes
I just want to thank YOU, Cat! For starting this thread, for encourging all of us to seriously consider these things, and for giving resources to promote thought on the subject. Everyone deep down thinks that it won’t happen to me, but the Shyne labs incident has definitely been a wake-up call for me. I am proud of where our processes and facility is currently at in development. When we started, I definitely resembled the remarks about garage wannabe chemists that were out of their element, and I am so thankful that we were able to scrounge enough together to elevate our equipment, processes, and knowledge to a level that we deem safe without serious injury or worse. However, we all know that work is never “finished”. I encourage other members that have a keen eye for safety both in practice and in theory to post their thoughts, documents, etc here in order to give myself and others insight into how they set up their safety protocols.
It would be really sweet if we could have examples to put together into a formal safety plan that companies can use as a guidance when they want to implement those procedures in their organization. I definitely feel that would fall right in line with the mission that @Future set out for when he open sourced his pesticide remediation SOP. I totally feel that free SOPs, guidance, and documents relating to lab safety would be huge to add to the arsenal of resources that Future4200 has to offer this industry!
4 Likes
Hi everyone!
Excited to contribute to the conversation around safety.
Some initial thoughts after reading this thread…
- While in general, having a close relationship with your local fire department is a great idea. One should remember, that for a facility of this size (shyne) you should keep urban search and rescue and HAZWOPER just as close.
This applies to a lot of us here. Scale and level of hazard are the two general axises although, if you read the Process Safety Management federal regulations you can get an idea of some of the others. At the level of shyne, they likely qualify on scale alone. But some of us here use pyrophoric substances and other dangers and could qualify on hazard.
This leads well into a second, more important, point.
- OSHA’s process safety management standards and site-specific monitoring program. These exists for highly hazardous materials and industries that handle them. Pretty soon here, OSHA is gonna catch notice and we will have had enough accidents under their scrutiny to qualify for these programs. We’re gonna be screwed if our industry ever does qualify for these. Things like the hydrocarbons we already use are on that list at the quantity of 10,000 pounds or more. But the worst thing could be getting cannabinoids added to that list in any quantity.
If the idea of making an IIPP scares you, then this program should make you wet your pants. Play time is over, your employees will be getting lung x-rays to ensure their PPE fits correctly, environmental sampling that rivals the medical industry, and worse - people could be restricted to operate in zones that have HAZWOPER public units (Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120(a), (p) and (q)). We can get around that by having an employee obtain the 40-hour HAZWOPER course or having a private HAZWOP response unit on standby. Either way, this would change the landscape of our industry.
We should be proactive as an industry to take safety seriously, so that this industry can remain accessible. Raising the level of entry to that of pharmaceutical or comparable industries won’t help anyone reading this right now.
But we do need to take safety seriously.
- While PPE is great, it is the actual worst safety control. Something as simple as an administrative control (the second worst) which is basically just safety rules, is considered to be a more effective safety control.
The administrative control could be as benign don’t jump off that cliff or maybe don’t run with scissors. It would be better to follow those rules, than to put a parachute near every cliff - or perhaps to require a butcher’s smock purchase with every scissor.
-
Don’t get complacent because of your controls. The Shyne facility definitely had the next best control from admin, which is engineering. Things like a safe-stop blade or a fire control valve, are engineering controls which do a better job of isolating the employee from the danger than the previous controls. But as many people know, they can fail as well. Our industry bears a heavy reliance on fixed gas detection systems, which are not perfect. Nothing is.
-
It is the synergy of all these systems in conjunction, with proactive safety at every level of the organization, which protects people.
-
Our IIPP.
This is not a final product.
This is a guide or template, that we give to California small businesses IN CONJUNCTION with our consulting services. We’ve added some exposition to try and help people create their own final product.
It is NOT a safety plan, but hopefully it helps some of you improve safety at your lab. At the very least, I hope it is helpful as you move through your own safety documentation.
This document has taken us many hours to compile, but it is important to share it now to maybe even save a life. All we ask is, please do not remove our logo from the header or our company name from the footer, if you choose to use this. We hope this encourages many of you to integrate what you find here with the information that pertains to your own unique lab.
CA_IIPP_AJCC_template_22.pdf (1.8 MB)
13 Likes
Great contribution to the conversation. Thank you for the documentation and I hope that people lean in to what you are offering on this thread.
2 Likes
Excellent addition! I learned a few things for sure. Do you offer consult outside of CA? I’m in MI.
3 Likes
I’m happy to hear that.
We are CalOSHA and FedOSHA experts, though we feel comfortable with any state’s specifics (they’re all substantially similar.) That said, we can do everything except help you appeal a citation in your state, that would be best left to a MIOSHA expert.
I will DM you to continue the conversation.
4 Likes
There is some good information here, I’m going to relay with the company and see if we can draft the template given, I definitely wasn’t prepared for the depth this requires, and I’m not the company owner, but I’m in charge of the lab, and now have a helper and I would like to take saftey seriously, throughout the whole facility, but formulating the actual saftey plan is more than I am capable alone, I can admit that.
Great job @MedicineManHempCo I might copy off your draft in the future as it’s a good start!
Thanks @Betterlivingwithchem some priceless foundational information!
4 Likes
I appreciate the kind words. I would like to be the first to point out that I am not a safety expert, and I would absolutely love for others to poke holes in what I have drafted as I know there is more work to be done on my “safety plan”.
3 Likes
You definitely have more knowledge than I do on this subject, you at least understand what it takes to formulate a decent draft that can be improved upon and that’s alot more than I got
3 Likes
As soon as I have all of ours in place, I will post up for a ripping as well. Anyone that can be an asshole and tear apart safety, is an actual friend. If they don’t want you to die and will point it out, I’d like their input.
Ours is part of the cGMP process and hope it will help others in the future. It is an extensive process and guidance usually costs you dollars.
4 Likes
Love reading through this thread!! Awesome conversation! Thank you @Sidco_Cat for bringing this up!
3 Likes
1 Like
Bathroom lunch is top tier efficiency though 
4 Likes
There’s a limit to efficiency. You found it!
2 Likes
