Guest Post: Safe Work in Minnesota's Cannabis Industry

Cathy Hovde
Dec 10, 2025
5 min read

Updated: 7 days ago

Minnesota Right-to-Know Requirements

January 8, 2026

As Minnesota’s cannabis industry continues to expand, employers are navigating a regulatory landscape that blends traditional workplace safety rules with the unique hazards of cannabis cultivation, processing, and retail operations. Within OCM’s worker safety requirements, is a requirement to comply with Minnesota Employee Right-to-Know (ERTK) Standard, found in Minn. Stat. § 182.653 and Minn. R. 5206.

Whether you’re a grower, manufacturer, testing lab, or dispensary, ERTK applies to you. Below I will break down what employers must do to stay compliant and protect their workforce.

WHY ERTK MATTERS IN CANNABIS WORKPLACES

Cannabis operations involve a mix of agricultural, chemical, and industrial processes. Employees may be exposed to:

Fertilizers, pesticides, and nutrient solutions
Cleaning and sanitation chemicals
CO₂ enrichment systems
Solvents used in extraction
Biological hazards such as mold
Physical hazards like repetitive motion

ERTK ensures workers understand these hazards and know how to protect themselves. It’s not optional, it's a core requirement of Minnesota OSHA.

KEY ERTK REQUIREMENTS FOR CANNABIS EMPLOYERS

1. Written ERTK Program (MN OSHA Model Program)

Every cannabis employer must maintain a written program describing:

How hazardous substances, harmful physical agents, and infectious agents are evaluated

How training is conducted
How Safety Data Sheets (SDS) are managed
How non-routine tasks and new hazards are communicated

This document must be accessible to employees at all times.

2. Safety Data Sheets (SDS) and Chemical Inventory

You must maintain SDS for all hazardous chemicals on site, including:

Isopropyl alcohol
Butane, propane, or other extraction solvents
Cleaning agents
Pesticides and plant nutrients

SDS must be readily accessible, both physical and digital access is acceptable.

3. Employee Training

ERTK training must be:

Provided before an employee begins work with any hazardous substance or agent
Repeated annually
Documented with dates, topics, and trainer information

Training must cover:

Hazard recognition
Safe handling and storage
PPE requirements
Emergency procedures
Labeling and SDS use

For cannabis operations, this often includes specialized topics such as CO₂ monitoring, compressed gases, and mold prevention.

4. Labeling Requirements

All containers, primary and secondary, must be labeled with:

Product identity
Hazard warnings
Manufacturer information

Improperly labeled spray bottles, nutrient mixes, or solvent containers are among the most common citations.

5. Non-Routine Tasks & New Hazards

If employees perform tasks outside their normal duties (such as deep cleaning, equipment maintenance, or extraction system troubleshooting) you must provide task-specific hazard training.

When new chemicals or processes are introduced, training must be updated immediately.

ERTK IN CANNABIS: COMMON COMPLIANCE GAPS

From my work, the most frequent issues include:

No written ERTK program
Missing or outdated SDS
Incomplete or undocumented training
Secondary containers without labels

These gaps are preventable, and correcting them strengthens both compliance and worker safety.

BOTTOM LINE

ERTK is more than a regulatory checkbox, it’s a foundational safety requirement that protects employees and reduces operational risk. For cannabis businesses, where hazards span multiple disciplines, a robust ERTK program is essential.

WANT MORE GUIDANCE OR SUPPORT?

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The Most Common OSHA Citations

December 22, 2025

With the expansion of cannabis industries across cultivation, extraction, distribution, and retail, states such as Michigan have developed OSHA emphasis programs specifically for the cannabis sector. While the industry feels new, the violations showing up are the same ones OSHA cites across general industry year after year: Hazard Communication, PPE, electrical safety, and emergency preparedness.

Note: The OSHA trends discussed here use inspection data from businesses sharing the cannabis industry code, which includes both cannabis and similar businesses.

HAZARD COMMUNICATION (HAZCOM) / EMPLOYEE RIGHT-TO-KNOW

MN OSHA: Chapter 5206

Federal OSHA: 29CFR1910.1200

In Minnesota, HazCom is known as Employee Right to Know. HazCom remains one of OSHA’s most frequently cited standards nationwide. Cannabis facilities handle fertilizers, pesticides, nutrients, cleaners, flammable liquids, carbon dioxide, and cleaning chemicals. Many lack complete Safety Data Sheet (SDS) libraries, proper labeling, employee training, or a written HazCom program

PERSONAL PROTECTIVE EQUIPMENT (PPE)

Federal OSHA: 29CFR1910.132 through 29CFR1910.138

Electrical wiring methods and general electrical requirements regularly appear on OSHA’s most cited lists. Rapid buildouts, retrofits, and high demand equipment (grow lights, HVAC, extraction systems) often lead to overloaded circuits, exposed wiring, and improper installations.

ELECTRICAL AND WIRING

Federal OSHA: 29CFR1910 Subpart S – Electrical

EMERGENCY RESPONSE AND PREPAREDNESS

Federal OSHA: 29CFR1910.37 – Evacuation Routes

Federal OSHA: 29CFR1910.38 – Emergency Action Plans

Federal OSHA: 29CFR1910.157 – Fire Extinguishers

Federal OSHA: 29CFR1910.151 – Medical Services and First Aid

Emergency planning issues frequently surface during inspections: blocked exits, missing emergency action plans, inadequate fire extinguisher training, and absent eyewash stations. Facilities using flammable solvents or compressed gases face elevated risks when emergency procedures aren’t clear and practiced.

WHY THIS MATTERS

The cannabis industry may be emerging, but OSHA’s expectations are not. Strengthening HazCom, PPE programs, electrical safety, and emergency preparedness is the fastest way to reduce risk—and avoid the citations that dominate enforcement across the country.

Navigating OCM Requirements

December 10, 2025

Worker safety in Minnesota’s cannabis and hemp industry is governed by the Office of Cannabis Management (OCM) and Minnesota Occupational Health and Safety Administration. The rules are spread across several sections of state regulation, depending on the type of business. Below is a streamlined guide to the key requirements specific to worker health and safety.

GENERAL WORKER SAFETY (RULE 9810, 1102: CANNABIS AND HEMP WORKERS)

All cannabis and hemp businesses must:

Provide annual training covering:
- Standard operating procedures, including safety protocols
- Emergency response procedures for fire, power loss, robbery, natural disasters, and workplace violence
Comply with all applicable federal and state OSHA regulations
Equip premises with a functioning carbon monoxide detection system
Prominently display emergency procedures, including evacuation and shelter-in-place instructions
Comply with Minnesota’s Right to Know regulation, ensuring workers are informed about hazardous materials they may encounter
Provide workers with safe handling and equipment operation procedures

MANUFACTURING FACILITIES (RULE 9810, 2102: MANUFACTURING)

Cannabis and hemp manufacturing facilities must:

Maintain ventilation and air-handling systems with temperature and humidity controls adequate for safe processing and sanitary operations
Install lighting fixtures sufficient for safe manufacturing and sanitation tasks
Provide hand-washing facilities in all areas where unpackaged product is handled

CONCENTRATE MANUFACTURING (RULE 9810, 2205: CANNABIS AND HEMP CONCENTRATE)

Businesses manufacturing cannabis or hemp concentrates face additional requirements:

Electrical, gas, fire suppression, and exhaust systems, along with hazardous substance storage and disposal plans, must be certified by an industrial hygienist or qualified professional engineer
Even if no solvents are used in extraction, concentration, or conversion, businesses must obtain an exemption letter from a qualified professional

WHY THIS MATTERS

Minnesota’s cannabis regulations highlight a clear priority: worker safety, hazard prevention, and compliance. Whether you’re running a cultivation site, retail business, or manufacturing facility, these rules ensure that employees are trained, protected, and supported with safe infrastructure.

This isn’t just about meeting legal requirements—it’s about building a resilient industry where safety and health are integral to success.

COMING UP NEXT

In future posts, I’ll explore:

Key safety programs such as Right to Know, Personal Protective Equipment (PPE), and Respiratory Protection

Stay tuned for practical insights that will help you strengthen compliance while creating safer workplaces.

Cathy Hovde is the Founder of Resilient EHS. She specializes in industrial hygiene and workplace health, helping organizations turn complex safety rules into clear, practical solutions. With experience teaching and consulting across industries, Cathy is passionate about empowering workers and employers to build safer, more resilient environments. To contact or learn more about Cathy and her organization check out her website at www.ResilientEHS.com.