Guest Post: Safe Work in Minnesota's Cannabis Industry
- Cathy Hovde
- Dec 10, 2025
- 7 min read
Updated: Jan 21
Personal Protective Equipment (PPE) Requirements
January 21, 2026
Ensuring worker safety in cannabis cultivation, processing, and retail settings goes beyond best intentions—it demands strict adherence to OSHA’s PPE standards and an informed awareness of the specific hazards present in these environments. In this newsletter edition, we outline the essential responsibilities for employers: what must be provided, documented, and taught to maintain compliance and protect employees.
To help you develop a thorough, hazard-based PPE program, the following guidance organizes requirements by type. While not exhaustive, these examples offer a practical starting point for compliance. You’ll find additional resources at the end of this newsletter to further support your safety efforts.
OSHA REQUIREMENTS FOR PPE
Federal OSHA Standard: 29 CFR 1910.132–1910.138
Under OSHA's Person Protective Equipment standards, employers must:
Assess the workplace to determine hazards present, which necessitate the use of PPE. The PPE hazard assessment must be documented.
Provide PPE and employee training appropriate for the hazards present.
PPE must meet relevant standards, such as ANSI Z87.1 for Safety Glasses.
Ensure PPE is used and maintained in a sanitary and reliable condition, replace whenever necessary.
There are significant additional requirements for each type of PPE, especially respiratory, fall, and electrical protection.
EYE AND FACE PROTECTION
OSHA Standard: 29 CFR 1910.133
ANSI Standard: Z87.1
When Required:
Chemical splashes (cleaning agents, disinfectants, extraction solvents)
Dust from trimming, grinding, and sifting
UV exposure in grow rooms
Flying particles from machinery or packaging equipment
Relevant Hazards:
Cannabis dust and pollen
Ozone exposure
Solvent handling during extraction
Recommended PPE:
Safety glasses (ANSI Z87.1)
Chemical splash goggles
Face shields for high‑splash tasks
UV‑blocking eyewear for grow lighting
HAND PROTECTION
OSHA Standard: 29 CFR 1910.138
When Required:
Handling chemicals, disinfectants, or pesticides
Working with solvents (e.g., isopropyl alcohol)
Trimming, cutting, or working with sharp tools
Exposure to plant material or mold
Relevant Hazards:
Sensitization from plant contact
Dermal exposure to pesticides or cleaning agents
Recommended PPE:
Nitrile or chemical resistant gloves (SDS based selection)
Cut resistant gloves for trimming and equipment cleaning
Heat resistant gloves for packaging equipment
BODY PROTECTION (CLOTHING, LAB COATS, APRONS)
OSHA Standard: 29 CFR 1910.132
When Required:
Chemical splash risk
Mold or biological exposure
Solvent handling
High‑dust tasks
Relevant Hazards:
Mold spores
Cannabis dust and pollen
Extraction solvents
Recommended PPE:
Lab coats or protective gowns
Chemical‑resistant aprons
Flame‑resistant clothing for extraction or flammable liquid handling
Disposable sleeves for trimming and cultivation tasks
RESPIRATORY PROTECTION
OSHA Standard: 29 CFR 1910.134
REQUIRES A FULL WRITTEN PROGRAM WHEN RESPIRATORS ARE USED
When Required:
Grinding, sifting, or handling dried flower
Mold exposure
Chemical fumes or inadequate ventilation
RESPIRATORY HAZARDS ARE ONE OF THE TOP RISKS IN CANNABIS WORKPLACES, INCLUDING:
Cannabis dust
Mold spores
Required Program Elements:
Medical evaluations
Fit testing
Training
Written procedures
Proper respirator selection
Recommended PPE:
N95 or P100 filtering facepiece respirators
Half mask elastomeric respirators with appropriate cartridges
Powered air purifying respirators (PAPRs) for high dust tasks
RESOURCES
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?
If you’d like:
A customized ERTK program for your cannabis operation
On-site or virtual employee training
SDS organization and labeling support
A compliance audit before OCM or MNOSHA visits
Updates on evolving cannabis safety regulations
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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
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.
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.
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