The Washington State Department of Agriculture confirmed in an email distributed through their new listserv that they recently began conducting routine unannounced pesticide inspections at cannabis grow facilities. During these visits the Department of Agriculture may or may not be accompanied by the liquor and cannabis board. They warn that if pesticide violations are found a notice of correction is issued outlining what needs to be corrected and the WSLCB will review the inspections to make sure the growers are complying. They provided a list of items that they will review during their inspection:
- Pesticide application records
- Personal Protective Equipment (PPE)
- Compliance with pesticide label requirements
- Chemical (pesticide) storage
- Pesticide products used
- Fertilizer products used
- Pesticide mixing / loading area
- Chemigation (pesticide) / Fertigation (fertilizer) – products run through an irrigation system
- Pesticide application equipment
- Disposal of pesticide containers / old pesticides / rinsate. Empty pesticide containers cannot be reused.
The bulletin goes on to warn growers about the use of wetting agents as all spray adjuvants must be listed by the WSDA as a pesticide before they can be used on cannabis production.
Finally, they clarified that the use of home brews (Lemon juice, dish soap, cooking oils, etc.) for pest control may be problematic as they are normally not registered with the WSDA as a pesticide. Home Brews are not prohibited under WSDA regulations. However, LCB WAC 314-55-084 requires growers to use only pesticides registered with WSDA under RCW 15.58.
What does all this mean for your cannabis business? Start by only having WSDA listed and WSLCB approved pesticides and fertilizers at your operation. Next, to meet your responsibilities as an employer start with a chemical and pesticide inventory and a good look at the labels for the chemicals and pesticides present in your operation. The trainings, PPE, and plans you need are going to depend on what those labels contain.
For example, if a pesticide in your operation has an Agricultural Use label and is being used in pre-harvest production you are going to need to train your employees as workers and handlers on the Worker Protection Standard with an approved trainer and materials. If a label requires respirator protection involving a half or full-face respirator as PPE, you must have the employees complete a medical evaluation and be fit tested before use as well as a written plan for managing your respirator program. Having a respirator present without all these elements can be its own violation.
At Think Happy Consulting we understand these complicated rules across multiple agencies. We’ve got the plans, trainings, and support you need to stay ahead of compliance and prepare your operation before the WSDA visits you. From central postings to fit testing or chemical hazard communication, we can help you with all aspects of pesticide compliance and safety.