Over the past five months, COVID-19 has had a devastating effect on multiple industries and their employees across the globe. This global pandemic has caused much uncertainty in regards to when businesses would be able to resume normal operations, and when employees could return to work. As a result of this uncertainty, we have witnessed a number of layoffs across Canada that have directly affected the Canadian cannabis sector. At the time this article was written, BNN Bloomberg1 had reported on a number of these layoffs and the impacts they’ve had on the sector as a whole from cannabis production through to retail sales. In April, Canopy Growth Corp. temporarily laid off 200 retail staff following the closure of a number of retail locations in order to support social distancing measures. Also, in April, Organigram Holdings Inc. temporarily laid off 400 workers in order to help stop the spread of the virus. Toronto-based producer WeedMD Inc. also temporarily laid off 40 employees as a result of the pandemic as well. With no definitive end in sight, many people were left wondering when they would be able to return to work, if at all.
As of late, things have started to take a turn for the better. Provinces across Canada have begun re-opening, restrictions are starting to be lifted and people are beginning to return to work. Although progress has been made, it is important to keep in mind that COVID-19 is still very real and could rapidly have devastating effects across the globe once again if the proper precautions are not taken. With that being said, it is important to understand the necessary measures that cannabis production facilities can implement on-site and integrate into their operations and procedures, if they haven’t done so already, in order resume and continue operations while dealing with the ongoing crisis.
Licensed Producers: Ensure that you have a robust sanitation and hygiene program in place
As part of their sanitation program, licensed producers (LPs) are required to have procedures in place that deal with personnel health and hygiene (s. 87(1)(d), CR). It is important for all LPs to review their programs to integrate the new health guidelines that have been provided by healthcare officials at both the federal and provincial levels. It is also important for them to remind their employees of the protocols that are currently in place and to have their employees trained or retrained on any procedures that have been revised. Sanitation programs should also be revised to include new measures regarding increasing the frequency at which high-touch surfaces are disinfected. High-traffic and high-touch areas such as door handles, light switches and tables should be disinfected on a more frequent basis. It is recommended that these surfaces be disinfected at least twice a day or more depending on the level of employee traffic.
It is important for management to have continuous and ongoing communication with employees at the beginning of each shift. Management teams should be asking their employees questions about any symptoms they may have experienced, screening for individuals who have been in contact with an infected person in the previous fourteen days, or if they’ve been to a healthcare facility or any other high-risk area. Health Canada resources in regards to symptoms should be posted throughout the facility where it can be easily seen by employees and updated as new information becomes available. By doing so, employees can monitor one another and report any symptoms related to COVID-19 to the appropriate officials. Another option is taking your employees’ temperature. Although a good idea, it is important to understand that employee temperature measurements can also be interpreted as medical information which is a privacy concern. As such, if you intend to implement this at your facility, it is important that the necessary steps are taken to ensure all medical information is kept private and managed appropriately.
Personal Protective Equipment (PPE) in Cannabis Production
Prior to COVID-19, the use of personal protective equipment (PPE) in cannabis production was already quite prevalent throughout the industry. This provides LPs with an advantage when compared to other businesses where PPE is not needed on a regular basis. However, it is important to understand that the use of this PPE should be considered the last line of defense due to limitations around its use. Infection risk as such should be mitigated using the following hierarchy of controls:
By properly implementing this hierarchy of controls safeguards employees to exposure to COVID-19 or any other infectious agent. It is for this reason that PPE’s should be considered a last line of defense and not be the only risk mitigating measures taken against COVID-19. LPs should review their PPE management programs to ensure that it meets a standard that allows for employees to be kept safe on an ongoing basis, especially now when additional PPE may need to be considered. It is also important for management to ask the right questions when ensuring that employees understand the proper use and expectations of PPE. This includes, but is not limited to:
- Where and when should it be used and by whom?
- Do employees understand how to properly use their PPE and can they demonstrate their understanding?
- Has management done fit testing for employees to ensure their PPE fits properly?
- Does the PPE fit with both the individual and with any other equipment they use?
- Have employees been educated on the limitations of PPE?
It is also extremely important to monitor PPE use. Supervisors should regularly conduct checks to ensure that all employees are wearing their PPE and that it is being worn in the appropriate manner to ensure effectiveness. Depending on the size of the company, a Health and Safety committee should be in place. This committee uses both employees and management to ensure that an all-around review of how operations are proceeding can be provided and concerns can be appropriately addressed. It is important to know that each province may have specific program requirements so it is important to check with your local authorities.
Social Distancing in the Production Facility
The implementation of social distancing measures in the production facility can be quite challenging. This is because most, if not all, production facilities are not designed for employees to effectively complete their daily tasks with the implementation of the new distancing requirements. Some production facilities are implementing physical distancing measures to be at two meters even with PPE being used. In other facilities, measures have been implemented to ensure that interactions between employees are limited and gathering of groups of employees is not permitted. Steps should be taken by management to reevaluate who is considered to be an essential employee based on their duties. By doing so, management can eliminate extra workers that do not need to be on-site which can help with the distancing requirements. Other creative ways to assist with social distancing in the production facility also include staggering shift starts and break and enacting different operating hours.
Working from Home
By reevaluating which employees are considered to be essential to the production of cannabis in a facility, management can also determine which employees can work from home. If a “work-from-home” policy is implemented, it is important for management to ensure that they do everything they can to accommodate their employees as it is their responsibility to ensure the protection of their employees regardless of their location. This includes, but is not limited to:
- Determining if employees have adequate equipment at their place of residence. Injuries can occur to some who do not have the appropriate workplace setup (i.e. ergonomic issues if they don’t have the appropriate seating).
- Determining if employees have or are able to have a dedicated workspace. Steps should be taken to ensure employee needs are addressed if they are required to work from home.
- Ensuring that employees have regular work hours with boundaries in place. By understanding that there are regular office hours, boundaries allow for work and home responsibilities to not clash which could potentially increase stress levels.
- Ensuring that employees are provided with processes for managing confidential and sensitive information.
Although some employees may be designated to work from home, it is important for management to keep up communication with employees on a regular basis to ensure both company and employee needs can continue to be met.
If you are looking to apply to become a cannabis retailer or looking for more information on regulatory requirements related to cannabis, contact dicentra Cannabis Consulting today.
1COVID-19 jobs tracker: Layoffs, furloughs and hiring during the pandemic