Employee, Volunteer, and Contractor Safety and Health Policy for Marijuana
July 28, 2014
IN REPLY REFER TO
1112/1703/9260 (CA-940) P
EMS TRANSMISSION: 7/28/14
Instruction Memorandum No. CA-2014-028
Expires: 09/30/15
To: All Employees
From: State Director
Subject: Employee, Volunteer, and Contractor Safety and Health Policy for Marijuana
Cultivation Site Remediation and Rehabilitation
Program Areas: Safety and Occupational Health; Fire and Aviation Management; Hazardous Materials Management; National Landscape Conservation System; Law Enforcement and Security; Rangeland Resources; Recreation; and Wilderness.
Purpose: This Instruction Memorandum establishes the Bureau of Land Management, California (BLM-CA) Marijuana Cultivation Site Clean-up Protocol and provides safety procedures (see attachments) for implementation prior to the eradication, cleanup, or rehabilitation of marijuana cultivation sites.
Please ensure all your employees, volunteers, and contractors are aware of these procedures and the identified safeguards are in place before any work begins with respect to the cleanup and/or rehabilitation of a marijuana cultivation site.
Most employees, volunteers, and contractors should already be aware of the increase in marijuana cultivation throughout the nation on public lands; BLM-CA lands are no exception to this trend. Law enforcement personnel have developed a training session covering marijuana garden hazards. All employees, volunteers, and contractors should be briefed concerning the hazards and dangers of marijuana cultivation sites according to the Risk Assessment.
Many of the chemicals used in these illegal operations are hazardous to humans and to the environment. All chemicals and solid waste must be treated with special precautions and disposed of properly. Chemicals and waste products that are commonly associated with marijuana gardens include pesticides (both plant and animal), fertilizer, propane tanks, batteries, irrigation tubing, foodstuffs, and household garbage.
BLM-CA employees, volunteers and contractors must adhere to this policy to protect both their personal safety and that of the public lands. Specific Occupational Safety and Health Administration and Bureau of Land Management training are required for all personnel that are assigned duties which involve transport and disposal of hazardous and non-hazardous waste.
In a few specific instances, BLM-CA employees, volunteers, contractors, and members of the public have been injured due to inadvertent contact with chemical byproducts associated with these cultivation sites.
Policy/Action: The workload associated with remediation of marijuana cultivation sites has increased throughout California along with inherent safety concerns. The procedures identified in the Health and Safety Plan (see attachment) have been developed to address these concerns.
Timeframe: This policy is effective immediately.
Budget Impact: A minimal cost to the District/Field Offices is expected for the annual required training for personnel to maintain the Hazardous Waste Operations and Emergency Response (HAZWOPER) qualification. The purchase and maintenance of Personal Protective Equipment will also add some costs to those normally associated with on-going program requirements.
Background: This IM was developed to outline specific protocols that must be considered when remediating marijuana cultivation sites in order to protect employees, volunteers, and contractors from injuries and illnesses, and to enhance communications with law enforcement officials.
Manual/Handbook Sections Affected: This policy supplements the 29 CFR 1910.120; 29 CFR 1910.1200; BLM H-1112-2 Chapter 3, Risk Management; and Bureau of Land Management Environmental Contingency Plan for Emergency Preparedness and Response to Oil and Hazardous Materials Incidents.
Coordination: CA Advisory Safety and Health Committee; Law Enforcement and Security; Hazardous Materials Specialist; NFFE Local 2152
Contacts: Daryl Avery, State Safety Manager at 916-978-4521; Kynan Barrios, Special Agent in Charge at 916-978-4457; Peter Graves, Hazardous Materials Specialist at 916-978-4685.
If you have any questions or require additional information, please contact Daryl Avery, California State Safety and Occupational Health Manager at 916-978-4521.
Signed by:
Karen L. Barnette
Acting State Director
Authenticated by:
Richard A. Erickson
Records Management
Attachments - 4
1. Health and Safety Plan (HASP) for Rehabilitation of Marijuana Cultivation Sites Template (13 pp)
2. Risk Assessment for Marijuana Cultivation Site Clean up Field Operations (8 pp)
3. What to do if you Encounter a Marijuana Cultivation Site Poster (1 p)
4. Avoid Grow Site Poster (1 p)