As the world adapts to this new reality, reassessing and updating business practices has become the new normal. In the pre-COVID-19 world, cannabis operators often reached out to FOCUS with an interest in improving a certain aspect of their internal business processes. Whether seeking help with improving existing standard operating procedures (SOPs), expanding employee training efforts, making sure risk assessments are effective, or developing supplier qualification and hazard analysis and critical control points (HACCP plans). Every company has areas which they would like to improve, yet all struggle to find the necessary time and resources to dedicate towards the actual improvement activities.
All that has dramatically changed over the past few weeks, making this a perfect time to reassess and improve operations – to help prevent the spread of this deadly virus – but also to assure continued business success.
It is critical that all cannabis companies understand their requirements as employers under the General Duty Clause (Section 5(a)(1) of the Occupational Safety and Health Act of 1970 [29 USC 654(a)(1)]. Employees are the backbone of every successful company, and their health and safety should always be the first concern – not just during a pandemic.
If your company has not revisited the federal and state OSHA requirements that apply to your business since this pandemic began, doing so should be your first and biggest priority.
Under the Act, employers are required to comply with all occupational safety and health standards, and to furnish each worker “employment and a place of employment, which are free from recognized hazards that are causing or likely to cause death or serious physical harm”. The Act also includes requirements that employees comply with occupational safety and health standards and all rules, regulations and orders issued pursuant to the Act, which are applicable to his/her own actions.
Companies with more than 10 employees must also be aware and in compliance with the recordkeeping and reporting requirements as they related to workplace exposures to COVID-19 under 29 CFR 1904, as well as any applicable state requirements.
Cannabis businesses must also be sure to use cleaning and disinfecting agents approved by the Environmental Protection Agency for use against SARS-CoV-2, the virus that causes COVID-19. There have been a lot of new companies advertising services to clean and disinfect cannabis facilities, many of which are making false claims about the effectiveness of their services against COVID-19. Don’t make the mistake of going through the efforts to improve your operations only to find they did not work.
Many cannabis companies are asking employees to work remotely. Even companies operating in jurisdictions that have deemed cannabis as essential are limiting staff and splitting shifts to comply with social distancing requirements and do their part to prevent further transmission.
Suddenly, employees are finding themselves at home, with very little actual work to do – providing a tremendous opportunity to improve your company’s practices. Employees working from home can become your biggest resource and best defense against future quality, safety, and compliance related issues within your cannabis business. If handled properly, these changes do not need to equate to a lack of progress. In fact, this is a terrific time to assess the effectiveness of existing operational plans, policies, procedures and training.
Updating and improving Standard Operating Procedures is one of the most straightforward ways to improve. SOPs are one of the most useful systems to streamline a business because they create specific measurable business outcomes. Data shows that just a 10% improvement in productivity from a better SOP could give you 35-40 more productive minutes a day from each one of your employees. Think what that could mean to your bottom line! If you are not sure if your company’s SOPs need improvement, ask these questions to assess the business value of your SOPs:
- Does everyone in the organization have easy visibility on how things are done at all levels?
- Are roles and responsibilities clearly defined?
- Are training costs too high?
- Is it taking too long to get a new employee productive?
- How much supervisor time is required to get a new employee trained?
- Are there areas where you would be at significant risk of incurring high costs or project failure if a key employee or consultant left today?
One way to begin the process of updating your SOPs is by asking each of your employees to go through an existing SOP and update it with any information they identify that is missing, as it relates to that procedure. That updated draft should be shared with any other employees who perform the same function to assure its completeness and that everyone is in agreement. Once completed, the Quality Director or Management should review the SOP, reach out to any employees to resolve any issues, and then approve the SOP for use.
Another way to approach this is by having employees use the Notes app on their cell phone to explain each process they perform within a typical workday. They should do their best to include as many specifics as possible, including work location, materials and amounts, steps, time of day, etc. Ask them to explain it like a recipe, step by step, from beginning to end. These documents can then be used to determine if employees are all following the same steps, and where policies should be updated. It will also exemplify where SOPs may be in need of additional Work Instructions to be truly effective.
If effective, SOPs improve productivity, decrease costs, control for quality, and ensure consistent results. Use this time to make sure you are getting everything you should be out of yours. This is especially true for businesses that paid for SOP templates and have not yet customized them to their operations. Unless SOPs are built upon the daily needs and happenings of your company, and implemented as a part of how you do business each day – they are not likely doing much to protect your business, employees, or customers.
This is also a good time to reassess your job descriptions. Have employees working from home go through and update their specific job description with any additional duties that they perform. Circulate them between employees to ensure completeness and agreement. Once completed, management can approve and update them for later use.
Training is also something that cannabis businesses should be revisiting during this time. Obviously, hygiene, health and safety training should be the first priority, as we all make efforts to mitigate the transmission and spread of this virus. All employees should complete a hygiene related course at this time, regardless of whether they have previously or not. This includes management and executives too. There are plenty of companies offering complementary online training during this pandemic, and cannabis businesses should be taking advantage of these. A terrific example is the ServSafe™ Food Handler Course,which is being offered for free through April 30th. Additionally, ServSafe™ is also offering free state specific training, as well as COVID-19 Delivery and Takeout Training on demand.
Conducting internal training is also of critical importance right now, As we move through the different phases of this pandemic, more and more people will fall ill, or be forced to stay home to take care of sick loved ones. Do your employees understand all of the functions in your business? Do you have back up employees to cover all aspects of your operations if a crucial member of your team is no longer able to work? Cross training employees now is one of the best ways to prepare yourself for business continuity during this time.
While we all learn to exist in this new reality, smart cannabis business owners will take advantage of the situation and recognize there are plenty of ways to protect the future of their business by making sure they are fully compliant and operating at an optimal level.