The disposal of cannabis requires both the employee and a witness to dispose of the product – a process derived from medical practices for disposing of unused, post-operational anesthesia narcotics. Procedures and documentation will define what constitutes complete and timely documentation of any and all cannabis waste.
An individual witnessing waste disposal should verify the product label, that the volume or amount being wasted matches the inventory documentation, that the product is disposed of physically matches the product in the documentation, and that the disposal occurs per Standard Operating Procedures (SOP’s) for safe disposal and in a manner that makes the cannabis product irretrievable (or un-usable).
The entire process of disposal needs to be witnessed and carried out on video, so the individual verifying can be certain that the actual product is being wasted, and not substituted for an adulterated product. Approved methods for wasting cannabis are defined by government laws and regulations, as well as by guidance given by addressing pharmaceutical agents. Key elements of returning, wasting, and disposal of cannabis products include the following components:
- For defined high-risk areas, waste is witnessed and reconciled with an authorized employee.
- Approved methods for disposal are defined in policies, local government laws, and cannabis industry regulations of the appropriate authorities in your legal jurisdiction.
- Procedures should comply with universal precautions and specific organizational cannabis waste disposal requirements that are required to be implemented by regulations.
- Waste containers with any waste cannabis products are secured to prevent tampering or made otherwise irretrievable whenever cannabis is being wasted for disposal.
Managing Solid Waste Materials
Like any other business, cannabis businesses generate a variety of common waste materials. While some cannabis materials need to be disposed of in the trash, others should be recycled or composted whenever possible.
Cannabis industry regulators have waste disposal ban regulations that ban the disposal of certain materials in the trash. Commonly generated cannabis industry waste that you’ll find is banned from disposal includes cardboard, bottles and cans, paper, and leaves, and yard waste.
In the cannabis industry, it is considered that the cannabis plant material is a “commercial organic material.” If a cannabis business generates more commercial organic material per week for disposal than what can be managed, it would need to DIVERT all of the cannabis material from disposal, typically to compost or Anaerobic Digestion (or AD) type of operations you’ll find available.
If a cannabis business generates a manageable amount of plant material waste, the material may be disposed of in the trash, although it is still encouraged that material is composted whenever possible.
Waste Composting and Anaerobic Digestion
For proper waste disposal, cannabis plant parts and associated materials sent for composting or Anaerobic Digestion (or AD), but it must first be ground and mixed with other organic materials such that the material is rendered UNUSEABLE. Other organic materials may include growing media, soil, mulch, food waste, or agricultural material such as manure or other materials.
Typically, there are no unique requirements for hauling the cannabis material to compost or anaerobic digestion facility. The best place to start is to check with haulers that currently service businesses in the area, though ideally, cannabis businesses should work with a hauler that has experience hauling other similar organic materials. A hauler can help you determine which facility to deliver your material to, as well as the number and size of containers you need to meet your cannabis waste needs.
In some cases, it may work well for a cannabis business to compost materials on site. Composting on-site REQUIRES sufficient space to construct and maintain a compost pile, as well as additional materials to mix with cannabis plant material to compost successfully in the industry.
Solid Cannabis Waste Disposal
The cannabis business requirements for disposing of solid cannabis waste operations are similar to those for sending it to composting or Anaerobic Digestion (or AD). The cannabis waste MUST be ground and mixed with other solid wastes so that the material is rendered unusable. Suitable materials for mixing cannabis wastes for disposal include food waste, coffee grounds, manure, sawdust, or growing media.
The best approach is to work with your existing waste hauler to provide this collection service. Cannabis wastes mixed with other solid waste can be brought to any permitted transfer station, landfill, or municipal waste combustion facility for disposal. Your solid waste hauler will typically determine the best nearby facility to deliver the waste to for disposal. A hauler can also help you determine what number and size of containers you need to meet your needs in the industry.
Waste Storage, Documentation, and Recordkeeping
Cannabis wastes should be stored in a secure and locked container and location prior to collection. It is required that at least two (2) cannabis business agents must witness and document how cannabis waste is handled. The same regulation requires your business to develop and maintain records about:
- How cannabis waste is secured prior to collection for disposal management
- The date the material is sent for composting, anaerobic digestion, or disposal
- The type and amount of cannabis material managed during the disposal process
- The name, location, and type of facility to which the material was delivered (the facility can provide a scale or load ticket that includes all of this information)
- The manner of cannabis material disposal or waste handling and management
- The names and signatures of the two (2) agents who witness material management
Hazardous Waste Management
Cannabis businesses may also generate some wastes that need to be managed as hazardous wastes. This may include spent lighting, pesticides, solvents, used oil, or other chemicals used in facility operation and maintenance.
Hazardous waste regulations include provisions governing storage (how much material and for how long), labeling, manifest, transportation, and FINAL management and disposal. If you generate hazardous waste, you will need to determine how much waste you may accumulate at your site at one time, and how quickly you need to ship all of the cannabis materials off-site for recycling or disposal.
Managing Liquid Waste
Liquid waste containing cannabis or by-products of cannabis processing shall be disposed of in compliance with all applicable government and local law requirements. These requirements will depend on how liquid cannabis material waste from a facility is being managed, whether this disposal is discharged via a sewer connection, holding tank, or to groundwater or surface water.
Cannabis Product Packaging
It is recommended that recyclable and compostable packaging be used for cannabis products. For recycling, cannabis regulators will MAINTAIN educational guidance that summarizes what types of packaging are recyclable at recycling facilities. For compostable packaging, search the Internet for organizations that verify compostable packaging that is used in the cannabis industry.
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