Showing posts with label Cannabis. Show all posts
Showing posts with label Cannabis. Show all posts

Tuesday, August 1, 2017

How To Handle Cannabis Waste Legally

Whether professional growers are producing dried buds or collecting resin for extraction, the steps of harvesting and processing create by-products and waste that must be disposed of according to all applicable regulations. Growers must be aware of and comply with the comprehensive regulatory scheme enacted by governing bodies to ensure that environmental protections and safety are in place.
Proper waste disposal regulations apply whether the grow operation is a caregiver for a few patients or a large-scale facility that supplies dispensaries. The legal responsibility is on growers to ensure proper disposal.
Waste disposal regulations have been slowly adopted and are being constantly updated through piecemeal legislation. This complex legal framework makes any generalizations about disposal requirements for growers difficult, because compliance must be followed on a federal, state and local level, and it varies widely.
Categories of waste
The types of waste that must be evaluated for proper disposal include:
  • Waste from solid plant material, whether a usable plant trim or flower or unusable plant material, such as stalks, roots, or soil
  • Waste solvents that were used in processing, such as a flammable solvent for the purpose of producing a concentrate
  • Any laboratory wastes that were used during processing for quality assurance testing
  • Any plant waste or extract that is not being used, because it does not meet quality assurance or has been contaminated in some way that would make it unusable in a safe and medical capacity
  • Liquids or water that could contaminate ground water due to pesticide use
It should also be noted that waste is limited not just to the by-product of growing. Many states also have regulations for how to properly destroy and dispose of any excess product that would place the grower in violation of the allowable limit.
Usable vs. unusable waste
Growers should look first to their state regulations that outline procedures for waste disposal. Many states’ disposal regulations distinguish between usable and unusable waste (which is defined in the law) and require that any usable waste, such as buds or trimmings, be rendered unusable before disposal.
For example, the state of Washington’s statute requires that usable waste be rendered unusable by grinding and incorporating it with other ground materials like food waste or yard waste to create a mixture of at least 50% non-cannabis waste, or delivering it to a permitted solid waste facility.
In addition to determining usable vs. unusable waste, many states require that growers determine whether it would be categorized as dangerous waste vs. non-dangerous waste and dispose of it accordingly to the states’ general statues on hazardous waste.
Another advisable practice for growers is to keep records that delineate what type of waste was disposed of, and how it was disposed of and where, including any facilities that the grower uses to dispose of the waste properly.
Because growing cannabis is still considered a federal crime under the Controlled Substances Act, it is important for growers to be aware that any trash placed outside a business is searchable by police without a warrant. This type of search is not considered within the subjective expectation of privacy of the Fourth Amendment.

Sunday, July 23, 2017

Marijuana waste disposal—Liquids and solids.

Washington state reg, but should be standard everywhere....(1) Solid and liquid wastes generated during marijuana production and processing must be stored, managed, and disposed of in accordance with applicable state and local laws and regulations.
(2) Wastewater generated during marijuana production and processing must be disposed of in compliance with applicable state and local laws and regulations.
(3) Wastes from the production and processing of marijuana plants must be evaluated against the state's dangerous waste regulations (chapter  173-303 WAC) to determine if those wastes designate as dangerous waste. It is the responsibility of each waste generator to properly evaluate their waste to determine if it is designated as a dangerous waste. If a generator's waste does designate as a dangerous waste, then that waste(s) is subject to the applicable management standards found in chapter  173-303 WAC.
(a) Wastes that must be evaluated against the dangerous waste regulations include, but are not limited to, the following:
(i) Waste from marijuana flowers, trim and solid plant material used to create an extract (per WAC  314-55-104).
(ii) Waste solvents used in the marijuana process (per WAC  314-55-104).
(iii) Discarded plant waste, spent solvents and laboratory wastes from any marijuana processing or quality assurance testing.
(iv) Marijuana extract that fails to meet quality testing.
(b) Marijuana wastes that do not designate as dangerous shall be managed in accordance with subsection (4) of this section.
(c) A marijuana plant, usable marijuana, trim and other plant material in itself is not considered dangerous waste as defined under chapter  173-303 WAC unless it has been treated or contaminated with a solvent.
(4) Marijuana waste that does not designate as dangerous waste (per subsection (3) of this section) must be rendered unusable following the methods in subsection (5) of this section prior to leaving a licensed producer, processor, or laboratory. Disposal of the marijuana waste rendered unusable must follow the methods under subsection (6) of this section.
(a) Wastes that must be rendered unusable prior to disposal include, but are not limited to, the following:
(i) Waste evaluated per subsection (3) of this section and determined to not designate as "Dangerous Waste."
(ii) Marijuana plant waste, including roots, stalks, leaves, and stems that have not been processed with solvent.
(iii) Solid marijuana sample plant waste possessed by third-party laboratories accredited by the WSLCB to test for quality assurance that must be disposed of.
(iv) Other wastes as determined by the WSLCB.
(b) A producer or processor must provide the WSLCB a minimum of seventy-two hours notice in the traceability system described in WAC 314-55-083(4) prior to rendering the product unusable and disposing of it.
(5) The allowable method to render marijuana plant waste unusable is by grinding and incorporating the marijuana plant waste with other ground materials so the resulting mixture is at least fifty percent nonmarijuana waste by volume. Other methods to render marijuana waste unusable must be approved by the WSLCB before implementation.
Material used to grind with the marijuana falls into two categories: Compostable waste and noncompostable waste.
(a) Compostable mixed waste: Marijuana waste to be disposed as compost feedstock or in another organic waste method (for example, anaerobic digester) may be mixed with the following types of waste materials:
(i) Food waste;
(ii) Yard waste;
(iii) Vegetable based grease or oils; or
(iv) Other wastes as approved by the WSLCB.
(b) Noncompostable mixed waste: Marijuana waste to be disposed in a landfill or another disposal method (for example, incinerator) may be mixed with the following types of waste materials:
(i) Paper waste;
(ii) Cardboard waste;
(iii) Plastic waste;
(iv) Soil; or
(v) Other wastes as approved by the WSLCB.
(6) Marijuana wastes rendered unusable following the method described in subsection (4) of this section can be disposed.
(a) Disposal of the marijuana waste rendered unusable may be delivered to a permitted solid waste facility for final disposition. Examples of acceptable permitted solid waste facilities include:
(i) Compostable mixed waste: Compost, anaerobic digester, or other facility with approval of the jurisdictional health department.
(ii) Noncompostable mixed waste: Landfill, incinerator, or other facility with approval of the jurisdictional health department.
(b) Disposal of the marijuana waste rendered unusable may be managed on-site by the generator in accordance with the standards of chapter  173-350 WAC.
(c) A record of the final destination of marijuana waste rendered unusable.
[Statutory Authority: RCW  69.50.342 and  69.50.345. WSR 16-11-110, § 314-55-097, filed 5/18/16, effective 6/18/16; WSR 15-11-107, § 314-55-097, filed 5/20/15, effective 6/20/15. Statutory Authority: RCW  69.50.325,  69.50.331,  69.50.342,  69.50.345. WSR 13-21-104, § 314-55-097, filed 10/21/13, effective 11/21/13.]

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