There are different ways to compliantly handle cannabis waste. Some operators may choose to render their cannabis waste on-site and then have it hauled off-site. That is one option. Another option is to utilize a third-party licensed cannabis waste management service provider. Essentially, using the latter option ensures compliant waste management. However, as an operator, you need to know what elements to look for when seeking Cannabis Disposal Programs.
What Are Compliant Cannabis Disposal Programs?
Third-party licensed cannabis waste management service providers are able to pick-up your unrendered cannabis waste and process and dispose of it on your behalf. This means that once your unrendered waste has been picked up from your site, it becomes the responsibility of the waste management service provider (and they are liable for proper disposal). Here are some key indicators to look for:
A Type-11 license is essential to compliant cannabis disposal programs. Typical municipal waste haulers do not have Type-11 licenses. They can only haul rendered cannabis waste. Cannabis waste management service providers must have a Type-11 license, which allows them to transport the cannabis by-product (unrendered cannabis product) from the client’s facility to another facility the cannabis by-product is made unrecognizable and unusable and destroyed.
Waste profiling is the responsibility of the waste generator (the cannabis operator). It is important that compliant cannabis disposal programs know how to address both hazardous and non-hazardous streams of cannabis waste and know how to identify each. Working with your third-party licensed cannabis waste management service provider to identify your streams of waste will ensure proper disposal.
It is essential that a waste manifest is created and maintained from the moment your third-party licensed cannabis waste management service provider picks up your unrendered cannabis waste until it’s final disposal (cradle-to-grave). Waste manifests contain pertinent information such as operator details, waste management provider details, the volume/weight of unrendered product picked up, and more. For example, if your cannabis waste management provider is for some reason pulled over between your facility and their own, having this manifest shows that both operators are compliantly executing a waste management service.
As a standard best practice, we advise that operators provide their cannabis waste management service providers with waste logs. Waste logs are the responsibility of the operators and can make or break an internal or external audit. The waste logs should denote what product was disposed of, and in which waste container, so when the waste manifest has been completed by the service provider, the operator knows specific details of destruction.
Reporting is a huge indicator to look for when seeking compliant cannabis disposal programs. Reporting compliant waste disposal to the proper regulatory agencies ensures that regulators have evidence of proper waste destruction. In a highly regulated market like the cannabis market, this sort of reporting is key. For cannabis waste management in California, reporting should be made to the Bureau of Cannabis Control.