All cannabis waste is not created equally. Due to the various streams of cannabis byproduct, waste streams also vary and must be handled appropriately. Cultivation byproduct (leaves, trim, stalks, stems, root balls etc.) for example, is organic and can be compliantly disposed of sustainably. Byproduct produced by other cannabis industry stakeholders such as manufacturers, testing laboratories, and microbusinesses, however, is completely different and much higher profile than their cultivation counterparts, though they may also include cultivation byproduct in addition to other forms of hazardous cannabis waste. What is the difference between non-hazardous cannabis waste, traditional hazardous waste, and hazardous cannabis waste?
Non-hazardous Cannabis Waste
The Bureau of Cannabis Control (BCC) defines cannabis waste as waste that is not hazardous waste, as defined in Public Resources Code section 40141, that contains cannabis and that has been made unusable and unrecognizable in the manner prescribed in sections 5054 and 5055 of this division.
The EPA defines “hazardous waste” as waste that is dangerous or potentially harmful to our health or the environment. Hazardous wastes can be liquids, solids, gases, or sludges. They can be discarded commercial products, like cleaning fluids or pesticides, or the by-products of manufacturing processes.
The EPA categorizes types of hazardous wastes noting that waste that has not been specifically listed may still be considered a hazardous waste if exhibits one of the four characteristics defined in 40 CFR Part 261 Subpart C:ignitability, corrosivity, reactivity, and toxicity.
Hazardous Cannabis Waste
“Hazardous cannabis waste” is hazardous waste that contains cannabis and its chemical constituents; a Schedule 1 Federally Controlled Substance (FCS).
Handling Hazardous Cannabis Waste
Hazardous cannabis waste is categorized separately from non-hazardous cannabis waste, and furthermore, is treated differently than traditional hazardous waste in that it contains cannabis and its chemical constituents; a Schedule 1 Federally Controlled Substance (FCS).
Cannabis waste may be considered hazardous if it holds the property of being ignitable, reactive, corrosive, or toxic. Hazardous streams of waste are common among all types of cannabis operators, with emphasis on volatile manufacturers and testing laboratories, and may include, but are not limited to, spent organic solvents and refining chemicals, used reactants, biohazards, aerosols/compressed gases, bulk or residual pesticides and fertilizers, cleaning solutions, contaminated disposables, and universal waste (lighting/ballasts, batteries, etc.).
Operators that generate hazardous waste are required to register with the Environmental Protection Agency (EPA) to obtain either a State EPA ID Number or a Federal EPA ID Number depending upon the type and quantity of waste they generate. Temporary EPA ID numbers can be granted to operators that generate small, inconsistent quantities of hazardous waste. The EPA has certain rules and regulations specific to the type of generator, pertaining to accumulation, storage, and handling of hazardous waste. Hazardous waste must be transported by an EPA-registered entity and disposed of at a permitted hazardous waste treatment, storage, and disposal facility (TSDF). The cradle-to-grave concept requires operators to notify the EPA when disposing of hazardous waste via a Uniform Hazardous Waste Manifest.
Gaiaca is not only an EPA-registered hazardous waste transporter and State-licensed type-11 cannabis distributor, but is also equipped with years of experience in hazardous material management and consulting. We can assist all types of cannabis operators with necessary duties such as hazardous waste management program development, generator identification and registration, waste profiling, and disposal. Gaiaca will ensure that all hazardous cannabis waste is properly handled, stored, transported, documented, and disposed of with respect to the Federal, State, and local government.
Want to learn more? Read here to learn more about the differences between “cannabis waste” and “cannabis byproduct.”