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Lesson 1, Topic 1
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Cannabis Waste

Purpose

House Premium Cannabis is committed to establishing policies and procedures to ensure the compliance of the Massachusetts Cannabis Control Commission (CCC).  All refuse containing any part of cannabis or finished cannabis is known as “Green Waste.”  Handling of cannabis and cannabis-infused products that have been declared unusable or unrecognizable. Cannabis must be disposed of in a strictly monitored and regulated capacity. Different forms of cannabis waste include but are not limited to cannabis leaves, stems, unusable cannabis flowers, roots, spent soil, stalks, and any other part of the cannabis plant or finished cannabis-infused product. All cannabis waste shall be documented. All records maintained.

Definitions

  • Commission: The Massachusetts Cannabis Control Commission (CCC).
  • Green Waste: Unused, surplus, returned, or out of date cannabis, recalled cannabis, and any plant debris, including dead plants, all unused plant parts, and roots.
  • Marijuana Establishment (ME): a Marijuana Cultivator (Indoor or Outdoor), Craft Marijuana Cooperative, Marijuana Product Manufacturer, Marijuana  Microbusiness, Independent Testing Laboratory, Marijuana Retailer, Marijuana Transporter, Deliver Licensee, Marijuana Research Facility, Social Consumption Establishment or any other type of licensed Marijuana related business, except a Medical Marijuana Treatment Center (MTC).
  • Marijuana Establishment Agent (Agent): Any Owner, employee, executive, or volunteer of a Marijuana Establishment, who is 21 years of age or older.  Employee includes a consultant or contractor who provides on-site services to a Marijuana Establishment related to the cultivation, harvesting, preparation, packaging, storage, testing, or dispensing of marijuana.

Responsibilities

This SOP applies to all individuals who are Agents or affiliated with House Premium Cannabis. House Premium Cannabis management will update SOP’s as needed per regulation or other mandates.  This SOP will be reviewed at a minimum annually.

Procedures

Green Waste Can Occur Within Normal Operational Practices and the Designated Areas

  1. The reason why cannabis is unusable or has become unrecognizable can be:
    • General expected waste yield loss from process/repacking.
    • Returned product.
    • Expired product; or
    • Unusable product.
  2. If green waste is due to the product being returned by a customer due to an adverse event or complaint, the Agent should also follow the processes in SOP Adverse Events – Recall.

Documenting and Completing the Cannabis Waste Disposal Log

  1. When marijuana products or waste is disposed of or handled, House Premium Cannabis must create and maintain an electronic record of the date, the type and quantity disposed or handled, the manner of disposal or other handling, the location of disposal or other handling, and the names of the two House Premium Cannabis Agents present during the disposal or other handling, with their signatures. 
  2. This period shall automatically be extended for the duration of any enforcement action and may be extended by an order of the Commission.
  3. Maintain the Cannabis Waste Disposal Log and ensure METRC is updated, confirmed, and verified. 
    • Ensure the inventory is reconciled and verified accordingly.
    • The name of the employee who determined the expiration date and/or determined that the cannabis was unusable or unrecognizable.
    • Date and time of recording on a log.
    • The complete name of the product.
    • The product expiration date.
    • The METRC tag number (#).
    • Reason for disposal.
    • The number (#) of units.
    • The actual weight of the product placed into Storage (if not destroying immediately). 
    • The actual weight of the product when disposed of.
    • Verifiable inventory tracking information of the product.
  4. Two signatures required from House Premium Cannabis Agent.
  5. Update and confirm the METRC system have accepted changes, and inventory has been adjusted.

Cannabis Waste Disposal

  1. Cannabis and cannabis-infused products must be destroyed/disposed of after it has been determined unusable/unrecognizable following the methods outlined in this section.
  2. ALL cannabis waste MUST be disposed of in a YELLOW bag. This includes, but not limited to, waste from retail returns, lab cannabis waste, cultivation waste, and harvest waste. If there are no yellow bags please report to management.
  3. The allowable method to render cannabis waste unusable is by mixing and incorporating cannabis waste with other ground materials, so the resulting mixture is at least (50%) non-cannabis waste by volume. 
  4. All recyclables and waste, including organic waste composed of or containing finished marijuana and marijuana products, shall be stored, secured, and managed per applicable state and local statutes, ordinances, and regulations. 
  5. All exterior waste receptacles located on the premises of House Premium Cannabis shall be locked and secured to prevent unauthorized access. 
  6. Liquid waste containing marijuana or by-products of marijuana processing shall be disposed of in compliance with all applicable state and federal requirements, including but not limited to, for the discharge of pollutants into surface water or groundwater.
  7. No fewer than two (2) Agents must witness and document how the solid waste or organic material containing marijuana is handled on-site including, but not limited to, the grinding up, mixing, storage and removal from House Premium Cannabis.
  8. When marijuana products or waste is disposed or handled, House Premium Cannabis must create and maintain an electronic record of the date, the type and quantity disposed or handled, the manner of disposal or other handling, the location of disposal or other handling, and the names of the two (2) House Premium Cannabis Agents present during the disposal or other handling, with their signatures. 
  9. House Premium Cannabis shall keep these records for at least three (3) years. 
  10. This period shall automatically be extended for the duration of any enforcement action and may be extended by an order of the Commission.

Organic Waste Disposal

  1. Organic material, recyclable material and solid waste generated at House Premium Cannabis shall be redirected or disposed of as follows:
    • Organic and recyclable material shall be redirected from disposal per the waste disposal bans described at 310 CMR 19.017: Waste Bans. 
    • To the greatest extent feasible:
      • Any recyclable material as defined in 310 CMR 16.02: Definitions shall be recycled in a manner approved by the Commission; and
      • Any Marijuana containing organic material as defined in 310 CMR 16.02: Definitions shall be ground up and mixed with other organic material as defined in 310 CMR 16.02 such that the resulting mixture renders any Marijuana unusable for its original purpose. 
      • Once such Marijuana has been rendered unusable, the organic material may be composted or digested at an aerobic or anaerobic digester at an operation that is in compliance with the requirements of 310 CMR 16.00: Site Assignment Regulations for Solid Waste Facilities.
  2. Solid waste containing Marijuana generated at House Premium Cannabis shall be disposed of by having a House Premium Cannabis Agent make sure solid waste containing Marijuana is ground up and mixed with other solid waste such that the resulting mixture renders any marijuana unusable for its original purpose. 
  3. Once such marijuana has been rendered unusable, the resulting solid waste may be brought to a solid waste transfer facility or a solid waste disposal facility (e.g., landfill or incinerator) that holds a valid permit issued by the Department of Environmental Protection or by the appropriate agency in the jurisdiction in which the facility is located.
  4. Ensure all cannabis waste procedures are conducted in an area recorded by video.

Maintaining Records

The House Premium Cannabis Manager or designated representative shall have the responsibility for the following procedures.

  1. Ensure records are maintained that provide an audit trail of conformity to operational requirements and effective operation regarding the quality of service and overall management.
  2. All records are to be dated, appropriate employee’s signature/initials on all documents, legible, identifiable, completed, stored appropriately, and easily retrievable for inspection.
  3. All records shall be retained for a minimum of (3) years or as required by state or local regulation. Records can be disposed of when the retention period has ended.
  4. Statistical information shall be compiled and reviewed. 
  5. The review process shall look for improvements to ensure that the highest stand of quality is being met, optimal experience efficiencies “lean processes” and cost effectiveness for the overall operation and management.
  6. An after-action report should be discussed with all employees on the event and its findings.  

References

935 CMR 500.105 General Operational Requirements for Marijuana Establishments: (1) Written Operating Procedures; (3) Requirements for the Handling of Marijuana (b); (9) Recordkeeping; (12) Waste Disposal.