On November 29, the MED issued a Position Statement regarding marijuana waste disposal.  The statement was issued in response to a question posed by a regulator in Grand County.  In short, the regulator was seeking clarity surrounding the use of waste transfer stations because some mountain regions do not have landfills (and thus waste must be transferred to the front range).  The MED Position Statement clarified that the use of transfer stations by waste haulers is compliant.

While this is a very nuanced and specific scenario, we wanted to take this as an opportunity to remind our readers of waste disposal best practices.  The MED takes waste disposal very seriously, so it’s important to make sure your facility is in compliance.  It’s critical to recognize marijuana waste is basically any material that contains marijuana in any form.  This includes plant material such as trim and fan leaf, extract residue, oils, and infused products among others.  In other words, if there is any detectable THC, make sure the waste is handled compliantly.

Specifically, the MED requires that all marijuana waste be:

  • Mixed with other waste so that the resulting mixture is at least 50% non-marijuana waste;
  • Rendered unrecognizable and unusable; and
  • Stored in a secure, locked container.

Additionally, one of our users suggested drilling small holes in your locked container which allow for water vapor to escape from the container.  This reduction in waste weight will save you money on your trash collection services!

Moreover, all waste disposal must be captured in a waste log.  As a matter of best practice, the waste log should include a range of information including:

  • Applicable license
  • Time and date
  • Weight
  • Associated METRC tag(s)
  • Individual who was responsible for the waste

Additionally, the appropriate waste information must be inputted in METRC as well.  The MED requires that all businesses maintain records for the current year and the previous three calendar years.  In other words, the MED could walk into your facility today and ask for waste logs from January 2013 (provided you were operational at that time).  Would you be able to locate logs dating back to 2013?

Complia has developed the marijuana industry’s first comprehensive document management system.  With just a few clicks, you can upload your waste logs, visitor logs, signed manifests, and more.  If the MED requests logs from years ago, there is no easier way to find the records you need!  Drop us a line if you’d like to see Complia’s document management system in action.

 

Yours in Compliance,

Team Complia