Too much of a good thing? Legalization means there is more cannabis-related waste
Common disposal methods include incineration, shredding, soaking waste in vinegar or mixing with cat litter and water
NationalPost.com
Jan 15, 2019
Emma Spears
Canadians who love, need, cultivate or sell cannabis may be rounding into another month of legalization, but any growing comfort should not be accompanied by complacency around disposal-related issues that are also gaining profile.
As it turns out, all those plants generate a whole lot of trash. And like all things post-legalization, the destruction and disposal of cannabis and its byproducts is governed by rules and regulations that are anything but simple.
Since the flower is the only part of the plant sold to consumers, the production of tonnes of cannabis yields even more tonnes of biological waste, including leaves, stems, stalks and rootballs (the masses formed by the roots of the plant). Some forecasts put Canada’s cannabis waste at approximately 6,000 tonnes annually by 2020.
“Anything that doesn’t go into the dried flower, essentially, has to be destroyed in a fashion where Health Canada makes sure there isn’t any odour, or any [recognizable] properties [of the plant],” explains industry expert Ivan Ross Vrana, such as incineration or mixing with other substances.
Beyond odour, “the risks to it are fairly limited in that nobody’s going to be able to go through a landfill and find all these cannabis flowers that have bugs on them, or some mould,” says Ross, who formerly worked at Health Canada developing the federal government’s position on cannabis, currently lectures at both Carleton University and Concordia University and advises on health and cannabis files at Hill+Knowlton Strategies.
Not only must waste be odourless, it must be unrecognizable.
“Cannabis is considered to be destroyed when it is altered or denatured (stripped of its natural qualities) to such an extent that its consumption and propagation are rendered impossible or improbable,” says André Gagnon, media relations advisor for Health Canada.
Approved methods of “denaturing” and disposal must also “not result in any person being exposed to cannabis smoke, and (must) be witnessed by at least two persons who meet the stated requirements,” Gagnon continues. Regulations require witnesses to be “the senior person in charge, the qualified person in charge or the alternate qualified person in charge” of the entity, or “an employee of the (license)-holder,” per the federal government.
Rules relate to security, storage and pick-up
Licensed producers (LPs)--who can denature the waste themselves or hire specialists to do so--are required to take additional security precautions, such as placing cameras at facilities where plant matter is destroyed, and ensuring that waste is stored securely while awaiting pick up if the plant waste is being transported off site by a third-party. Provided the waste has been denatured according to regulations, no extra certification is required for those performing the pick-up.
If adequately denatured, says Ross, it can be picked up by municipal waste collectors--“if they accept plant matter.”
Specialized cannabis waste disposal companies such as Micron Waste, which has partnered with licensed producer Aurora, are also an option. As part of an announcement last January, Aurora reported that “Micron has developed a new technology, based on aerobic digestion and subsequent treatment, that converts organic waste into clean water that meets municipal effluent discharge standards. Currently used methods to dispose of organic waste generally require the utilization of municipal landfill sites, which is costly and has a negative impact on the environment,” it added at the time.
Waste needs to be appropriately tracked
As with cannabis that is sold, LPs must also report the amount of cannabis destroyed via detailed monthly reports to the federal government’s Cannabis Tracking and Licensing System (CTLS), a program created “to track only what is needed to monitor the flow of cannabis at a national level to meet regulatory requirements under the Cannabis Act.”
Federal LPs conducting activities related to cultivation, processing and the sale of cannabis are required to submit monthly reports to Health Canada. As well, they are subject to regular inspections by Health Canada--LPs face introductory, pre-sales and targeted inspections, with an additional annual inspection--to ensure compliance with disposal obligations.
Although every LP has its own methods, some of the most common disposal methods used by the cannabis industry include incineration, shredding and soaking waste in vinegar, or mixing waste with cat litter and water to form an unusable sludge.
“We’ve got a large-scale, industrial shredding machine,” Greg Engel, CEO of Moncton-based LP OrganiGram, says of his company’s disposal process. “We grow in coco, which is coconut husks that have been ground up. So, what we end up doing is mixing the combination of plant material that we’re not going to use with the coco, grinding it up together, adding water to it. And it does go to landfill, but it is--from a landfill perspective--a decent-quality fill, because it does break down,” Engel suggests.
Just how long the process would take has not been nailed down, but the waste is biodegradable while much of what ends up in landfills may not be.
The cost of sending waste to landfill isn’t cheap. Fees can add up quickly, depending on the jurisdiction. Waste companies charge a pick-up fee, and many charge subsequently by the tonne--meaning that depending on the size of the LP, the frequency of harvest and the location of the production site, producers can easily spend thousands of dollars per pick-up.
Waste and byproducts are one thing, but what about the cannabis flower itself? What would it take to require an LP to destroy the fruits of such a potentially lucrative harvest?
“If it’s destroyed, like the whole flower and plant, typically it’s because you’ve got an infestation of some kind… Or you’ve got mould, or the product is not up to practices and standards, or there’s a chemical in there that’s a banned substance for whatever reason,” Ross points out. “We’ve seen things where a company doesn’t use (a banned substance), but they’ve retrofitted facilities, the lines haven’t been 100 percent flushed out, so there’s trace amounts of a previous pesticide, for instance. So that crop that’s contaminated has to be destroyed,” he explains.
Yet more disposal rules for retail
Cannabis retailers face a different set of municipal regulations. “This means that local jurisdictions could vary in a number of ways,” notes the Federation of Canadian Municipalities. “Still, there are common elements across the country for which municipalities are responsible,” such as where cannabis may be disposed.
Unlike LPs, sellers must look to provinces and/or municipalities to set the guidelines for how to dispose of any tainted, past-due or forgotten cannabis. Retailers discard cannabis that has passed its shelf life, suffered damage to the packaging or seal, was used in smell jars or has been returned by a customer. Although Health Canada does not currently have a shelf life guideline, damaged package or returned cannabis would be unfit for sale since they do not meet packaging and labeling requirements.
Like LPs, however, every gram destroyed must be accounted for.
“Provincial and territorial retailers are required to include the amount of cannabis destroyed by class of cannabis (such as plants/seeds or dried/fresh), if any destruction took place at their location, as part of monthly reporting” through CTLS, says Gagnon.
The penalties for non-compliance with regulations--detailed in Section 5.3 of the Compliance and enforcement policy for the Cannabis Act--are severe, ranging from loss of licence to fines that Ross says can cost upwards of a million dollars and even jail time.
