Allay Consulting December Newsletter: Hazardous Waste Disposal

Hazardous Waste Disposal

Erin Brockovich said so eloquently, “you cannot put a contaminant in the ground and just think that Mother Nature whips it up and runs it off somewhere else and we never see it again.” Erin’s reference to “contaminants” is describing hazardous waste and if not disposed of properly can result in decades to infinity of harm to our ecosystem. For this very reason, federal (EPA, OSHA), state, and local regulatory authorities have strict guidelines to follow when handling and disposing of hazardous waste.

Notorious examples of improper waste disposal in the United Sates: The Cuyahoga River catching on fire at least 14 times due to industrial pollution; decades of dumping toxic manufacturing byproducts into the Love Canal resulting in chronic health issues in its community; and Colorado’s Rocky Flats suspected linkage to plutonium exposure and cancer at surrounding communities. If you are not aware of these extreme examples, enjoy a Google search leading to a rabbit hole of US disasters!


What is Hazardous Waste?

The Environmental Protection Agency (EPA) defines hazardous waste as “a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment.” Hazardous waste can negatively impact our air, water ways, and soil that in turn can harm humans. Waste comes in many forms such as liquids, gases, and sludges. Hazardous waste can be generated from our homes and industrial manufacturing processes. Waste from cannabis operations occurs from seed to sale. Common hazardous waste in the cannabis industry include pesticides, nutrients, bulb waste, disinfectants/cleaning chemicals, liquid solvents, gaseous solvents, spent biomass with residual solvents, etc. More and more states categorize THC waste as hazardous waste and have specific requirements for disposal.


How is Waste Determined to be Hazardous?

The EPA takes into account the material’s ignitability, corrosivity, reactivity, and toxicity when evaluating the severity of a substance and disposal methods. There are three main resources available to determine if a substance requires professional waste disposal: material’s SDS (section 13), EPA, and unique state guidance. These are valuable resources, use them and learn how to stay compliant.


How to Dispose of Your Hazardous Waste:

Disposal methods for hazardous waste will depend on the type of waste. Most hazardous waste will need to be disposed of by a professional hazardous waste company. Additionally, most companies who accumulate waste need to register with the EPA and with their state while also maintaining documentation for traceability to complete the cradle to grave for each hazardous waste. Reach out to your local environmental department for details on how to properly dispose of your hazardous waste to ensure you are in compliance.


Don’t be that Person – Take Action!

Incentives for properly handling/disposing of hazardous material for most of us is to live in a safe and healthy environment. If that’s not enough incentive, perhaps hefty fines, jail and even prison time may jolt us into abiding by rigorous waste regulations. Do your research, connect with your state environmental department, and don’t be that person.


Although Allay Consulting does not specialize in hazardous waste management, we can help connect you to industry professionals who do! For other cannabis compliance, reach out to Allay Consulting for assistance with FDA, cGMP, ISO, Fire, OSHA, and unique state requirements.


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