Any observer of cannabis licensing is familiar with the primary categories of licenses: Cultivation, Manufacturing and Dispensing/Retail. At Cannabiz Media, we strive to cover the entire value chain including testing, distribution, research, and more recently, event and consumption licenses. This article highlights the Waste license – a rare activity that is required in Oklahoma, Mississippi, and Maryland.

We have identified 22 licenses in these three states, and no company has more than one license, so it is safe to say that there is no MSO of waste licenses. Given that these companies serve other license holders, Oklahoma is the market to be in with almost 12,000 licenses. Below is an alphabetical leaderboard, sorted by state and business name. 

Background

In reviewing the regulations, applications, and guidance, there are definitely some commonalities across the three states:

• Track & Trace: All three states reference waste as a critical part of their track and trace rules.
• Video: Mississippi and Maryland both require the destruction to be captured on video
• Fees: Fees vary greatly (as they do with most licenses). Maryland is $100, Oklahoma is $5,000, and Mississippi is a one-time application fee of $5,000 and an annual license fee of $7,500.
• Manner of Destruction: The waste must be rendered unusable. Maryland and Mississippi provide detailed information on the manner of destruction.

Oklahoma 

Oklahoma spells out the requirements for how this waste should be handled and the records that must be kept:

Regulations require the medical marijuana business transferring the medical marijuana waste for disposal to document in the electronic inventory system all waste placed in the secure container and transferred to the medical marijuana waste facility licensee. The inventory manifest for transport of medical marijuana waste shall also contain this information. Each person authorized by the waste facility licensee to transport to a waste disposal facility shall maintain records before and during transport and at the waste disposal facility. Electronic inventory should match the inventory manifest form prior to travel and upon arrival at the disposal facility.

Each waste disposal facility shall use the seed-to-sale tracking system established by the Department or a seed-to-sale tracking system that integrates with the Department-established system at the time of its implementation.

There is a $5,000 application fee – which is double the $2,500 for other Oklahoma cannabis licenses.

Maryland 

Maryland highlights the procedures for tracking this process at the dispensary and ensuring that it is sent back to the licensed grower or processor. They provide a sample spreadsheet for recordkeeping and compliance. Their regulations center around registrations of the drivers, vehicles, and the businesses engaged in this practice. All must be in good standing.  

All product not manifested back to a licensed grower or processor shall immediately be rendered unusable, entered into Waste log and placed into the waste container. This action must be clearly captured on video. 

1. Flower/Dry leaf waste will be ground to the smallest possible degree prior to mixing with a non-cannabis product to a 50:50 ratio or a higher content of non-cannabis product (Example: alcohol, bleach, any other solvent that renders it non-useable, kitty litter, mulch, dirt, or other loose non-consumable material that will render it non-useable). 

2. Non-flower/Non-dry leaf Waste will be emptied into a non-consumable product for disposal. Final destruction will occur no later than 7 days the waste is entered into the Cannabis Green Waste Log and placed in a designated commercial waste bin for pick up and removal from the facility.

Similar to Oklahoma, all of the waste has to be accounted for via track and trace, and Maryland also has a requirement to capture the destruction on video.

Mississippi

In Mississippi, the regulations focus on the facility where the disposal happens. The term “cannabis disposal entity” means a business licensed and registered by the Mississippi Department of Health that is involved in the commercial disposal or destruction of medical cannabis. These license holders are prohibited from transporting cannabis and/or cannabis products for general purposes such as transfer from one medical cannabis establishment to another.

All medical cannabis waste set for disposal shall be properly weighed and recorded in the state’s seed to sale system. Waste set for disposal must be weighed and recorded.

Cannabis waste shall be disposed through either a process which renders the waste unusable and unrecognizable through physical destruction or a recycling process that the waste disposal facility is authorized to conduct pursuant to Mississippi law.

The disposal/destruction of cannabis waste must be done under video surveillance by the cannabis disposal entity’s video surveillance system described in Rule 8.9.3.

Grinding and incorporating the cannabis waste into compostable mixed waste until it is unusable and unrecognizable: Cannabis waste to be disposed of as compost or in another organic waste method may be mixed with the following types of waste materials:

The one anomaly in this state is Bragg Canna. They are the only license holder we found that has other state cannabis licenses.

About the Author

Ed Keating is a co-founder of Cannabiz Media and oversees the company’s data research and government relations efforts. He has spent his career working with and advising information companies in the compliance space. Ed has managed product, marketing, and sales while overseeing complex multijurisdictional product lines in the securities, corporate, UCC, safety, environmental, and human resource markets.  

At Cannabiz Media, Ed enjoys the challenge of working with regulators across the globe as he and his team gather corporate, financial, and license information to track the people, products, and businesses in the cannabis economy.  

Ed graduated from Hamilton College and received his MBA from the Kellogg School at Northwestern University.

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