As a cannabis operator in Missouri, understanding hazardous waste is an extremely important part of waste management.
Operators who produce hazardous waste are known as “generators,” and are subject to the rules and regulations set forth by the Environmental Protection Agency (EPA) and the Missouri Department of Natural Resources (MO DNR). In addition to affecting the environment, violating hazardous waste regulations can result in expensive fines, which will have a directly negative effect on a facility’s economic bottom line. In some cases, failure to properly manage hazardous waste can also result in suspension of a facility’s cannabis license by the Missouri Department of Health & Senior Services (DHSS).
The answers to the questions below are derived from DHSS 19 CSR 30-95, EPA Hazardous Waste Generators, and MO DNR PUB2570.
Is Cannabis Waste Hazardous?
“Medical marijuana flowers, trim, and solid plant material are not in themselves considered hazardous waste unless they have been treated or contaminated with a hazardous waste constituent.” On the other hand, solvents like ethanol, commonly used by manufacturing facilities during the extraction process, are considered hazardous, and are subject to the applicable hazardous waste management standards set forth by the EPA and MO DNR for storage, transport, and disposal.
All solid wastes must be evaluated under the following hazardous waste regulations:
Waste from medical marijuana flowers, trim, and solid plant material used to create an extract
Waste solvents, pesticides, and other similar materials used in the cultivation, manufacturing, or testing process
Discarded plant waste, spent solvents, and laboratory wastes from any medical marijuana processing or quality assurance testing
Medical marijuana extract that fails to meet quality testing
Federal Hazardous Waste Regulations
Federal regulations require large and small quantity generators (SQGs) of hazardous waste to obtain an EPA Identification (EPA ID) number using EPA Form 8700-12. This Site Identification Form (EPA Form 8700-12) must be submitted to the authorized state agency or EPA regional office. The form includes information such as the following:
Facility’s name and address
Description of hazardous waste activities conducted at the site
Categories of hazardous waste generators
The volume of hazardous waste each generator produces in a calendar month determines which regulations apply to that generator. Recognizing that generators produce waste in different quantities, the EPA established regulations for each of the following three categories of generators:
Very Small Quantity Generators (VSQGs)
Generate 100 kilograms or less per month of hazardous waste or one kilogram or less per month of acutely hazardous waste.
May not accumulate more than 1,000 kilograms (220 pounds) of hazardous waste at any time.
Small Quantity Generators (SQGs)
Generate more than 100 kilograms, but less than 1,000 kilograms of hazardous waste per month.
May accumulate hazardous waste on-site for 180 days without a permit (or 270 days if shipping a distance greater than 200 miles).
Must never exceed a quantity of 6,000 kilograms of hazardous waste on-site.
Must always have at least one employee available to respond to an emergency. This employee is the emergency coordinator responsible for coordinating all emergency response measures. SQGs are not required to have detailed, written contingency plans.
Large Quantity Generators (LQGs)
Generate 1,000 kilograms per month or more of hazardous waste, or more than one kilogram per month of acutely hazardous waste
May accumulate waste on-site for 90 days only. Certain exceptions apply.
Do not have a limit on the amount of hazardous waste that can be accumulated on-site
Must submit a Biennial Hazardous Waste Report.
For more information on the different Categories of Hazardous Waste Generators click here. Additionally, most states are authorized to implement the Resource Conservation and Recovery Act (RCRA) program. The quantity limits for state generation categories can be different from the federal limits. For details see the differences in hazardous waste generator categories table.
State of Missouri Hazardous Waste Regulations
After successfully registering with the EPA, generators in Missouri must also register with the Missouri Department of Natural Resources (MO DNR). See the MO DNR’s Hazardous Waste Generator E-Reporting Guide for a detailed fact sheet that provides an overview of the e-reporting system requirements.
To get an ID number as a small quantity generator, operators must fill out MO DNR form 780-1164, which notifies the Missouri Department of Natural Resources (MO DNR) of regulated waste activity.
Forms must be mailed with an original ink signature and a $150 registration fee. After receipt, ID numbers might take up to 3 – 4 days to be issued.
If you are a comprehensive or microbusiness cannabis facility in Missouri, contact Monarch Waste for additional information about hazardous waste or to get a free quote for hazardous waste pickup.
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