The purpose of this study is to identify what strategies can be implemented to dispose of and mitigate hazardous and non-hazardous waste from cannabis industries in Puerto Rico. Hazardous and non-hazardous waste generated in the industry was evaluated. Ideal management methods for the strategic development of environmental mitigation were designed.
In 2017, Puerto Rico passed Medicinal Law 42, which allows the consumption of Cannabis sativa for the purpose of treating certain debilitating conditions, as a natural alternative for Puerto Ricans. Like any industry that involves production processes, a certain amount of waste is generated. An important detail of this growing industry is that it’s classified as a Type 1 Drug by the Federal Government, because of that the Environmental Regulatory Agencies do not have any jurisdiction. Law 42 establishes that the handling, storage, and disposal of waste must be managed according to federal and state regulations. However, it does have a degree of ambiguity as to what methods are necessary for waste management.
TABLE OF CONTENT
LIST OF TABLES
LIST OF FIGURES
LIST OF ANNEXES
RESUME
ABSTRACT
CHAPTER I
Background of the Problem
Problem
Justification
Research Question
Goal
Objectives
CHAPTER II
Historical Background
Conceptual Framework
Legal Framework
CHAPTER III
Methodology
CHAPTERIV
Discussion
CHAPTERV
Conclusion
Recommendations
CHAPTER VI
Strategic Plan
CITED LITERATURE
DEDICATION
I dedicate this investigative work to all human beings who in some way or another have empathy for natural resources worldwide. Without those grains of love the hope of saving our planet was nothing more than aimless dust.
On the other hand, I also acknowledge the support of my parents and Wilmarie in the course of all the mastery and patience that I was awarded in the investigative process.
ACKNOWLEDGEMENT
My gratitude goes to each person who enlightened me in each step of the thesis development. Thanks to the director Dr. Juan Musa Wasil, Dr. Karlo Malavé and Professor Carlos Morales, the development of the thesis was full and undoubtedly an enriching experience. Each tip was key to continue and never give up.
I cannot fail to mention my coworkers who were an engine of ideas to implement strategies for collective growth. Finally, I thank my classmates Karola, Pedro and Luz who were an emotional support and allowed the online mastery to be bearable and above all rich in knowledge.
TABLE LIST
Table 1. Waste Generated by Department monthly in the Medicinal Cannabis Industry X East of Puerto Rico
Table 2. Medicinal Cannabis Industries in Puerto Rico
Table 3. Annual Hazardous Waste Projection for Industry X of Medicinal Cannabis in Puerto Rico
Table 4. Classification of Hazardous and Non-Hazardous Wastes of the Industry X of Medicinal Cannabis in the eastern area of Puerto Rico
Table 5. Functions of the company for the management of hazardous waste and non-hazardous and their action time to take
Table 6. Waste minimization activities
Table 7. Materials Recovery Plants in Puerto Rico
Table 8. Equivalence of environmental indicators by the Department of Natural Resources
LIST OF FIGURES
Figure 1. Hazardous and Non-Hazardous Waste Generated from the Company X of Medicinal Cannabis in Puerto Rico
Figure 2. Waste Generated by the Crop Department of Company X of Medicinal Cannabis in Puerto Rico
Figure 3. Waste Generated by the Manufacturing Department of Company X of Medicinal Cannabis in Puerto Rico
Figure 4. Example of colors assigned for containers
Figure 5. Example of Labeling with Descriptive Information of the Content
Figure 6. Classification of Hazardous Materials
LIST OF APPENDICES
Attachment 1. List of Hazardous Waste Codes by the Environmental Protection Agency
Annex 2. Information Needed for the Registration and Labeling of Waste Generation
Annex 3. Inspection record of storage area of Hazardous Waste
Annex 4. Storage Area Security Inspection Record of Hazardous Waste
Annex 5. Registration of Inspection of Labeling in Containers of Hazardous Waste
RESUMEN
En el 2017 se aprueba la Ley 42 MEDICINAL en Puerto Rico que permite el consumo de Cannabis sativa con el proposito de tratar ciertas condiciones debilitantes, como una alternativa natural para los puertorriquenos. Como cualquier sector industrial en sus procesos de produccion, se genera cierta cantidad desperdicios. Un detalle importante de esta creciente industria es que al catalogarse como Droga Tipo 1 por el Gobierno Federal las agencias de regulacion ambiental no entran en jurisdiccion. En la Ley 42 se establece que el manejo, almacenamiento y descarte de los desperdi cios deben regirse segun la normativa federal y estatal. Sin embargo, la misma, deja un grado de ambigüedad en cuales son las medidas necesarias para la gestion de residuos. El proposito de este estudio es identificar que estrategias se pueden implementar para disponer y mitigar los desperdicios peligrosos y no peligrosos de industrias de cannabis en Puerto Rico. Se evaluaron cuales residuos son peligrosos o no peligrosos que se generan en la industria. Se disenaron herramientas de gestion ideales y métodos para el desarrollo estratégico de mitigacion ambiental. La informacion se obtuvo en un marco exploratorio de data en la Industria de Cannabis Medicinal X en el area este de Puerto Rico sin realizar encuestas ni trabajar de manera de directa con la sustancia. La revision literaria en el pa^s es limitada, sin embargo, en ciertos lugares en Estados Unidos en los cuales es aprobado el uso recreacional, existen estudios de referencia en cuanto a generacion de residuos y desarrollo investigativo. Se logra identificar los residuos generados en la compama X permitiendo una proyeccion anual de 6,695.4kg de desperdicios peligrosos y 24,852.6kg de desperdicios no peligrosos para una sola compama detallando que en Puerto Rico existen 43 centros de cultivos y 34 manufacturas. Las estrategias y gmas para la mitigacion ambiental se desarrollaron para determinar recursos aprovechables de los desperdicios generados de las industrias, métodos de manejo e identificacion de sustancias peligrosas con respectivos rasgos de almacenamiento segun estipulado por la EPA. Ademas, se presentan ejemplos de documentos necesarios y un listado de agencias a cargo del recogido de desperdicios en Puerto Rico.
ABSTRACT
In 2017, Puerto Rico passed Medicinal Law 42, which allows the consumption of Cannabis sativa for the purpose of treating certain debilitating conditions, as a natural alternative for Puerto Ricans. Like any industry that involves production processes, a certain amount of waste is generated. An important detail of this growing industry is that it's classified as a Type 1 Drug by the Federal Government, because of that the Environmental Regulatory Agencies do not have any jurisdiction. Law 42 establishes that the handling, storage, and disposal of waste must be managed according to federal and state regulations. However, it does have a degree of ambiguity as to what methods are necessary for waste management. The purpose of this study is to identify what strategies can be implemented to dispose of and mitigate hazardous and non-hazardous waste from cannabis industries in Puerto Rico. Hazardous and non-hazardous waste generated in the industry was evaluated. Ideal management methods for the strategic development of environmental mitigation were designed. The information was obtained in an exploratory framework of data in the Medical Cannabis X Industry in the eastern area of Puerto Rico without conducting surveys or working directly with the substance. The literature review in the country is limited; however, in certain U.S. states where recreational use is approved, there are reference studies on waste generation and research development. The waste generated in company X was identified, allowing an annual projection of 6,695.4kg of hazardous waste and 24,852.6kg of non-hazardous waste for a single company, detailing that in Puerto Rico there are 43 cultivation centers and 34 manufacturing centers dedicated to the medical cannabis industry. Strategies and guidelines for environmental mitigation were developed to determine reusable resources from the waste generated by the industries, handling methods, and identification of hazardous substances with respective storage features as stipulated by the EPA. In addition, examples of necessary documents and a list of agencies in charge of waste collection in Puerto Rico are presented.
STRATEGIES FOR PROPER HANDLING OF HAZARDOUS AND NON- HAZARDOUS WASTE IN THE MEDICINAL CANNABIS INDUSTRY IN PUERTO RICO
CHAPTER I INTRODUCTION
Background of the Problem
In 2015, an Executive Order (OE-2015-10) was approved in Puerto Rico that includes a program in order to Manage the Study, Development and Research of Cannabis for Innovation, Applicable Standards and Limits. It is not until 2017 that it becomes law (MEDICINAL Law, 2017) with different purposes, highlighting the obtaining of a legal framework that allows the use of medicinal cannabis as a natural alternative for patients with certain conditions and/or diseases (Department of Health of Puerto Rico, 2018). In addition to this, it is expected to generate a large amount of income for the country's economy (Rodriguez, 2019). Therefore, it directly increases some sectors such as real estate, construction and security in the same way. Otherwise, the economy is stimulated indirectly with payments to the jobs generated and the payment of millions of dollars in taxes (Hall & Lynskey, 2020).
Although the medicinal program has been beneficial for many patients with certain conditions established by the Government of Puerto Rico and the Department of Health, it has shown a limited approach that regulates the generation of waste that affects environmental quality in the short and long term. The lack of programs that reduce air pollution due to the generation of toxic gases that are released into the atmosphere, the vague environmental management and management, the pollution of bodies of water, the lack of commitment by the government and society seem to not cease. due to the lack of tools, capital, and implementation measures (Aguilar, Gutiérrez, Sanchez, & Nougier, 2018). It is extremely important to include that by 2019 there were 37 crops, 34 manufactures, 3 laboratories and more than 150 dispensaries in Puerto Rico, each of these generating both hazardous and non-hazardous solid waste (Negron, 2019). Later on, it is detailed what each establishment is dedicated to take into account the expenses of all sectors in the cannabis industry in Puerto Rico, not only in the cultivation and manufacturing, which will be limited in this investigative study. So, everyone should contribute their grain of sand to reduce environmental problems and thus achieve a collective union to achieve sustainability.
Now there is a regulation for waste management, however, it is very general and does not provide alternatives or clear strategies to achieve a specific management or monitoring system that allows maintaining control over generated waste (Parvez, Lewis, & Afzal, 202). Law 42-2017, together with Regulation 9038 in Puerto Rico, establishes the general regulations for the industry on the use and management of waste. It is true that Puerto Rico currently has a millionaire debt, so obtaining capital to treat environmental problems is a great challenge. As data from the Department of the Treasury of P.R. indicate that from January to July 2020, the Medicinal Cannabis Industry generated an increase of 142% in its sales, of which 11 million were collected for that department (ICEX, 2020).
Based on this large amount of money, the government can include or demand strategies, leaving behind the indifference of environmental reality and its deterioration.
The regulation that falls on the use of medicinal cannabis is given from a federal context. So, federal law determines that marijuana (cannabis) belongs to the classification of type I controlled substances (Labiano, 2020). This establishes that it can have a high power over its consumption, it has no medical use and does not have security measures for its use. Today it is important to clarify that this definition of type I controlled substances does not apply to cannabis and there are different studies that have shown this, however, the federal government has not yet managed or reclassified medical cannabis (Rodriguez, 2019). The MEDICINAL Law in Puerto Rico establishes that the regulatory, supervisory, and administrative entity will be the Regulatory Board attached to the Department of Health. Accompanying this law, different administrative determinations, resolutions, and current circular letters were incorporated that also address the reality that we face globally, about the COVID-19 pandemic (Huggins, C., 2020).
Beyond the general requirements, under the state law and regulation of Puerto Rico it is specifically required that the establishments (cultivation, manufacturing, laboratory, and dispensaries) linked to the industry, have permits for the disposal of monitored medical cannabis waste. through a tracking system stipulated by the Department of Health called Biotrack THC and Seed to Sale. Law 42-2017 includes requirements that maintain quality control and good practices in the areas of agriculture, manufacturing, clinics, and laboratories. The processes to confiscate products containing medical cannabis are obliged to notify the confiscation as stipulated in Regulation 9038. This method is based on incorporating the residues of cannabis containing THC in its different states, and they are mixed with residues that do not are consumer. Some examples are solid waste such as: food waste (from plants), fats or oils suitable for compost, soil and others (Calabuig, 2020). It is curious that there are different infractions which establishments related to medicinal cannabis in Puerto Rico may fail, however, of the existing fines, none is directly linked to the disposal of solid or dangerous waste.
Beyond the medicinal, it is emphasized that the Cannabis sativa or hemp plant has many benefits to treat or mitigate environmental problems. This includes the development of raw materials for construction materials (hempcrete), organic animal feed, bioremediation (heavy metals), composite materials, bio-combustion, creation of paper and textiles, among others (Pavlovic, Panseri, Giupponi, Leoni, Citti, Cattaneo, & Giorgi, 2019). For this, the government of Puerto Rico must also make its policy more flexible, so that those who benefit from it can be marketed in a more direct way. It is important to create educational policies that reduce the stigma of cannabis use, promote recycling and waste mitigation programs, and present alternatives that reduce the excessive generation of waste.
Knowing the generalities about the indoor and outdoor cultivation process is required to address the problems of waste generation since an indoor crop requires a greater amount of energy and production expenses that at the same time contribute to an increase in the natural resources that are used and in the same way increases the carbon footprint in a negative way (Mills, 2012). Despite its complexity in its regulatory standards, the Medical Cannabis Industry has managed to exceed expectations where by 2019 there were 92,499 patients and they continue to increase, thus increasing production and waste generation expenses.
Study Problem
The great generation of waste worldwide and in Puerto Rico has brought many environmental problems that have deteriorated natural resources. In the case of Puerto Rico, the closure of landfills is added due to lack of environmental compliance (Diaz, 2019). The practices carried out by human beings contribute greatly to this increase, thus being a social problem that must be addressed with intervention and management policies to gradually improve the economic, health and social sector. The history of the country in political and environmental terms has largely followed the legal norms of the United States since 1898 (Serrano, 2018).
Companies or industries linked to production, manufacturing, pharmacy, and others, can have a direct and indirect impact on environmental and public health, causing the deterioration of many natural resources and their dependents. This occurs through growth in production and development in civilizations due to an increase in population and the lack of resources to remedy, mitigate and plan to reduce the impact. Since the country has solid waste management as one of its main problems, documents have been signed with a series of consequences where the controversy between the protection of natural resources and the development of Puerto Rico's economy is clear (Serrano J., 2018). An example of this is the Medical Cannabis Industry which is generating and increasing waste that affects the ecological imbalance. If we do not act quickly, the result can be irreversible and catastrophic in our tropical resources.
The generation of solid and hazardous waste in Puerto Rico is not constantly monitored or regulated. The elements that occur at the time of generating production activities or providing a service may include solid, liquid, or gaseous waste, sewage, emissions into the atmosphere, increase in noise, exorbitant energy consumption, increase in water consumption. and others (Febus, 2019). This becomes more difficult when projects that contain protection tools for different ecosystems are not implemented where air quality, noise pollution, generation of odors, consumption of resources, the increase of pollutants to the bodies are affected. of water and deterioration of the quality of the soils, although they are not limited to these. Losing the natural, economic, cultural, aesthetic, and social values of our resources is not acceptable, so acting is urgent.
There are countless local, state, and federal regulations and laws that regulate these environmental impacts, however, at the federal level the use of Cannabis sativa is criminalized. Therefore, the state government must have protocols that enforce its laws and thus provide the necessary tools for environmental control. So, although Law 42 establishes that certain materials must be discarded correctly, there is ambiguity and some strategies that they pose in a scant way. After studying this regulation, the investigative problem of this thesis arises, which focuses on presenting strategies for industries to obtain key adaptation methods andthus face the consumption, technological and legislative change in Puerto Rico, including the Medicinal Cannabis Industry (Albino, 2018).
For medical cannabis patients in Puerto Rico to continue to benefit from the properties of the cannabis plant, strategic and implementation plans for environmental protection must also be promoted. In this way we can maintain environmental homeostasis for flora and fauna species in Puerto Rico. It must be focused on sustainable development where the possibility of future generations to meet their own needs or aspirations is not compromised. Strategic measures may include, but are not limited to, the implementation of prevention and correction measures, staff training, good environmental practices, efficiency techniques, environmental management and control systems, ongoing audits, and legal advice.
Justification
Environmental strategies for industries or companies give way to the reduction or mitigation of environmental problems that can deteriorate or in the most drastic cases, deplete the natural resources that nature provides us. Adverse effects can lead to excessive accumulation, emission, and collateral effects that affect the flora and fauna of Puerto Rico. Good management in environmental policy by a company promotes the minimization of environmental problems and sustainable development through a commitment to continuous compliance in production activities and / or offering services that is accessible to the public (Gomez, 2020).
The benefits for the Medicinal Cannabis Industry in Puerto Rico can be of different types. The hyperactive considers that environmental protection is a necessity since it gives way to acquire opportunities within the market or advantages over other industries. Proactive is considered an industry responsibility as it allows them to anticipate new rules or regulations. The reactive one implements environmental strategies to reduce costs, the follower opts for strategies to comply with the law and the inactive one is the industries that do not accept the existence of pollution problems (Astudillo & Velasquez, 2020). Therefore, the implementation of environmental strategies should be aspired because in one way or another current problem can be devastating both in the short and long term.
It is essential that the Medicinal Cannabis Industry in Puerto Rico be provided with mitigation and environmental management strategies so that they can take immediate action to avoid creating impacts greater than the degradation of natural resources. It is not a falsehood that the acquisition of tools and the understanding of the magnitude of the generation of waste does not occur only in Puerto Rico, but also worldwide, and it is alarming. In this way, compliance with state and / or federal laws and regulations is guaranteed with the promulgation of procedures that seek to comply with environmental goals, the interpretation of data harmful to the environment and / or personnel, qualify personnel for problem solving. environmental, etc. (Quiroga, Rodriguez, Acosta, Pastor, & Gonzalez, 2020). The fact that an industry has collection methods, recovery alternatives, waste management, effective treatments and adequate and safe provisions allows the company's planning to be safe and pro-environmental. This helps the industry not to be fined or sanctioned for decisions that affect the environment.
Then the strategic methods that are desired to be achieved focus on the Medical Cannabis Industry in Puerto Rico obtaining planning methods and tools for continuous improvement, achieving its proposed objectives. On the other hand, that they achieve the execution of the measures for continuous improvement, seek to put into action the most efficient methods and act immediately in cases where the goals are not as expected. An effective key to maintaining these compliance standards is to refer to the ISO 14001 Standard which is an Audit for the Environmental Management System (Ikram, Mahmoudi, Shah, & Mohsin, 2019). Giving the advantage of the process to meet objectives, increase knowledge of environmental problems, reduce production costs, increase the credibility of the company and others. It is important and necessary that the Board of the Medicinal Cannabis Program look for alternatives that, in addition to benefiting patients, manage to benefit the environmental health that is constantly weakening, with adequate management measures for hazardous waste and in turn alternatives for recycling materials and / or handling of substances.
To then develop this investigative process, the problem to be studied is justified in such a way as to promote control in industry inventories by emphasizing materials, waste or emissions generated, avoiding accidents such as spills or leaks, productivity improvements using sequences of reuse, recycling and cleaning, control and prevention, maintain and inspect periodically, separation and correct disposal of waste and hazardous materials for environmental health. It is extremely important to note that the way in which the regulations in Puerto Rico and the United States indicate they are not specific in terms of converting solid and hazardous waste in an unrecognizable way. This term remains ambiguous because it can promote risks to public and environmental health, also involving safety and contamination problems on the part of the medicinal cannabis industries that grow indoors (Ashworth, & Vizuete, 2017). Most of this waste ends up in landfills and in the atmosphere. When there are more efficient methods for its collection, such as composting and reducing the impact of the carbon footprint, we can improve the negative environmental impact (Mills E., 2012). Finally, achieve the implementation of guidelines or strategies that mostly do not require technological changes, but rather cooperation and improvement in the attitude and environmental empathy of companies and pharmaceutical companies as well as organizations or industries that have a high production system and can result in environmental impacts.
Research Question
What strategies can be implemented for the disposal and mitigation of hazardous and non-hazardous waste in the Medical Cannabis Industry in Puerto Rico?
Goal
Develop strategies for the proper handling and management of hazardous and non- hazardous waste in the Medical Cannabis Industry in Puerto Rico
Objectives
1. Evaluate what wastes are generated in the industry to determine which are dangerous or non-dangerous.
2. Design tools or strategies for proper waste management
3. Identify mitigation strategies that impact the environment
CHAPTER II CITED LITERATURE
Historic Background
Environmental Quality Board
In the mid-1970s, the Environmental Quality Board (EQB) was created in Puerto Rico. The JCA aims to create, coordinate, regulate, develop, and create plans through which an environmental public policy is achieved (Rivera M., 2017). In the same way, it creates a link between the human being and the environment where it is possible to mitigate, eliminate or make the necessary adjustments to reduce the impacts or anticipate certain scenarios that affect nature, while protecting the resources for the subsistence of different species.
The Environmental Quality Board channels different areas of focus to maintain control of the quality of water, air, pollutants in land areas, noise emission and the advisory part in scientific processes (Febus H., 2019). To achieve environmental control on the island, solid waste is generally considered whether hazardous or non-hazardous. Therefore, under the environmental public policy, the incorrect management of waste, disposal inspections, transportation, the evaluation of the permits granted and a strategic development for the control of substances, whether chemical, biological or from any area that result in damage to ecosystems. Noting that a large amount of hazardous waste has a direct impact on the environment by different industries of production of some good or material in general, it is not only limited to the Medicinal Cannabis Industry in Puerto Rico.
Current Problem of Hazardous Waste in Puerto Rico
The Puerto Rico Environmental Quality Board makes estimates that determine that around 2.27kg of garbage per day is generated per person. This is only measured for generators that are properly identified, so it can be added generators that are not properly identified. This large amount of waste ends up in landfills where the matter is decomposed thus releasing gaseous methane that goes into the atmosphere, promoting a deterioration of the ozone layer and increasing the rate of global warming. The Environmental Protection Agency (EPA) and the EQB issue reports that indicate that, between transport, treatment, and disposal, it is close to 71,667,594kg, so this transport receives 10% of a total of 136,077,7111kg that is generated (Diaz, C., 2019).
It is the responsibility of the Government of Puerto Rico to address the environmental problem in terms of expenses and investments for cleaning or methods that promote the decontamination of certain areas in such a way that they also adequately manage the federal funds allocated for it (Rondo, MR, 201). Also, as part of this responsibility, the JCA oversees the inspection, monitoring and interaction with entities to monitor the compliance of each waste generator and its associates through a Manifest System until the final provisions. The entities involved must also obtain operating licenses where it is ensured that the waste will be handled and transported correctly, in favor of environmental protection. It should be noted that these processes mediated by the EQB are not solely intended to control, but also allow the generating party to be oriented and obtain environmental consulting with a high degree of environmental advice.
For 1988, an Executive Order was placed into context establishing the Public Policy for the management of Solid Waste in the country mediated by the Solid Waste Authority in Puerto Rico in order to create disposal rehabilitation systems (Li, B., Yang, J., Zhao, F., Zhi, L., Wang, X., Liu, L., & Zhao, Y., 2020). Compared to the year in which this Executive Order is issued, there are 33 fewer landfills for a total of 29 landfills for the year 2020 (Diaz, C., 2019). The landfills that no longer exist were operating in a poor way or in breach of federal and state regulations, so it is important that new methods be legislated to combat the real problem of hazardous waste in Puerto Rico with rates collected at least until 2020.
Medicinal Cannabis Industry
In the United States, cannabis entered the pharmaceutical industry in 1850, thus treating different ailments including withdrawal from the use of opioids. It is then in the 19th century that consumption began to be associated with criminal acts against Hispanics and blacks, being penalized in 1937 (Bridgeman, M., & Abazia, D., 2017). At present, marijuana continues to be classified as a Type I Drug, which indicates that it has a high rate of abuse and addiction and that it has no medicinal value, which multiple recent studies have denied this detail. It is not until 2013 that the United States Department of Justice establishes that the federal government will not intervene in regulatory schemes of different states considering that the sale or distribution to minors is not allowed, nor that the company's profits go to business criminals, interstate prevention of cannabis is taken and that it is not used for illegal trafficking (Vancouver, M., & Alba, C., 2020). Added to this is the non-use of firearms, and the fact that vehicles are not driven under the influence of drugs, among others.
Law 42 of 2017 together with Regulation 9038 of 2018 determine the processes and regulations of how the Medical Cannabis Industry must operate in Puerto Rico. Among the licenses that can be requested for an establishment are cultivation, manufacturing, laboratories, transportation, dispensary and research establishments. Each company must submit the request and it will be approved under the laws of the Commonwealth of Puerto Rico (MEDICINAL Law, 2017). It is understandable that when requesting these permits, a waste management plan is required for each establishment and that it is determined which agency will oversee its compliance and regulation.
As has been well mentioned as the medical cannabis industry is a new and natural alternative, more and more people are opting for its certification and consumption, conditioning themselves to the benefits offered by cannabinoids and terpenes for certain diseases or ailments ascribed under the law. Consumer demand in Puerto Rico is much more than expected and in the last two years it has been increasing, which brings with it higher production expenses and subsequently the generation of more waste. This problem does not only occur in Puerto Rico, but also in the United States, where it has been pointed out that the disposal of industrial waste with general waste is a common and incorrect practice in the medical cannabis industries. Some residues or wastes are pesticides, universal waste lamps, release of "green gas", increased packaging of which most are developed with polypropylene, plant food nutrients, contaminated water, alcohol waste and others. solvents, used equipment or machinery oils, refrigerants, etc. (Butsic, V., Carah, J., Baumann M., Stephens C., & Brenner, J., 2018).
Conceptual Background
To keep clear the waste management approaches, whether hazardous or non- hazardous, ascribed to industries, theoretical or conceptual concepts that involve the environment and the health of living beings are developed, focused on the cultivation and standards of medicinal cannabis. Through this research and the analysis of Regulation 9038 and Law 42 of Medicinal Cannabis in Puerto Rico, it is desired to achieve an improvement in the efficiency of the current regulation regarding the management and management of waste generated by the newly industry. To achieve significant contributions to the sustainability and sustainability of our natural resources in the future. It should be noted that this research requires the analysis of models that regulate the food, medicine, and production industries. They must be governed by the State since it has direct participation. Cannabis plants and their current system is extremely diverse and with a certain degree of complexity due to its federal regulations (Delgado, M., 2017). In the same way it can give way to the realization of future investigations.
Classifications and Components of Medicinal Cannabis
There are three classifications for the cannabis plant according to its origin and its forms known as sativa, indica and hybrids, each with specific functions such as focus, relaxation, analgesic, antibacterial, concentration, relaxing, etc. These plants contain active compounds called cannabinoids and terpenoids. Cannabinoids have no odor and have effects in animals and humans which can adhere to receptors in the brain and body when consumed in their activated form (Perveen, S., & Al-Taweel, A., 2018). On the other hand, terpenoids give characteristic odors not only to cannabis plants, but to most medicinal plants. The incorporation of the use in pharmacology on medicinal plants has been around the world for many years, evidencing its use in the Asian continent as anesthesia in different surgical processes, stomach pains, headaches, and others (Delgado, M., 2017). In 1964, the isolation of a psychoactive component of the plant called tetrahydrocannabinol, commonly known as THC, was achieved, which had a chemical potential in the neuronal system of people. On the other hand, there is cannabidiol (CBD) which regulates psychotic symptoms with highly analgesic properties and binds to receptors in the endocannabinoid system of humans and animals (Sinclair, J., Adams, C., Thurgood, GR, Davidson, M., Armor, M., & Sarris, J., 2020).
Some of the diseases approved in Puerto Rico for the consumption of Medicinal Cannabis are Alzheimer's, cancer, diabetes, chronic pain, insomnia, heart and gastrointestinal diseases, epilepsy, PTSD, fibromyalgia, osteoporosis, and HIV. In total, there are 23 approved conditions for the use of medical cannabis. This must be recommended by an authorized doctor for the approval of its use and consumption method, not just any doctor can take action to recommend the patient license, and this must be managed through the Department of Health. The validity must be renewed annually or until the doctor so indicates. It is important to consider the effects that they produce in the body since each patient reacts to it differently.
Medicinal Cannabis and Cultivation Processes
Cannabis or Medicinal Cannabis refers to any compound, product, mixture, derivative, or preparation derived from any part of the plant including its seeds, flower or resin. Mature stems or fibers that are obtained from the plant are not included. The cannabis sativa plant tends to have a longer maturation process compared to others, but also due to its broad root system, its production rates are higher. The indica cannabis plant has a faster growth as does its flowering. The cultivation methods can be exterior or interior depending on the regulatory framework of each State and among the cultivation media to be used is coconut, perlite, earth, rock wool, moss and others. In addition to this, an irrigation system, environmental controllers, thermometers, hygrometers, fans, air conditioners, water filters, screens, greenhouses, dehumidifiers, C1D1 rooms, among many more, must be incorporated (Chandra, S. 2017).
In the vegetation stage, the nutrients for the plant must be high in nitrogen's, with mycorrhizae, vitamins, and supplements with a supplement of CO2 between 9001200ppm. The flowering stage already has a lesser number of hours exposed to light (12 hours) with nutrients high in potassium and vitamins, thus increasing the CO2 supplement up to a maximum 1500ppm (Wang, C., Ashworth K., Wiedinmyer C., Ortega, J., Harley, P., Rasool, Q., & Vizuete, W., 2020). Humidity plays an important role since it must be less than 50% to prevent the proliferation of fungi and bacteria that deteriorate or damage crops.
Toxic cleaning, disinfecting or chemical compounds must be approved by the Environmental Protection Agency (EPA), their labeling must be in optimal and legible conditions, and storage preferably away from any regular, locked-up processing area. The water should comply with the standard regulation of the Environmental Protection Agency, even if its derivation comes from the municipality or from a private entity. Pesticides must be organic products and for the infusion of any product it must be classified as "food grade" (Orenstein, D. G., 2018).
Legal Backround
Cannabis under Law 42-2017 in Puerto Rico becomes a Type II Drug classification of the Controlled Substances Act and the amount between Puerto Rico and any other place is prohibited. Its use will only be for medicinal purposes. The control and quality requirements should be like those required by the Federal Government for the pharmacy industries with their reports and good practice licenses. The required tests of cannabis in the country must have its moisture content, analysis of potency, terpenes, inspection of foreign matter, test of microbe and heavy metals, tests of residual solvents, pesticides and chemicals. For the seizure, non-consumable and solid waste must be ground and incorporated where 50% of these do not come from a derivative of medicinal cannabis such as food, fat, bokashi and waste approved by the Solid Waste Authority of the Commonwealth of Puerto Rico (Law 42, 2017).
Puerto Rico has ecosystems of great diversity, and each habitat is essential for flora and fauna, but as a result of poor planning and environmental management, these have deteriorated, increasingly destroyed, especially by humans. The National Environmental Policy Law has as its main requirement that nations guarantee environmental protection (Glicksman, R.L., 2019). In 1970, the Clean Air Law was introduced, which seeks to regulate the emission of pollutants into the air (Seguel, J. M., Merrill, R., Seguel, D., & Campagna, A. C., 2017). The Toxic Substances Control Law seeks to present reports and statistics that involve one or more substances that give way to an alteration or destruction of any ecosystem (Kasimir, Â., He, H., Coria, J., & Nordén, A., 2018). RCRA will determine a control over hazardous waste from its development, transportation, storage, and decommissioning. One of the most important laws for the environment is this, since its amendments have contributed to minimizing large amounts of waste to land, also giving way to planning that allows controlling emissions in different land areas. The Law for the Reduction and Recycling of Solid Waste in Puerto Rico establishes by obligation to create programs for the reduction and recycling of solid waste that seek to reduce the volume of these in landfills and implement them to recover resources and energy (ICEX, 2020). As it is a plant crop that uses organic pesticides, the Federal Law on Insecticides, Fungicides and Rodenticides is considered (Ebner, L. S., & Webb, D. A., 2019). The Autonomous Municipalities Law specifies that each town can establish its own projects and services. Also included is Law No. 416 of 2004 that establishes the implementation of a digital bank and Regulation 7470 for the Commercial Transportation of hazardous waste.
At present it is required that each municipality in Puerto Rico have a policy that allows its own waste management, however, not all of them are effective. Even more alarming is that it does not even reach 10% (ICEX, 2020). The barriers that mostly fluctuate in the procedures and that must be actuated quickly are deficit in the control, recycling as a political priority, lack of establishments, little awareness and others.
CHAPTER III
METHODOLOGY
This chapter has the purpose of presenting the methodology that I used to achieve the objectives of this investigative work. At present, the Medicinal Cannabis Industry in Puerto Rico is a recent one, so the information is not so extensive in terms of measures related to the generation of solid and dangerous waste. The information that was collected was in an exploratory framework, so the review of the data was measured through general documents of a Medicinal Cannabis company in the eastern area of Puerto Rico. It is worth mentioning that the research did not conduct a survey process, it did not work directly with any compounds derived from cannabis or any solvents or wastes.
The study had a focus within the Cannabis Industry in Puerto Rico in the eastern area. The data was obtained from the waste generated from an X industry in eastern Puerto Rico, which I categorized into hazardous and non-hazardous waste as the first objective. Then, based on that data, I was able to determine in a table, the amount of hazardous waste generated monthly to make comparisons of which strategic methods were most viable to find sustainable development (Montes, & Monreal, 2019). Each strategy presented can be considered for different medical cannabis industries and is not limited to just one so that in this way greater valorization and recovery of the natural resources that are being weakened can be achieved.
To meet the objectives stipulated in this investigative process, the general elements were the study of the parameters so that they could be described and explained from an environmental point of view, I include a stage of legal comparisons whether at the state, federal or treaty level international standards for prevention and precautionary measures for cannabis industries that provide services, which are widely produced.
History
This first phase consisted of collecting literature references to achieve an exhaustive analysis of the material to be investigated in competent and legislative documents of Puerto Rico. I thus include mechanisms that can be sanctioned for not complying with these environmental regulations. Subsequently, I analyzed the data obtained to promote a discussion and reflect to disrupt the investigative problem.
The information collected from historical data on medicinal cannabis and the generation of waste was obtained from different publications and scientific articles mostly associated with the European continent since the regulations are less strict as well as a comparison with California and Colorado where it is already completely legal. use of cannabis not only medicinal, but also recreational. Regarding environmental regulations, I was able to carry out searches mostly in federal contexts since Puerto Rico being a colony, many of its regulations are mediated by federal regulations (Serrano, 2018).
Evaluation
To carry out the investigative process, I studied different articles, publications and books that focus on environmental requirements and regulations at the state and federal level. The purpose of this was to identify which are the environmental dependencies that comprise the Cannabis Industry to meet the objectives and determine management strategies. Most of these documents are environmental laws of public order and were found via the web or internet of the Government of Puerto Rico, Department of Health, Department of Natural Resources, Environmental Quality Board and others (TardÉ 2020). The study period was approximately 4 weeks of analysis after obtaining the established data of the Medical Cannabis Industry X of the eastern area, which was provided in July 2021.
Planification
When there is little or no participation on the part of a company, then consequences associated with the misuse of natural resources can be observed, which can degrade the quality of products or services that in turn increase the costs and waste generated. So, in order to reduce these potentially harmful problems for the environment, it is necessary to make decisions that seek to establish order of priorities in the short and long term. Analytical research is necessary to understand whether a company complies with environmental protections, and this is achieved by planning, then the model to be followed must be carried out, verified and finally executed the plan. Questions must be answered such as: where is the company currently? Where does it want to go? What is the purpose and what resources are necessary? A SWOT analysis can be performed to measure the strengths, opportunities, threats, and deficiencies in the Medical Cannabis Industry in Puerto Rico to determine a number of strategies of which should be ranked in order of priority by the industry in order to maintain or incorporate a good management and waste management (Wicaksono, Nawisworo, Wahyuni, & Cholily, 2021).
For a design of environmental management tools, I developed different comparative research studies which have shown a high degree of effectiveness so that in this way the general objectives are oriented to an adequate management to reduce the amount of waste generated in the clearest and clearest way. concise possible. The measures adapted in this research mainly involve environmental recovery, recycling, and waste reduction. Additionally, I managed to incorporate implementation strategies that allow a reduction in electricity consumption, water and gases released into the atmosphere. It would also be key to consider the implementation of a regulation based on ISO 14000 standards for the evaluation of the industry and what is its position regarding environmental problems.
The risk management stage identifies problems that have not been solved, problems that are expected to occur in the future, risks that have already been manifested, and so on. It should be noted that risks can be minimized, however, they cannot be eliminated, so the strategies will not be aimed at completely eliminating waste. Therefore, the probability in which these risks occur and what their negative impact would be if they occurred should be analyzed. To fully enter a management then each area must be involved in the process of identification, solutions to the problem, communication with the different parties, they cannot involve decisions that alter the future, but they can be prevented in the future. Then you can establish a scheme that given a certain condition then there is the possibility of a consequence. In this way, the investigation is directed to estimate the probability of the risks occurring, the causes and measures to be taken for correction. The action plan may be inclined to avoid a risk, mitigation and contingency plans and accept the risks without acting (which is not what is expected).
CHAPTER IV
DISCUSSION
The purpose of this discussion of data and results is to present how the strategies for the implementation of a hazardous waste management were determined in an adequate manner in the Medical Cannabis Industry in Puerto Rico. The objectives were to evaluate which waste generated in the industry is classified as hazardous and which is classified as non-hazardous, it also allows the design of tools for proper management and which of this impact the environment. Therefore, with the data obtained, the Strategic Plan for the Generation of Hazardous and Non-Hazardous Waste in the Medical Cannabis Industry in Puerto Rico is presented. It should be noted that it is the first research study on the generation of hazardous waste in Puerto Rico within the Medical Cannabis Industry and therefore cannot be compared with other studies. Reference is made to different countries such as Canada, and states such as Colorado and California where its recreational use is legal and there are similar studies for comparison.
According to the Economic and Commercial Office of the Consulate of Spain in San Juan Puerto Rico, the country has been predicted with high probability of an environmental crisis because of the scarcity of management measures, management, and generation of waste. It is taken into consideration that many of the landfills that currently operate are reaching their capacity limits, adding that others were closed by the EPA due to failure to comply with federal and state regulations (Diaz, 2019). The key point is that if the innovation industries that arise with the new advances in science and technology do not have generation, mitigation, and recycling plans in terms of hazardous and non- hazardous waste, the country in addition to entering that crisis The environment can also have losses for the economy, negative effects on public health and others. How was the waste generated in the past managed? Puerto Rico has long depended on China for the proper export of waste, but with the new economic measures regarding taxes, it is difficult to have the capital to do so.
The waste generated in Industry X in the eastern area of Puerto Rico is not fully quantified since the medical cannabis industry on the Island is relatively in its infancy, so the data available on waste generation does not exist. In (Table 1) it is possible to present the amount of waste generated in industry X generating a total of 2,632.76 kg of waste monthly. Of the quantity presented, 2071.5kg are produced by the cultivation phase and 561.71kg by the manufacturing phase. Regarding what is vegetative material from the cultivation phase, this corresponds to 78.7% (Figure 1). On the other hand, the remaining 21.3% corresponds to the manufacturing phase. It is possible that the amount of waste per department will result in changes, however, the data of each generation was not available at the time of obtaining information. The waste with the highest amount generated are the stems with 94%, followed by the defoliation leaves with 6% and 0.2% associated with the waste of pots / coconut that are the medium used for transplantation of the total generation (Figure 2). It is important to note that not all waste generation data is available so these amounts are approximate and may increase as the data becomes available or is correctly the manufacturing phase is mainly linked to hazardous waste, so the data presented, although compared to the cultivation phase in terms of waste generation is lower, the degree of danger is greater, so its quantification is important for this research study. The data on the amount of waste in the phase is presented in (Table 1). The waste in greater quantity in this phase is the solvent Ethanol 200% representing 74% of the total data (Figure 3), followed by nitrogen for 15%, the waste of isopropyl alcohol and the pump oil used is close to 3 %. Regarding the “trim” treated with residual solvents (butane / propane) represents a generation of 2% of the waste, the gas mixture (butane / propane) is another 2% and finally the heptane dates 1% of the total amount of waste.
A study carried out in Vancouver estimated that its waste for plant cultivation is between 8,253.56 kg, a truly alarming and worrying number for the environment (Vancouver, M., & Alba, C., 2020). If we make a comparison of waste generated in the cannabis industry in Puerto Rico and Vancouver, we can determine that the generation of waste in Vancouver is higher, also understanding that the industry in Vancouver is only for cultivation and does not include the manufacturing phase.
In Puerto Rico there are 43 growing companies and 34 manufacturing companies (Table 2) that continuously emit different types of both hazardous and non-hazardous waste, so if each of these generated an amount of waste close to 31,000,000kg, the total would be close to of the 2 million kilograms. It should also be taken into consideration that not all these industries generate at the same capacity. In addition to the crops and manufactures, as is also shown in, there are other companies that work in some way or another with medicinal cannabis directly, which also have their generation of both dangerous and non-dangerous waste that there is a probability that in the future they may be incorporated into related studies. The State of Washington reported from 2014-2017 a 771,000kg of waste associated with the production and sale of cannabis which includes both organic matter and materials and solvents from its extraction processes Dalia, K., 2020). Another alarming figure for the environmental health of the United States is that the amount of waste generated from the cannabis industry is greater than 150 million tons, equivalent to 136,077,711,000kg (Vancouver, M., & Alba, C., 2020).
The cultivation phase generates approximately 2,077.4 kg of waste, most of which is not hazardous and data on hazardous waste in this phase is not available (Figure 3). The manufacturing department generates an exorbitant number of residual solvents where 200% ethanol is the highest figure with 414.13kg of hazardous waste in relation to the cultivation department that with the data obtained the generation of hazardous waste is 0. Gases used in the extraction processes indicate 9.43kg of butane / propane and 83.46kg of nitrogen from waste that are released by extractors. Many of the processes involve machinery that requires oil, so it is also properly maintained, thus discarding 18.96kg of used oil. In addition to this, both phases of both cultivation and manufacturing have waste in common, such as the masks required by the COVID 19 pandemic since 2020, protective equipment, sanitary waste, packaging, and others which are not fully quantified. Of the waste generated in Company X, the hazardous waste is determined to be plant nutrients, pH adjusters, ozone, “grow lamps”, residual solvents, gases, pump or equipment oils, medicated food residue, and cleaning chemicals. The available data provides us with an idea of what the annual hazardous waste projection would be, where 157.8kg comes from residual solvents, 113.16kg from extraction process gases, 4,969.56kg from 200% ethanol, 225.8kg from isopropyl alcohol, 227.52 kg of used oil and 1001.5kg of nitrogen for company X (Table 3). In studies carried out in the United States, they add to their expenses and emissions of “greenhouse gases” because cultivation in the open air is not permissible, thus increasing them within indoor crops (Summers, HM, Sproul, E., & Quinn, JC, 2021).
The classification of hazardous and non-hazardous waste in the medical cannabis industry X in Puerto Rico (Table 4) is summarized in that the non-hazardous waste is: vegetative material (leaves, stems, growing media such as coconut), laboratory equipment, safety equipment such as "shoe covers", blotting paper, packaging, and others. Hazardous wastes were identified as: nutrients, pH adjusters, residual solvents, gases, used equipment oils, heater fluids, and cleaning chemicals. This helps us meet the first objective of the research study.
Because the use of cannabis has not been legalized at the federal level, as mentioned above, there is still no regulatory framework or agencies that provide information or provide guidance to industries, therefore there are also discrepancies between environmental regulations by State. For this reason, it is necessary that the different state governmental entities, departments of agriculture, food and others begin to regulate this industry in a direct way, focused on the generation of both dangerous and non-dangerous waste. An environmental analysis of the cannabis cultivation processes details that the environmental policy related to cannabis advances in an extremely slow process and the states that have established recreational use do not have regulatory standards for specific pollutants (Salerno, S., 2020).
Another problem related to the lack of environmental policy and the recycling proposal for waste in the cannabis industry is due to this limit of federal regulation (Anderson, JE, Hughes, M. Ü., & Nguyen, C., 2019). We can understand how the problem does not occur only in Puerto Rico but that throughout the United States there are also limitations on the disposal and management of hazardous and non-hazardous waste, mostly where its use is already recreational. Much generated biodegradable material can be recycled or reused as bioenergetic feedstock, which is where Canada wants to move, but there are many gaps due to the lack of research data related to the potential for greenhouse gas reduction (Parvez, AM, Lewis, JD, & Afzal, MT, 2021). Based on this, 78% of the leaf removal leaves, stems, pots / coconut or vegetative material could be recycled or reused for industry X if new regulations at the state or federal level allowed their use for processes such as phyto-extraction, curl-filtered, phyto-degradation, among others (Alufasi, R., Zeman, S., Bagar, T., & Chingwaru, W., 2020).
To mitigate the generation of waste, action must be taken quickly before the quantities become uncontrollable because the quantities of waste in the landfills of Puerto Rico are intolerable where their capacity is already on the brink and for that reason most have closed. additional to the fact that they did not handle these correctly. The Medical Cannabis Industry has brought much improvement in the health of Puerto Ricans and Puerto Ricans, but we must also be aware that if they are not disposed of correctly, the health sector, the environmental sector and the economic sector can be affected.
CAPTTULO V CONCLUSIONS AND RECOMMENDATIONS
Conclusion
The main problems related to the management and mitigation of hazardous and non-hazardous waste faced by the cannabis industry in Puerto Rico and in the United States are linked to deficiencies due to the lack of jurisdiction on the part of the Federal Government since cannabis is classified as Drug Type I. On the other hand, there are already laws that allow its medicinal or recreational use depending on each State or country together with their laws or regulations for use. Now, the fact that the Federal Government still classifies it as a Type 1 Drug, indicating that it has no medicinal use, this puts environmental health and its protection at both direct and indirect risk. Therefore, as the federal government does not enter into jurisdiction, environmental protection and waste management laws are not being considered in operating processes for both the medicinal or recreational fields.
Puerto Rico's hazardous and non-hazardous waste disposal regulations have a certain degree of ambiguity since it stipulates that they must be disposed of according to state or federal laws and other regulations, rendering the material unrecognizable or unusable. They do not provide any additional information or reference to carry out these processes. This in turn brings with it a problem of misinterpretations since making a material unrecognizable allows a wide degree of interpretations where it is possible that mixing substances or waste with other materials produces dangerous mixtures for humans and the environment.
Most of the waste can serve as usable resources, significantly reducing waste up to about 79%, thus providing reduced economic costs for the medical cannabis production industries. The remaining percent comes from hazardous waste that must be stored and disposed of properly. When analyzing the results, the Crop Department generates waste that can mostly be reused or recycled, establishing an action plan for it. This indicates that the hazardous waste management plan is more associated with the Manufacturing Department due to the amount of solvent it uses in its processes. On the other hand, the correct management of hazardous waste must be strictly given by the laws, norms and regulations stipulated at the federal level since they have high degrees of toxicity, dangerousness, explosiveness to which no one wants to expose and is not healthy for the ecosystems and nature in Puerto Rico.
Companies need a compliance group in charge of maintaining processes and quality standards in accordance with federal regulations, keeping internal audits with them so that when external audits are presented mediated by the Department of Health they are not fined. Staff development is ideal by maintaining compliance group leaders and educating others. For this reason, you are provided with a list of rules, regulations, and laws of Puerto Rico associated with the correct use and management of hazardous and non-hazardous waste. When this type of waste planning and management guidelines or strategies are not implemented in production industries, the risk of continuing to contribute to the large amount of garbage in Puerto Rico's landfills will not cease. So, we must enter into the context that if we do not act quickly in the industrial sector then in the near future, we will be surrounded by garbage that possibly has dangerous potentials for both public health and environmental health.
So, there is the ability to use non-hazardous waste from medical cannabis industries that can be reused or recycled. Among them you can compost, manufacture textiles, feed livestock, use culture media such as coconut to reincorporate plant growth processes, recycle material for energy production and to minimize CO2 released into the atmosphere, and others. On the other hand, the solvents used can be re-distilled for use if they are governed by safe standards for both the employee, the consumer and nature. Regarding hazardous waste, it is extremely important to have key information aimed at storage, handling, and disposal processes to avoid problems that affect the health of employees and the environment, for this reason strategies are incorporated for this. The importance of understanding the different types of materials (Figure 6) with their respective classifications allows broadening the context of where residual substances or waste material generated can be stored or not. It should be noted that each waste must maintain different storage containers, specific assigned areas and each one with labels that show each size for handling.
The limitation of this research study was the lack of data for many other wastes generated, so it is advisable to guide and educate companies to keep waste records for each operating process and thus fully quantify the waste in each area. The exact quantification of the processes is also complicated since that will depend on how the market moves and the technical conditions of the processes.
Finally, the impact that the mismanagement of hazardous and non-hazardous waste can cause within mostly indoor facilities can affect structures, water quality, air quality, alterations to the landscape and others. It is important to understand that the integral management of waste is the responsibility of each industry and its personnel regardless of the operational processes that are carried out in that place. The main objective will be to seek mitigation and continuous improvement strategies incorporating strategies presented in this research study and even more so not limiting ourselves to them. We are aware that the cannabis industry has a promising future and that it can provide great environmental, economic, and social benefits for sustainable and sustainable development.
Recommendations
One of the limitations for a more exhaustive study is the lack of scientific research and data associated with the generation of these solid and dangerous wastes within this brand-new industry, which is why it is urged to continue detailing the generation of each waste generated by the companies. industries.
Within the limitations of the medical cannabis industry in terms of federal regulations, environmental plans are difficult to access different companies to obtain the data, so it is advisable to call for environmental legislation within the industry for the protection of the natural resources of Puerto Rico.
It is recommended that the Department of Health, the agency in charge of the medical cannabis industry on the island, should directly and in detail demand the environmental plans of each industry to authorize their operating permits. Without forgetting to legislate in favor of a more specific and detailed regulation.
For future studies, the possibility of implementing the guide drawn up in a Medical Cannabis Industry in Puerto Rico would be sought to adjust it in real time and look for possible changes, modifications, or reinforcements of it.
CHAPTER VI
STRAGETIC PLAN
The strategic plan of this thesis was based on the selection of different strategies that present research studies that have been established or implemented in different industries or companies not necessarily linked to medical cannabis. The Medicinal Cannabis Industry around the world is recent, so there are no studies related to waste management directly from this industry, therefore the bibliographic support is linked to pharmaceutical and manufacturing industries in general.
To achieve this stage, responsibilities and roles must be assigned within the cannabis industry. In this way, a diagnosis and quantification of hazardous and non- hazardous waste begins to achieve the training and training desired by the company, modified for continuous improvement among the directors of the company. Subsequently, there is a separation of the sources to achieve a storage matrix with characteristics of the products, equipment and materials used. Thus, the description of optimal conditions and collection centers to store these wastes can be made until they are assigned or distributed to recycling or reuse processes, or they are completely discarded as long as it is carried out within the processes required by the Department. of Health established in the MEDICINAL Law and Regulation 9038 of Puerto Rico.
Strategy 1: Design of the General Strategic Plan
As a first stage, an internal audit should be carried out based on the identification of the amount of waste generated in a detailed way and to be able to develop a comprehensive report of which of these wastes can be harmful to the company, that is, which are dangerous (Semete- Makokotlela, DB, & Shapra, C., 2021). In this way, a specific approach is achieved for each waste and how it must be managed to reduce the negative impact that it may have on the environment in the short or long term.
Every company that has a large amount of production of some good or product should have a compliance department that collects data in a certain amount of time. You can begin to conduct interviews with specific areas of production to gain knowledge of the processes that are carried out in the industry. Thus, it is possible to establish time limits to carry out the audits and enforce the specific requirements determined by the laws for the management of hazardous waste (Mej^a Acevedo, J. D., 2020). When the data on the generation of waste is obtained, then projects begin to be developed where the departments are oriented as to how they should be managed in a specific way, since each one contains specific methods of collection, storage and disposal.
Strategy 2: Compliance Reports
For the Medicinal Cannabis Industry to improve its environmental management and waste management processes, it is necessary to produce reports that detail the failures and continuous improvements that must be implemented. There should be a "Safety Data Sheet" for each product, substance or chemical used in each department as well as the amount they have in storage, whether unused or used. The importance of this is to have the required and necessary documentation of the hazards to which the personnel or ecosystems of Puerto Rico may be exposed. This sheet contains the data on what to do in cases of dangerous situations associated with the substance and how they can be prevented from occurring, in addition to its composition, handling and storage, emergency measures and additional information.
Strategy 3: Meetings
Each Department must have one or more individuals in charge of managing and controlling the waste generated, who must attend meetings mediated by the Compliance Department, which can determine which indicators are on alert and what will be the order of priority to attack weaknesses. or failures. Based on this, in these meetings a SWOT analysis can be carried out which allows the combination of studies carried out by the company determining its strengths, opportunities, weaknesses and threats to establish future strategic plans. It was of great value that in these meetings a main objective could be established that in the process to promote an Internal Policy linked to Ecological and Environmental Responsibility.
Strategy 4: Material Flow Analysis
The next step would be to carry out a material flow analysis which is a systematic inventory of the substances or chemicals that are handled in the industry from the day it is received until it is finally discarded (Mora Aguilar, J. S., 2020). This analysis determines where the waste or emissions come from, and which are the weak points. In this way, projects are evaluated and developed to minimize waste and its emissions. The criteria to consider are the selection of volume, cost, toxicity and legal aspects.
The first stage of this analysis establishes the parameters to consider, the area and period of balance or lifetime. Then, the operational steps and other equipment associated or involved in the process of using that substance are entered and they are interconnected for the development of the flow sheet. From that point you can perform quantitative analyzes such as used solvents. The data is interpreted through flow sheets, histograms, and others. And it concludes with measures or recommended actions to mitigate the problems.
Strategy 5: Type of Materials in the Facility
Within a manufacturing or indoor cultivation there may be an immense capacity of products and materials that must be identified in the operating processes. Therefore, it is advisable to identify the type of storage required for its final disposal. Among the possible treatments are physical, chemical, biological, thermal and others. For an organizational management that involves the minimization of hazardous waste, a table of waste use is presented (Table 6). It is important to note that to carry out the proper management of hazardous and non-hazardous waste, Puerto Rico's environmental policy must be taken into consideration, therefore, a list of references that can be used will be provided below:
- Constitution of the Commonwealth of Puerto Rico, Article VI, Section 19
- Puerto Rico Solid Waste Authority Act - Act No. 70 of July 23, 1978, as amended
- Law for the Reduction and Recycling of Solid Waste in Puerto Rico - Law No. 70 of September 18, 1992, as amended
- Environmental Public Policy Act - Act No. 9 of June 18, 1970, as amended
- Autonomous Municipalities Law - Law 81 of August 30, 1991, as amended
- Act for the Proper Management of Used Oil in Puerto Rico - Act No. 172 of August 31, 1996, as amended
- Law for the Prevention of Pollution, Law 310 of September 2, 2000
- Non-Hazardous Solid Waste Regulation
- Executive Order 2001- 58th of October 5, 2001
- Organic Law of the Planning Board - Law 75 of June 24, 1975, as amended
- Puerto Rico Land Use Plan
- Organic Law of the Department of Natural and Environmental Resources- Law 23 of June 20, 1972, as amended
- Statutes of the Federal Government
- Law of Conservation and Recovery of Resources 1976
- Federal Regulations, Title 4
Part 256
Part 257
Part 258
Strategy 6: Identification of Hazardous Waste
According to the EPA, four criteria are used to identify a waste: content with a chemical that affects human health or the environment (toxic), those that can directly affect the environment, even if they are handled correctly (acute), contains any of these characteristics or simply the agency considers it to be part of the hazardous material category. Based on this, it is assigned a hazard code with the following characters (F, K, P, U). The P and U are chemicals that are destined to be discarded without their previous use, so they are not waste, the results of certain operational processes. The K code is assigned to specific sources that are specific industrial processes, manufacturing, explosives, etc., the F code is assigned to non-specific sources derived from common processes such as solvents used for degreasing, the P code are products Acute waste chemicals (Annex 1) and the U code refers to general toxic chemicals (Brechtelsbauer, E., & Shah, S., 2020)
Mitigation
Any process that involves production tends to generate waste, whether hazardous or non-hazardous. This means that a quantity of raw material is constantly lost which can cause inefficiencies in that production process. In this way, they are due to minimize or mitigate said waste either through recycling or reducing sources.
As a first strategic method, an assignment of responsibilities is proposed (Table 5) that determines what the company's functions are in terms of the comprehensive management of hazardous and non-hazardous waste. To quantify the waste, it is necessary to carry out a weighing at the time of disposing of them, recording them on a form of both hazardous and non-hazardous waste that indicates the name or type of material, the date of quantification, identification of hazardous or non-hazardous waste, determination of whether it is recyclable or reusable material, amount to be disposed of and a signature of who disposes of it. This will facilitate the proper and safe management of waste generated in industries without affecting the environmental quality or occupational safety of the company.
The training of employees for the disposal of waste must be given at least twice a month with an approximate duration of 30-45 minutes directed by the Compliance Department, Administrative Department and / or Operations Department. Among the topics to be discussed are educating as to what hazardous and non-hazardous solid waste is, how it is classified, what an integral waste management consists of, what environmental and occupational impacts can generate its mismanagement, legal framework of the solid waste according to the laws of Puerto Rico, importance of the separation of sources of hazardous and non-hazardous waste and finally the storage, recycling and final disposal of the waste generated.
A technical way to separate solid waste is by making legible and easy-to-understand labels to dispose of the waste, these must be located in such a way that anyone can understand and if colors are used it can be more effective. As an example, biodegradable material can be identified in green, inert materials in blue and recyclable material in yellow (Fig. 5). The labels may have additional information characteristic of each container (Fig. 6). Regarding non-hazardous waste, they must identify the permissible storage capacity and the place assigned for it.
The collection and storage of hazardous and non-hazardous waste is linked to the storage capacity, the time required or allowed for storage, the waste generated and others. As far as some of the required conditions of the collection or storage center must be in the physical plant, it must not be exposed to contact with pests, insects, rodents or other animals, it is important that it is in a place where the atmospheric conditions are not a problem for storage, preferably the walls and floors should be concrete and waterproof with enough lighting and ventilation. As a warning, it is required that there are extinguishers and spill material in case a spill or fire occurs, considering materials that can be flammable, corrosive, toxic or explosive such as gases, oils and chemical solvents. This area should be restricted to fully trained and authorized personnel. Monthly cleaning and maintenance schedules are also recommended. According to the Puerto Rico Environmental Quality Board, waste generators of more than 1000kg of waste per month can store them up to a period of 90 days, while for generators of 100kg or less they have a storage limit of 180 days (Kaelin, AB, 2019). Records of waste generation (Annex 2), Area Inspection (Annex 3), Safety Inspection (Annex 4) and Inspection of Labeling and Containers (Annex 5) must be kept.
The need for Satellite Hazardous Waste Accumulation Areas may be an option as regulations establish limited amounts of hazardous waste storage. It can hold up to a maximum of 55 gallons of different non-acute hazardous waste substances and up to 473ml of acute waste. As has been mentioned, each container must be properly labeled and covered, along with it there must be a weekly inspection record where they should not touch the floor. When the central storage container is full then we proceed to have contact with the agency in charge of its disposal. It is important not to store oxidants together with organic solvents at any time, their location should not be near doors, corridors or emergency exits. Disposal of waste through sinks or drains will never be permissible.
The recyclable material must be kept in containers intended for them so that the collection process is carried out with a company in charge of recycling cardboard, glass, plastic, etc. Inert material must be delivered to the agency in charge of disposal to landfills, mostly the contact comes from government agencies in each municipality, although they can also be private. Regarding hazardous materials and their collection, the disposal of these must be managed with mostly private companies, so it would be very effective to include in the regulation agencies in charge of this type of disposal that are not limited by acquiring hazardous waste from the cannabis industry. A list of Recovery Plants in Puerto Rico is presented (Table 7). To have a context of the benefit of this mode of mitigation, some environmental identifiers are presented with their equivalence presented by the Department of Natural Resources (Table 8).
The agencies in charge of the transport or final disposal of hazardous waste must have a contract with the company and together with each waste must be delivered manifests that contain the name, address, generator, transported, linked facilities, description and quantity of waste, type container and others.
Additional Recommendations
Residues that come from the cultivation phase classified as biodegradable can be reused as a source of nutrient for different stages of plant cultivation, so that the harvest can have decomposition techniques of organic bioprocesses, which can be resulting in composting processes. The coconut used as a base for the support or support medium of the plant can be reused by carrying out a cleaning and purification treatment, thus avoiding economic costs for the company and reducing production costs. Pruning waste may also serve as a high fiber feed source for animals such as livestock.
CITED LITERATURE
Aguilar, S., Gutiérrez, V., Sanchez, L., & Nougier, M. (2018). PoKticas y prâcticas sobre cannabis medicinal en el mundo. México Unido Contra La Delincuencia, 33.
Albino, O. A. V. (2018). El Reciclaje en Puerto Rico: Ley en Letra Muerta. Rev. Der. PR, 58, 313.
Alufasi, R., Zeman, S., Bagar, T., & Chingwaru, W. (2020). Cannabis sativa l. and Its Potential Applications in Environmental Bioremediation. A Review. hmeljarski bilten, (27).
Anderson, J. E., Hughes, M. Ü., & Nguyen, C. (2019). The highs and lows of startups in the Cannabis industry: A PESTLE analysis of the current issues. In Business Forum (Vol. 27, No. 2, p. 26).
Ashworth, K., & Vizuete, W. (2017). High time to assess the environmental impacts of cannabis cultivation.
Astudillo Arias, D. S., & Vicente Velâsquez, J. M. (2020). Técnicas de fitorremediacion para el tratamiento suelos contaminados con petroleo: revision sistemâtica.
Brechtelsbauer, E., & Shah, S. (2020). Update on pharmaceutical waste disposal regulations: strategies for success. American Journal of Health-System Pharmacy, 77(T), 574-582.
Bridgeman, M. B., & Abazia, D. T. (2017). Medicinal cannabis: history, pharmacology, and implications for the acute care setting. Pharmacy and Therapeutics, 42 (3), 180.
Butsic, V., Carah, J. K., Baumann, M., Stephens, C., & Brenner, J. C. (2018). The Emergence of Cannabis Agriculture Frontiers as Environmental Threats. Environmental Research Letters, 13 (12), 124017.
Calabuig Rovira, J. J. (2020). Desarrollo del Proyecto de Cultivo de Cannabis en Interior para uso Medicinal en Puerto Rico (Doctoral Dissertation).
Chandra, S., Radwan, M. M., Majumdar, C. G., Church, J. C., Freeman, T. P., & ElSohly, M. A. (2019). New trends in cannabis potency in USA and Europe during the last decade (2008-2017). European archives of psychiatry and clinical neuroscience, 269(1), 5-15.
Dalia, K. (2020). Green Garbage: A State Comparison of Marijuana Packaging and Waste Management. Golden Gate U. Envtl. LJ, 12, 175.
Delgado, M. A. (2017). Anâlisis de las implicaciones de la aprobacion del proyecto de ley 19.256, ley para la investigation, regulation y control de las plantas cannabis y cânamo para uso medicinal, alimentario e industrial: efectos socioeconomicos, ambientales y su implementation institucional.
Departamento de Salud de Puerto Rico (2018). Reglamento para Manejar el Estudio, Desarrollo e Investigation del Cannabis para la Innovation, Normas Aplicables y Limites. Recuperado de Reglamento Num. 9038.pdf (salud.gov.pr)
D^az Garced, C. G. (2019). Impacto social del dano medioambiental. Anâlisis de caso: Puerto Rico 50 anos después del Estado Libre Asociado.
Ebner, L. S., & Webb, D. A. (2019). Scope and Application of the FIFRA Treated Articles Exemption. Journal of Transportation Technologies, 10 (01), 16.
Febus, H. G. (2019). Anâlisis del desarrollo historico de la salud ambiental en Puerto Rico desde 1970 hasta el 2000 y su impacto en la education (Spanish Edition). Ibukku, LLC.
Glicksman, R. L., Markell, D. L., Buzbee, W. W., Mandelker, D. R., & Bodansky, D. (2019). Environmental protection: law and policy. Aspen Publishers.
Gomez Rivera, U. A. (2020). Optimization del recorrido en la disposition de desperdicios solidos industriales mediante dispositivos de medicion y comunicacion. Instituto de Ingenieria y Tecnolog^a.
Hall, W., & Lynskey, M. (2020). Assessing the public health impacts of legalizing recreational cannabis use: the US experience. World Psychiatry, 19 (2), 179-186.
Huggins, C. (2020). Experiencing COVID-19 in the health-system pharmacy. Pharmacy Today, 26(5), 3-4.
ICEX (2020). Cannabis medicinal en Puerto Rico. Espana Exportation e Inversiones, 112.
Ikram, M., Mahmoudi, A., Shah, S. Z. A., & Mohsin, M. (2019). Forecasting number of ISO 14001 certifications of selected countries: application of even GM (1, 1), DGM, and NDGM models. Environmental Science and Pollution Research, 26 (12), 12505-12521.
Kaelin, A. B. (2019). In Effect and Being Enforced: Hazardous Waste Generator Improvement Regulations. Journal of Protective Coatings & Linings, 36(2), 15-17.
Kasimir, Â., He, H., Coria, J., & Nordén, A. (2018). Land use of drained peatlands: Greenhouse gas fluxes, plant production, and economics. Global change biology, 24 (8), 3302-3316.
Labiano, V. (2020). State Styles of Illegal Drug Regulation in South America. Revista mexicana de ciencias polüicas y sociales, 65 (240), 89-118.
Ley Num. 42 (2017) de Puerto Rico. Ley MEDICINAL. Recuperado de “Ley para Manejar el Estudio, Desarrollo e Investigacion del Cannabis para la Innovacion, Normas Aplicables y Lrnites. Gobierno de Puerto Rico
Li, B., Yang, J., Zhao, F., Zhi, L., Wang, X., Liu, L., ... & Zhao, Y. (2020). Prevalence and impact of cardiovascular metabolic diseases on COVID-19 in China. Clinical Research in Cardiology, 109(5), 531-538.
Mecicano, H. K. V. (2017). Design of the Mechanical Recycling Process for Polyethylene Terephthalate Bottles Using the Lean Manufacturing Methodology in Puerto Rico (Doctoral dissertation, Universidad Politecnica Puerto Rico (Puerto Rico).
Mej^a Acevedo, J. D. (2020). Plan de negocios: production sostenible de extractos de cannabis, destilacion, purification y aislamiento de cannabinoides para comercializacion en el exterior (Bachelor's thesis, Uniandes).
Mills, E. (2012). The carbon footprint of indoor Cannabis production. Energy Policy, 46, 58-67.
Montes, N. G., & Monreal, L. A. (2019). Metodolog^as participativas para la planificacion de la sostenibilidad ambiental local. El caso de la Agenda 21. Empiria: Revista de metodolog^a de ciencias sociales, (44), 109-133.
Mora Aguilar, J. S. (2020). Anâlisis de ciclo de vida en cultivo de Cannabis sp. medicinal.
Negron Marin, J. (2019). El Empleado-Paciente de Cannabis Medicinal en Puerto Rico. Rev. Jur. UPR, 88, 920.
Orenstein, D. G., & Glantz, S. A. (2018). Regulating cannabis manufacturing: applying public health best practices from tobacco control. Journal of psychoactive drugs, 50 (1), 19-32.
Parvez, A. M., Lewis, J. D., & Afzal, M. T. (2021). Potential of industrial hemp (Cannabis sativa L.) for bioenergy production in Canada: Status, challenges and outlook. Renewable and Sustainable Energy Reviews, 141, 110784.
Pavlovic, R., Panseri, S., Giupponi, L., Leoni, V., Citti, C., Cattaneo, C., ... & Giorgi, A. (2019). Phytochemical and ecological analysis of two varieties of hemp (Cannabis sativa L.) grown in a mountain environment of Italian Alps. Frontiers in Plant Science, 10, 1265.
Perveen, S., & Al-Taweel, A. (2018). Introductory chapter: Terpenes and
terpenoids. Terpenes and terpenoids, 1-12.
Quiroga-Santana, A., Rodriguez-Velasquez, O., Acosta Leal, D. A., Pastor-Sierra, S., & Gonzâlez-Martmez, J. (2020). Prospective analysis of phytoremediation species for agricultural soils contaminated with cadmium in Mosquera-Colombia. Journal of Alternative Perspectives in the Social Sciences, 10 (2).
Rivera Rondon, M. (2017). La education ambiental en Puerto Rico: propuesta para un modelo interdisciplinario de education formal.
Rodriguez Burgos, N. (2019). Una Mirada a la Recien Instituida Industria del Cannabis Medicinal en Puerto Rico. Rev. Jur. UPR, 88, 960.
Salerno, S. (2020). An Environmental Analysis of Recreational Cannabis Cultivation & Processing (Doctoral dissertation, WORCESTER POLYTECHNIC INSTITUTE).
Seguel, J. M., Merrill, R., Seguel, D., & Campagna, A. C. (2017). Indoor air quality. American journal of lifestyle medicine, 11(4), 284-295.
Semete-Makokotlela, D. B., & Shapra, C. (2021). Guideline for Cultivation of Cannabis and Manufacture of Cannabis-Related Pharmaceutical Products for Medicinal and Research Purposes.
Serrano, J. R. (2018). Cambios en el Manejo de Desperdicios Solidos en Puerto Rico: Waste-to-Energy. UPR Bus. LJ, 10, 31.
Summers, H. M., Sproul, E., & Quinn, J. C. (2021). The Greenhouse Gas Emissions of Indoor Cannabis Production in the United States. Nature Sustainability, 1-7.
Tardi Galarza, A. (2020). Serie: 3Sb. 1.1. Departamento de Ingenieria Civil, Ingenieria Ambiental y Agrimensura/SubSerie: 3Sb. 1.1. 4. Facultad.
Vancouver, M., & Alba, C. (2020). Cannabis Waste Management in Metro Vancouver.
Wang, C. T., Ashworth, K., Wiedinmyer, C., Ortega, J., Harley, P. C., Rasool, Q. Z., & Vizuete, W. (2020). Ambient measurements of monoterpenes near Cannabis cultivation facilities in Denver, Colorado. Atmospheric Environment, 232, 117510.
Wicaksono, G. W., Nawisworo, P. B., Wahyuni, E. D., & Cholily, Y. M. (2021, February). Canvas Learning Management System Feature Analysis Using Feature-Oriented Domain Analysis (FODA). In IOP Conference Series: Materials Science and Engineering (Vol. 1077, No. 1, p. 012041). IOP Publishing.
TABLES
Table 1
Waste Generated by Department monthly in Industria X de Cannabis Medicinal del Este de Puerto Rico
Abbildung in dieser Leseprobe nicht enthalten
Table 2
Medicinal Cannabis Industries in Puerto Rico
Abbildung in dieser Leseprobe nicht enthalten
Table 3
Annual Hazardous Waste Projection for Medical Cannabis Industry X in Puerto Rico
Abbildung in dieser Leseprobe nicht enthalten
Table 4
Classification of Hazardous and Non-Hazardous Waste from Medical Cannabis Industry X in the eastern area of Puerto Rico
Table 5
Company functions for the management of hazardous and non-hazardous waste and its recommended action time
Abbildung in dieser Leseprobe nicht enthalten
Table 6
Activities to minimize generated waste
Abbildung in dieser Leseprobe nicht enthalten
Table 7
Materials Recovery Plants in Puerto Rico
Abbildung in dieser Leseprobe nicht enthalten
Table 8
Equivalence of environmental indicators by the Department of Natural Resources
Abbildung in dieser Leseprobe nicht enthalten
FIGURES
Figure 1
Hazardous and Non-Hazardous Waste Generated from Company X of Medicinal Cannabis in Puerto Rico
Abbildung in dieser Leseprobe nicht enthalten
Figure 2
Abbildung in dieser Leseprobe nicht enthalten
Figure 3
Waste Generated by the Manufacturing Department of Company X of Medicinal Cannabis in Puerto Rico
Figure 4
Example of assigned colors for containers
Abbildung in dieser Leseprobe nicht enthalten
Figure 5
Example of Labeling with Descriptive Content Information
Abbildung in dieser Leseprobe nicht enthalten
Figure 6
Hazardous Waste Classification
Abbildung in dieser Leseprobe nicht enthalten
ANNEXES
Annex 1
List of Hazardous Waste Codes by the Environmental Protection Agency
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EPA HAZARDOUS WASTE CODES
Abbildung in dieser Leseprobe nicht enthalten
EPA HAZARDOUS WASTE CODES (Continued)
Abbildung in dieser Leseprobe nicht enthalten
Annex 2
Information necessary for the Registration and Labeling of Waste Generation
Generation date:
Generator Name:
Department:
Waste Location:
Name of the substance:
Amount of the Substance:
Physical State: (solid, liquid, solid-liquid, gas)
Primary Hazard Category (corrosive, flammable, toxic, explosive, etc.) Accumulation Date
Annex 3
Hazardous Waste Storage Area Inspection Record
Abbildung in dieser Leseprobe nicht enthalten
Annex 4
Hazardous waste storage area Security Inspection Record
Abbildung in dieser Leseprobe nicht enthalten
Annex 5
Inspection Record of Labeling on Hazardous Waste Containers
Abbildung in dieser Leseprobe nicht enthalten
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