 We're here in our larger conference space that will look a lot different once we get permanent furniture for the space, but our conference room was a little tight with folks showing up to observe and put a comment, so I thought this might be a little bit easier for people to breathe. Show them a couple of desks together. So we're ready to rock Jacob whenever you are. All right, sounds good. Yeah, so we'll call the meeting. We're meeting to order at 12.04 p.m. Eastern. With us today, we have Natalie Marvel and Kyle Harris from the Cannabis Control Board. Who else do we have in the room there? We've got five members of the public. Five members of the public. From NACB, we have myself, Jacob Pollitzer, Megan, how is it going to be taking the meeting minutes, as well as Gina and then for the subcommittee, we have Stephanie Smith and Billy Koster joined by Anna Furukowski. It's actually Anna. Anna, sorry about that. Anna, thank you. And Josh Kelly. So with that, first order of business will be to review and approve last week's meeting minutes. Sorry it took a while to get that out to everyone. I was quite a lot to go through. Make sure kind of everything was concise and made sense. So Stephanie and Billy, have you had a chance to review it prior to the meeting? Yeah. I'll answer it quickly. Yeah. I have one clarification on page two on something that I said that from a farming perspective, excess life that is emitted from a greenhouse, not necessarily related to cannabis because we currently don't have cannabis growing. So it's just any like any greenhouse, not, you know, currently towns don't have regulations addressing that. So I just wanted to kind of clarify that towns would have to actively adopt regulations. Okay. Perfect. So I'll change the language to from cannabis that perspective, excess life that is emitted from a greenhouse is not regulated by the town. Yeah. Okay. It's just a slight clarification. I think the men say that light rarely affects wildlife habitat. And I think what I meant, I did say what I meant to say was that rarely has light come up as an impact on wildlife habitat in the regulatory context. It's not to say that it doesn't, it may not, it doesn't say that that really has an effect. It just rarely has come up in the regulatory context. Okay. Good clarification. Yeah. Perfect. Megan, you have that down in the meeting minutes. Yes. Awesome. Thank you. Okay. So then with those two amendments or a week or two, someone wants to bring to the floor to approve these meeting minutes. So moved. I'll second. Okay. All in favor of approving of February, I'll say 22nd. Yep. February 22nd meeting minutes. Hi, September. Hi. Hi. Hi. Minute meetings are approved unanimously. Okay. So with that housekeeping out of the way today, we'll be talking about waste, waste standards and waste regulations. I'm really happy that Billy brought some colleagues in because I'm, you know, in the kind of notes I put together of an overview of kind of like what we're seeing in the industry, you know, in every state, as far as it comes to like waste, waste management for most I think today we're going to be talking more about solid waste, you know, defaults to what's already in place on the state level to local state and federal. And so I think it'd be great to, you know, start to discussion on kind of what Vermont has in regards to regulations that canvas businesses would have to comply with. Would it be easier to kind of go through this on like a cultivation manufacturing retail distribution kind of breaking down that way or bring you down to like organic composting waste, hazardous waste, recyclable, single use kind of stuff that I kind of defer to you since you're the resident expert on these things. And I'm going to kind of pass a question along to Josh and Anna to see if they have a suggestion on how best to parse this out. And then I'm going to weigh it and say I like it broken up by the activity personally. Then I'll let others comment. Well, I can comment on hazardous waste regardless of whether it's a processing or sales because that's the part that I regulate. So I think if you want to hear from us by what the regulator would be better to break it into hazardous waste than solid waste and keep that because Josh and I will be speaking for to respect the program. And Josh is your expertise in, what is your expertise? Yeah, no thanks. I'm in the solid waste program. So I'll do my best to speak to solid waste today. Okay. So yeah, I think I'm actually looking at the notes up together have it broken down by I guess business type and then in that hazardous and not hazardous. I guess we kind of take it from the top and right kind of in your wheelhouse. Stephanie would be cultivation. So I guess to start off Stephanie, maybe you want to talk about how you're seeing non hazardous waste and hemp coming to play. Specifically, I guess with organic materials. Yeah, so currently, and actually, and Josh can weigh in on this as well, but hemp generally, you know, we would allow for composting of vegetative waste on the site where the cultivation occurred. And then we would also allow and that would be covered by the RAP as we have certain standards that the required agricultural practices, excuse me, that address composting of agricultural waste is just specifically defined in the RAPs. I don't have them in front of me right now, but that's treated that way relative to wastewater. My understanding over non expert is that outdoor irrigations along is not it's exempt from the Clean Water Act. I don't know. Maybe somebody correct me. But it so that's not happening. I guess there's no regulatory standard there. I suspect that if there's a, you know, a non point source pollution issue related to agricultural practices, it would be addressed by the RAPs and then point sources direct as addressed by DC and their programs relative to dealing with indoor cultivation and the idea of point source pollution either going to a municipal waste treatment facility or going in ground. My understanding, however, I don't believe that there's anything I can point to directly. We would prevent facilities from creating a point source contamination event or source point source pollution or discharge. I should say through a conversation between the agency of agriculture and DC, if it's not specifically outlined, if it is, you know, like to implement best practices to address those issues. But if it is a point source discharge, then are considered as such than that indoor operation would have to get a permit in compliance with rules in place. So that's my understanding and others can correct my understanding. Yeah, I guess to move the conversation a little bit more towards because we're going to be talking about discharging in water and all of that I think in next meeting. So as far as are there regulations as far as composting limits of on site composting or if you're generating X amount of, so like Massachusetts has a one ton weekly limit that you have to compost. Some other states have it. I think Colorado is less than that. I can't remember exactly. But are there regulations like that in Vermont that would require cannabis cultivators to have to compost their materials, either on site or if they're indoor work with a composter. And I guess the next question for you, Josh is, is there the capacity in Vermont to handle, you know, another three to 4,000 tons of organic waste? Yeah, great question. So I think Billy had translated my response on what's landfill banned before in a PowerPoint presentation. Billy, did you present that previously? I did, yeah. So essentially we do have a landfill ban on leaf and yard debris but that definition also includes compostable untreated plant and vegetable material. And so I can share my screen on this commentary where this little snippet of Billy can look it up and send it to you all again. But essentially we would consider these crop waste, just like any other crop waste and therefore landfill banned if they're compostable and untreated. And so those two terms are what we're using to interpret whether it is landfill banned and also whether it's compostable. So for example, if it's treated with some chemical that really falls under Anna's shop, then it's has waste, you know. Or maybe it's regulated by federal law such that the composters aren't permitted to take it. Or maybe they won't take it because it will really impact the composting process because of something I'm not aware of. Or it's been treated with herbicides and they don't want to accept it. So we sort of wrote it to be the definition is such that you can interpret it broadly and that's how we're interpreting it to consider that it is a banned normal plant material would be landfill banned except if it's treated or not compostable in some way shape or form. And then the question is, well, where is the capacity? And Stephanie can opine on this too because a lot of this stuff is, you know, farmers generally manage what they produce on their land and historically what corn residues and other things like that. However, this industry might be different for many reasons. So we do have an active composting network in the state and we do have some what we call stump dumps as well, which are sort of more inactive composting where they're just sort of piling leaf and yard debris and letting it static statically sit and remove things occasionally from it. But I think we have a pretty robust network, but I don't know if they're accepting this material now and I don't know if Stephanie knows more if she's having conversations with our composters. But I would expect it's going to likely be a mix of onsite management as well as shipping it off site for those that really don't want to deal with it to send to composting and then mostly composting will be economically beneficial over disposable. At least once you get it to the facility. The trucking is a whole other story. And then I can show my screen of Billy's things that's a good idea with our regulatory guidance on where a composter would trigger a permit from DEC. And I can do that whenever you're ready. Yeah, that would be great. I've looked at the presentation you have and I don't remember seeing that. So couple, I guess before we do that, I probably should have started with overall almost every state has required a 50-50 mix of THC containing materials. So flour and even the sounds of stocks, etc. Mix with 50%. So the language of the law is like unusable and unrecognizable. That really came from Colorado when we started in like 2012 and fearing like the legislator of like people were going to rummage through garbage or that it was a way of diverting into either the listed market or getting in the hands of, you know, people who shouldn't have it, not realizing, you know, nowadays, you know, it's just waste. Does everyone I guess on this call have strong feelings or no? Vermont is kind of leaning towards that. In regards to organic waste disposal, that also kind of is something that we should kind of decide or at least talk about now if that's going to be a requirement. So most states have it. California was the first to not have it required on cultivation sites. They require it for laboratory waste disposal. Retails like products that can't be sold or contaminated or something like that. But most other states have some kind of requirement reporting that, which is, you know, double the amount of waste essentially being produced because they'll have different guidelines by mixing it with, you know, at some level, we mix with anything. Now they're trying to do it more of a compostable or similar items or a minimum, you know, media, grow media or something like that, that, you know, will work. But has there been any discussion on your department on whether or not the state wants to include that kind of thing? I think that would really be more a question for Kyle around the kind of regulatory public safety piece. I don't think that's something that we discern in our salt waste rakes, as Josh would suggest otherwise. Stephanie, before I weigh in, which, all I would say is, you know, Jacob would present what other jurisdictions are doing. Doesn't make sense for Vermont. I'd love to get to take up the subcommittee on whether or not we should move in that direction, you know, from a consumer safety, public safety perspective, but also from a waste management perspective, where do we, where do we shake out recognizing that we've got a lot of experts in waste management on the call here? I was just going to say that USDA and the hemp program, as they've envisioned it, the rules, they allow for on-farm disposal of hemp that is non-compliant without a reverse distributor and they allow for, you know, composting, you know, disking into the field, deep burial, they allow for burning, but I know burning is probably not a good option at all. So we'll just leave that one out. So today actually offer probably at least four or five different methods that hemp growers can dispose of hot hemp. And we could potentially, as a group, apply those measures to this particular crop as well. So, but yes, unrecognizable, unretrievable, those are the terms that they use as well. Yeah, that sounds good. I'm in favor of having as little of that as possible, because I think especially for small farms or outdoor growers, you know, it's just a lot of compliance and regulation. You know, I've put down some of these, you know, like Massachusetts has this law that like repars two agents of the company have to witness and document the waste handling of it all. And so it's just like a big kind of, you know, burden on, you know, small cultivators have to do that. Whereas others, like in Oregon, they actually have to, might not be Oregon, it's actually called the State Police and Department of Ag telling that they're destroying these things. And so I think the less we go about those and potentially stick with like what you were saying, Stephanie, at the last meeting, like encouragement and, you know, not necessarily regulations, but this is how, you know, we want to see it. One question for you, Josh, and then I thought for you to share your screen was with the landfill, I guess like disbursement or, you know, taking organic material, is that at a certain level or just in general? So like all organic material is not essentially allowed to be in the landfill. It's in general. There's no, there's not a size cap. Like if you produce this amount, you have to, it's all, it's all encompassing. Let me, yeah, let me share my screen. We can talk about the regulatory side and we can talk about the landfill ban. Okay, and while we're doing policy, it's not something like tipping fees and you're saying that is it cheaper to compost than it is to bring to, kind of solid municipal waste? No, we don't regulate tipping fees so I don't have like at my disposal the accurate tipping fees for every facility in the state. So all I can tell you to be completely transparent with this group is that my information is anecdotal but from the people I have spoken with and from my years talking with composters their tipping fees range from nothing for some farmer composters to as much as $60 a ton or more in a few cases. $60 a ton tends to be the high end. Now landfill tip fees vary quite a bit and it really depends on whether you drive it directly to the landfill and how much material you bring or if you're driving it to an incinerator out of state, we don't have them in state but they are out of state but you know typical landfill fees that I've seen anecdotally you know range from the 70s to the hundreds and above and then if you're using an intermediary transfer facility there's a lot more cost. That's typically most of our waste goes before you the resident your trash gets to the landfill goes through a transfer facility so that tipping fee is usually much greater. So it kind of just depends and I generally find that composting could be cost effective but the piece that we're not talking about is just what the transportation costs are and those tend to be the highest amount of money you're spending is the money to aggregate the material or bring it to the ultimate facility and we can talk more but that's the anecdotal information I have. Okay, I was just wondering if some of the things in anecdotally as well was you have the law or regulation of places you have to do this but it seems like it's an encouraging composting it's a financial decision so if it's a lot more expensive to compost they're just going to defer to landfill and so I was wondering if we needed to expressly restate the mandatory organic waste diversion. Yeah, in terms of food waste ban laws there is triggers in some other states for like if it costs X percent over disposal then you don't have to do it we don't have any of that type of legislation in our law regarding the leaf and yard or the food waste ban so cost doesn't really factor into it but in general anecdotally the cost is at least in the case of leaf and yard debris is often and vegetative waste in the favor of composting it versus disposing I'm sure there's exceptions to that and again my knowledge is only anecdotally and we can spend the worst study on that but what you're looking at, sorry I was using it real quick before I forget do you have recycling facilities in Vermont? Yes, we have sorting facilities in Vermont we have two recycling I call them factories really because they're conveyor belts where our recyclables get sorted the two largest are in Rutland and Williston called material recovery facilities or MRFs and then most of that material is sent to other parts of the U.S. not all of it's used in the state but it is mostly used domestically. There is a sorting facility anecdotally I know of issues with overflow I guess for recycling and being if it's a cannabis consumer packaged good that technically could have residue in it there has been issues with the crossing state lines to go to a different facility but if it is not then that should be an issue. Okay, yeah as far as I know there is ample capacity for Vermont's recyclables at this time. Just this is a cheat sheet that DEC put together it actually does need to get updated Stephanie might know that there was a law changed to the way food waste is managed between on-farm composting it and off-farm composting of it so it does need to get updated but I'm trying to bring your attention to farm waste let me just see one, two, three, four rows down on the exempt side composting vegetative farm waste on a farm from any farm is exempt from our permits I'm not you know Jacob I'm not very aware yet of the 50-50 rules and if and I just know that from the DEC solid waste perspective I don't know that there's been discussions of that mainly what you were talking about in other states sounds like other kinds of government want requirements that then force a different agency to do something as far as I know from DEC I don't know of any 50-50 requirement or special management this is how we treat farm waste and vegetative waste for composting you can see that there's quite a large amount that a small a small leaf and yard composter can take you compost less than 10,000 cubic yards waste of untreated wood residuals you can get what's called a small registration where you just register once so I don't really know what types of material we're talking about in terms of tonnage or cubic yards per year but this is the regulatory framework we have I've got some numbers for that it's like estimates are like an acre of ham so like an acre of cannabis would be about 10 tons of plant material that would need to be composted and then the other figures I got was like for every pound of flour you're looking at one and a half sorry for an acre of ham you'll get two to five tons of stock waste or material waste and then for a pound of cannabis you'll get 10 pounds of stock or other non-usable biomass good and then Denver in 2019 which was about the size of the state of Vermont 650,000 people had 3,650 tons of plant waste yeah I mean we have we don't do assessments of our capacity but we do have information that's permanent with us and there's some as you can see in the exam category that we wouldn't have any information on so it's a little hard to determine like your other question is there a place you could bring it that could handle it I talked to a bunch of hemp growers and kind of northern Vermont and they take it to a composter and they say they're beloved by them because it's good nitrogen rich material that they can use to really ensure that their compost piles are composting so this is the regulatory chichi I guess for right now it does need to get updated with some info about the food waste change Stephanie anything you want to say here or Billy just want to make sure I'm not talking over you Josh I have a question this is Kyle so composting vegetative farm waste on a farm from any farm is that is that tied to the definition of a farm or is that just thinking through vegetative waste on a broader level I just want to be cognizant that technically this is not an agricultural product so it's a commercial product so what might that mean could we still expect to cover that and you might not have the answer right now from a broader perspective of vegetative waste or does it have to be tied strictly to the work farm Kyle I'd have to talk with Billy on that that's a good question that I can't quite get my head wrapped around this moment I think a lot of us are still trying to do that Kyle is there anything that the CCB can recommend that would allow for someone who's cultivating cannabis to compost the waste on the side of cultivation you noticed I didn't use the word farm so I would go ahead I was going to say when I was going through the regulations California has classified specifically in their waste as cannabis waste is organic waste and I don't know if they use the word iron culture in there but a few other states have like cannabis waste is commercial organic waste and so because they have the organic waste I think goes into that system so I think a lot of states have been bridging the gap for their organic waste to their hazardous waste etc. so I think it's just in the way you define it in the regulations there's potentially I mean using the term that Josh was using earlier that the cannabis waste is considered vegetative waste you know not to use the word farming and then I don't know I hear what you're saying Stephanie and I just two things to know I mean one we don't DC doesn't have oversight of the word farm that's really in Stephanie's camp and two we do have that definition of leaf and yardery which includes actually leaf and yard residuals and includes untreated vegetative waste so one could take an opinion that this exemption could apply to vegetative waste whether from farm or off farm because we would also consider a home where it was composting vegetative waste to be included in this I will also note that this is actually updated I didn't note my colleague Ben Gother did update the bottom that notes the food residual changes in the law that happened in the last session so this is accurate this seems like we're in the right one way to think about it is that scapers run commercial businesses they may have vegetative materials that they then have to compost they're not farms those are agricultural products but they're still using this schema to dispose of those materials I think the last kind of thing on this we're just kind of going to Kyle would just be how is the state considering classifying THC containing material and can that be composted without being treated in some way or what not I think that's kind of the main thing that regulation that needs to oversee it but realizing that halfway through this meeting I do want to get Anna's take so if we are anything else I want to say on the organic side of things well I was just going to I totally recognize that Jacob and I want to move to Anna your take here because the program here existed before USDA legalization of the hemp crop if I'm not mistaken and so I'm wondering you know from your perspective and the legislature's perspective in the context of hemp if tailing under onsite hot hemp has given consternation to the legislature you know so on and so forth or not yes we've had a hemp program for many years before at least since 2013 for the 2014 Farmville past and I think we considered it I remember when the change was but I think it was considered farming so the onsite composting piece was always in play from USDA's perspective it does allow for the let's see here plowing under mulching, disking rush mower, deep burial of hemp and I think it could just be based on you know that individual grower's activities I don't know that it would have to be observed by anybody maybe it's documented that it occurred just Jacob you just brought up like having to call some from the state from a visit of law maybe just documentation of that activity is sufficient to satisfy the CCD with respect to composting stock you know because we're just talking about the waste material well maybe we're talking about more but right now we're just talking about the waste material associated with cultivation so anyway there will be and it's probably something to talk about later or we might not need to necessarily get into it but yeah there is I'm trying to think of like the terminology but the like documentation record keeping kind of management like the overseeing of all of it you know there definitely need to be regulations on that and I think the more stringent those are then we don't necessarily need to go the route of the 50-50 or unrecognizable as long as there's you know regulations around that also like how they're stored does that need to be a lock container or can it be behind a locked fence that kind of stuff starts to come into play and and a lot of things but yeah moving to Anna as far as so it's trying to do some research with like Vermont's current regulation so with like I guess in general with cannabis you're going to see like the e-waste so for the lightings and the ballast and all that containing kind of mercury and all of that and then like the lithium ion batteries does Vermont currently have or in the regulations definitely has but these fall under that and need to abide by hazardous waste so those fall under the universal waste rules so they're managed under an alternative standard so they're not they're part of the hazardous waste rules but there's a separate management standard for them under the universal waste rules so the way it works for us for handlers that only have universal waste on site we only require large quantity handlers which are mostly like recycling facilities to notify with us so if you're a business and generate some small quantity of batteries or like fluorescent bulbs for instance fall mercury containing devices you would not be required to notify with us and be a registered generator which you would still be subject to the proper management standards that are set in the rules okay and is that covered for I saw that there's like the 2014 primary battery regulations is that covered lithium ion believe it covers our battery rules cover all batteries we have a separate recycling assumption for lead acid those are covered under recycling assumption rather than under the universal waste standards okay and for lithium ion batteries we are trying to come up with new guidance for those just because it's a relatively new waste stream and it has to be managed slightly differently than other batteries just because of the fire danger so we will have gotten more guidance coming out in the next year that we'll be sharing with that business community okay and then I had questions on the manufacturing perspective and from the concentrate side of things so that ILMAS that has higher levels of solvents that would classify it as hazardous waste are there other rules to that that will be on the federal what was the department of waste disposal I guess so yeah so we do have under the resource conservation and reactor requests those are the federal rules that we implement at a state level the hazardous waste rules flammable or ignitable solids if they fail the ignitability test they would be regulated as a hazardous waste it really depends for like plant matter with residual solvent concentration in them it really depends how much the residual is and as of right now we don't have things that sounds like if it's 5% or less it's not regulated but if it's this percent or more it is because we haven't established that it would be really useful to have that but that would require some testing we're hoping to work with actually a CBD processor and Broward Road to get some preliminary numbers and that didn't really work out so right now it's on the generator of the material to make waste determination to determine whether plant material needs to be regulated as a hazardous waste or not and that depends on the amount of the residual solvent obviously any waste solvent from the process that's generated is regulated as a federal realistic hazardous waste okay that's good to know so I'm on that form that I created for the regulatory issues to consider so these are kind of things that states are all over the place so I wanted to kind of see what everyone's opinions were with I guess going along the lines of classifying cannabis waste that has either like THC A so that would be in its natural form so it's technically what we consider like not psychoactive, so safer kids, etc this is more conversation and on some level for needing of child resistant packaging but I think that specifically contributes to the amount of waste we're generating what are I guess the state's thoughts or anyone else's thoughts on making differentiation between the requirement of child resistant packaging for THC A versus activated products which would be edibles, concentrates, etc I think from our perspective we would want to take the path that generates the least waste possible I understand that there may be other public safety issues that override that concern yeah I'm thinking that the health department may have an opinion about that specifically so I don't want to way, I mean I would agree like least amount of waste makes sense but then I feel like the health department needs to also weigh in regarding public health let me run that through the public health committee and we can let them kind of help us decide at the fork and all up in the road which path we need to go down one of least waste or one of the most consumer protection that sounds good because like right now how most states are doing it with that is enforcing manufacturers or packages processors to use kind of single used plastic because like the way they snap clothes and so like I always use the example like mason jars are not legal to use but that's one of the most reusable materials in there and potentially having them clean in depending on how you end up doing your point of sale retail systems being able to bring a jar in and not even starting that waste but right now that's not necessarily realistic unless you do exit packaging which a lot of states have started to do and have moved away from which is just requiring another opaque child resistant package when you leave the dispensary which is really just generating a whole another stream of waste and kind of along the lines of like the pharmaceutical you know if you go to the pharmacy they always put it in that bag it can be as simple as like stabling it or some have to actually have like a child resistant cinch to it but yes those are the things to consider I guess Josh I had a question on recycling and recyclability are there minimum sizes for products that the actual recycler can like the grates that they use to sort it will stay in there and not just follow the bottom and automatically go to the landfill are there I guess yeah the answer is yes and it's the it's the rule of two the MRVS the material recovery facilities do not want any material under two inches in at least two directions so it can be a two-dimensional item think of your yogurt tub lid which is almost two-dimensional it's a little thicker than that it has a thickness of course but it has to be beyond two inches in any two directions for the for it to not fall through the screens as you're talking about would you be in favor of either guidance or regulations putting in a minimum requirement for that because that's something we've seen a lot of with pre-roll tubes or a gram of concentrates are smaller and they just can't be recycled and so trying to get as much recycling material from a product into that stream I mean it's rare that I'm asked about a very specific industry regulating it on requiring the recyclability of something in the very specific industry and so I would just say we generally look much higher at our level of regulations and also policies and promotion we're in favor of recycling for sure we have state requirements we have a ban on certain recyclables that require those to be recycled and our ban from the trash as part of our universe recycling rollout that is pretty much just included in 2020 of which the leaf and yard debris ban and the food waste ban was a part of but I don't think I can say today whether we would require a specific industry to meet a specific standard okay so I guess I may not require it but as an educational piece I think it would be helpful because we have to get this industry kind of everything especially with the compliance and labeling aspects of things and also thinking with what is able to be recycled like the numbers of plastic as well and trying to guide the industry to as much of a standardization as possible or at least what can actually be recycled I think and as you probably know just a little bit about the pharmaceutical industry with pill bottles they're generally small they're often not recyclable and that causes a lot of people who really residents and customers who want to do the right thing can because of some of the material that they're in and the reuse of those materials is highly prohibited because there's different medicines going into bottles and people's privacy so it kind of unravels the whole thing but I can certainly say we ban plastics one and two in this state from food and beverages and beyond that we don't ban any other plastics our local governments have the right to put in their place their own ordinances on landfill bans and some of them do I'm not aware of any of them that have banned other plastics but more on the voluntary side they accept usually at least one through five but I guess the short again anecdotal information is the valuable plastics remain numbers one number two and number five if you're going to use glass you can use glass those are recyclable the material is not always used to the highest and best use that people might hope the fact of it going back into bottles is rare these days so a lot of it is used for aggregate uses like sand you know as a grit material whether that's for sandpaper whether that's in paint fillers whether that's in road base concrete you name it a lot of the material goes for that so happy to help with that all said if there are options for packaging materials we can provide some guidance on which types of plastic and sizes amongst those options are most preferable and then a couple more questions I think I have to open up all the commenting would be are there incentives right now so like I guess on some of this Salvermont has extended producer responsibility I guess for paint and maybe like one other thing is that something that's in the future kind of coming down the pipe I'm thinking I would just like take back schemes for these you know materials to be able to try to either reuse them if possible at one collection point to then bring it I was wondering if there's things in place already in Vermont and then also like is there guidelines on requiring or encouraging a certain amount of recyclable fiber material in the packaging so 30% like post-consumer paper or something like that yeah that's a great question Jacob we have five EPR extended producer responsibility programs currently in the state paint as you said batteries which is primary batteries meaning your non-rechargeable batteries electronics really your televisions computers and printers mercury bulbs the ones that you and Stephanie were talking about and mercury thermostats those are our five we call them special recycling because they shouldn't go in your blue bin that are drop-off locations specific to that so we're trying to keep those separate for the public and there is a bill proposed on extended producer responsibility for paper and printed packaging at the legislature I don't know if that will I cannot predict what will happen with that it has been discussed I don't know if there's been an introduction of a minimum post-consumer recycled content bill that could be in the but we have none of those laws currently so there's not a requirement we encourage post-consumer recycling content and we encourage sort of the the reuse opportunities to take back that you're talking about that can be done voluntarily and we have many examples of that we have milk that comes in as Stephanie knows and reusable glass jars I have one downstairs and then it's the last thing and then I'd love on it to kind of just talk to if I forgot anything or if you have anything to kind of say on the hazardous waste issue but with trying to like incentivize purchasers I guess manufacturers or processors to have to buy the more recycling option I guess because it's really hard in the cannabis industry with like 280E and not being able to take kind of regular deductions and so one of the things like I'll talk to some industry folks would be if the state could incentivize them paying the extra costs to get a more environmentally friendly product you know like a reusable glass that's legal because you're like we're going to accrue higher costs and it's really happening in the packaging area so trying to encourage more bros to kind of choose the more responsible most likely the more expensive packaging does Vermont have anything like that already in place or what do you think is that this was a question for me oh I was going to say I wanted to pose this question I wanted to get your opinion just on the hazardous waste in the cannabis industry and just like yeah I think in terms of packaging we really don't have anything like that in place we certainly work with our generators to encourage them to if there is a you know of their like a more environmentally friendly salt land for instance or you know we would encourage them to do that I think with salt with extractions this really seems like it's either CO2, oil or salt land so two of that those materials are not regulated as hazardous and do not generate hazardous waste but only one of them does but in terms of a more environmentally friendly ignitable solvent like we don't really necessarily have a suggestion for that because it all would be regulated this is an ignitable solvent but all need to go for incineration I would say the insolvent runs the gamut of yeah like just water to CO2 to ethanol to propane butane even naphtha and things like that so I think for us we always encourage facilities for ways for recycling the solvents that they're using so there's a way to get a recycling system so they can reuse the solvent and have just minimal waste amounts we would certainly encourage that we don't have a program that specifically you know provides them like grant money to purchase the equipment but please not not in my shop I'm not sure if there are other agencies that have programs like that yeah I just wanted to say that I was thinking about that earlier when we were talking about solvent does CCB an option could require the systems to centrifuge out the solvents to the extent possible so that they could reuse it I know at some point it's no longer usable but that would have twofold it would potentially however we haven't established it an ignitable standard it would help in producing ignitability and maybe if you have that piece of equipment you would meet the ignitable standard so it's not considered hazardous waste so there's that possibility of making those links that serves multiple purposes alright I guess we'll open it up to public commenting I don't think we have any eyes around anybody who's changed their mind I did have a couple a couple thoughts so the issue of child resistant packaging so we use packaging pop tops and environmental conservation it's my perspective the 164 was passed from a youth prevention consumer protection perspective I think obviously a lot of what might make sense from an environmental perspective might come into conflict with that but I would imagine that the board is likely going to defer the side of youth prevention and consumer protection because that's one of the charges that we have written in law so to the extent that we're able to thread that you know I think that is something that we should do but I think we need to err on the side of that perspective and because we have a question because my understanding is like child resistant packaging is for like toddlers like kids who if they got into it could be harmed you know by getting taking 100 milligrams of THC and so I feel like when you're talking about youth prevention the child resistant packaging doesn't necessarily come into play I'm thinking like a 10 year old onward I was going to be able to open almost not all of them because they're still ones that I can't open but you know along those veins absolutely and I totally understand that that's where I'm saying I just want to remind the subcommittee of that and I'll run this through public health to kind of gauge their perspective I don't want to make this impossible to open and create more ways to the extent that we're able to but I know that that was a huge focus of getting this across the finish line did we talk about the ability to refill containers did you guys mention that like it was a glass container and I don't know the sanitariness I know that in the state of Vermont we do have you know producers of beer that have refillable containers I don't know if they're refilling them like today right now due to the situation due to the pandemic but I know in the past they would you could bring them in and get them to be filled so I don't and I don't know if that's a possibility now Jacob was suggesting that and I think the challenge is whether they need to be child proof or not whether one has easy access to refillable containers of their child proof yeah yeah I was thinking from the waste perspective from the top thing the containers the opaque containers that have the pop top that you squeeze the sides on still contains a glass container yeah exactly and so that's what I was thinking is you have like the exit packaging aspect where you can you know acquire them to when you leave this so they have to be in the bag so they're kind of reusable but I think there's just like an opportunity for the industry to standardize some things and get some you know values aligned companies to all you know kind of agree to a certain container for 8 quarters ounces whatever and then you would bring in the old one because like there's definitely like any issues like if there was mold in there and then it got on to you know you're storing a dried herb but you would be able to exchange that so you buy it maybe for ten dollars you know the first time and then you just bring in your you know used one and you get a new one and then you're just kind of closed loop like kind of you know beer bottles in Europe kind of system and just we also have a ban on single use plastic bags in Vermont so there's now a kind of people there's a practice of people bringing their own bags into stores so that could help with large numbers of containers people could get in the habit bringing those into dispensaries with them are there jurisdictions doing that Jacob? I mean I like the idea I didn't hear you go are any other jurisdictions doing that with packaging? Not necessarily I have a bunch of growers I work with that do like recyclable totes for distribution of like wholesale material to the processor and so they're like closing that loop there and so like you know they're big kind of community processors so like you know the 20 farms that are bringing in their product to get trimmed or whatnot or packaged you know it's all bringing that in and then you get it back and get your product and so trying to not have to keep using like cardboard boxes and turkey bags and stuff like that and then yeah that's pretty much like most of what I have in the other one is just having the ability to sell and transfer fibrous materials because usually fibrous materials pretty much any cannabis plant material that could potentially contain THC is kind of classified as hazardous by a lot of state regulations and so the new frontier like Colorado starting January 1st 2021 now allows for an exemption of the waste management stream if you can now divert fibrous stocks to the industrial fiber industry now which was never allowed before so try to remove that from the waste stream and then I know I think Oregon allows you to sell waste material for research and development so I can get it processed or you know to like compress to extract a little bit of oil but not to be like consumed from my understanding on that and so there's just like those little things that I think just kind of depends on how your department classifies cannabis isn't cannabis waste I don't know there's really a hemp fiber market in Vermont to take advantage of that type of exemption Stephanie what are your thoughts there I mean we're tronin we're working on it at this point in time the only thing relative to fiber is sometimes when you're depends on what the end use is and whether or not there's a market for a specific like I mean stock from cannabis looks very different than hemp fiber grown for fiber specifically so there's that to juggle with but that doesn't mean that you know it doesn't have a use possibly does so long as the equipment's in place there's market available so again we continue to work on that we work with a lot of like paper makers small paper makers so it makes like a really great it's actually what our business cards are made out of that implanted with like wild pollinators but I know there's a lot of you know paper makers who want access to the stocks and they would need like a cannabis license or something so I think just facilitating as many ways to close these loops in the waste stream I think is you know the best way to think about it so most of everything I have so yeah I'm going to try to take the next couple days and do kind of the regulations we had talked about in the energy and kind of where we're at with this and try to start getting Kyle some language so it seems like we're all in agreement on the organic waste needs to get organic as little regulation as possible and then it seems like Vermont has all the laws in place for hazardous waste and e-waste and all of that and then potentially I think drafting some regulatory ideas on take back schemes or guidance options that I guess Billy and Josh's department could potentially have for the industry yeah and I just very quickly I'd like the direction of the conversation from the disposal of waste of 50-50 rule and kind of seeing if we can make do without it and California they exempt cultivators, processors, and nurseries from that render unusable or unrecognizable perspective and I just you know within 164 the only accommodation we cannot make for small cultivators is in the environmental context so the word exempt there or anything like that might cause some consternation at the board level so if we can draft things and you and I can have a conversation on applying Jacob about how we can draft things with small cultivators in mind without any exemptions from that unusable unrecognizable language if that's that USDA type of language if we're gonna do that or go in that direction instead of the 50-50 rule just so things don't hit a roadblock at some point well I don't think the 50-50 is mandated my understanding was Colorado put it in there because everyone's just really concerned I'm thinking that like wanting to be a hub for crime people will be breaking into you know dumpsters around you know cultivation sites and that like people are gonna be able to like get in and like get pounds of weed and you know get into the black market and that's just not the case and then just every state since has just copied it. Yeah no I'm not trying to confuse anybody I don't think it's mandated by any stretch but whatever direction we choose to go and we can't make special exemptions from an environmental perspective for small cultivators so I just want us to think about the industry broadly and how we might be able to work around to the extent that we're able that language with making sure that it's not overly burdened so I'm requiring two agents to witness the disposal and memorize and all this other stuff that other jurisdictions are dealing with waste disposal. I wanted to you you had mentioned making sure that stock is a category of waste that can be introduced into other industries without being classified as cannabis and if that clarity is needed I personally would support that as a or not personally but as a member of the subcommittee I don't know if the other billion of you would as well just that clarification that stock can enter into commerce. Yeah Deeds? I would say I support that and that I think just to the previous issue Josh should share with me that many of our compost facilities have the ability to kind of certify the destruction of material that might provide the kind of oversight security needed without lots of attestations that it's been handled properly and then we can certainly look at the composting laws to make sure that regardless of whether these materials are considered an agricultural or commercial product that they kind of qualify for the least athletic resistance. Awesome assistant. Thank you Billy. Yeah Billy I take it that your expertise is in policy and the language and all of that would it be helpful if I put together some stuff because there's a lot of that stuff in not my area of expertise as it comes to the requirements on the oversight and the containers and all of that so I've got you know for the main states kind of how they've rate in it in regards to requirements for permits and sustainability to render you know all of that to put that together and see if it's something. Yeah I'm happy to look at that. Did you have it included at the end of your notes that you sent out in the advances meeting? Yeah so the end of the notes was really just the regulations of main which were kind of more simple and I figured the ones I could find in Massachusetts is pretty intense and then Colorado and the reason I chose Colorado is because we were the first one and then also had a big change in 2021 to the regulations and how they were interpreted specifically because of the unintended consequences of the way waste was done so there it's like the overarching waste stuff is kind of the first section and then it goes into the new lawsuits of the collection of marijuana consumer waste and then towards the end is like the new ish law and like the fibrous industry stuff. Yeah so I'm happy to look at that and if you want to just point my attention to anything in particular please feel free to and I'm happy to help there and I want to make sure Josh and Anakin fell if they want to because we are after one now so they may have other commitments so thank you both very much. Yeah thank you guys. Yeah thank you everybody and Jacob and I will work together in language before the this up committee soon. Yeah Jacob feel free to reach out to me directly yeah. Yeah we'll do it and if anything comes to mind and I didn't think about please feel free to email me or your mobility to pass along to me things that we should be considering. Yeah thank you. Thank you all. Nice to meet you. Thank you. At least with that we can call the meeting to order at 11.04. 11.04? Yeah but yeah I'm free for the next few minutes if anyone wants to keep talking about this but officially we can end the meeting. Sounds good. Thank you all. Thank you. Jacob do you need anything? Not right now. Pretty good.