METRC Waste Management 5 — Questions and Answers
Question 1: Under METRC waste management rules, which of the following materials is typically approved as an adulterant for on-site cannabis waste destruction?
- Gasoline or petroleum-based solvents
- Cat litter, soil, or other compostable non-consumable material (Correct answer)
- Bleach or disinfectant alone without physical grinding
- Tap water added to the container
Correct answer: Cat litter, soil, or other compostable non-consumable material
States commonly require cannabis waste to be mixed with materials like cat litter or soil that make it unrecognizable and unusable without being hazardous.
Question 2: A METRC licensee realizes they failed to create a waste package before disposing of 2 lbs of cannabis trim. What is the most appropriate corrective action?
- No action needed since the waste is already gone
- Contact the state cannabis authority immediately to report the discrepancy and follow their guidance (Correct answer)
- Create a backdated waste entry in METRC to cover the disposal
- Offset the missing weight by underreporting the next harvest
Correct answer: Contact the state cannabis authority immediately to report the discrepancy and follow their guidance
Reporting discrepancies to the state authority promptly is the required response; backdating or offsetting records constitutes a compliance violation.
Question 3: Which employee role is typically authorized to approve and finalize waste destruction entries in METRC?
- Any employee with a METRC login at the facility
- Only the owner or a state-designated compliance officer with appropriate METRC permissions (Correct answer)
- The waste hauler's representative
- A third-party auditor
Correct answer: Only the owner or a state-designated compliance officer with appropriate METRC permissions
Waste destruction must be approved by personnel with the correct METRC permission level, typically a compliance officer or owner-level user.
Question 4: A retail dispensary has expired cannabis products that were never sold. How should this waste be handled in METRC?
- Return it to the cultivator who supplied it for re-labeling
- Create a waste entry for the expired inventory, render it unusable, and document the destruction (Correct answer)
- Sell it at a discount to avoid waste logging requirements
- Transfer it to a testing lab for destruction
Correct answer: Create a waste entry for the expired inventory, render it unusable, and document the destruction
Expired retail inventory must be logged as waste in METRC, rendered unusable on-site or via an approved waste service, and fully documented.
Question 5: What is the primary reason METRC requires waste to be weighed and recorded rather than estimated?
- To calculate tax liability on destroyed goods
- To ensure accurate inventory reconciliation and prevent diversion of cannabis from waste streams (Correct answer)
- To generate reports for federal DEA audits
- To determine insurance reimbursement for lost product
Correct answer: To ensure accurate inventory reconciliation and prevent diversion of cannabis from waste streams
Precise weight recording ensures that the quantity destroyed matches inventory records, closing any potential pathway for cannabis to be diverted under the guise of waste.
Question 6: A cannabis manufacturer produces extraction waste containing residual solvents. What additional compliance consideration applies compared to standard plant waste?
- Solvent-contaminated waste may require hazardous waste disposal compliance in addition to METRC logging (Correct answer)
- Solvent waste is exempt from METRC tracking requirements
- Solvent waste can be poured down a drain if diluted with water
- Only the cannabis portion needs METRC tracking; solvents are tracked separately by the EPA only
Correct answer: Solvent-contaminated waste may require hazardous waste disposal compliance in addition to METRC logging
Extraction waste with residual solvents may be classified as hazardous waste under EPA rules, requiring proper hazmat disposal alongside METRC documentation.
Question 7: How long are cannabis licensees generally required to retain waste destruction records to remain compliant with state regulations enforced alongside METRC?
- 30 days after disposal
- 6 months after disposal
- At least 3 to 7 years, depending on state-specific record retention rules (Correct answer)
- Until the next state inspection only
Correct answer: At least 3 to 7 years, depending on state-specific record retention rules
Most states require cannabis business records, including waste destruction documentation, to be retained for a minimum of 3 to 7 years for audit and enforcement purposes.
Under METRC waste management rules, which of the following materials is typically approved as an adulterant for on-site cannabis waste destruction?