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How and where should you record your waste? It’s not always clear.
Health Canada can audit you without warning. They usually do give warning, but it’s in their right to show up at your door whenever they like. So it’s important to understand how to make sure your waste records are accurate and up to date.
For how important it is to record waste, you would think Health Canada and the CRA would make it easy to record in the monthly reports – but they don’t. There just isn’t a clear spot for it.
One Plant - No Problem
If you cut down one non-viable plant and destroy it right away – then it’s no problem… the Health Canada CTS report and the CRA’s B-300 report have categories for ‘Quantity destroyed’, and you just record in the appropriate box that one plant has been destroyed. Simple.
But most facilities don’t destroy waste immediately… they let it pile up, perhaps for an end of day destruction, perhaps until their container is full, perhaps every couple days when they have the time. Waste gets accumulated. Here’s where it gets a little tricky.
Record Your Accumulated Waste
You need a way to show in your inventory records that this accumulated waste is accounted for. Also, if your waste has been sitting around, that means it’s drying up and reducing in weight. 5kg worth of plants might, in a couple days, weigh in at 3kg. Health Canada wants to know what the weight is at the time of destruction (not the time of creation)… but they also want to know what the drying loss was.
That means you need two weights – the weight at the time of creating the waste, and the time of destruction. Ok, fair enough… but where do you record that since neither the CTS nor the B-300 have a ‘waste’ category? How do you account for drying loss?
The Secret ‘Other’ Category
For the CTS report, the key is in the generic ‘Other’ category. Instead of using the ‘Quantity destroyed’ like we did for our one plant above, have it as a reduction of ‘Other’ (meaning there is no specific reduction category that matches what we did). Then, in the ‘Other’ product category, log an addition of ‘Quantity Produced’. Basically, you’re ‘producing’ waste first. Later on, when you destroy your waste, it is then easy to track both the amount destroyed and the drying loss as two different reductions within the relevant ‘Reduction’ categories.
With the B-300, unfortunately, there is no straightforward way to track waste that has yet to be destroyed. There is no generic ‘Other’ category that can serve as an alias for ‘Waste’. However, since the CertiCraft system generates both CTS and B-300 reports for our customers, we had to find a solution for this. We received permission in writing from the CRA to treat the ‘Non-Flowering Cannabis Material’ as ‘Waste’ for the reports that we generate for all of our customers. If you would like to do this, make sure that you get permission to do so from the CRA in writing! Otherwise, you run the risk of getting in trouble during a CRA audit, as this is not part of the official documentation or policies for the B-300 report.
If you want to read the Cannabis Tracking and Licensing System 2019 report, you can find it here. Look for Section 9.5
This article was written in tandem with Mike F.