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Abstract
Every new industry has it’s false starts, failed business ventures, and competition from operators that
skirt the regulations. Growing marijuana requires the use of pesticides, plant nutrients and plant growth
modifiers/regulators. Cannabis Grow Facilities that go out of business, have catastrophic losses from
fires or business that are set up outside of the regulatory framework will oftentimes abandon what is
most likely hazardous waste when they vacate the premises. This has become a problem for health
departments who are oftentimes left “holding the bag” and who find the need to efficiently identify all
of the products/wastes that are abandoned in the wake of a business failure. The products/wastes left
behind must by law be considered as hazardous waste until otherwise identified. This presentation will
introduce a solution to the need for efficient identification of wastes found at a Cannabis Grow Facility.
The solution is a qualitative chemical analysis scheme that employs wet chemistry using the
commercially available HazCat Kit. This presentation will quickly demonstrate the use of the HazCat Kit
on various Cannabis Grow Facility pesticides/nutrient solutions and their identification/hazard
classification.
Background
For the past eighty years, a prohibition era type economy has molded how Marijuana is
grown and harvested in the United States [1]. Now that legalization is slowly becoming a
realization, many of the practices employed by marijuana growers are coming to light. The
environmental impact of marijuana cultivation has suddenly come to the forefront and it is not
a pretty picture [2]. Marijuana is a crop with high demand for water and nutrients that is also
attractive to a wide range of pests. In order to maintain a good yield and an attractive product,
marijuana growers employ a wide range of plant nutrients, plant growth modifiers and
regulators, as well as pesticides and herbicides. The semi-legal nature of the business makes
regulating the use of these substances almost impossible. As such, marijuana grows may be
using banned pesticides, heavy metal contaminated fertilizers, etc.. These products are
oftentimes abandoned at the site after the crop is harvested or after a business failure due to a
fire or an arrest. State Fish and Wildlife agencies, County Environmental Health Departments,
Local Fire Departments and Law Enforcement Agencies are left to clean up the mess and this
requires that they know the identity of these substances that are abandoned at the site. These
various products may be dissolved into makeshift mixing ponds, into unlabeled Hudson
sprayers, or found in any number of various size/shape containers left at the scene. Identifying
the waste is the first step in conducting an environmental clean-up of the site. There are only a
few tools available for field use that have some capability to identify these substances. This
paper introduces a tool well suited for this purpose. This tool, called the HazCat Kit, involves a
focused qualitative chemical analysis scheme that employs wet chemistry to arrive at the
identity of unknown “cannabis grow liquids.”
The approach taken by the wet chemistry qualitative analysis Hazcat Kit is successful
because it narrows the number of possible unknowns to a finite list of liquids that would have a
high probability of being found at a cannabis grow facility. Using this approach it is not
necessary to identify every component of a commercial formulation but only to characterize it’s
differences from all the other liquids on the finite list of possibilities. Here is one example:
Cutting Edge Solution Micro (6-0-0) is an aqueous solution of Cobalt Sulfate, Ammonium
Molybdate, Citric Acid, Manganese EDTA, Zinc EDTA, Copper EDTA, Iron DPTA, Iron EDDHA,
Calcium Nitrate, Potassium Carbonate, Sodium Borate. The appearance of this commercial
formulation is a blood red liquid.
Raman spectroscopy comes back with ten matches: manganese nitrate solution, gallium
nitrate, beryllium nitrate solution, nitric acid, manganese nitrate hydrate, ammonium nitrate
solution, calcium nitrate hydrate, cesium nitrate, lanthanum hydrate hexahydrate and cerium
nitrate hexahydrate. For the non-chemist operator of the Raman tool; this list does not make a
lot of sense – there is no gallium, beryllium, cesium, lanthanum or cerium in this mixture. It is
not acidic (not nitric acid). When the individual compounds are referenced they are found to
be white, water-soluble solids that; in solution, would not produce a blood red liquid. The end-
user of the Raman tool is unable to verify its findings based on comparisons of the physical
appearance of the compounds or their solutions.
The focused field identification approach using the Hazcat Kit keys out the commercial
formulation by trade name. Amongst the finite list of liquids used at a cannabis grow facility,
this solution is the only liquid that is blood red, whose color is pH sensitive and gives a positive
test for the nitrate anion. In just two tests the identity of the substance is found. The Hazcat
system allows the user to link to the SDS (Safety Data Sheets) where they can verify their
findings by comparison with the published physical appearance of the mixture. They also have
the option to perform several more verification tests for the presence of other components
listed in the SDS. If the hazmat technician performs a manganese test it gives a positive, the
test for the Ammonium Cation gives a positive, the Sulfate test gives a positive. In just two
tests the Hazcat Kit identifies the mixture and after a few more tests the identification can be
verified.
- Phosphate
Test - Acid changes
carbofuran, uFuran,
Furatox, Furadan,
Sulfur spray 1 + Test color Carbodon
fungicide/insecticide: Water Solubility any changes
Viscosity Hydrogen peroxide reacts
-
(may contain pyrethrin) Floats Test BioSafe Systems other color again
(see List B)
Test Oxiphos
fungicides: violently reaction
with addition +
2-5 Dissolves Sinks contains phosphate (see List J)
6 of RE2307
-
go to
- Sinks Water Solubility
foams, Main Liquids Test Nitric Acid
Oil
Magnesium
Test
suds form
+ 13 - 14
Chart
Citric Acid Spray & pH
Dissolves floats
or
- Test
+
(see List I) emulsifies
Test 0-3
+ + pH
Soil Conditioner pH Test 0-3 Micronutrient solution
solid stays liquid/emulsion
containing: Test 13 - 14
ammonium lauryl sulfate Carboxylate go to Cutting Edge Solutions
in tube 4 - 8 9 - 12
4 - 12 Main Liquids
-
or Test Micro 6-0-0 (blood red)
Plant Nutrients go to Chart
Fungicide
Botanicare CNS17 containing: Liquid Acids
myclobutanil Potassium silicate solution Chart
Mineral Oil Spray Magnesium
insecticides:
(see List E) (see List G)
Cilantro Oil Test +
(see List C)
Continue to pH Test
Nutrilife
SM 90 Ammonium Phosphate
-
Neem Oil spray
Magnesium + any
other fertilizer solution
contains azadirachtin: for Silicate
Test reaction Plant Nutrients
-
(see List D) Plant Nutrients
Neem Oil + Phosphate Ammonium Salts (see List M)
indicated mixed vegetable oil Test Test
- -
(seaweed odor)
Vegetable Oil organic +
Test
Canola Oil
any
other
fungicide/insecticide
(see list A)
Potassium silicate solution
Advanced Nutrients
+
- Ammonium Nitrate
fertilizer solution
Test Rhino Skin Phosphate
-
indicated result +
+ Test
Phosphate for Silicate Potassium phosphate Phosphate
Phosphate Test fungicides: Test
Canola Oil / Pyrethrin spray:
(see List F) Test
-
+ (see List H) + -
+
- Ammonium Sulfate
fertilizer solution
Potassium phosphate
fungicides: Nitric Acid
+
Ammonium Salts + (see List L)
-+ Test Test
Test
Polarity Combustibility -
- + Test
Ammonium Salts
Test
Test
yellow
dark purple,
brown
- Fruit & Flower Nutrient:
see Procedure N
mixed vegetable oil
fungicide/insecticide
combustible (see list A)
Plant Growth Regulator
Phosphate Plant Oil Booster in Alcohol Solvent Alcohol Mineral Oil based or Neem Oil concentrate
Test Fruit & Flower Nutrient containing: + Test spray insecticide
- +
Advanced Nutrients
Sensi Bloom Part B pH = 7
Terpinator pH = 6
potassium sulfate
solution
IBA Indole Butyric Acid
Dip-n-Grow - (see List C)
solid stays
liquid/emulsion in tube
Phosphate
Test
- Thermal Analysis
Oil
Test
perform all 5 Parts
Nitric Acid + unless directed to stop in Thermal Explosives
Test
- -
check all Thermal Analysis results
Test dissolves ? Water
+ +
- + Plant Growth Nutrient
Cutting Edge Solutions
+ Thermal
Ignition
residue ?
Thermal
pH Thermal
Oxidizer
Thermal
Ignition
Solubility
Test
Grow 2-1-6 pH = 5 9 -12
combustible
Ca-Mg Nutrient + color +
-
Botanicare or no residue of
Thermal ammonium nitrate,
Oxidizer potassium nitrate,
Cal Mag Plus Sulfate Sulfite residue Combustibility
Sugar
Test
- probably pure water -
white yellow
+ - or calcium nitrate
fertilizer solution
foams ? Test
Test
+ may contain very low black
ammonium phosphate
+ -
-
concentrations of: diluted mixed
+ Fruit & Flower Nutrient plant nutrients, or sulfur fungicide fertilizer solution vegetable oil, neem oil
fungicides/pesticides solution
Cutting Edge Solutions ammonium phosphate insect killing soap fungicide/pesticide
Bloom 0-6-5 pH = 4
(see Procedure N) contains ethanol & soap (see list A)
fertilizer solution
-
Fruit & Flower Organophosphate Do Alcohol Test
Fruit & Flower calcium, magnesium, zinc or
Nutrient Test color amber dilute solution of:
Nutrient silicate plant nutrient solution +
TechnaFlora of original black, plant food with sugars, or
Advanced Nutrients (do Magnesium, Calcium, Humic Acid Solution
SugarDaddy Organophosphate or unknown a vegetable oil pesticide,
Bud Candy pH = 7 Zinc and Phosphate Tests) dark General Hydroponics
Carbamate pesticide brown Diamond Black or lauryl sulfate fungicide
List C List G
Company Name Product Name Web Link Company Name Product Name Web Link to SDS List K
Ortho Volck Oil Spray SDS Cutting Edge Solutions Bulletproof Si SDS Company Name Product Name Web Link to SDS
Bonide Dormant Spray Oil SDS Greenstone Power Silicate SDS Nature's Care Garden Disease Control Website
Loveland Leaf Life Gavicide SDS Mad Farmer Silica Shield SDS Bonide Copper Fungicide Label
Helena Chemical Omni Oil SDS Southern Ag Liquid Copper SDS
Brandt Tritek Label Monterey Liqui-Cop Label
Certis Cueva Website
List H
Company Name Product Name Web Link to SDS
List D Loveland Rampart Fungicide SDS
Company Name Product Name Web Link Agro-K Sysstem-K 0-30-20 Label List L
General Hydroponics AzaMax SDS Nufam Phostrol Website Company Name Product Name Web Link to SDS
Sun Bionaturals Terra Neem Leaf Website Oganocide Plant Doctor Label Quest Reliant Systemic SDS
NimBioSys Neem Oil Website JH Biotech Fosphite SDS Actagro Resist 57 SDS
Plasma Neem Oil Website Drexel Phiticide Website Nufarm Allude Fungicide SDS
Ferti-Lome Triple Action SDS Monterey Agri-Fos Systemic SDS
Monterey Fruit Tree Spray + Label
Schultz Garden Safe Fungicide SDS & Label
Einstein Oil Leaf Shine SDS
List I
Company Name Product Name Web Link to SDS
Greenspire Procidic Website List M
List E Path-Away Plant Protectant SDS Company Name Product Name Web Link to SDS
Company Name Product Name Web Link Big Time Exterminator SDS Safer Gro Full Mag SDS
SaferGro Penex SDS SaferGro pH Down SDS Botanicare Sweet Berry SDS
Spectracide Immunox SDS & Label Rhizoflora Guard and Spray Website General Hydroponics Flora Bloom SDS
9/30/2016
Procedure N
check box example:
if positive contains Nitrogen
Ammonium ammonium nitrate
Plant Nutrients Testing + in the form of the
Salts Test ammonium phosphate
Ammonium cation ammonium molybdate
to fully characterize the
nutrient solution
example:
perform all tests
*Nitric Acid contains Nitrogen ammonium nitrate
Test + in the form of the copper nitrate
Nitrate anion zinc nitrate
potassium nitrate
contains Phosohorus
*Phosphate or Silicon example:
Test + in the form of the mono potassium phosphate
ammonium phosphate
Phosphate or Silicate anion
example:
Magnesium contains Magnesium
magnesium sulfate
Test + in the form of the magnesium carbonate
Magnesium cation magnesium phosphate
example:
contains Copper
Copper copper sulfate
+ in the form of the
Test copper nitrate
Copper cation copper octanoate
Cannabis Grow
Liquid Iron contains Iron example:
Iron DPTA
Test + in the form of the
FeEDDHA
Fe(II) or Fe(III) anion Ferric nitrate
contains Manganese
Manganese example:
+ in the form of the manganese sulfate
Test
Manganese cation manganese EDTA
Author’s Details:
Dan Keenan is a Hazardous Materials Specialist/ Firefighter with Oakland Fire, a chemist for
HazTech Systems, State Certified Hazardous Materials Instructor.
Maria Duazo is a Hazardous Materials Specialist with Contra Costa Health Services, Hazardous
Materials Programs and a State Certified Hazardous Materials Instructor.
References:
[1] Siff, Stephen. 2014. The Illegalization of Marijuana: A Brief History. Origins: Current Events in
Historical Perspective, Vol 7, Issue 8
[2] Jennifer K. Carah; Jeanette K. Howard; Sally E. Thompson; Anne G. Short Gianotti; Scott D.
Bauer; Stephanie M. Carlson; David N. Dralle; Mourad W. Gabriel; Lisa L. Hulette; Brian J.
Johnson; Curtis A. Knight; Sarah J. Kupferberg; Stefanie L. Martin; Rosamond L. Naylor; Mary E.
Power. High Time for Conservation: Adding the Environment to the Debate on Marijuana
Liberalization, BioScience (2015) 65 (8): 822-829
[3] Standards for Maximum Allowable Levels of Metals in Fertilizer
http://www.ecy.wa.gov/programs/hwtr/dangermat/fert_standards.html.
[4] California District Attorneys Association Environmental Circuit Prosecutor Project. 2016.
Environmental Crimes Associated with the Cultivation of Cannabis.