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B-46 2020-Current: Cannabis Cultivation and Restrooms

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The purpose of this technical bulletin is to clarify the permitting requirements for proper handling of domestic waste related to various types of cannabis operations. For all cannabis cultivation, some form of waste storage and/or treatment is required. This policy distinguishes between standalone, portable toilets and fixed restrooms, the latter being connected to either an existing on-site septic system or to a sanitary sewer.

Version: 04/01/2020
Effective Date: 09/11/2018

Technical Details

  1. The California Building Code Volume I, Chapter 3 (Building Occupancy) defines a structure’s occupancy and delineates thirteen categories of occupancies.
  2. The California Plumbing Code Chapter 4 (Plumbing Fixtures) requires a specific number of water closets, toilets, urinals and other fixtures through a matrix of occupancy and occupant load. However, the fixture count for Utility and Miscellaneous Group U occupancies is not codified and is left to the discretion of the jurisdiction having authority.
  3. The Sonoma County Code Section 26-02-140 (Cannabis Zoning Code definitions) provides the definitions of terms and structures related to cannabis cultivation.
  4. The California Building Code Volume I, Chapter 3 (Building Occupancy) does not include cannabis operations or processing within any of the thirteen categories of occupancy. When occupancies or uses are not listed in the building code, Building Officials are directed to find and use the most comparable occupancy group listed in the building code.
  5. The two pertinent occupancy groups are Utility and Miscellaneous Group U, and Factory Group F-1. Utility and Miscellaneous Group U includes structures such as agricultural buildings, barns, greenhouses and sheds. Factory Group F-1 includes the use of a building or structure for assembling, disassembling, fabricating, finishing, manufacturing, packaging, repair or processing operations for tobacco and hemp products, as well as other unrelated products.


Utilizing all sources of available information including verbal disclosures, aerial photography, permit history, apparent age of construction, etc., Permit Sonoma staff shall make a determination as to the type of cannabis cultivation and the type of group occupancy and structure being utilized. Based on these two factors, the type of restroom is outlined below.

  1. Outdoor cannabis cultivation shall use portable toilets as the minimum.
  2. When cannabis cultivation is conducted outdoors in conjunction with a greenhouse or hoop house, the structure will be considered a Group U occupancy and structure provided the greenhouse or hoop house does not contain artificial grow lights, light deprivation and/or a combination of natural and supplemental artificial light.  Portable toilets shall be used at minimum to serve that structure.
  3. When cannabis cultivation is conducted within any structure not detailed in item B above, that structure(s) will be considered a Factory Group F-1 occupancy and structure. Fixed restrooms shall be used to serve that structure.
  4. Structures used as cannabis processing facilities shall be served by fixed restrooms.
  5. The following are general provisions that apply to all cannabis operations:
    1. Where a portable toilet is allowed, fixed restrooms are generally acceptable.
    2. Existing permitted septic systems may be utilized provided the septic system has the capacity to properly treat and dispose of the proposed domestic waste flow.
    3. Existing permitted restrooms are acceptable provided they are sized for the occupant load of the structure and are connected to an on-site septic system or to a sanitary sewer. Existing private restrooms may not be utilized to serve commercial restroom requirements without an approved change of use (from private to commercial) of the structure within which they are contained.
    4. Either type of restroom shall be located within the 500 feet of the entrance of the structure.
    5. All commercial restrooms, portable or fixed, shall meet the disabled access requirements of the California Building Code and shall be served by an accessible route.
    6. The limited allowance to utilizing portable restrooms as defined above applies to the California Building Code occupancy classifications of Utility and Miscellaneous Group U structures only. All other occupancy classifications are required to have fixed restrooms connected to an on-site septic system or connected to a sanitary sewer in accordance with the California Building and Plumbing Codes.


  • 2019 California Building Code Volume I, Chapter 3, Use and Occupancy Classification
  • 2019 California Plumbing Code Chapter 4, Plumbing Fixtures and Fixture Fittings