California’s Emerging Path for Mobile Drug Incinerators

California has always been at the forefront of air quality regulation, but when it comes to mobile drug incinerators, the policy playbook is still being written. Today, law enforcement agencies rely heavily on open burn permits and exemptions to destroy contraband drugs. Yet the future may look very different. With thoughtful policy evolution, mobile incinerators could become a powerful, environmentally safer, and legally sound alternative.

Where We Stand Now

• Open burn rules currently fill the gap.
  Local air districts like South Coast AQMD (Rule 444) and Bay Area AQMD (Regulation 5) already allow contraband destruction through controlled open burning—but only if no safer, reasonably available method exists. This provides a pathway, but it is far from ideal: burning is subject to weather, smoke management, and public visibility.

• Mobile incinerators don’t fit existing permit frameworks.
  Air districts treat incinerators as stationary sources requiring a full Authority to Construct and Permit to Operate—an impractical process for law enforcement and incineration equipment rental companies that needs flexibility. Unlike low-impact equipment (covered under SCAQMD’s Rule 222 filing program), mobile incinerators aren’t listed for streamlined approval.

• Federal rules complicate things, but don’t close the door.
  EPA’s CISWI/OSWI rules often trigger Title V permits for incinerators. Yet, with technology advances—such as cleaner-burning mobile units and improved monitoring—there’s a clear opportunity to design compliant, mobile-ready incineration systems that meet federal standards while still serving law enforcement’s urgent needs.

Why Mobile Incinerators Are the Future

1. Cleaner than open burning.
   Purpose-built incinerators can incorporate emissions controls, making them significantly cleaner than open-pit or pile burns.

2. Faster, safer, more controlled.
   Law enforcement doesn’t always have time or flexibility to schedule burns around permissive burn days. Mobile incinerators allow on-demand destruction while reducing risks of diversion, theft, or mishandling.

3. Technology is catching up.
   Manufacturers are developing compact, energy-efficient mobile incinerators that are far easier to permit than the older, smoke-heavy designs.

The Road Ahead: From Open Burn to Mobile Policy

California’s drug stewardship laws already expect pharmaceuticals to be incinerated at permitted facilities. Extending that principle to contraband drugs with mobile units is a logical next step. Districts could create specialty permit-by-rule pathways or integrate certain mobile incinerators into CARB’s Portable Equipment Registration Program (PERP)—with the right emission safeguards.

Regulators have already proven willing to carve out narrow exemptions for contraband destruction under open burn rules. The same rationale—public safety and environmental protection—could justify a new, cleaner alternative: registered, mobile incinerators operated under strict protocols.

Bottom Line

Today, California law enforcement agencies are stuck with open-burn permits. But the future is bright for mobile incinerators: with better emissions control, alignment with federal standards, and cooperative policy-making, they can become a gold-standard method for contraband destruction.

This is not about replacing regulation but evolving it—to give police the tools they need while upholding California’s unmatched air quality standards. In other words, the matchstick is the past; the mobile incinerator could be the future.

Sources

• South Coast AQMD, Rule 444 (Open Burning).

• Bay Area AQMD, Regulation 5 (Open Burning).

• EPA & CARB guidance on incineration and portable equipment.