The Three Paradigms of Household Hazardous

Waste Management

Jim QuinnNAHMMA NW Chapter Conference June 2015

The Three Paradigms

• Local government responsibility• State government responsibility• Producer responsibility

#4 Source reduction upstream

from:“Sustainable Materials Management: The Road Ahead”US EPA 2009

The Three Paradigms

• Local government responsibility• State government responsibility• Producer responsibility

#4 Source reduction upstream#5 Do nothing

Local govt. responsibility ADF EPR

Local govt. responsibility ADF EPR

Also known as: Advanced disposal fee, advanced recycling fee (ARF)

Extended producer responsibility, product stewardship

Local govt. responsibility ADF EPR

Who is responsible?

Local govt. agency, typically at the county level, e.g. solid waste or public works agencies

Government agency, typically at the state level

The industry that manufactures, distributes, and/or sells the product

Local govt. responsibility ADF EPR

Who pays? Usually local taxes or solid waste rates, spread across all taxpayers or ratepayers

Added to the product at point of sale

Industry, with costs passed on to the consumer. Either internalized or explicit “eco-fee”.

Local govt. responsibility ADF EPR

Legislated? Typically voluntary, but sometimes state requirements on local governments

Yes Yes, but voluntary stewardship can also take place

Local govt. responsibility ADF EPR

Pros Many fine examples out there

Appears to be a simple fundraising method

• Sustainable funding• In theory: induce

changes in toxicity and recyclability• Fairness• Can provide a truly

convenient collection system

Local govt. responsibility ADF EPR

Cons Sustainable funding is hard to come by

•Big new government program•Funds can be raided by legislature

• Heavy legislative lift• Potential for

conflict between industry stewards & govt. oversight agency

Local govt. responsibility ADF EPR

Examples Most HHW programs

California e-waste program

OR &WA e-waste, PaintCare,Call2Recycle

California’s AB45-Requires local government HHW programs to increase collection and diversion by 15% over baseline

-“intent of the legislature” to establish curbside & door-to-door collection as the principle means of collecting

- No reimbursement by the state, since local agency can levy service charges, fees, or assessments

Metro’s HHW EPR legislation• Why is Metro tackling EPR for HHW?• Legislative concept • Next steps

Why EPR for HHW?

• PaintCare saves Metro about $1 million annually• Consultant report: if other HHW

programs are brought under EPR in Oregon, it could save Metro nearly $2 million more annually - Cascadia Consulting December 2012

Why EPR for HHW?

• Fairness- why should local governments bear the burden?• Will help us fully realize the mission

of our HHW program• Three Canadian provincial programs

have implemented EPR for HHW (BC, Ontario, Manitoba)• It’s a logical next step

Legislative Concept• Producers that sell covered products

into the state must have a program• What’s covered?• How are things paid for?• What services provided? • What’s specifically required: – of stewards? – of government?

Product Coverage Focus

The “other stuff”• Flammables (e.g.,

solvents)• Pesticides• Corrosives• Other toxics &

hazardous materials

Works in progress• Paint (covered)• Mercury lights• Batteries

– Primary & Rechargeables

• Sharps• Pharmaceuticals

Legislation Overview

Element Draft Legislative Concept

Coverage Any consumer product that:• is DOT hazardous• exhibits a RCRA hazardous waste

characteristic, or • is FIFRA registered

Financing No government approved fees, up to industry to work out financing

Services •Collection sites authorized by DEQ•Maximize use of existing HHW infrastructure

Performance requirements:• convenience• recycling\recovery rates and

dates

“Status quo plus” (what’s collected now with more service in underserved areas)

What’s next?

•Stakeholder process, including: industryOR local governmentswaste services providersnational interested partiesNGOs