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United States Solid Waste and EPA530-R-92-026Environmental Protection Emergency Response August 1993Agency (OS-305)

Household HazardousWaste Management

A Manual for One-DayCommunity Collection Programs

This handbook is designed to help communities planand operate a successful household hazardous waste(HHW) collection program. The handbook focuses on

one-day drop-off programs. Other types of HHW collectionprograms—permanent, mobile, and special-are not discussedin detail.

The handbook is intended for community leaders and HHWcollection program organizers. It provides guidance for all as-pects of planning, organizing, and publicizing a HHW collec-tion program. It does not provide technical information aboutthe treatment, disposal, or transport of HHW. These jobs areperformed by professional contractors or others with special-ized training. The manual includes information about select-ing a qualified hazardous waste contractor

I

Household HazardousWaste Management

A Manual for One-DayCommunity Collection Programs

Section 1

Section 2

Section 3

Section 4

Section 5

Section 6

Section 7

Section 8

Section 9

Section 10

Section 11

Appendix A

Appendix B

Appendix C

Appendix D

Page

Introduction . . . . . . . . . . . . . . . . . . . . . . . ...1

Getting Started . . . . . . . . . . . . . . . . . . . . . ...5

Selecting Wastes and Collection Methods . . . . . . . . . .11

Selecting Waste Management Methods . . . . . . . . . . .17

Minimizing Liability . . . . . . . . . . . . . . . . . . ...21

Funding the Program and Controlling Costs . . . . . . . . .25

Publishing the Request for Proposals and

Signing the Contract . . . . . . . . . . . . . . . . . . ...31

Selecting, Designing, and Operating the

Collection Site . . . . . . . . . . . . . . . . . . . . . ...37

Training the Collection Day Staff . . . . . . . . . . . . . .41

Education and publicity . . . . . . . . . . . . . . . . ...45

Evaluating the Program . . . . . . . . . . . . . . . . ...49

Case Studies . . . . . . . . . . . . . . . . . . . . . . ...51

Hazardous Waste Laws and Regulations . . . . . . . . . . .58

State and Regional Hazardous Waste Contacts . . . . . . .62

Information Resources . . . . . . . . . . . . . . . . . ...68

Sample Participant Questionnaire . . . . . . . . . . . . . .74

What Is Household once the consumer no longer has any use for

Hazardous Waste? them. The average U.S. household generatesmore than 20 pounds of HHW per year. As

Many common household products con- much as 100 pounds can accumulate in the

1

I N T R O D U C T I O N

home, often remaining there until the resi-dents move or do an extensive cleanout.

Hazardous waste is waste that can catchfire, react, or explode under certain circum-stances, or that is corrosive or toxic. TheU.S. Environmental Protection Agency(EPA) has set stringent requirements for themanagement of hazardous waste generatedby industries. Some HHW can pose risks topeople and the environment if it is not used,stored carfully, and disposed of properly.However, Congress chose not to regulate itbecause regulating every household is sim-ply too impractical.

Government and industry are working todevelop consumer products with fewer orno hazardous constituents. However, forsome products, such as car batteries and

photographic chemicals, no “safe” substi-tutes exist. So, communities will need effec-tive HHW management programs for sometime to come.

Communities FindSolutions

HHW programs can benefit communitiesin several important ways. They can reducethe risks to health and the environment re-sulting from improper storage and disposalof HHW. They can reduce communities’liability for the cleanup of contaminationresulting from improper HHW disposal.Finally, HHW programs can increase com-munity residents’ awareness of the potentialrisks associated with HHW and promote a

ommon Household Hazardous Wast

(These items, and others not included on this list, might contain materialsthat are ignitable, corrosive, reactive, or toxic.)

● Drain openers

● Oven cleaners

● W and metal cleaners and polishers

● Automotive oil and fuel additives

● Grease and rust solvents

● Carburetor and fuel injection cleaners

● Air conditioning refrigerants

● Starter fluids

• Paint thinners

• Paint strippers and removers

• Adhesives

• Herbicides

• Insecticides

• Fungicides/wood preservatives

Source: A Survey of Household Hazardous Wastes and Related Collection Programs, Office ofSolid Waste and Emergency Response, U.S. Environmental Protection Agency. EPA/530-86-038.

1990

1991

175

2 4 8 31 94

19881989

I N T R O D U C T I O N

PROGRAMS

1 ,000

800

600

400

200

0

better understanding of waste issues ingeneral.

Many communities have established pro-grams to manage HHW. The impetus forstarting a HHW program can come from thegrassroots level, from local or state gover-nment agencies, from community groups, orfrom industry. The number of HHW collec-

tions in the United States has grown dramati-cally over the last decade. Since 1980, whenthe first HHW collection was held, morethan 3,000 collection programs have beendocumented in all 50 states.

Although programs vary across the coun-try, most include both educational and col-lection components. Communities usually

273

1980 1981 1982 1983 1984 1985 1986

YEAR

300

L1987

484

859802

693

Number of HHW Collection Programs in the United States, 1980-1991.SourceWaste Watch Center, Andover, Massachusetts, 1991.

N T R O D U C T I O N

begin a HHW program by holding a single-day drop-off HHW collection. Organizing acollection event is an important first step inreducing and managing risks associatedwith HHW.

Some communities hold annual or semia-nnual collections, while others have estab-lished permanent HHW collection programswith a dedicated facility (open at least onceeach month) to provide households withyear-round access to information and reposi-tories for HHW. By 1991,96 permanentHHW collection programs were operating in

16 states. In addition, communities haveinitiated pilot programs for curbside pick-upby appointment, neighborhood curbside col-lection programs, and drop-off programs forspecific types of HHW.

The efforts of communities across thecountry provide a wealth of experience forother communities beginning HHW manage-ment programs. As the number of these pro-grams continues to grow, public awarenessabout HHW will also grow, and the environ-mental problems associated with improperstorage and disposal of HHW are likely todecrease.

Getting Started

5

G E T T I N G S T A R T E D

P lanning for your first HHW collection must begin very early-as long as 6 to 18months before a projected HHW collection date. See box for a sample timeline forplanning the HHW collection. In addition, the case studies presented in Section 11

describe how two communities successfully planned HHW collection days.

Define Roles andResponsibilities

Although one person can be the catalystfor beginning a community program, thesuccess of the program depends on the in-volvement of a variety of individuals andorganizations. A key initial step in planningthe program is identifying who should beinvolved and defining their roles andresponsibilities.

The PlanningCommittee

The most important step in beginning aprogram is enlisting a core group of peoplewho can assemble the needed resources andmanage the program. The planning commit-tee can perform or oversee many differentfunctions, such as:

Providing background information.Setting policy and goals.Obtaining finding and other resources.Championing the program in thecommunity.Supervising a sponsor.

The process of forming a planning com-mittee can begin at a meeting of communityofficials and interested members of the pub-lic where they can discuss instituting aHHW management program. Telephoninginfluential community members and placingannouncements in the local media can helpboost attendance at the meeting.

If sufficient support for a program exists,the people gathered can choose a programcoordinator, form a planning committee andsubcommittees, and begin planning the pro-gram. The planning committee usually in-cludes solid waste, health, public safety, andplanning officials; legislators; members of

citizen groups; and representatives from lo-cal business and industry.

The HHWProgram Sponsor

Every community HHW managementprogram needs a sponsor or co-sponsors.Usually the sponsor is a government agency,but some programs are sponsored by a civicorganization or a business. The sponsor’srole includes:

Managing and funding all aspects of theprogram.Developing Requests for Proposals(RFPs) and contracts with a licensed

hazardous waste contractor.Recruiting, managing, and delegating re-sponsibilities to supporting agencies andstaff.

■ Involving community leaders and resi-dents in planning and implementing theprogram.

The HazardousWaste Firm

Most communities contract with a quali-fied hazardous waste firm that handles theHHW at the collection site and brings it to ahazardous waste treatment storage, and dis-posal facility (TSDF). If you hire a hazardouswaste contractor to handle the HHW collec-tion, be sure to choose a firm or firms licensedto store, transport and dispose of HHW ac-cording to federal and state requirements. Haz-ardous waste contractors might not need tobe fully licensed (see Appendix A) to per-form the duties your contract requires.Licensing, however, helps to ensure that thecontractor is experienced. The roles of the

6


contractor are spelled out in the contract andcan include: Providing necessary materials and

equipment. Properly training its collection staff.■ Obtaining necessary insurance. Consulting with the program planners

about waste management methods to be used.

■ Providing necessary services on collec-tion day, such as unloading wastes fromvehicles; screening, packaging, testing,and labeling wastes; supervising volun-teer personnel; and hauling and dispos-ing of the waste.

■ Complying with all applicable federal,state, and local requirements.

■ Submitting post-collection reports.

■ Identifying appropriate hazardous waste Information on selecting a contractor is

TSDFs. provided in Section 6.

6 to 18 Months before Collection •Identify/order equipment

•Establish planning committee•Arrange disposal and recycling of

•Identify program goalsnonhazardous material

•Select program sponsor and cosponsors brought in

•Contact environmental regulatory •Continue education and intensify

agencies publicity efforts

•Begin designing education program •Solicit volunteers

•Initiate community outreach •Acquire insurance

•Research laws, regulations, and guidelines •Develop collection day surveys

•Determine collection methods•Set tentative collection date(s) 0 to 6 Weeks before Collection

•Select potential sites •Receive equipment and supplies•Initiate public education program •Conduct worker training/safety training• Determine targeted wastes/excluded •Complete publicity campaign

wastes/generators • Confirm police/emergency service•Estimate costs involvement•Secure funding•Issue Requests for Proposals (RFPs) Collection Day

• to S Months before Collection •Set up site

•Evaluate RFP submissions •Orient community staff and volunteers

•Interview contractors •Complete participant questionnaires

•Select contractor ● Receive, package, and ship HHW

• Identify markets for reusable and •Clean up site

recyclable HHW Post-Collection Day•Involve emergency services (fire,

police, etc.) •Tabulate survey responses•Begin publicizing collection program •Evaluate collection/public education•Obtain permits results

6 to 12 Weeks before Collection•Publicize results•Thank participants and volunteers

• Design site layout and draw site plan through the media•Develop collection day •Write summary report

procedures/written plan •Prepare for future events

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Involve theCommunity

Community involvement is critical to thesuccess of a HHW management program.Government agencies, community groups,local legislators, businesses, industries, andconcerned citizens should be involved fromthe start. They can promote the HHW pro-gram in a number of ways:

Building acceptance for the programIf key community leaders participate in

the planning process, they can help buildcommunity acceptance and support for theproject. In addition, local officials will knowthe mood and interests of the communityand can help avoid or overcomesensitive issues.

Developing a sense of community‘ownership”

People involved in planning and imple-menting a project will feel that the programbelongs to them. Community ownershiphelps to ensure greater participation on col-lection day as well as community prideabout the outcome of the event.

Providing community assistanceVolunteer groups and residents often can

contribute expertise or resources and canshare the responsibilities of planning andimplementing the program withthe program sponsor.

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Providing leadership on HHW issuesThe more community leaders learn about

managing and reducing HHW, the morelikely they will be to support an ongoing orpermanent program. Many community lead-ers also will alter their buying and disposalpractices, becoming examples for the com-munity.

Assemble the FactsMembers of the planning committee

should conduct background research duringthe program’s early planning stages. At leasta month or two is needed to acquire the in-formation necessary to plan the program andinform the community. This research can beconducted by planning committee members,who can provide important information intheir own areas of expertise:

Health department officials can pro-vide technical data (such as materialsafety data sheets) about specific hazard-ous materials.Police and safety officials can provideprocedures for handling materials andfor preventing and managing accidents(such as site selection procedures andtraffic management).Legislators and public officials canprovide relevant regulations andguidelines.Public interest groups can provide siteselection considerations, media con-tacts, informational materials, and proce-dures for volunteer recruitment.Businesses can provide informationabout sources of funding and materialand equipment donations.Educators can provide curricula andaudiovisual materials.

It is essential that the sponsor and theplanning committee learn about the federal,state, and local regulations that apply totheir HHW management program as well asthe steps they can take to minimize liability.It is important to note that state regulations

9


might be more stringent than federal hazard-ous waste management regulations. For ex-ample, states might require HHW collectionprograms to obtain operating permits. Localgovernments also might have applicable re-quirements, such as zoning laws or buildingcodes. These issues are discussed in Section4 and Appendix A. The sponsor or planningcommittee should review current literature,attend conferences or workshops about man-aging HHW, if possible, and contact thestate hazardous waste management agency,the EPA regional office, and local agencies(see Appendix B).

It is also important to anticipate the typesof wastes to be collected, since differenttypes of HHW present different transportand handling requirements. The type of ac-cumulated HHW is strongly influenced bywhether the community is in an urban, sub-urban, rural, or agricultural area. For exam-ple, an agricultural area might generate largequantities of pesticides. Pesticides areamong the most expensive wastes to disposeof. HHW programs in rural or agriculturalareas, therefore, might be more expensivethan programs in urban or suburban areas.Collection programs in environmentallyproactive communities usually will havehigher participation and collection rates thanprograms in less environmentally activecommunities.

Establish GoalsEvery HHW management program needs

clear, realistic goals and feasible ways ofachieving them. Typical program goalsinclude:

■ Maximizing public participation. Bymaximizing participation in the HHWprogram, the quantity of hazardous ma-terials will be reduced in both the solidwaste stream and the wastewaterstream. Greater participation will meanhigher costs for the community in theshort run but will help avoid or reduce


costs associated with potential environ-mental cleanups. It will also help to pre-vent or minimize health and safetyproblems associated with improperHHW storage and handIing in homes.

maximizing the reuse and recyclingof HHW. By maximizing reuse and re-cycling, program sponsors will mini-mize their hazardous waste disposalcosts and will conserve natural and fi-nancial resources. Collecting productssuch as paint for reuse and recycling,

however, might result in higher laborcosts (e.g., for paint consolidation). Inaddition, communities will have to lo-cate and secure markets for the materials.

■ Removing from homes those wastesconsidered most hazardous. Instead ofcollecting all wastes, some communitiesmight want to collect specific wastesthat they consider to present an unac-ceptable risk or to be a likely source ofenvironmental contamination, such asoil-based paint and used motor oil. Itmight be difficult, however, to educatepeople to bring only those wastes to thecollection. In addition, environmental,health, and safety problems couldresult from uncollected wastes in thecommunity.

9 Educating the public about reducinggeneration of HHW. Some programsponsors might want to establish aHHW program to provide informationto consumers about proper HHW man-agement and alternative ways to reducegeneration of HHW. No matter how ef-fective education is, however, collectionprograms will still be needed for wastesfor which there are no alternatives (suchas car batteries) and for existing HHWstored in homes.

Identifying goals will help collection pro-gram organizers determine the basic type ofcollection program (e.g., periodic drop-off,curbside, or permanent), the amount of fund-ing needed to collect and manage the wastesand to educate the community about the pro-gram, and the waste management practicesthat the program will use.

10

Selecting Wastesand Collection

Methods

S E L E C T I N G C O L L E C T I O N M E T H O D S

wDecide

hen initiating a collection program, the planning committee must decide whomay bring wastes to the collection, what types and quantities of waste will beaccepted, and how the waste will be collected.

WhoMay Bring Wastesto the CollectionProgram

Most collections are limited to wastesgenerated by individuals at home and ex-clude hazardous waste from commercialand institutional generators. This is primar-ily because programs are expensive, aver-aging $100 per participant. In addition, bylimiting the number of participants it ispossible to limit the amount of wastes (al-though it also reduces effectiveness).

Some HHW collections, however, areopen to small businesses that are “condi-tionally exempt small quantity generators”(CESQGs) of hazardous waste (see Appen-dix A). Examples of businesses and institu-tions that might be considered CESQGsunder certain circumstances include flo-rists, home repair businesses, gas stations,and schools. CESQGs often are unawarethat they produce hazardous waste, and sosometimes store and dispose of wastes im-properly. A HHW program that includesthese generators can educate them aboutenvironmentally sound ways to managetheir hazardous waste. Requirements thatmust be followed if a HHW collection pro-gram accepts wastes from these small busi-nesses are explained in Appendix A. Thesegenerators usually are charged based onthe cost of managing their wastes. Thecharge for CESQG waste is less than whatgenerators would pay if they managed thewaste themselves.

Decide What TypesOf HHW to Accept

The two types of waste received mostoften at HHW collections are used motor oiland paint. Pesticides usually are the thirdlargest category. Programs also receive sig-nificant numbers of car batteries. Over thenext few years, the types of wastes collectedmight begin to change, and the volume ofcertain types of HHW will probably de-crease. For example, the proportion of latexpaint compared to oil-based paint will prob-ably increase since sales of oil-based painthave been decreasing. It will take a longtime, however, to remove stored materialsfrom all the homes in a community. (In SanBernardino County, California, for example,the paint brought to HHW collections is anaverage of 10 years old.)

To minimize costs, some programs tar-get only specific recyclable HHW, such asused oil, car batteries, antifreeze, and latexpaint. In addition, HHW collections oftenexclude certain wastes that the contractoris not licensed to receive or does not havethe necessary equipment to identify or han-dle. Certain wastes also might be excludedif the TSDF will not accept them. Fre-quently excluded wastes include garbage,asbestos, dioxin-bearing wastes, explo-sives, radioactive such as smoke detec-tors, and unlabeled or unknown wastes.Most programs also exclude medicalwastes. In New Jersey, however, some pro-grams have begun to collect medical wasteusing a hauler licensed to handle suchwastes.

12

Decide Whether to Limit the Amount Of HHW

A few programs limit the amoubt of HHW that each participant may bring to the collectopn. For example, some collections

impose a five-gallon or 50-pound limit per participant, while others limit the size of the containers. This practice holds down

collection-day costs. Limits can also prevent CESQGs or small quanity generators (SQGs) (see AppendixA) from bringing

wastes to the collection, if that is a goal of the program. In some states, limits on the amount of HHW are set by law. In addition,

state permits for one-day collections or program contracts may forbid overnight storage of the hazardous waste. Amounts, therefore,

might need to be limited so that all wastes can be properly packaged before the end of the day.

Programs accepting waste from small businesses (CESQGs only) might limit amount acepted ro charge a participation

fee so that the program will not be overwhelmed by disposal costs. Allowing dropoff "by appointment only" will prevent the

collection site from being overwhelmed by too many CESQGs.

S E L E C T I N G C O L L E C T I O N METHODS

Select a CollectionMethod

To maximize participation, many commu-nities are experimenting with a variety ofcollection methods. Some use a combinationof collection methods. Common collectionmethods include one-day, permanent facil-ity, mobile facility, door-to-door pickup,curbside, and point-of-purchase. Althoughthis manual focuses on one-day drop-off pro-grams, the next section briefly introduceseach of the major types of HHW collectionprograms.

One-Day Drop-OffMost communities begin HHW programs

with one-day, one-site events at which resi-dents drop off their HHW. The events usu-ally are scheduled in the spring or fall;participation during other seasons is limitedby summer vacations and winter weather inmuch of the country. One-day drop-off col-lections typically are held on Saturday, with-out appointments, starting in the morningand ending in the afternoon.

A potential limitation of drop-off pro-grams is finding a date for the collection onwhich the hazardous waste contractor will

13

S E L E C T I N G C O L L E C T I O N

be available. It is important to confirm thedate with the contractor as early as possible(six months in advance is recommended), es-pecially if HHW collections are scheduledon the weekend. Weekend HHW collectionsin the spring and fall are very popular, andthese dates fill up quickly.

Another potential limitation of one-dayprograms is that the chosen day might notbe convenient for some residents. To ad-dress this concern, some communities holddrop-off collections on more than one day—for example, a Saturday and Sunday-or ontwo successive weekends. The selectedHHW collection date(s) should not conflictwith other major events in the community.Holding collections in more than one loca-tion within the community also can increaseparticipation.

Still another potential limitation is thatparticipants sometimes must wait an hour ormore to drop off their wastes. Organizers ofdrop-off collection events need to plan waysto avoid long waits. Strategies for reducingwaiting time include using express lanes forcertain wastes (see Section 7), holding thecollection in several different locations,holding the collection over several days, andimplementing a two-phase program (for ex-ample, accepting paint and oil one day andother wastes the next).

Permanent Drop-Off

If the limitations of one-day collectionsprove too great, a community might want toconsider instituting a permanent drop-offprogram. The community must anticipate anumber of needs that accompany permanentdrop-off programs, including:

Managing the increased annual quantityof HHW and increased participationrates.

■ Ongoing public education and publicity.■ A facility for onsite storage of HHW.

■

■

M E T H O D S

Training local staff to perform many ofthe responsibilities usually assumed bythe hazardous waste contractor atone-day collections.An institutionalized, predictable fundingsource.Compliance with additional state and lo-cal regulatory requirements that mightapply to permanent programs.

Permanent programs require a larger up-front investment than one-day collections,but they probably will reduce costs per par-ticipant for the community in the long run.For example, communities generally usetheir own employees instead of contractors,often resulting in lower costs.

Drop-Off at aMobile Facility

Most surveys show that the average col-lection day participant travels five miles orless to the site. Sponsors can purchase a mo-bile facility and equipment to provide peri-odic collections on a regular schedule atdifferent sites within a county or large com-munity. This is an effective method for pro-viding service to geographically large anddiverse regions. Like permanent programs,these mobile collection programs might costmore than one-day programs in the begin-ning, but they probably will reduce costs perparticipant over the long term.

Door-to-Door Pickup

Door-to-door pickup by appointment isexpensive, but it is more convenient for par-ticipants than drop-off. The personnel whocollect materials must be trained in handlinghazardous waste, including how to pack andseparate the waste in the collection vehicle.It also allows participation by houseboundindividuals and others who cannot travel toa collection site. Sometimes the programs

14

S E L E C T I N G

are offered to certain individuals in additionto the one-day event.

Curbside CollectionCurbside programs usually are limited to

a few selected wastes collected from house-holds on a regularly scheduled basis. Restric-tions on the types of waste are necessary

C O L L E C T I O N M E T H O D S

because leaving highly toxic or incompat-ible wastes at the curb can be dangerous,and because collecting and transportinga variety of hazardous materials in residen-tial neighborhoods presents logisticaldifficulties.

The most common type of wastecollected at curbside is used oil. More than115 communities have set up programs to

S E L E C T I N G C O L L E C T I O N M E T H O D S

collect recyclable used oil at curbside. Othercommunities collect household batteries andpaint at curbside.

Point of PurchaseIn some immunities, a few types of

HHW can be returned to retail stores.community HHW program planners canpublicize these point-of-purchase programsas part of an overall HHW managementstrategy.

Retailers have implemented some point-of-purchase programs voluntarily. in NewHampshire andVermont for example, somehardware and jewelry stores collect custom-ers’ spent household batteries in buckets orspecially designed cardboard boxes.

In addition, several states require that cer-tain retailers take back some types of HHW.In Massachusetts and New York, for exam-ple, retailers must take back automobile bat-teries and used motor oil. Regulations inConnecticut, Minnesota, and Oregon bancar batteries and used oil from landfillsand/or require deposits and retailer redemp-tion.

Regulations regarding proofs of pur-chase, deposits, and surcharges for returnsare different in each state. Massachusettsused oil law, for example, requires proof ofpurchase. Auto battery regulations usuallyrequire retailers to post a notice informingcustomers that they may return their batter-ies and stating how many may be returned atone time.

16

Se ecting WasteanagementMethods

17

S E L E C T I N G M A N A G E M E N T M E T H O D S

n designing a collection program, it is important to determine what will happen to thewastes that are collected. When selecting among various waste management options,HHW program planners should try to recycle or offer for use as much of the collected

wastes as possible. The HHW that cannot be recycled or used should be managed as a hazardo-us waste. If the communities use contractor services to manage some or all of this HHW,waste management priorities and procedures should be communicated clearly to the hazard-ous waste contractor.

In addition, it is essential that the pro-gram planners investigate the soundness ofany facility where the waste will end up-particularly if CESQG waste is accepted(see Appendix A). The planners should askpotential contractors about the methods theywill use to manage the wastes, and theyshould also ask for copies of the permits forthe hazardous waste facilities that are to beused. Planners can also contact the state haz-ardous waste agency (see Appendix B) tofind out if a facility is properly permitted.

Reduce through UseReusing materials brought to HHW col-

lections can reduce the amount of HHW thatthe contractor must manage, often signifi-cantly lowering program costs. Some com-munities have set up waste exchanges tomake materials available for other partici-pants’ use. These exchanges can take placeat a HHW drop-off site or throughtelephone/hotline referrals. For example,reusable paint can be placed on “drop-and-swap” tables for collection program partici-pants to pick up, or it can be bulked andblended for use by people or institutionswho request the paint. This “second-hand”paint is readily accepted by the public, com-munity groups, religious and recreationalcenters, graffiti removal programs, and

1Duxbury, Dana and Philip Morley. 1990. Overview of

collection&management methods. Proc. of the FifthNational Conference on Household Hazardous wasteManagements, November 5-7, 1990, San Francisco,California, pp. 251-274.

schools. Experience shows that paintexchanges can reduce the amount of paintbeing disposed of at HHW collections by asmuch as 90 percent. 1

EPA recently prohibited mercury in indoor latex paint. Latex paintexchange programs and disposal, however, still must be carefullymanaged.

Interior latex paint manufactured before August 20,1990, mightcontain mercury. For this reason, all latex paint in a paint exchange or“drop-and-swap” program should be assumed to contain mercuryand labeled “FOR EXTERIOR USE ONLY.” Using interior paintoutside will substantially reduce the risk from exposure to mercury.Interior paint used outside, however, might not hold up as well aspaint originally manufactured for exterior use. Alternatively, interiorlatex paint may be swapped for interior use if mercury levels of lessthan 200 parts per million (ppm) can be confirmed. This can be donein several ways

A commercial laboratory can test the paint for mercury.

The National Pesticides Telecommunications Network(800-858-7378) provides names of paint brands that contain lessthan 200 ppm of mercury.

The date of manufacture might appear on the label; no interiorlatex paint manufactured after August 20, 1990, containsmercury. No paint manufactured after September 30, 1991, maycontain mercury.

Usable latex paint can be consolidated and then might or mightnot be reprocessed. The consolidated paint should be tested formercury. If it contains more than 200 ppm, it must be labeled “FOREXTERIOR USE ONLY.”

Unusable latex paint (such as paint that is frozen or solidfied) thatcontains more than 200 ppm of mercury should be managed ashazardous waste.

18


Other materials suitable for reuse caninclude unwanted pesticides, cleaning prod-ucts, and automotive products. These materi-als often can be used by the sponsoringmunicipality for its buildings and vehicles.Communities should offer products only ifthey are in the original container and the la-bel is intact and legible. They should not of-fer products if the container is banned,leaking, rusting, or otherwise damaged.Products should not be repackaged for reuse.

RecyclingA significant percentage of HHW can be

recycled. For example, used oil can bererefined for use as a lubricant. It also canbe reprocessed for burning as a supplemen-tal fuel (as can oil-based paint and ignitableliquids). EPA has issued several publicationsto help communities safely collect and recy-cle used oil (see Appendix C, ProjectROSE).

Other recyclable HHW includes:

Antifreeze.Latex paint. (Up to 50 percent of latexpaint can be recycled by filtering, bulk-ing, and blending it for reuse.)Lead acid batteries. Lead used in dentalx-rays.Mercury-oxide, mercury-silver, silver-oxide, and nickel-cadmium householdbatteries. Several firms in the UnitedStates take these batteries for a fee; thecontractor can be required in the con-tract to investigate the option of ship-ping used batteries to one of these firmsfor recycling.Fluorescent light bulbs.

Some communities sponsor “recyclables-only” days to divert the large-volume materi-als (motor oil, car batteries, and latex paint)from HHW collections and to reduce theamount of waste that the contractor has to re-ceive, package, and process. Recycling days

save money because they often are staffedby the sponsor. Communities that sendHHW off site for recycling should contacttheir state environmental regulatory agen-cies to identify recyclers and to verify thatthe recycler is reputable (see Appendix Bfor a list of state regulatory agencies).

The results of the State of Florida’s“Amnesty Days” show the great potentialfor recycling HHW received at one-day

R e c y c l i n g U s e d O i l :

ject ROSE

For over 14 years, a trailblazing

program in Alabama has worked to

stimulate the collection of used

automobile oil for recycling. Project ROSE(Recycled Oil Saves Energy) has taken the

lead in helping communities across the

state develop used oil recycling programs

tailored to local circumstances.

Project ROSE has built an extensive

infrastructure for recycling used

automobile oil generated by people who

change their own oil (do-it-yourselfers)

throughout Alabama. Because much of

Alabama is rural, collection centers, in

the form of service stations, are the mostwidely used system. In addition, several

larger cities provide curbside collection of

used oil.

The program uses publicity and

education to develop the momentum to

start local used oil recycling programs and

then coordinates the effort of

established networks by matching buyers

of used oil with collectors. This strategy

relies heavily on recruiting leaders from

local organizations, who then work with

Project ROSE to help introduce and

support recycling programs in their area.

19


collections. Thirty-six percent of the HHWcollected at 107 Amnesty Days (984,655pounds out of a total of 2.7 million pounds)was recycled over a two-year period. The re-cycled material consisted of used oil, car bat-teries, and latex paint.

Treatment

Treatment technologies reduce the vol-ume and/or toxicity of HHW after it is gener-ated. These technologies include chemical,physical, biological, and thermal treatment.Common treatment procedures are neutrali-zation of acids and bases, distillation of sol-vents, and incineration. The methods aredictated by the types of waste, proximity totreatment facilities, cost, and the contrac-tor’s access to treatment facilities. However,the contract can specify the waste manage-ment methods to be used. If the waste is sentoff site for treatment, the contractor shouldprovide the sponsor with documentationverifying the waste’s final destination.

Landfill

As a result of current and pending banson land disposal of certain hazardous wastesand the efforts of communities to reduce theamount of HHW sent to municipal solidwaste landfills, more HHW is being reused,recycled or treated. As with waste destinedfor offsite treatment the hazardous wastehauler should provide the sponsor withmanifests, state-approved shipping docu-ments, or similar documentation verifyingthe waste’s final destination and showingthat the hazardous waste landfill is properlypermitted.

Procedures forExcluded Wastes

HHW program planners and contractorsoften exclude certain wastes from collectionprograms. Frequently excluded wastes in-clue radioactive materials, explosives,banned pesticides, and compressed gascylinders. Program organizers must let par-ticipants know which wastes will not be ac-cepted and must give them other optionsand instructions for managing the excludedwastes. For example, the police usually willarrange for pickup of explosives. Smoke de-tectors, which often contain a minute quan-tity of radioactive material, are accepted bysome manufacturers (see product labelingfor instructions). If participants are not pro-vided with alternative management options,they often discard these wastes in the near-est trash can.

Information is available through EPA-sponsored environmental

outreach programs

Informational materials on recycling reuse, disposal, andcollection program design are available through: RCRA

Hotline 800424-9346; the Waste Watch Center

508470-3044 and the Solid Waste Information

Clearinghouse 800-67SWICH.

With EPA support the International City Managers

Association (202-962-3672) and the Solid Waste Associationof North America (301-585-2898) provide technicalassistance to communities and other nonprofit groups

through a peer matching program. This program provides

direct, hands advice and assistance on a peer-to-peer

basis (e.g., mayor-to-mayor).

20

Minimizing Liability

21

M I N I M I Z I N G L I A B I L I T Y

C ommunities can be liable for an injury to a collection day worker, an accidental re-lease of HHW to the environment at the site, or an accident during the transportationof HHW from the collection site to the disposal site. The following recommendations

can help communities minimize potential liability.

Become FamiliarWith National,State, and LocalHazardous WasteRegulations

Planners of community HHWprograms must know the laws that governtheir collection activities. Planners alsoshould be aware that their state might have

requirements that are more stringent thanthose set by the federal government.

In addition, program planners should befamiliar with regulations governing manage-ment of specific wastes. For example, con-solidated oil-based paint must be tested forpolychlorinated biphenyls (PCBs) before itis sent to a supplemental fuel-burning facil-ity. Paint that contains more than 50 partsper million of PCBs must be sent to an incin-erator permitted to burn PCBs under the

22

M

Toxic Substance Control Act. Latex paintusual] y is not considered a hazardous waste.Several states recommend treating it as ahazardous waste, however, because of thelevels of heavy metals found in some brandsand formulations.

While hazardous waste regulations mightseem complex at first, program plannersshould remember that there is potential li-ability associated with taking no action at allto manage HHW. By complying with the re-quirements set out in federal, state, and locallaws, communities can reduce their overallliability. Appendix A summarizes the federalrequirements that apply to HHW programs.

Develop a Safety Plan

Well in advance of collection day, thesponsor (or contractor) should develop asafety, accident prevention, and contingencyplan. Hazardous waste management firmsexperienced in servicing HHW collectionscan provide a sample plan. The plan shouldinclude steps for preventing spills, a contin-gency plan in the event of a spill or acci-dent and a list of the health and safetyequipment available on site. The plan alsoshould specify when an evacuation wouldbe necessary, the evacuation routes andmethods, and who would be in charge of anevacuation. For example, primary emer-gency authority should be designated to aspecific police and fire department if morethan one department has jurisdiction. Policeand fire departments should be involved inthe planning and provided with the layout ofthe collection site, information about thewastes that will be handled, and possibleevacuation routes.

A copy of the safety plan should be avail-able at the collection program. One personshould be designated to control any emerg-ency operation.

I N I M I Z I N G L I A B I L I T Y

Make Training andPublic Education aHigh Priority

Proper training of the sponsor’s in-housestaff and volunteers is essential for minimiz-ing potential problems on collection day.Section 8 discusses training requirements ingreater detail. Public education and public-ity also can help ensure a safe operation.Publicity should inform participants abouthow to safely package their HHW and trans-port it to the collection site. For example,participants should be instructed not to trans-port HHW within the passenger compartm-ents of their vehicles.

Obtain theNecessary Insurance

The sponsor should ensure that theprogram has adequate insurance to covergeneral, employee, transportation, and envi-ronmental liability, Some communities willchoose to self-insure for any HHW collec-tion liability, especially when a contractorhas most of the responsibility. The minimuminsurance required includes:

General Liability Insurance. Contrac-tors managing all collection site opera-tions and activities usually provide $1million to $2 million of general liabilityinsurance for damage to property or forbodily harm at the collection site causedby actions of the contractor’s staff. Thiscoverage does not apply to propertydamage or bodily harm caused by thesponsor’s staff or volunteers.Motor Vehicle Insurance The contrac-tor needs insurance to coverall driversand vehicles transporting the collectedwaste.In-Transit Insurance. In-transit insur-ance is required by the Department ofTransportation for interstate movement

23

M I N I M I Z I N G L I A B I L I T Y

of hazardous materials or waste. Thecontractor’s coverage, up to $5 million,will vary according to the types of mate-rials transported. This insurance coversenvironmental restoration of property orcompensation for bodly harm.

■ Indemnification Clause. The contractwith the hazardous waste firm should in-clude an indemnification clause statingthat the sponsor is blameless in theevent of contractor negligence, acts ofomission or wrongdoing. Similarly, thecontractor can request indemnificationby the sponsor for any costs incurred bythe sponsor’s negligence.

■ Workers’ Compensation InsuranceThe sponsor should obtain coverage forany staff or volunteers working at thecollection day who are not provided bythe contractor.

The sponsor also can require additionalprotection from the contractor to help mini-mize liability, including:

A “bid bond” to cover the sponsor fortime and expenses for the bid period inthe event that a contractor turns downthe contract after it is awarded.A “performance bond” to ensure satis-factory performance and, if necessary,cover the costs of completing the pro-ject according to the contract.A “certificate of insurance” fromthe contractor’s insurance company,and a clause in the contract requiringthat the sponsor be given notice in theevent of cancellation of the contractor’spolicy.

In addition, the sponsor should ask to seea copy of the TSDF’s environmental impair-ment liability insurance. These facilitiesneed this insurance to cover lialility underthe Resource Conservation and RecoveryAct (RCRA), the federal law covering haz-ardous waste management. The insurance isnot available to HHW collection programs.

F U N D I N G T H E P R O G R A M

A nticipating and reducing costs of a HHW program, as well as locating fundingsources, are major concerns for program planners. However, many communitieshave found creative ways to finance their programs and effective ways to cut costs.

HHW program costs generally increaseas the amount of waste collected increases.It is important to keep in mind, however,that the potential consequences of mismana-ged HHW-soil and ground-water contami-nation, hazardous emissions at landfills,worker injury and equipment damage, inter-rupted water treatment, and contaminated ef-fluent at water treatment plants-can resultin much greater costs.

Factors that Affectcosts

A review of the data on approximately3,000 collection programs held since 1980indicates that costs for a one-day HHWcollection range from as little as $10,000to more than $100,000. The final cost of aHHW collection is difficult to predict be-cause many variables cannot be estimatedor controlled easily. These variables in-clude the number of households that par-ticipate, the types and amount of wastecollected, and the waste managementmethods used. Major urban multi-sitecollection events, targeted farm pesticidecollections, and collections in communi-ties located a long distance from hazard-ous waste disposal facilities willexperience higher costs. See box for devel-oping a rough cost estimate for a one-dayHHW collection. This formula is based on1991 estimates of disposal costs. Theseestimates might need to be adjusted ifwaste management costs change. Thisformula is based on much of the work be-ing done by a contractor. Programs thatuse less contractor help and that rely more

on recycling and reuse for waste manage-ment will greatly reduce the cost.

ParticipationOn average, each participant brings 50 to

100 pounds of HHW to a collection, at acost to the sponsor ranging from $50 toslightly more than $100 per participant.Participation rates usually range from one tothree percent of eligible households and canbe as high as 10 percent. Suburban commu-nities, especially those with a hazardouswaste problem or a solid or hazardous wastefacility, experience high rates of participa-tion. Extensive education or publicity pro-grams also can increase participation rates.

Waste ManagementMethods

Waste management costs are the largestitem in the HHW program budget. The over-all waste management costs will depend onthe types of waste collected and the wastemanagement methods that are used. For ex-ample, programs that accept only recyclablematerials or provide a “drop-and-swap” areawill experience much lower waste manage-ment costs and lower personnel costs aswell. Reusing or recycling HHW or burningit as a supplemental fuel is less expensivethan incinerating the waste at a hazardouswaste facility. Pesticides, especially thosecontaining dioxin, and solvent paints andother materials containing PCBs can be veryexpensive to manage ($850 per 55-gallondrum in 1991). Burning used oil and solvent-based paint as supplemental fuel typicallycosts the sponsor $175 to $250 in manage-ment fees. In 1991, the cost of sending most

26

Controlling Costs

FundingProgram

theand

25


other wastes to a hazardous waste incineratoror land disposal facility ranged from $350 to$500 per drum. These costs can vary andmight increase over time; the hazardous wastecontractor or appropriate state agency can pro-vide current rate schedules.

Other factors will affect waste manage-ment costs as well. For example, contractorswho own and operate their own TSDFs orhave access to facilities close to the collec-tion site might be able to charge less for acollection than other contractors. Communi-ties that are located closer to hazardouswaste management facilities also mightbenefit from lower costs.

Collection Methods

The program’s collection method alsoaffects the overall cost. For example, col-lecting HHW door-to-door is more expen-sive than holding a drop-off collectionday. Permanent programs might be morecost effective than one-day collections.The number of participants might increasewith a permanent program; however, in apermanent program, there are often moreopportunities to arrange for recycling orreuse of collected materials, resulting inless waste per participant to be disposed ofas hazardous waste.

Estimating Costs.

There are no proven formulas for estimating cost fora one -day HHW collection.

Below is a formula for a very rough cost estimate range:

.01 H (low participation) x $350 + $5,000=$

8 (consolidation)(low estimate)

.03H (high participation) x $350 +$5,000=$

4 (no consolidation)(high estimate)

H is the number of households in the target area.

The formula produces a range, reflecting a participation rate from one to

three percent of the targeted households.

If oil and paint are to be consolidated, divide the number of expected

participants by eight, as shown in the equation, to calculate the number of55-gallon drums. (It generally takes seven or eight households to fill a

55-gallon drum of waste.) If no wastes are consolidated, divide by four, as

shown in the equation.

$350 is the average cost of treatment/disposal per 55-gallon drum.

Add $5,000 for set-up and personnel costs.

Local staff time, publicity, and education are additional but are usually not a major

cost item for one-day collection programs.

Note: Dollar figures above are 19% estimates.

27


Ways To MinimizeCosts

program sponsors continue to find waysto reduce both overall costs and the averagecost per participant. For example:

Consolidating instead of lab-packingHHW reduces costs by allowing formuch more waste per drum. (A lab-packconsists of a large container that holdsseveral smaller containers.) Paint usedoil, and antifreeze are frequentlyconsolidated.Some programs reduce costs by usingvolunteers (only for low hazard items)or city or county personnel to receive,consolidate, and package the waste,rather than using contractor staff forthese functions.The sale of some recyclable items, suchas silver-oxide button and lead-acid bat-teries, can help defray a program’s costs.

Of course, one of the best cost-cuttingmeasures is to educate the public about howto reduce HHW generation and how to mana-ge existing HHW without bringing it to acollection center. For example, consumerscan bring used Oil and antifreeze to someservice stations. In addition, wastewatertreatment plants in some communities takeused oil to discourage improper disposal ofthis waste and prevent damage to the treat-ment plant. Generally, car batteries can bereturned to the point of purchase.

Obtaining FundingHHW management program sponsors

have obtained funding from a wide varietyof sources. They have used state, county,and local general funds; taxes, fees, and pen-alties; “in-kind” contributions from industry,cities, and districts; and the help ofvolunteers.

State and LocalGovernments

The majority of funding for local govern-ment programs comes form municipal solidwaste budgets. In addition, county and localagencies that benefit from HHW collectiondays often contribute a portion of their budg-ets to HHW management programs. Amongthe agencies that benefit from HHW collec-tions are water and sewer departments, sinceless HHW is poured down drains; fire andhealth departments, since less HHW isstored in homes; and public works &part-ments, since less HHW is discarded withmunicipal trash. Some state environmentalagencies, such as departments of natural re-sources or the environment also providefunds for HHW management programs.Sources of state funding have included stateSuperfund budgets, oil overcharge funds,surcharges on environmental services or haz-ardous products, and special environmentalbond issues and trust funds.

Fees and TaxesMany communities increase landfill tip-

ping fees, property taxes, or water/sewerfees to create a fund for managing HHW.Some communities also have imposed userfees, but these might be a deterrent to partici-pation in the collection program, sincehousehold residents in most states legallycan throw HHW in their trash.

Some states have instituted specific taxesfor HHW programs. For example, the Stateof Washington has imposed a tax on the firstuse of certain chemicals by manufacturersor wholesalers. The tax will be used in part,to fired county HHW collections. Retailersin Iowa selling prducts covered under theshelf labeling law pay a $25 registration fee.In New Hampshire, a tax on hazardous

28


waste generators funds matching grants tocommunities for HHW collection programs.In Florida, local governments receive threepercent of the gross receipts from permittedwaste management facilities.

Contributions,In-Kind Donations,And Volunteers

Donations of money, materials, and laborare the lifeblood of many community HHWprograms. These donations can come frommany different sources:

■

Cities counties, civic groups, environ-mental organizations, and corpora-tions often provide seed money ormatching grants for collections.Hazardous waste contractors some-times donate collection and transporta-tion services.Local industries or businesses that pro-duce or distribute household productsthat can become HHW sometimes con-tribute money or services to HHW man-agement programs because theyrecognize the importance of productstewardship. In some communities, lo-cal printers have donated services for ad-vertising or education materials.

In late 1986, the Seattle Metrocenter Young Men’s Christian Association (YMCA)

(see Appendix C for address), the community development branch of the Greater

Seattle YMCA launched an impressive campaign to sponsor and fund a HHW

collection day in King County, Washington.

Metrocenter decided to seek the help of outside catalysts to develop a HHW

collection program. Ultimately 15 cities, King County, and several other public

authorities and agencies joined together to sponsor a series of major HHW“roundups” between 1987 and 1989.

Fourteen different local and regional government agencies provided funding for the

roundups. Additional financial support was provided by:

. A cigarette tax.

. Revenue from a Department of Ecology tax on hazardous materials sold within

the state.

. A water quality fund, a county solid waste fund, and the general funds of cities.

. In-kind contributions from cities, districts, and corporations.

Metacenter also made extensive use of volunteers to stretch its resources for the

“roundups.” For example, chemistry graduate students performed some of the

actual site work.

29

State and municipal agency staff and


■ Civic and environmental organizationscan provide volunteers to help plan, publi-cize, or staff the HHW collection. Volun-teers can be used to direct traffic, hand outliterature, fill out questionnaires, and han-dle nonhazardous waste.

local fire and police departments oftenprovide supervision and traffic control.

Programs can attract direct financialcontributions, in-kind donations, and vol-unteer services by giving donors positiverecognition, such as a mention in flyers,an award, or a recognition ceremony. Apublicly acknowledged donation from onegroup or company often encourages othersto contribute or participate in some otherway.

30

Publishing theRequest for

Proposals andSigning the Contract

313 5 7 - 4 4 5 0 - 9 3 - 3 : Q L 3

R F P s A N D C O N T R A C T S

I

f a contractor is to be used to do some or all of the collection work, the HHW collectionprogram probably will issue a Request for Proposal (RFP). An RFP will solicit informa-tion on which contractors are available and qualified to manage a HHW collection pro-

gram, and the amount they will charge. Most local governments have specific procedures forissuing RFPs. A contractor should be selected based on the proposals received in response tothe RFP, and a formal contract between the sponsor and contractor must be signed. This proc-ess ensures that the community is provided with all the necessary services at a reasonablecost, and that the roles of everyone involved in the collection event are clearly defined. This isthe only way to ensure proper management of the waste.

Issue the RFPA good RFP provides a comprehensive

description of the services to be provided sothat prospective contractors can bid on thecost of delivering those services. The morespecific and clear the RFP, the better thechances of obtaining complete proposalsand realistic bids.

An RFP can include the followinginformation:

A detailed narrative description of thesponsor’s goals for the program.The proposed collection site(s) anddate(s).The size of the targeted population andtypes of generators (e.g., households,farmers, and/or schools).The size and relevant characteristics,such as community demographics, ofthe targeted geographic area.The percentage of the targeted popula-tion within five miles of the selected site.Copies of the completed manifests.The extent and focus of planned educa-tion and publicity (to help estimate par-ticipation rates).The targeted waste categories.The type of collection (drop-off, curb-side, etc.)Any specific waste handling require-ments.Use of volunteers and in-house staff andthe tasks they will perform.Training required for HHW handlers.All services required of the contractor,potentially including:

●

●

●

●

●

●

●

●

●

●

unloading HHW from participants’vehicles (for a drop-off collection).

pre-screening waste.

sorting, segregating, and packagingwaste.

testing unknown wastes.

labeling wastes.

combining materials for reuse (e.g.,paint consolidation).

filling out hazardous waste forms(manifests).

obtaining a temporary EPA identifica-tion number, if necessary (see Appen-dix A).

controlling traffic.

hauling and disposing of the waste.

Post-collection reports to be submitted.The materials and equipment to be pro-vided by the contractor (see box).The waste management preferences ofthe sponsor, including the wastes thatthe sponsor wants recycled.The ultimate destination for each waste(when the sponsor has preferences).Proof of insurance.An “escape clause” to ensure that thesponsor reserves the right to reject allbids or to modify the plan.costs.

The RFP can be advertised in the localpress (this might be required by localordinance) and in waste management tradejournals. It also can be sent to the contrac-tors on “bid lists” (lists of qualified

32

I


contractors are available from state, local,and EPA regional offices).

Select the ContractorThe program sponsor should base the se-

lection of the contractor on the following in-formation requested in the RFP and suppliedin the proposal:■ Contractor’s license. The contractor

must be licensed to handle hazardouswaste in the state where the HHW col-lection will be held.

■ Contractor’s HHW experience andreferences. The proposal should includea narrative section describing the

contractor’s qualifications and experi-ence. It also should include a list of ref-erences from any previous HHWcollection programs handled by the con-tractor. (The sponsor should carefullycheck these references.)

Equipment

The equipment needed at the

collection day is supplied by either the

contractor or the collection program

sponsor. It usually includes:

Waste management/disposalequipment: Awning or tent (ifneeded for shelter), drums,

absorbent for spills, shipping

manifests, labels, testing equipment,

and a dumpster.

Safety equipment: Plastic

ground covering, safety

coveralls/Tyvek suits, aprons,

goggles, splash shields, gloves,

respirators, traffic safety/refIector

vests, eye wash hoses, fire

extinguishers, first-aid kits, towels,

blankets, washtubs for scrubbing

contaminated clothing, and air

monitoring instruments

(recommended for monitoring

explosive vapor and organic vapor

levels).

Traffic control equipment:Traffic cones, barriers, and signs.

Furniture: Tables, benches,

stools, and chairs.

Other equipment: Portable

bathroom (if needed), portable

water (if needed), food, dollies,

dumpster for garbage, stapler, tape,markers, scissors, hammers,

clipboards, coolers with ice, coffee

maker, shovels, brooms, and

garbage bags.

33


■

■

■

■

■

■

■

Compliance record. (State and environ-mental regulatory agencies also can pro-vide the regulatory compliance/violationrecords of contractors.)Insurance/indemnification providedby the contractor. A list of insurancecarriers and policy numbers should beincluded.Waste management services offeredand the immediate and ultimate desti-nation of the collected waste. A con-tractor might own waste managementfacilities or might contract inde-pendently with incinerators, landfills,treatment facilities, and recycling firms.The sponsor should confirm the relation-ship of the contractor with any treat-ment and/or disposal facilities to beused. The sponsor also should receivecopies of manifests or other shippingdocuments confirming the receipt of thewastes at the facilities identified by thecontractor.Contractor costs. The proposal shouldinclude itemized costs for site set-up, la-bor, equipment materials, hazardouswaste training, transportation, anddisposal.Available collection dates. Fall andspring weekends are especially busy.The contractor should have enoughequipment and personnel to operate atthe times the sponsor selects.A list of wastes not accepted by thecontractor. If a community expectslarge quantities of unusual wastes, thismight be a consideration in choosing thecontractor.A list of wastes that will be consoli-dated and those that will be lab-packed in original containers.Consolidation of high-volume wastescan result in significantly reduced coststo the sponsor.A sample Contract The contractor usu-ally provides a sample contract with the

proposal. (If the RFP contains a modelcontract, the contractor can accept it ormodify it as necessary.)How recyclable materials, such asused oil, batteries, paint and anti-freeze, will be managed. This shouldspecify any offsite recycling facilitiesthat will process these materials.The number and level of training ofpersonnel proposed for the collection.Highly trained personnel are more ex-pensive and are not always needed. (Forexample, they might not be necessary ata recyclables-only event or a paint drop-and-swap.)A health and safety plan. The proposalshould include a safety, accident preven-tion, and contingency plan. (The spon-sor also might need to be involved inensuring the availability and coordina-tion of emergency services.)Cost per drum, per product, or perunit of waste. It also must be clear howmuch waste will be placed in each drumor container.

Write the ContractOnce a contractor is selected, the sponsor

and contractor sign a formal contract agree-ing to the services the contractor will pro-vide and the compensation the contractorwill receive. The contract usually is basedon the contract in the original RFP or theone supplied in the proposal. It usually is alengthy document, containing addenda withcopies of insurance policies and rate and per-sonnel schedules. It should include the fol-lowing clauses:■ The names and addresses of all the par-

ties to the contract. The specific role and status of each

party, and the terms and conditions un-der which each operates.

A full description of the services to be

performed.

34


The time, place, and duration of the ■

work.The fee schedules for all thework to be ■done.Submission of proof (manifests) of de-livery of all wastes prior to payment tothe contractor.The default guarantees and assurance

Any insurance and liability guaranteesand requirements.The procedure for amending provisionsof the contract.The contractor’s guarantee of compli-ance with any applicable laws.

and bond provisions for the qualityand completeness of the work to beperformed.

35


■ The data the contractor will provide toassist in evaluating the program.

■ A “savings” clause that protects the re-mainder of the contract should any partof it be deemed illegal or inappropriate.

As with the RFP, the more specific, com-plete, and clear a contract is, the less the con-tractor will have to assume and the moresatisfactory the results will be. State hazard-ous waste contacts (see Appendix B) usually

have current model contracts that cover allfederal and state requirements. The indemni-fication and insurance clauses usually causethe most difficulty. The contract should indi-cate clearly which liabilities and hazards arecovered and to whom the indemnificationand insurance clauses apply (e.g., contrac-tors, haulers, municipality and individualdepartments, or volunteers). The sponsor’slegal advisors should review the contractbefore it is signed.

36

Selecting, Designing,and Operating the

Collection Site

37

S I T E C O N S I D E R A T I O N S

P roper site selection, design, and operation are crucial in promoting maximum participa-tion in the HHW collection and subsequent collections. An easily accessible, effi-ciently run site will help ensure positive experiences on collection day, which can

result in favorable publicity for the next event.

Site Selection

The site chosen for the collectionshould be well known, centrally located,and easily accessible. It also should bewell removed from residences, parkswhere children play, and environmentallysensitive areas, such as open bodies ofwater, wells, faults, and wetlands. Localzoning regulations might specify requiredsetbacks and buffer zones and might iden-tify acceptable or restricted areas. Usingsites with an impermeable surface (e.g.,pavement or concrete) helps to minimize

environmental risks. Onsite utilities shouldinclude running water, fire hydrants, andelectric hookups (or generators) in caselights are needed to pack and label theHHW after dark.

Collection sites typically are located onpublicly owned land, such as stadium park-ing lots, solid waste landfills or transfer sta-tions, schools, fire stations, and publicworks yards. A wastewater treatment plantis a good collection site because it alsooffers the opportunity to educate the publicabout water pollution problems caused byimproperly managed HHW.

Simple site plan for a one-day drop-off HHW collection program.

38

Shower Rest Rooms Safety Gear Check-Out Fork LiftBreak Area Kitchen

Dumpster

Waste Management Company's Semi Truck

Decontamination Area Safety Station

Recycling Area

Flammables Explosive Poisons Aerosols Corrosives

Unloading Zone for Paint

Paint Receiving

Fire Truck or Aid Van

"ESCAPE ROUTE

EXIT

ENTRANCE CHECK IDENTIFICATION TRAFFIC FLOW & TRAFFIC HOLDING LINE

Legend (not to scale): DRUM TABLE PALLET


The simple plan shown in Figure 1 mightnot be adequate for all programs, however.Depending on the design and goals of theprogram, a more complex layout might berequired, such as the layout shown in Figure2. Described below is a commonly used sys-tem for designing the site layout. There aremany other ways an effficient collection can

Site Design andOperation

A well-designed and well-operated HHWcollection site allows participants to movethrough the collection area quickly and effi-ciently. It includes areas for people who re-quire special attention, and adequate spacefor waiting lines. It also has staff on hand todirect traffic, offer informational materials,and answer questions.

The size of the site is critical to the effi-ciency of the program; sponsors should planfor traffic overflow. The site should beatleast 10,000 square feet.

Figure 1 shows one example of a site planfor a one-day drop-off collection program.

be achieved.

Entrance

Collection staff or volunteers shouldstand at the entrance or check-in station togreet the participants and direct them to thereceiving area. Police officers or volunteerpersonnel should be stationed just outside

Drum storage

I

Unloading Zone forNon-Hazardous

Wastes Unloadfor Paint

‘for Ineligible Vehicles Unloading Zone

I

Pallet

More complex site plan for a one-day drop-off HHW collection program.

39


the entrance to manage traffic flow that can-not be contained on the site.

Several unloading lanes with signs andtraffic cones can help control the flow oftraffic on and off the site. Separate expresslanes for the wastes received in the highestvolume (usually paint and used oil) can helpspeed up service to participants.

Before participants drop off their HHW,they can be asked to document their eligibil-ity to participate in the collection (resi-dency), complete questionnaires, and list thewastes they have brought to the site. (A sam-ple questionnaire is provided in AppendixD.) The staff can offer informational materi-als, answer questions, and provide informa-tion about what to do with excluded wastes.To minimize traffic delays, these tasks canbe completed while participants wait to en-ter the receiving area.

Receiving AreaAt the receiving areas, trained personnel

(usually the contractor’s staff) screen eachvehicle for unknown, unacceptable, recycla-ble, or nonhazardous waste. Participantsshould not be permitted to remove anywastes from their own cars and should be en-couraged to remain in their cars. The staffmembers unload recyclable materials andtake them to the recycling area. The recy-clable should be handled and packaged ac-cording to any instructions from therecycling firm. They then take the rest of theacceptable wastes to a sorting table. After re-moving the HHW from the vehicle, the staffmembers direct the participant to the exit.

Sorting AreaIn the sorting area, staff members or con-

tractor personnel sort the wastes into hazardcategories and deliver them to the packingarea. They place empty containers and non-hazardous waste in dumpsters located in the

sorting area. Arrangements can be made forremoving and replacing the dumpsters dur-ing the day if necessary. A volunteer can flat-ten boxes for recycling or to reduce theamount of room the boxes take up in thedumpster. Any unknown material needs tobe sorted as a hazardous material.

Packing AreaIn the packing area, trained personnel

(usually contractor staff.) lab-pack thewastes or bulk them into drums. Theythen label all containers by hazard classand load them onto the appropriate truck(s).Consolidation of wastes (e.g., paint, motoroil, or antifreeze) can be performed in thisarea.

Temporary StorageArea

Empty drums are kept in the temporarystorage area. Fully packed and sealed drumscan be placed in the storage area until theyare loaded onto a truck. To ensure that thisarea stays dry and uncontaminated, it shouldbe covered, at least by an awning, and thefloor should be covered with chemically re-sistant plastic.

Break AreaStaff and volunteers should have a break

area, separate from the waste-receiving area,where they can eat, drink, rest, and use abathroom.

Parking AreaA special parking area is recommended to

accommodate people who need extra atten-tion, such as those who bring in unidentifiedwastes or have spilled a container in their ve-hicle. Parking spaces also can be designatedfor volunteer and staff vehicles.

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Training theCollection Day Staff

T R A I N I N G T H E S T A F F

roper training of all personnel is essential to a safe and efficient collection. Trainingrequired for the contractor’s staff, volunteers, and the sponsor’s in-house staff is

described below.

The Contractor’sStaff

The contractor is responsible for ensuringthat all of its technical and professional staffare properly trained and certified. The con-tract should specify the qualifications of theprofessional personnel who will be presentat the collection.

If your state requires an operating permitfor HHW collection, staff training mightneed to meet the requirements of the Occu-pational Safety and Health Act, Section1910.120. Check with your state agency todetermine training requirements. These regu-lations specify the content and length oftraining required for personnel at hazardouswaste operations. The level of training re-quired for each employee depends on his orher job functions and responsibilities. Topicsthat must be covered include the names ofpersonnel responsible for site safety andhealth, the hazards present at the site, theuse of personal protective equipment, workpractices that can minimize risks, the safeuse of engineering controls and equipmenton the site, and medical surveillance require-ments. In any case, this training is recom-mended for all personnel who will behandling the waste, even if it is not required.

The contractor’s staff can include techni-cians, chemists, and a manager. Themanager should receive training appropriatefor his or her involvement in the physicaloperation of the program. Chemists shouldhave 40 hours of field chemist/techniciantraining to the Occupational Safety andHealth Administration’s (OSHA’S) “SiteEmergency Responder” level. Techniciansshould have eight hours of training to the“First Responder Operations” level, sincethey would have to evacuate everyone from

the site in the event of an emergency. Thecontractor’s staff also must be briefed onany limitations of the permit or the facility,including excluded materials and proceduresto be followed.

Reviews and drills of the emergency planshould be conducted for all collection daypersonnel by qualified instructors. For regu-larly scheduled collections, the training pro-gram should provide for update sessions toreinforce safety procedures and provide up-dated packing information.

42


Volunteers andIn-House Staff

The volunteers and in-house staff whowill work at the collection site must also re-ceive proper training. Because of accidentand liability concerns, the responsibilities ofthe volunteers at a one-day collection areusually limited to controlling traffic, con-

ducting participant surveys, and providinggeneral assistance, such as running errands,emptying trash, and providing refreshments.

The sponsor’s in-house staff can performother collection day tasks, such as unloadingcars, pouring used oil into consolidationdrums, or opening and scraping out paintcans, depending on the volunteers’ trainingand qualifications. All these tasks must

43

n


be performed under the contractor’ssupervision.

In some cases, the state or municipalitywill provide professional staff to carry outsome of the more technical work. The statehazardous waste contact (Appendix B) canprovide information about appropriatetraining for these personnel (such as OSHA’s40-hour, 20-hour, and 8-hour courses).

The sponsor’s project coordinator and thecontractor should explain to volunteers andin-house staff what they may and may notdo on collection day; the procedures for re-

ceiving participants, controlling traffic, andhandling waste; and what their roles wouldbe in the event of an accident or spill.

Before the collection date, the sponsorshould hold an orientation session with thecontractor for all volunteers and in-housestaff who will be working at the collectionsite. This session should inform the volun-teers about the operating procedures andemergency plan. Police and other emer-gency personnel who will be on site or oncall should participate in the planning andorientation.

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E D U C A T I O N A N D P U B L I C I T Y

A HHW collection program cannot succeed without a strong public education effortthat provides general information about HHW and specific instructions about howto participate on collection day. This education also might benefit the community by

reducing the quantity of HHW collected in subsequent programs. It is still too early to know,however, just how effective educational efforts will be in reducing the generation of HHW. Atcurrent collection program participation rates, it will be some time before the stored waste iscleaned out of a community. It is likely, though, that the amount of waste per participant willdecrease in communities with regular or permanent collection programs. Many examples ofwell-planned education programs are available. Sources for these materials are listed inAppendix C.

Target the AudienceResidents are the most important target of

a HHW education program. Informationabout HHW also should reach public offi-cials, civic groups, solid waste personnel,and the business community to encourage fi-nancial support, donations of in-kind serv-ices, or other assistance. The media is anespecially important vehicle; media under-standing of HHW issues helps ensure accu-rate and responsible reporting. Educatorsneed resources to develop and communicatea strong understanding of the issue to thepeople they teach. Manufacturers, retailstores, school chemistry departments, hospi-tals, agricultural extension services, andfarmers also can benefit from educationabout HHW.

Determine theMessage and SelectEducational Methods

Public education about HHW is a goodidea even if a HHW collection event is notyet planned. The scope of this effort willdepend on the finds and personnel avail-able. Early education can focus on:

■ What products contain hazardous con-stituents.

■ How household generation of hazardouswaste can contribute to pollution.

Why source reduction is a major goal ofa HHW management program. (Source

reduction is defined as the design, manu-facture, purchase, or use of materials orproducts to reduce their amount or toxic-ity before they enter the solid wastestream.)What products contain fewer or no haz-ardous constituents.How to shop “smart” (e.g., buying onlywhat is needed).How to reduce the amount of HHW gen-erated (e.g., using up household prod-ucts or giving away what cannot beused).How to use products in a way that mini-mizes harm to the environment.How to properly store and handle prod-ucts containing hazardous constituentsin the home.

Public education before a planned collec-tion day should not only focus on identify-ing HHW and helping people understand thehazards associated with HHW, but alsoshould present the sponsor’s plans for ad-dressing HHW management. Public educa-tion efforts also should communicate theindividual’s role in the HHW managementprogram, including what to bring to a collec-tion and how to transport it safely. Thisphase of the education program should be-gin at least six months before the collectionday. Intensified education in the final twoweeks before a collection day can have amajor impact on participation rates.

Publicity, a component of public educa-tion, focuses on a single goal-bringing the

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Public Education Methods and Techniques

Education through the media. Well-prepared mediahandouts-feature articles, public service announcements, andother materials for the press—m inexpensive options andrequire less staff time than many other educational methods.Information about HHW can be presented in a variety ofways. For example, a radio broadcast might feature ahazardous waste expert who can answer phone-in questionson HHW. A local television station can cover a tour througha home with an environmental expert, who can discuss theproducts that can become HHW and how to manage themsafely.

Information and referral services. A publiclyadvertised local telephone hotline can encourage people tocall for information about managing HHW, and also canfacilitate a waste exchange/referral service. These servicescan be effective but require telephones, office space, training,and personnel.

Mailings and mailing inserts. Utilities, banks, billers,and advertisers may be willing to include HHWannouncements and informational literature in their regularmailings. Inserts mailed with water bills, garbage bills, or taxbills not only provide information about HHW, but also caneducate the public about the links between HHW generation,waste management ground-water protection, andwater/garbage rates. Community groups can includeeducational information about HHW management in theirmailings or newsletters. HHW program sponsors can senddirect mailings to people who participated in previous HHWcollections.

Posters, handouts, and brochures. Flyers andposters often are displayed or handed out at schools,libraries, community centers, and senior citizen centers.Businesses can post signs and notices for shoppers andcustomers on how to safely manage household products thatmight become HHW. Real estate agents can offer their clientsinformation about HHW with their other communityresource materials. Solid waste facility personnel at drop-offlandfills, transfer stations, and recycling centers can discussHHW and provide written information when residents dropoff waste or recyclable. Handouts can include HHW“wheels” that highlight the potential hazards of householdproducts and suggest less hazardous substitutes (seeAppendix c).

Garbage can labeling. Some communities distributeplastic adhesive labels that residents can put on their trashcans. The labels alert people to the potential hazards ofmixing HHW with their trash, list products containinghazadous constituents, and advertise whereto dispose ofHHW properly.

Street banners. Banners announcing the place and timeof collection have worked well for some communities.

Displays/exhibits/audiovisual presentations. Publiceducation staff can use slide shows, video presentations, andhands-on exhibits at community group meetings, county fairsor other special events, public information sessions/workshops, shopping malls, and other public forums. Forexample, the League of Women Voters of Martha’s Vineyard,Massachusetts, bought a video on managing HHW andoffered it free to any group on the island who would show itat a meeting. (Slide shows available for rental or purchase arelisted in Appendix C.) The local public library also might bewilling to set up a HHW resource center.

Speaker bureau. Municipal departments usually haveaccess to knowledgeable speakers who can makepresentations to local groups at a nominal fee or free ofcharge. Sources for community education experts includecooperative extension services, soil and water conservationdistricts, and health and solid/hazardous waste administrators.

Formal education. Presentations in schools and specialcurricula can educate students (and their parents) aboutmanaging HHW. A number of organizations have developedschool curricula on HHW (see Appendix C).

Point-of-purchase information. Information aboutthe potential hazards of household products can bedistributed where the products are sold. For example,hardware stores can distribute handout on what to do withused motor oil, paints or varnishes. An Iowa law requiresstores that sell products covered under the shelf labeling lawto provide HHW content and hazard information throughshelf labeling and informational materials. A hardware storechain in San Diego, California voluntarily initiated a similarprogram.

Workshops and conferences. Workshops,presentations, and conferences on managing HHW can beanexcellent way to bring information to citizens, HHW programvolunteers, local business groups, and community officials.

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desired number of participants (and HHW)safely to a collection program. Good public-ity explains:

Why people should participate in HHWcollection programs.When and where the collection will beheld.Which materials will be accepted andwhich will be excluded.What to do with excluded HHW.How to transport HHW to the collectioncenter.

To maximize participation in the collec-tion program, publicity should begin assoon as a date for the collection is chosen.The publicity should appear on a regular ba-sis, highlighting progress in the planning,presenting additional facts about HHW, andproviding contacts for more information.

Advertising in local newspapers andnewsletters is a highly effective form ofpublicity. The local press usually will pub-lish articles, photographs, and letters to theeditor. The planning committee should pre-pare a press kit to facilitate newspaper pub-licity. It should contain: A list of local contacts and experts who

can answer questions about HHW.■ Press releases about the HHW manage-

ment program and the upcoming HHWcollection(s).

■ Two or three short feature articles.■ Black and white photographs (with cap-

tions) of hazardous materials (in thehome, on store shelves, at collection

programs) that can either stand alone orbe used with news or feature articles.

■ Press-ready ads publicizing the collec-tion day. Newspapers and radio and TVstations might run these ads free ofcharge on a space-available basis, or lo-cal firms might sponsor them.

Local groups, such as civic groups, pub-lic agencies, schools, local media, and busi-nesses, often are willing to help withpublicity and outreach. A local advertisingagency or public relations firm might agreeto plan or produce the publicity campaign.Invite the firm to participate on the planningcommittee.

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Evaluating theProgram

E V A L U A T I N G T H E P R O G R A M

E valuation is important to the continued success of any HHW collection program,whether it is a one-time event or an on-going, regularly scheduled program. The spon-sor should compile data from the program, including the number of participants, the

percentage of the target population served, the quantities of the different wastes collected, thequantities and percentages of recycled waste, the itemized total costs, the cost per participant,and the waste management cost per pound. This information can help the sponsor determinewhether program goals have been met. The sponsor’s contract with the hazardous wastecompany should specify what data the sponsor needs from the contractor for post-collectionevaluation.

In addition, sponsors can ask contractorsand participants for input on flaws in theProgram, such as inconvenient operatinghours and locations or inefficient collectionmethods. This information allows programsto adapt to meet the needs of the public.

Public satisfaction with the HHW man-agement program can be measured throughquestionaires published in newspapers orfilled out when participants arrive at the col-lection site (see Appendix D for a sample on-site questionnaire), and by requests forfeedback when people call a HHW hotline.In addition, garbage sorts and wastewater

studies can detect whether less HHW is pre-sent in the municipal solid waste and waste-water streams after HHW collections, ifpre-collection data also are available. Thismight indicate changes in disposal practices.

Finally, followup is important after aHHW collection event, especially for spon-sors who hope to maintain and institutional-ize the program. Local media should beprovided with followup stones of the event,such as a report about the amount of HHWcollected. A summary report should beprepared to document the results of theprogram.

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Raleigh

C A S E S T U D I E S

Raleigh, North Carolina

n October 1989, the Raleigh, North Carolina Public Utilities Department (the city’s waterand sewer utility) sponsored a pilot HHW program at the Department’s Operations Center.The program had two objectives: to educate the citizens of Raleigh about HHW and

proper HHW management methods; and to collect HHW from Raleigh residents and recyclesome of the collected wastes.

The program met both of these goals,demonstrating that a water utility can effec-tively design and implement a HHW collec-tion. The first collection day in 1989 drewan extraordinary number of participants fora first-time drop-off HH W collection-a to-tal of 1,149, or 1.4 percent of the targeted80,000 households.

Planning theCollection

The collection was planned by a HHWsteering committee that included repre-sentatives from the public utilities depart-ment the Governor’s Waste ManagementBoard; the North Carolina Hazardous WasteBranch; the Institute for EnvironmentalStudies at Chapel Hill; the City of Raleigh’sEnvironmental Quality Advisory Board; thecity’s public works, fire, transportation,police, and safety departments; and others.The committee began planning for thecollection day a full year before the eventwas held.

Publicity

Advertising for the October collectionstarted at the beginning of January. A varietyof publicity and public education methodswere used:

■

■

9

■

■

■

More than 40 press releases were pre-pared for newspapers, TV, and radio.Five hundred letters were mailed tocivic organizations.Presentations with videotapes were de-livered at civic group meetings.Bright yellow inserts were placed inevery Raleigh water bill approximatelysix weeks before the collection.A member of the EnvironmentalQuality Advisory Board sponsored anentire afternoon on a classical musicradio station that included repeatedannouncements about the HHWcollection.Raleigh’s cable television station airedan informational program on HHWseveral times.

52

Graduate students from a local universitysurveyed the collection participants to findout how they heard about the collection. Theresults are shown below. (Note: The totalpercentage exceeds 100 because some peo-ple heard about the collection program frommore than one source.)

Newspaper

Water bill inserts 34%

Radio 16%

Television 14%

Other forms of advertising 8%

Civic groups 3%

Among the factors credited for the re-markable turnout at the collection was thesteering committee’s ability to personalizethe issue when presenting it to the commu-nity. The program manager focused her ad-vertising efforts to ensure that peopleunderstood that HHW management is an en-vironmental issue that literally “hits home.”

The highlight of this personalized effortwas a press conference held in a home-owner’s basement. This enabled the press toactually see what HHW is, to recognize thatit is something most people have in theirown homes, and to take advantage of aphoto opportunity. Several major newspa-pers ran feature articles about HHW follow-ing this press conference. Television stationsalso included the press conference in theirnews reports.

Types of HHWCollected andWaste ManagementMethods Used

The hazardous waste contractor for thecollection sent 355 drums of collected HHWfor hazardous waste treatment and/ordisposal. Three types of materials brought

53


to the HHW collection were identified forrecycling: good-quality latex paint, usedoil, and automobile batteries. More than100 gallons of latex paint were donated tothe Raleigh Housing Authority for use inits projects. An oil service company inRaleigh accepted 2,800 gallons of motoroil for processing as industrial-grade fueloil. A battery firm in Wilson, NorthCarolina, took 105 automotive batteriesfor recycling. Wastes not accepted at thecollection included radioactive, biologi-cal wastes, explosives, ammunition, andnonhazardous waste.

Funding and CostsExcept for a one-time $10,000 matching

grant from the state, Raleigh’s program wasfunded entirely from the city’s Departmentof Public Utilities budget. HHW collection(waste management and public educa-tion/publicity) was performed under con-tract; these direct costs totaled $141,147.Indirect costs-the cost of providing citystaff on site (police and fire) and the hoursspent by the HHW steering committee toplan the program-totaled an additional$26,017. City employees bulked used motoroil, directed traffic, and were available foremergency response.

Expanding theProgram

On April 7,1990, Raleigh and WakeCounty held a collection open to the entirecounty. This collection drew 1,778 partici-pants. The cost of the event was $175,210.It was funded by a separate line item on thecity water and sewer bill (40¢/month), andthe county share was funded through thelandfill tipping fee.

An ad hoc group of Raleigh publicworks, utility, and transportation employeesmanaged the program. The group wasresponsible for expanding the program to


the full county and for developing a HHWcurriculum for local schools. The group alsois planning future collections.

The most effective publicity techniquesfor the April 1990 collection were flyerssent with water bills one month before theevent and a series of press releases in the fi-nal week before the collection. The base-ment press conference was not repeated.

Organizers of the April 1990 event set agoal of increased recycling. A local paintcompany consolidated and blended 2,500gallons of latex paint, charging only for thefive-gallon plastic buckets used ($2 apiece).The City Housing Authority will save an es-timated $9,500 by using this paint. In addi-tion, the Parks and Recreation Departmentreceived 12 drums of pesticides from thecollection.

The collection organizers made severalother improvements over the 1989 event.The two most frequent suggestions fromparticipants at the first collection were toreduce waiting time and to ban smoking.In response to these suggestions, organiz-ers staffed two sites with 100 contractorand local personnel, reducing the waitingtime at the second event to a maximum of15 minutes. In addition, the sites now havepermanent signs that ban smoking. In1990, Habitat for Humanity bulked thegood-quality latex paint at the collectionsite and then used it to paint low-incomehousing. The hazardous waste contractoranalyzed the bulked latex paint for heavymetals. None of the bulk paint wasrejected.

Source: Cindy Kling, City of Raleigh, PublicUtilities Department.

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New York

Monroe County, New York

M onroe County in upstate New York held its first HHW collection on October 21,1989, in the City of Rochester. The collection was attended by 1,400 of the 250,000households in the county (0.56 percent participation rate) even though the day was

overcast and cold. The site was open from 9 a.m. to 2 p.m. Lines formed as early as 8:20 a.m.Program organizers believe that hundreds of additional households did not participate becauseof the long wait or because many were turned away at 2 p.m.

Planning theCollection

Initial planning meetings began 18months before the collection. A 12-personvolunteer subcommittee of the county’s En-vironmental Management Council (EMC)conducted background research, and theCounty unanimously accepted the EMC’srecommendations in January 1990.

Monroe County established a committeeof county professionals from the depart-ments of solid waste, planning, health, andfirm, as well as legislative and legal repre-sentatives, to plan and implement the collec-tion event. The EMC coordinator was theproject manager for the event. The CountyDivision of Solid Waste carried out the de-tails of site planning and provided the sitecoordinator. Chemists from the CountyHealth Department sampled and handled the

55

used oil and automotive batteries. The haz-ardous materials team was on site all dayand the bomb squad was on call. Countyand municipal police and hospitals were no-tified about the day’s event.

Publicity

The Monroe County EMC HouseholdHazardous Waste Committee was responsi-ble for education for the event. The planningcommittee arranged for publicity before thecollection day through newspapers, TV, ra-dio, flyers, and slide shows. Eastman Ko-dak, a local employer, also publicized theevent in its in-house newsletter and encour-aged all employees to participate. Kodakalso purchased fill-page newspaper adsabout the company’s recycling efforts and in-cluded a quarter of a page in the ads aboutthe HHW collection.


Types of HHWCollected andWaste ManagementMethods Used

The program collected 3,000 gallons ofused oil, 13,375 pounds of automotive bat-teries, and 80,000 pounds of other types ofHHW. Used oil was reprocessed into fuel oilby a local firm, and automobile batterieswere sold to a local broker for recycling.Wastes excluded from the collection in-cluded unlabeled waste, latex paint, radioac-tive and biohazardous waste, explosives,shock-sensitive wastes, and propane tanks.

Funding and CostsTo pay for the collection program, Mon-

roe County spent $62,000, the City of Roch-ester contributed $5,000, and localbusinesses donated $57,000 (as well as in-kind contributions such as free publicity).Eastman Kodak saved the county an addi-tional $32,410 in waste management costsby accepting 384 thirty-gallon drums and135 five-gallon pails of paints and solvents.These wastes were burned at Kodak’s haz-ardous waste incinerator at no cost to the

county. Thus, the total cost of the program,including all monetary and in-kind contribu-tions, exceeded $150,000.

Program EvaluationThe county considered its frost-time

HHW collection a tremendous success.Recommendations for future one-day collec-tions include designating an individual to as-sist the media on site (no one was availablefor this on the collection day) and using vol-unteers in shifts so that they can take breaks.

The only significant problem at the eventwas that many potential participants had tobe turned away. Collection organizers do notbelieve that increased staffing would havesolved this problem—the contractor pro-vided 24 staff people and worked efficiently,processing four households per minute. In-stead, the county has decided to establish apermanent HHW collection program. Thecounty hired an engineering firm to design apermanent facility and selected a site for theprogram. The facility opened in the springof 1992.

Source: Alice Young, League of Women Vot-ers, Rochester Metro, Chair Monroe CountyEnvironmental Management Council,Household Hazardous Waste Committee.

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A. Hazardous Waste Laws andRegulations

B. State and RegionalHazardous Waste Contacts

C. Information Resources

D. Sample ParticipantQuestionnaire

57

Hazardous WasteLaws and

Regulations

FederalRequirements ForHHW ManagementPrograms

EPA has issued regulations governing haz-ardous waste under the Resource Conserva-tion and Recovery Act (RCRA) and theComprehensive Environmental Response,Compensation, and Liability Act (CERCLAor Superfund). This Appendix generallysummarizes the regulations that may be applicable to HHW collection programs man-aging various types of hazardous wastes. Itis important for organizers to consult appro-priate EPA regional and state personnel toget abetter understanding of how these regu-lations apply to HHW collection programs.

In addition, state laws maybe more strin-gent than the federal regulations describedbelow. Therefore, it also is important thatHHW collection organizers familiarize them-selves with and follow state hazardouswaste requirements. Consult your state solidand hazardous waste agency (see AppendixB) for further information.

The Resource Conservation andRecovery Act (RCRA)

RCRA is the federal law requiringsafeguards and encouraging environmen-tally sound methods for disposal ofhousehold, municipal, commercial, and

industrial waste. Hazardous waste is regu-lated under RCRA’s Subtitle C program.Subtitle C establishes a system for control-ling hazardous waste from “cradle tograve’’-from the moment it is generateduntil its ultimate disposal. These controlsinclude:

A tracking system that requires amanifest document to accompanytransported hazardous waste from thepoint of generation to the point of finaldisposal.An identification and permitting sys-tem that enables EPA and the states toensure the safe operation of all facilitiesinvolved in the treatment, storage, anddisposal of hazardous waste. Certaingenerators, transporters, and treatment,storage, and disposal facilities (TSDFs)must obtain an EPA identification num-ber. TSDFs also must obtain a permit tooperate, which ensures that they meetthe standards established under theRCRA program for proper wastemanagement.A system of restrictions and controlson the placement of hazardous waste onor into the land.

RCRA requirements for hazardouswaste management vary depending onwhether the waste is HHW, condition-ally exempt small quantity generator(CESQG) waste, or small quantitygenerator (SQG) waste. These require-ments are described below.

Household hazardous waste

Household waste, including HHW, isexempt from federal hazardous wasteregulations and liability under RCRASubtitle C. Therefore, HHW is not regu-lated under RCRA as a hazardous waste(see 40 CFR 261 .4(b)(l)). Programs thatcollect HHW do not need a Subtitle C

58

L A W S A N D R E G U L A T I O N S

permit or EPA identification number, andHHW can be transported without followinghazardous waste transportation regulations(e.g., people can bring HHW to a collectionfacility in their cars). No quantity of HHWor length of time of accumulation triggersthe Subtitle C requirements.

To be defined as “household” waste andthus be exempt from federal hazardouswaste regulations, the waste must be:

Generated by individuals on the prem-ises of a residence for individuals (ahousehold).

andComposed primarily of materials foundin the wastes generated by consumers intheir homes.

Even if waste generated by a commercialor industrial establishment looks like house-hold waste, it is not exempt from federalhazardous waste regulations.

The household waste exemption appliesto HHW through its entire management cy-cle. The waste collected through a HHW col-lection program does not lose its exemptionby being consolidated with other householdwaste. In summary, if a program acceptsonly waste from households, there are no ap-plicable federal hazardous waste regulations.

Conditionally exempt small quantitygenerator (CESQG) wasteSome communities decide to run pro-

grams that collect CESQG waste as well asHHW. Communities generally make this de-cision to help small businesses keep hazard-ous waste out of the municipal wastestream. Hazardous waste generators are con-ditionally exempt from the federal hazard-ous waste regulations if they generate lessthan 100 kilograms (approximately 220pounds or about half of a 55-gallon drum) ofhazardous waste per month. Like HHW,CESQG waste is exempt from most of the

federal hazardous waste requirements. NoSubtitle C permit or EPA identification num-ber is needed, and CESQG waste can betransported without following the federalhazardous waste transportation requirements.

In general, CESQGs must comply withtwo requirements. They do not store morethan 1,000 kilograms (about 2,200 pounds)of hazardous waste at their facility at onetime, and they send their hazardous waste toa recycling facility, a hazardous waste facil-ity, or a facility permitted, licensed, or regis-tered by the state to manage municipal orindustrial solid waste (usually, a municipallandfill). These CESQGs may send their haz-ardous waste to HHW collection programsthat are state-permitted, licensed, or regis-tered to manage municipal or industrialsolid waste. Because CESQG waste is condi-tionally exempt throughout its managementcycle, collection programs managingCESQG waste are not covered by the fed-eral hazardous waste regulations, but aresubject to requirements imposed by statesthrough their municipal or industrial wastepermit, license, or registration programs.

EPA encourages the collection and propermanagement of CESQG waste. Communitycollection programs can help meet this goalby accepting CESQG waste from schools,small businesses, farms, government agen-cies, and other commercial and institutionalhazardous waste generators.

CESQGs are responsible for ensuringthat their waste is managed in compliancewith federal requirements. They may ask thecollection program for documentation of reg-istration or licensing if required by the state.CESQGs can refer to EPA’s Understandingthe Small Quantity Generator HazardousWaste Rules: A Handbook for Small Busi-ness for more information about the require-ments that apply to them. Contact your

59


regional EPA office for this publication orfor more information.

EPA recommendations forprograms that collect HHW andCESQG wasteAlthough HHW and CESQG waste are

exempt from most federal hazardous wasteregulations, EPA recommends that sponsorsof HHW collection programs manage thecollected waste as a Subtitle C hazardouswaste-that is, it should be managed at a re-cycling or licensed hazardous waste facility.Given the effort and expense a communityhas already put into its HHW collection pro-gram, it makes sense to ensure the greaterlevel of environmental protection that willresult from the Subtitle C controls.

EPA also recommends that HHWcollection programs use licensed hazardouswaste transporters who will properly iden-tify, label, manifest, and transport the col-lected wastes for recycling, treatment, ordisposal. State hazardous waste agencies(see Appendix B) can provide a list of li-censed facilities and transporters.

Small quantity generator (SQG) wasteSQGs are those that generate more than

100 kilograms (220 pounds) and less than1,000 kilograms (2,200) pounds) of hazard-ous waste per month. SQGs must use speci-fied packaging for their waste; use a fullycompleted manifest form when shipping thewaste off site; use only hazardous wastetransporters; and send their waste to author-ized hazardous waste management facilitieswith EPA identification numbers to trans-port, treat, store, or dispose of their hazard-ous waste.

HHW collection programs may not ac-cept SQG wastes unless the program has aRCRA Subtitle C permit (or is a transporterwho stores manifested shipments of hazard-ous waste at a transfer facility for a period

of 10 days or less). Therefore, sponsorsshould be careful to limit participation intheir programs to households and CESQGsto avoid the need to obtain a RCRA permit.To ensure that a hazardous waste generatoris a CESQG and not a regulated SQG, pro-gram sponsors should establish proceduresto differentiate between the two types ofgenerators. Some programs exclude SQGwaste by requiring pre-registration byCESQGs. At the time of pre-registration,program personnel can inquire about thetypes and quantities of waste that the gener-ator wishes to bring to the collection.

The ComprehensiveEnvironmentalResponse, Compensation,And Liability Act(CERCLA/Superfund)

Congress passed CERCLA in 1980 to ad-dress the cleanup of inactive and abandonedhazardous waste sites. Under CERCLA, ifcleanup of a hazardous waste disposal site isnecessary, all sources of the waste, as wellas the owner or operator of the site, mightbe potentially responsible parties (PRPs),who are liable for the entire cleanup cost forthe site.

CERCLA does not exclude HHW from li-ability, nor does it allow any exemptionbased on the amount of waste generated. IfHHW contains a substance defined as haz-ardous under CERCLA, potential liabilityexists. The Agency, however, will generallynot notify generators or transporters of mu-nicipal solid waste—including HHW collec-tion programs—that they are consideredPRPs, unless EPA has information indicat-ing that the waste came from an industrial,institutional, or commercial process or activ-ity. This includes, but is not limited to, SQG

60


waste from commercial or industrial proc-esses or activities, and used or spent sol-vents from private or municipally ownedmaintenance shops. EPA makes decisionsabout notifying PRPs on a case-by-case ba-sis, and may, in exceptional situations, no-tify parties who generated or transportedonly household waste to a site. PRPs maysue other parties that they believe share li-ability. Citizen suits are unrestricted.

While CERCLA does not exempt HHWcollection programs from liability, it is im-portant to realize that the potential for liabil-ity might be greater if a community takes noaction to ensure proper disposal of HHW.The additional safeguards provided byHHW collection and Subtitle C managementcan reduce the likelihood of environmentaland human health impacts, and therebymight reduce potential CERCLA liability.

For more information about federallaws pertaining to HHW, you can call theRCRA/Superfund Hotline at 800-424-9346.In Washington, DC, please call 703-412-9810. The Hotline is open Monday throughFriday, 8:30 a.m. to 7:30 p.m. EST. Forthe hearing impaired, the TDD number is

800-553-7672. Alternatively, you can contactyour EPA regional office (see Appendix B).

State and LocalRequirements

Some states have regulations or guide-lines for HHW management programs orpermanent HHW management facilities thatare more stringent than the federal require-ments. These may include requirements fora permit, permit variances, or a plan for thecollection day.

Some states do not have an exemption forCESQGs; others might use a lower cut-offthan 100 kilograms per month or have differ-ent management requirements. States alsomight have CERCLA-type legislation allow-ing recovery of the costs of hazardous wastesite cleanup. Organizers of HHW manage-ment programs must check with their stateenvironmental officials (see Appendix B) tolearn about applicable regulations. In addi-tion, local zoning, building, and fire codesmight apply to HHW collections; the appro-priate local agencies must be contacted toensure compliance.

61

ArkansasHazardous Waste Division

State and RegionalArkansas Department of Pollution

Control and Ecology

Hazardous Waste P.O. BOX 8913

ContactsLittle Rock, AR 72219-8913501-562-7444

State Contacts

AlabamaLand DivisionAlabama Department of Environmental

Management1751 Cong. William L. Dickinson DriveMontgomery, AL 36130205-271-7730

AlaskaSolid and Hazardous Waste

Management SectionAlaska Department of Environmental

Conservation410 Willoughby Avenue, Suite 105Juneau, AK 99801-1795907-465-5150

American SamoaEnvironmental Quality CommissionGovernment of American SamoaPago Pago, American Samoa 96799Overseas Operator: 684-663-2304

ArizonaOffice of Waste ProgramsArizona Department of Environmental

Quality3033 N. Central AvenuePhoenix, AZ 85012602-207-4108

CaliforniaDepartment of Toxic Substances ControlHazardous Waste DivisionP.O. BOX 806400 P StreetSacramento, CA 95812-0806916-324-1826

ColoradoHazardous Materials and Waste

Management DivisionColorado Department of Health4210 E. 1 lth AvenueDenver, CO 80220303-331-4830

Commonwealth of Northern MarianaIslands

Division of Environmental QualityDepartment of Public Health and

Environmental ServicesCommonwealth of the Northern

Mariana IslandsSaipan, Mariana Islands 96950Overseas Operator: 670-234-6114Cable Address: Gov. NMI Saipan

ConnecticutBureau of Waste ManagementDepartment of Environmental ProtectionState Office Building165 Capitol AvenueHartford, CT 06106203-566-8476

62

H A Z A R

DelawareDivision of Air and Waste ManagementDepartment of Natural Resources and

Environmental ControlP.O. Box 140189 Kings HighwayDover, DE 19903302-739-4764

District of ColumbiaPesticides and Hazardous Materials

DivisionDepartment of Consumer and

Regulatory Affairs2100 Martin Luther King Avenue, SE.Suite 203Washington, DC 20020202-404-1167

FloridaDivision of Waste ManagementUSTDepartment of Environmental

RegulationsTwin Towers Office Building2600 Blair Stone RoadTallahassee, FL 32339-2400904-487-3299

GeorgiaLand Protection BranchFloyd Towers East/Room 1154205 Butler Street, SE.Atlanta, GA 30334404-656-2833

GuamHazardous Waste Management programGuam Environmental Protection AgencyIT& E Harmon Plaza130 Rojas Street, Unit D-1Harmon, Guam 96911Overseas Operator 671-646-8863

D O U S W A S T E C O N T A C T S

HawaiiSolid and Hazardous Waste BranchDepartment of Health5 Waterfront Plaza, Suite 250500 Ala Moana BoulevardP.O. BOX 3378Honolulu, HI 96813808-586-4226

IdahoHazardous Materials BureauWater Quality Bureau, Division of

Environmental Quality1410 North Hilton StreetBoise, ID 83706208-334-5860

IllinoisDivision of Land Pollution ControlIllinois Environmental Protection

Agency2200 Churchill RoadSpringfield, IL 62794-9276217-785-8604

IndianaHazardous Waste Management BranchIndiana Department of Environmental

Management105 S. Meridian StreetIndianapolis, IN 46206-6015317-232-3292

IowaAir Quality and Solid Waste SectionDepartment of Natural Resources900 East Grand AvenueDes Moines, IA 50319-0034515-281-8852

KansasAir and Waste ManagementDepartment of Health and EnvironmentForbes Field, Building 740Topeka, KS 66620913-296-1593

63

H A Z A R D O U S W A S T E C O N T A C T S

KentuckyDivision of Waste ManagementDepartment of Environmental Protection18 Reilly RoadFrankfort, KY 40601502-564-6716

LouisianaHazardous Waste DivisionLouisiana Department of Environmental

QualityP.O. BOX 821787290 Bluebonnet DriveBaton Rouge, LA 70884-2178504-765-0355

MaineBureau of Hazardous Materials Control

and Solid Waste ControlDepartment of Environmental ProtectionState House, Station #17Augusta, ME 04333207-289-2651

MarylandHazardous and Solid Waste

Management AdministrationMaryland Department of the

Environment2500 Browening HighwayBaltimore, MD 21224410-631-3304

MassachusettsDivison of Solid and Hazardous WasteMassachusetts Department of

Environmental ProtectionOne Winter Street, 7th FloorBoston, MA 02108617-292-5853

MichiganWaste Management DivisionDepartment of Natural Resources608 W. Allegan StreetBOX 3338Lansing, MI 48933517-373-2730

MinnesotaHazardous Waste DivisionMinnesota Pollution Control Agency520 Lafayette Road, NorthSt. Paul, MN 55155612-297-8502

MississippiDivision of Hazardous Waste

ManagementDepartment of Natural ResourcesP.O. BOX 10385Jackson, MS 39289-0385601-961-5171

MissouriWaste Management ProgramDepartment of Natural ResourcesJefferson Building205 Jefferson StreetP.O. BOX 176Jefferson City, MO 65102314-751-3176

MontanaSolid and Hazardous Waste BureauDepartment of Health and

Environmental SciencesCogswell BuildingHelena, MT 59620406-444-2821

NebraskaDepartment of Environmental ControlP.O. BOX 98922301 Centennial Mall S.Lincoln, NE 68509-8922402-471-4210

NevadaWaste Management programDivision of Environmental ProtectionDepartment of Conservation and

Natural ResourcesCapitol Complex123 West Nye LaneCarson City, NV 89710702-687-5872

64


New HampshireOffice of Waste ManagementDepartment of Environmental Services6 Hazen DriveConcord, NH 03301-6509603-271-2900

New JerseyDivision of Hazardous Waste

ManagementDepartment of Environmental Protection401 East State Street/CN 028Trenton, NJ 08625609-292-1250

New MexicoHazardous and Radioactive Waste

BureauEnvironmental Department525 Camino de los MarquezP.O. BOX 26110Santa Fe, NM 87502505-827-4308

New YorkDivision of Solid and Hazardous WasteDepartment of Environmental

Conservation50 Wolf RoadAlbany, NY 12233518-457-6603

North CarolinaSolid and Hazardous Waste

Management BranchDivision of Health ServicesDepartment of Human ResourcesP.O. BOX 27687Raleigh, NC 27611-7687919-733-2178

North DakotaDivision of Waste ManagementDepartment of Health Management and

Special Studies1200 Missouri Avenue, Room 302Bismarck, ND 58502-5520701-221-5166

OhioDivision of Solid and Hazardous Waste

ManagementOhio Environmental Protection AgencyP.O. Box 1049Columbus, OH 43266-0149614-644-2958

OklahomaHazardous Waste Management ServiceOklahoma State Department of Health1000 Northeast l0th StreetOklahoma City, OK 73117-1299405-271-7052

OregonHazardous and Solid Waste DivisionDepartment of Environmental Quality811 Southwest 6th Avenue, 8th FloorPortland, OR 97204-1390503-229-5913

PennsylvaniaDivision of Hazardous Waste

M a n a g e m e n t Pennsylvania Department of

Environmental ResourcesP.O. BOX 2063Fulton BuildingHarrisburg, PA 17105-2063717-787-9870

Puerto RicoEnvironmental Protection Agency1413 Fernadez JuncosSanturce, PR 00909809-729-6920

Rhode IslandAir and Hazardous Materials ProgramDepartment of Environmental

Management291 Promenade StreetProvidence, RI 02908401-277-2797

65


South CarolinaBureau of Solid and Hazardous Waste

ManagementDepartment of Health and

Environmental Control2600 Bull StreetColumbia, SC 29201803-734-5200

South DakotaOffice of Air Quality and Solid WasteDepartment of Water and Natural

Resources523 E. CapitolFoss Building, Room 416Pierre, SD 57501605-773-3153

TennesseeDivision of Solid Waste ManagementTennessee Department of Public Health701 BroadwayCustoms House, 4th FloorNashville, TN 37219-5403615-741-3424

Texas

Industrial and Hazardous Waste DivisionTexas Water CommissionP.O. BOX 13087Austin, TX 78711-3087512-908-2334

UtahBureau of Solid and Hazardous Waste

ManagementDepartment of Environmental Quality288 North 1460 WestSalt Lake City, UT 84114-4880801-538-6170

VermontHazardous Waste Management DivisionAgency of Environmental Conservation103 South Maine StreetWaterbury, VT 05761-0404802-244-8702

Virgin IslandsDepartment of Planning and Natural

ResourcesSuite 231, Nisky Center45-A Estate NiskySt. Thomas, VI 00802809-774-3320

VirginiaHazardous Waste DivisionVirginia Department of Waste

ManagementMonroe Building, llth Floor101 North 14th StreetRichmond, VA 23219804-225-4761

WashingtonSolid and Hazardous Waste

Management ProgramDepartment of EcologyP.O. BOX 47600Olympia, WA 98504-7600206-459-6316

West VirginiaWaste Management DivisionCommerce, Labor, and Environmental

Resources1356 Hansford StreetCharleston, WV 25301304-348-5929

WisconsinBureau of Solid and Hazardous Waste

ManagementDepartment of Natural ResourcesP.O. BOX 7921 /SW-3Madison, WI 53707-7921608-266-2111

WyomingSolid Waste Management ProgramState of Wyoming Department of

Environmental Quality122 West 25th StreetHerschler BuildingCheyenne, WY 82002307-777-7752

66


EPA Regional Contacts

EPA Region 1(Connecticut Maine, Massachusetts, New

Hampshire, Rhode Island, Vermont)Contact: -

Waste Managen

90 Canal Street

Boston, MA 02617-573-5707

EPA Region 2

ent Division

14

(New Jersey, New York, Puerto Rico,Virgin Islands)

Contact:Hazardous Waste Compliance Branch26 Federal Plaza, 10th FloorNew York, NY 10278212-264-2301

EPA Region 3(Delaware, District of Columbia,

Maryland, Pennsylvania, Virginia,West Virginia)

Contact:Waste Management Branch (3HW30)841 Chestnut StreetPhiladelphia, PA 19107215-597-6633

EPA Region 4(Alabama, Florida, Georgia, Kentucky,

Mississippi, North Carolina, SouthCarolina, Tennessee)

ContactResiduals Management Branch345 Courtland Street, NE.Atlanta, GA 30365404-347-7603

EPA Region 5(Illinois, Indiana, Michigan, Minnesota,

Ohio, Wisconsin)Contact:

RCRA Program Management Branch77 W. Jackson Boulevard HRE-8Chicago, IL 60604-3507312-886-4434

EPA Region 6(Arkansas, Louisiana, New Mexico,

Oklahoma Texas)Contact:

RCRA Programs Branch (6H-H)First Interstate Bank Tower1445 Ross Avenue, Suite 1200Dallas, TX 75202-2733214-655-6700

EPA Region 7(Iowa, Kansas, Missouri, Nebraska)

Contact:RCRA Branch726 Minnesota AvenueKansas City, KS 66101913-551-7051

EPA Region 8(Colorado, Montana, North Dakota,

South Dakota, Utah, Wyoming)Contact

Hazardous Waste Management DivisionOne Denver Place999 18th Street Suite 500Denver, CO 80202-2405303-293-1720

EPA Region 9(Arizona, California, Hawaii, Nevada,

Guam, Marianas)Contact

Office of Waste Programs (T-2A)75 Hawthorne StreetSan Francisco, CA 94105415-744-1500

EPA Region 10(Alaska, Idaho, Oregon, Washington)

Contact:Hazardous Waste Management1200 Sixth Avenue, 1 lth FloorSeattle, WA 98101206-553-4973

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InformationResources

OrganizationsAgency of Environmental Conservation

(paint swaps)103 S. Main Street, M BuildingWaterbury, VT 05671-0407802-244-7831

P.O. Box 7414Berkeley, CA 94707510-524-2567

California Integrated Waste ManagementBoard

8800 Cal Center DriveSacramento, CA 95826916-255-2200

Center for Safety in the Arts5 Beekman Street, Suite 1030New York, NY 10038212-227-6220

Concern, Inc.1794 Columbia Road, NW.Washington, DC 20009202-328-8160

Ecology Center of Ann Arbor201 Detroit StreetAnn Arbor, MI 48104313-761-3186

Environmental Health Coalition1717 Kettner Drive #100San Diego, CA 92101619-235-0281

Household Hazardous Waste Project1031 East Battlefield, Suite 214Springfield, MO 65807417-889-5000

Metrocenter YMCA909 Fourth AvenueSeattle, WA 98104206-382-5013

Minnesota Office of Consumer PolicyNCL Tower, Suite 1400445 Minnesota StreetSt. Paul, MN 55101-2131612-296-7575

Minnesota Pollution Control Agency520 Lafayette Road, NorthSt. Paul, MN 55155612-296-6300

National Coalition Against the Misuse ofPesticides

701 E Street, SE., Suite 200Washington, DC 20003202-543-5450

National Recycling Coalition1101 30th Street, NW.Suite 305Washington, DC 20007202-625-6406

Nuclear Regulatory Commission (smokedetectors)

Washington, DC 20555301-504-2240

Environmental Hazards ManagementInstitute (EHMI) (HHW wheels)

10 Newmarket Road, P.O. Box 932Durham, NH 03824603-868-1496

68

Office of Solid WasteU.S. EPA401 M Street, SW. (0S-305)Washington, DC 20460EPA RCRA/Superfund Hotline:800-424-9346

Project ROSE (used oil)University of AlabamaP.O. BOX 870203Tuscaloosa, AL 35487-0203205-348-4878

Solid and Hazardous Waste ManagementProgram

Washington Department of EcologyP.O. BOX 47655Olympia, WA 98504-7655206-459-6303

Solid Waste Information Clearinghouse(SWICH)

800-67-SWICH

Toxicant/HHW ProjectMETRO821 Second Avenue, Mail Stop 81Seattle, WA 98104206-684-1233

University of Wisconsin CooperativeExtension

Environmental Resources Center1450 Linden DriveMadison, WI 53706608-262-0020

Washington Toxics Coalition4516 University Way, NESeattle, WA 98105206-632-1545

Waste Watch Center16 Haverhill StreetAndover, MA 01810508-470-3044

I N F O R M A T I O N R E S O U R C E s

Books and Pamphlets

Alternatives (a series of fact sheets),Washington Toxics Coalition.(EPA/530-SW-88-014).

Bibliography on Household HazardousWastes, U.S. Environmental ProtectionAgency. Available through theRCRA/Superfund Hotline, 800-424-9346.

Chemicals in Household Products, BradleyC. Clark, Ingham County HealthDepartment, 5303 S. Cedar, P.O. Box30161, Lansing, MI 48909.

Decision Makers Guide to Solid WasteManagement (1990), U.S. EnvironmentalProtection Agency. Available through theRCRA/Superfund Hotline, 800-424-9346.(EPA/530-SW-89-072).

Disposal—Do It Right, Household ProductsDisposal Council, 1201 ConnecticutAvenue, NW., Suite 300, Washington, DC20036,202-659-5535.

The “Environmentally Friendly” ConsumerOffice of the Minnesota AttorneyGeneral, Consumer Services Division,1400 North Central Life Tower, St. Paul,MN 55101,612-296-3353.

Fire Protection Guide to HazardousMaterials (1990), National FireProtection Association, 1 BatterymarchPark, P.O. Box 9101, Quincy, MA02269-9101,800-344-3555.

Guide to Hazardous Products Around theHome (1989), Household HazardousWaste Project, Springfield, MO.

Hazardous Wastes from Homes, Enterprisefor Education, 1320 A Santa MonicaMall, Santa Monica CA 90401,213-394-9864.

Home Safe Home, Washington ToxicsCoalition.

Household Batteries in Minnesota, KarenArnold et al., Minnesota PollutionControl Agency.

69

I

I N F O R M A T I O N R E S O U R C E S

Household Hazardous Waste: Guidelinesfor Conducting Collection Events (1989),Washington Department of Ecology.

Household Hazardous Wrote: Solving theDisposal Dilemma, Gina Purin et al.,Local Government Commission, 90912th Street, Suite 205, Sacramento, CA95814,916-448-1198.

Household Hazardous Waste ManagementPlanning (1990), Donald Seeberger,Hennepin (MN) County Environment andEnergy Division/Urban ConsortiumNinth Year Energy program.

Household Hazardous Waste Wheel, EHMI,Durham, NH.

Household Hazardous Wastes: Feasibility ofOperating a Collection and DisposalAssistance Program, (1989), IllinoisEnvironmental Protection Agency(IEPA/ENV/99-066).

Household Hazards: A Guide toDetoxifying Your Home (1991), Leagueof Women Voters, 35 Maiden Lane,Albany, NY 12207-2712,518-465-4162.

Household Waste: Issues and Opportunities,(1989) Andy Knaus et al., Concern, Inc..

How to Organize a Community CollectionDay, Department of EnvironmentalProtection, Hartford, CT.

How to Set Up a Local Program to RecycleUsed Oil (1989), U.S. Environmentalprotection Agency(EPA/530-SW-89-039a).

The Merck Index: An Encyclopedia ofChemicals and Drugs, Merck andCompany, Rahway, NJ.

Proceedings of the Sixth NationalConference on Household HazardousWaste Management, Dana Duxbury &Associates, 1991. Summaries of the First(PB89-179-501), Second (PB89-179-519),and Third (PB89-179-527) NationalConferences also are available from theCenter for Environmental Management,

Tufts University. Proceedings from theFourth (PB90- 163-189) and Fifth(PB91-206-607) National Conferencesare available from the National TechnicalInformation Service, Springfield, VA800-553-6847 or Waste Watch Center508-470-3044.

Recycling Used Oil: What Can You Do?(EPA/530-SW-89-039B), Recycling UsedOil: 10 Steps to Change Your Oil(EPA1530-SW-89-039C), Recycling UsedOil: For Service Stations and OtherVehicle Service Facilities(EPA/530-SW-89-039d), U.S.Environmental Protection Agency. Thesepamphlets are available through theRCRA/Superfund Hotline,800-424-9346.

States’ Efforts to Promote Lead-Acid BatteryRecycling (PB92-119-965), U.S.Environmental Protection Agency.Available from the National TechnicalInformation Service, 800-553-6847.

A Survey of Household Hazardous Wastesand Related Collection Programs, U.S.Environmental Protection Agency.Available through the RCRA/SuperfundHotline, 800-424-9346(EPA/530-SW-86-038).

Take Me Shopping: A Consumer Guide toUsing Specific Materials, Techniques,and Substitutes for HHW Santa ClaraCounty Hazardous Waste ManagementProgram, 408-441-1195.

Used Oil Recycling (newsletter), U.S.Environmental Protection Agency.Available through the RCRA/SuperfundHotline, 800-424-9346.

PeriodicalsBioCycle419 State Avenue, Second FloorEmmaus, PA 18049215-967-4135

70


Garbage2 Maine StreetGloucester, MA 01930508-283-3200

Household Hazardous Waste ManagementNews

The Waste Watch Center16 Haverhill StreetAndover, MA 01810508-470-3044

Resource RecyclingP.O. Box 10540Portland, OR 97210800-227-1424

Wanner BulletinThe World Resource Foundation83 Mount EphraimTunbridge Wells, Kent UK TN4 8BS0892-24626

Waste Age1730 Rhode Island Avenue, NW.Suite 1000Washington, DC 20036202-861-0708

World WastesCommunications Channels, Inc.6255 Barfield RoadAtlanta, GA 30328404-256-9800

Audiovisual Materials

Videotapes and other audiovisual materialsare available from:

Ecology Center of Ann Arbor417 Detroit StreetAnn Arbor, MI 48104313-761-3186

Environmental Health Coalition1717 Kettner Blvd. #100San Diego, CA 92101619-235-0281

HHW ProjectWashington Department of EcologyP.O. BOX 47655Olympia, WA 98504-7655206-459-6303

Massachusetts League of Women Voters133 Portland StreetBoston, MA 02114617-523-2999

Prevention ProgramContra Costa County Health Services75 Santa Barbara RoadPleasant Hill, CA 94523510-646-6511

Refuse Industry Products, Inc.P.O. Box 1011Grass Valley, CA 95945916-274-3092

San Bernardino County DHSHazMat Risk Assessment & Planning385 N. Arrowhead Ave.San Bernardino, CA 92415-0160714-387-4629

The Video ProjectLMV of California926 J Street, Suite 1000Sacramento, CA 95814916-442-7215

HHW Curricula forSchools

(compiled from information provided bythe Household Hazardous Waste Project,Springfield, MO)

Activities for Teaching about HazardousMaterials in the Home (1989). Grades:K-3, 4-6,7-9, 10-12. ERIC Science,Mathematics, and EnvironmentalEducation Clearinghouse, The Ohio StateUniversity, 1200 Chambers Road, 3rdFloor, Columbus, OH 43212,614-292-6717.

71


Bags, Beakers, and Barrels: An ActionCurriculum Toward Resolving HazardousMaterials Issues (1987). Six units and 35activities. Grades: Middle and HighSchool. Industrial States Policy Center,17 Brickel Street, Columbus, OH 43215,614-224-4111.

CHEM: Chemicals, Health, Environment,and Me (1990). Ten teaching units.Grades: Middle or High School.Chemical Education for PublicUnderstanding Program (CEPUP),Lawrence Hall of Science, University ofCalifornia, Berkeley, CA 94720,510-642-8718.

Garbage in America (1988). Recycling andenvironmental curriculum, includingvideo. Grades: K-6, Junior High, SeniorHigh. Refuse Industry Productions, P.O.Box 1011, Grass Valley, CA 95945,916-274-3092.

Hazardous Waste Education Kit. Kit with 5workbooks and a resource section.Grades: 7-9. Federation of OntarioNaturalists, 355 Lesmill Road, Don MillsON, M3B 2W8 CANADA,416-444-8419.

Hazardous Wrote School Curriculums.Grades: K-12. State of Alaska,Department of EnvironmentalConservation, PO. Box O, Juneau, AK99811-1800,907-465-2671.

Healthy Environment-Healthy Me (1990).Interdisciplinary with videos. Grades:K-5. Resource Center for EOHSI,Brookwood II, 45 Knightsbridge Road,Piscataway, NJ 08854,908-463-5353.

Household Hazardous Materials andLabels: A Reference for Teachers (1986).Book and worksheets. Grades: MiddleSchool. East Michigan EnvironmentalAction Council, 21220 WestFourteen-mile Road, Birmingham, MI48010,313-258-5188.

Household Hazardous Materials: PollutionSolutions Start at Home ( 1989). Three5-day units. Grades: Middle School.Environmental Health Coalition, 1717Kettner Blvd. #100, San Diego, CA92101,619-235-0281.

Household Hazardous Waste EducationalProgram Kit (1986). Handbook andinstructional materials. Grades: K-6. SanBernardino County, Department ofEnvironmental Health Services,Environmental Education Program, 385N. Arrowhead Avenue, San Bernardino,CA 92415-0160,714-387-4639.

Household Hazardous Waste LearningStations (1990). Ten learning stations anda video. Grades: 4-6. MinnesotaPollution Control Agency, 520 LafayetteRoad North, St. Paul, MN 55155,612-297-8324. Will distribute only in MN.

Household Toxics (1988). Grades: 4-6. Sixlesson plans with activities and games.Environmental Health Coalition, 1717Kettner Blvd. #100, San Diego, CA92101,619-235-0281.

Household Toxics (1 989). Interdisciplinarywith activities and teaching materials.Grades: 5-6. Municipality of Anchorage,Solid Waste Services, P.O. Box 196650,Anchorage, AK 99519-6650,907-261-5221.

Making the Connection. A Teacher's Guideto Household Hazardous Substances andthe Classroom. Video with activities andresources. Grades: Middle and HighSchool Teachers. Ecology Center of AnnArbor, 201 Detroit Street, Ann Arbor, MI48104,313-761-3186.

A Manual for the Household HazardousMaterials Audit (1987). Booklet andsurvey. Grades: Middle Schools throughAdults. Alaska Center for theEnvironment, 519 W 8th Avenue, Suite201, Anchorage, AK 99501,907-274-3621.

72


Project Erase Waste (1991). Ten lessonsabout solid waste management withactivities. Grade: 6. Kern County WasteManagement 2700 “M” Street, Suite 500,Bakersfield, CA 93301,805-861-2159.

SLEUTH: Strategies and Lessons toEliminate Unused Toxicants, Help!(1982). Teaching unit that presents HHWissues. Grades: 4-12. METRO, WaterResources Section, HHW Project, 821Second Avenue, MS 81, Seattle, WA98104-1598,206-684-1233. Thisdocument is only available on acheck-out basis.

Too Close for Comfort: ReducingHousehold Toxics. Video on health andenvironmental problems associated withcommon household products. Grades: 4through Adult. Prevention Program, 75Santa Barbara Road, Pleasant Hill, CA94523,510-646-6511.

Tools for the Environmental Teacher (1992).Inventory, worksheets, and a game.Grades: Junior and Senior HighSchool. Household Hazardous WasteProject, 1031 East Battlefield, Suite214, Springfield, MO 65807,417-884-5000.

Toxics in My Home? You Bet! (1984).One-week curriculum available inEnglish and Spanish. Grades: K-12.Local Government Commission, Inc.,909 12th Street, Suite 205, Sacramento,CA 95814,916-448-1198.

73

Medications

1. Do you own or rent your home?

❑ Rent Own

Sample Participant 2 . A g e u n d e r 2 5❑ 26-40 ❑ 41-65 ❑ Over 65

Questionnaire 3. Sex

❑ Female ❑ Male

4.

5.

6.

7.

8.

9.

10.

Il.

l2.

13.

14.

C i t y Zip Code

This waste is left over from what type of operation?

❑ Household ❑ Farming/ranching ❑ Commercial/business

Please check the type of hazardous waste you brought:

❑ Used oil ❑ paint ❑ Unlabeled Containers Solvents ❑ Pesticides ❑ Batteries ❑ Other Wastes

Are the wastes you brought from more than one household?

Yes ❑ No

How many households?

How long have you had the wastes?

How far did you drive to come to today’s collection event?

❑ 1-5 miles 6-10 miles 11-15 miles 16-20 miles Over 20 milesHow far would you be willing to drive?

How did you hear about the collection day?

❑ Poster ❑ Billboard ❑ Radio ❑ Brochure delivered to home❑ Television ❑ Insert with utility bill ❑ Newspaper article ❑ Word of mouth

❑ Newspaper ad ❑ School/children ❑ Grocery store flyer

Other

Have you ever been to a household hazardous waste collection before?

Yes N o

How much would you be willing to pay to dispose of your household hazardous waste on a regular basis?(Household hazardous waste is very expensive to dispose of properly-over $350 per drum for waste paint.)

Nothing $5/month $ (fill in amount)

How often would you use a household hazardous waste collection in your area?

Monthly Twice a year Once a year Once every 2 years

If this collection event had not been held, what would you have done with yourhousehold hazardous waste?

Source Dakota County Household Hazardous Waste Collection Inventory and Data Sheet; San Francisco Household Hazardous Waste Collection FacilityParticipant Questionnaire; Klickitat County Household Hazardous Waste Collection Days Questionnaire; Iowa Deportment of Natural Resources Toxic Cleanup

Days Questionnaire.

74

T his publication was reviewed by professional expertsnot employed by the Environmental ProtectionAgency, and by appropriate offices within the Agency.