United States
Evironmental Protection
Agency
Solid Waste and
Emergency Response
(OS-305)
EPA530-R-92-026
August 1993
v>EPA
Household Hazardous
Waste Management
A Manual for One-Day
Community Collection Programs
Recycled/Recyclable
' Printed on paper that contains at least 50% recycled fiber
-------
ABOUT THIS HANDBOOK
This handbook is designed to help communities plan
and operate a successful household hazardous waste
(HHW) collection program. The handbook focuses on
one-day drop-off programs. Other types of HHW collection
programs—permanent, mobile, and special-are not discussed
in detail
The handbook is intended for community leaders and HHW
collection 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 about
the treatment, disposal, or transport of HHW. These jobs are
performed by professional contractors or others with special-
ized training. The manual includes information about select-
ing a qualified hazardous waste contractor
-------
v>EPA
Household Hazardous
Waste Management
A Manual for One-Day
Community Collection Programs
CONTENTS
Page
Introduction 1
Section 1 Getting Started 5
Section 2 Selecting Wastes and Collection Methods 11
Section 3 Selecting Waste Management Methods 17
Section 4 Minimizing Liability 21
Section 5 Funding the Program and Controlling Costs 25
Section 6 Publishing the Request for Proposals and
Signing the Contract 31
Section 7 Selecting, Designing, and Operating the
Collection Site 37
Section 8 Training the Collection Day Staff 41
Section 9 Education and publicity 45
Section 10 Evaluating the Program 49
Section 11 Case Studies 51
Appendix A Hazardous Waste Laws and Regulations 58
Appendix B State and Regional Hazardous Waste Contacts 62
Appendix C Information Resources 68
Appendix D Sample Participant Questionnaire 74
-------
INTRODUCTION
What Is Household
Hazardous Waste?
Many common household products con-
tain hazardous substances. These products
become household hazardous waste (HHW)
once the consumer no longer has any use for
them. The average U.S. household generates
more than 20 pounds of HHW per year. As
much as 100 pounds can accumulate in the
-------
INTRODUCTION
home, often remaining there until the resi-
dents move or do an extensive cleanout.
Hazardous waste is waste that can catch
fire, react, or explode under certain circum-
stances, or that is corrosive or toxic. The
U.S. Environmental Protection Agency
(EPA) has set stringent requirements for the
management of hazardous waste generated
by industries. Some HHW can pose risks to
people and the environment if it is not used,
stored carfully, and disposed of properly.
However, Congress chose not to regulate it
because regulating every household is sim-
ply too impractical.
Government and industry are working to
develop consumer products with fewer or
no hazardous constituents. However, for
some products, such as car batteries and
photographic chemicals, no "safe" substi-
tutes exist. So, communities will need effec-
tive HHW management programs for some
time to come.
Communities Find
Solutions
HHW programs can benefit communities
in several important ways. They can reduce
the risks to health and the environment re-
sulting from improper storage and disposal
of HHW. They can reduce communities'
liability for the cleanup of contamination
resulting from improper HHW disposal.
Finally, HHW programs can increase com-
munity residents' awareness of the potential
risks associated with HHW and promote a
Common Household Hazardous Was
(These items, and others not included on this list, might contain materials
that 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 of
Solid Waste and Emergency Response, U.S. Environmental Protection Agency. EPA/530-86-038.
-------
INTRODUCTION
better understanding of waste issues in
general.
Many communities have established pro-
grams to manage HHW. The impetus for
starting a HHW program can come from the
grassroots level, from local or state gover-
nment agencies, from community groups, or
from industry. The number of HHW collec-
tions in the United States has grown dramati-
cally over the last decade. Since 1980, when
the first HHW collection was held, more
than 3,000 collection programs have been
documented in all 50 states.
Although programs vary across the coun-
try, most include both educational and col-
lection components. Communities usually
PROGRAMS
1,000
800
600
400
200
0
484
273
300
175
94
8
31
1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991
YEAR
Number of HHW Collection Programs in the United States, 1980-1991.
SourceWaste Watch Center, Andover, Massachusetts, 1991.
-------
NTRODUCTION
begin a HHW program by holding a single-
day drop-off HHW collection. Organizing a
collection event is an important first step in
reducing and managing risks associated
with HHW.
Some communities hold annual or semia-
nnual collections, while others have estab-
lished permanent HHW collection programs
with a dedicated facility (open at least once
each month) to provide households with
year-round access to information and reposi-
tories for HHW. By 1991,96 permanent
HHW collection programs were operating in
16 states. In addition, communities have
initiated pilot programs for curbside pick-up
by appointment, neighborhood curbside col-
lection programs, and drop-off programs for
specific types of HHW.
The efforts of communities across the
country provide a wealth of experience for
other communities beginning HHW manage-
ment programs. As the number of these pro-
grams continues to grow, public awareness
about HHW will also grow, and the environ-
mental problems associated with improper
storage and disposal of HHW are likely to
decrease.
-------
SECTION ONE
Getting Started
-------
GETTING STARTED
Planning for your first HHW collection must begin very early-as long as 6 to 18
months before a projected HHW collection date. See box for a sample timeline for
planning the HHW collection. In addition, the case studies presented in Section 11
describe how two communities successfully planned HHW collection days.
RolGS and citizen groups; and representatives from lo-
ca' business and industry.
The HHW
Program Sponsor
Every community HHW management
program needs a sponsor or co-sponsors.
Usually the sponsor is a government agency,
but some programs are sponsored by a civic
organization or a business. The sponsor's
role includes:
Managing and funding all aspects of the
program.
Developing Requests for Proposals
(RFPs) and contracts with a licensed
hazardous waste contractor.
Recruiting, managing, and delegating re-
sponsibilities to supporting agencies and
staff.
Involving community leaders and resi-
dents in planning and implementing the
program.
The Hazardous
Waste Firm
Most communities contract with a quali-
fied hazardous waste firm that handles the
HHW at the collection site and brings it to a
hazardous waste treatment storage, and dis-
posal facility (TSDF). If you hire a hazardous
waste contractor to handle the HHW collec-
tion, be sure to choose a firm or firms licensed
to store, transport and dispose of HHW ac-
cording to federal and state requirements. Haz-
ardous waste contractors might not need to
be fully licensed (see Appendix A) to per-
form the duties your contract requires.
Licensing, however, helps to ensure that the
contractor is experienced. The roles of the
Although one person can be the catalyst
for beginning a community program, the
success of the program depends on the in-
volvement of a variety of individuals and
organizations. A key initial step in planning
the program is identifying who should be
involved and defining their roles and
responsibilities.
The Planning
Committee
The most important step in beginning a
program is enlisting a core group of people
who can assemble the needed resources and
manage the program. The planning commit-
tee can perform or oversee many different
functions, such as:
Providing background information.
Setting policy and goals.
Obtaining finding and other resources.
Championing the program in the
community.
Supervising a sponsor.
The process of forming a planning com-
mittee can begin at a meeting of community
officials and interested members of the pub-
lic where they can discuss instituting a
HHW management program. Telephoning
influential community members and placing
announcements in the local media can help
boost attendance at the meeting.
If sufficient support for a program exists,
the people gathered can choose a program
coordinator, form a planning committee and
subcommittees, and begin planning the pro-
gram. The planning committee usually in-
cludes solid waste, health, public safety, and
planning officials; legislators; members of
-------
GETTING STARTED
contractor are spelled out in the contract and
can 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.
• Identifying appropriate hazardous waste
TSDFs.
• Providing necessary services on collec-
tion day, such as unloading wastes from
vehicles; 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.
Information on selecting a contractor is
provided in Section 6.
HHW Collection Program Timeline
6 to 18 Months before Collection
•Establish planning committee
•Identify program goals
•Select program sponsor and cosponsors
•Contact environmental regulatory
agencies
•Begin designing education program
•Initiate community outreach
•Research laws, regulations, and guidelines
•Determine collection methods
•Set tentative collection date(s)
•Select potential sites
•Initiate public education program
• Determine targeted wastes/excluded
wastes/generators
•Estimate costs
•Secure funding
•Issue Requests for Proposals (RFPs)
• to S Months before Collection
•Evaluate RFP submissions
•Interview contractors
•Select contractor
• Identify markets for reusable and
recyclable HHW
•Involve emergency services (fire,
police, etc.)
•Begin publicizing collection program
•Obtain permits
6 to 12 Weeks before Collection
• Design site layout and draw site plan
•Develop collection day
procedures/written plan
•Identify/order equipment
•Arrange disposal and recycling of
nonhazardous material
brought in
•Continue education and intensify
publicity efforts
•Solicit volunteers
•Acquire insurance
•Develop collection day surveys
0 to 6 Weeks before Collection
•Receive equipment and supplies
•Conduct worker training/safety training
•Complete publicity campaign
• Confirm police/emergency service
involvement
Collection Day
•Set up site
•Orient community staff and volunteers
•Complete participant questionnaires
• Receive, package, and ship HHW
•Clean up site
Post-Collection Day
•Tabulate survey responses
•Evaluate collection/public education
results
•Publicize results
•Thank participants and volunteers
through the media
•Write summary report
•Prepare for future events
-------
GETTING STARTED
Involve the
Community
Community involvement is critical to the
success of a HHW management program.
Government agencies, community groups,
local legislators, businesses, industries, and
concerned citizens should be involved from
the start. They can promote the HHW pro-
gram in a number of ways:
Building acceptance for the program
If key community leaders participate in
the planning process, they can help build
community acceptance and support for the
project. In addition, local officials will know
the mood and interests of the community
and can help avoid or overcome
sensitive issues.
Developing a sense of community
'ownership"
People involved in planning and imple-
menting a project will feel that the program
belongs to them. Community ownership
helps to ensure greater participation on col-
lection day as well as community pride
about the outcome of the event.
Providing community assistance
Volunteer groups and residents often can
contribute expertise or resources and can
share the responsibilities of planning and
implementing the program with
the program sponsor.
-------
GETTING STARTED
Providing leadership on HHW issues
The more community leaders learn about
managing and reducing HHW, the more
likely they will be to support an ongoing or
permanent program. Many community lead-
ers also will alter their buying and disposal
practices, becoming examples for the com-
munity.
Assemble the Facts
Members of the planning committee
should conduct background research during
the program's early planning stages. At least
a month or two is needed to acquire the in-
formation necessary to plan the program and
inform the community. This research can be
conducted by planning committee members,
who can provide important information in
their own areas of expertise:
• Health department officials can pro-
vide technical data (such as material
safety data sheets) about specific hazard-
ous materials.
• Police and safety officials can provide
procedures for handling materials and
for preventing and managing accidents
(such as site selection procedures and
traffic management).
• Legislators and public officials can
provide relevant regulations and
guidelines.
• Public interest groups can provide site
selection considerations, media con-
tacts, informational materials, and proce-
dures for volunteer recruitment.
• Businesses can provide information
about sources of funding and material
and equipment donations.
• Educators can provide curricula and
audiovisual materials.
It is essential that the sponsor and the
planning committee learn about the federal,
state, and local regulations that apply to
their HHW management program as well as
the steps they can take to minimize liability.
It is important to note that state regulations
might be more stringent than federal hazard-
ous waste management regulations. For ex-
ample, states might require HHW collection
programs to obtain operating permits. Local
governments also might have applicable re-
quirements, such as zoning laws or building
codes. These issues are discussed in Section
4 and Appendix A. The sponsor or planning
committee should review current literature,
attend conferences or workshops about man-
aging HHW, if possible, and contact the
state hazardous waste management agency,
the EPA regional office, and local agencies
(see Appendix B).
It is also important to anticipate the types
of wastes to be collected, since different
types of HHW present different transport
and handling requirements. The type of ac-
cumulated HHW is strongly influenced by
whether the community is in an urban, sub-
urban, rural, or agricultural area. For exam-
ple, an agricultural area might generate large
quantities of pesticides. Pesticides are
among the most expensive wastes to dispose
of. HHW programs in rural or agricultural
areas, therefore, might be more expensive
than programs in urban or suburban areas.
Collection programs in environmentally
proactive communities usually will have
higher participation and collection rates than
programs in less environmentally active
communities.
Establish Goals
Every HHW management program needs
clear, realistic goals and feasible ways of
achieving them. Typical program goals
include:
• Maximizing public participation. By
maximizing participation in the HHW
program, the quantity of hazardous ma-
terials will be reduced in both the solid
waste stream and the wastewater
stream. Greater participation will mean
higher costs for the community in the
short run but will help avoid or reduce
-------
GETTING STARTED
costs associated with potential environ-
mental cleanups. It will also help to pre-
vent or minimize health and safety
problems associated with improper
HHW storage and handling in homes.
maximizing the reuse and recycling
of HHW. By maximizing reuse and re-
cycling, program sponsors will mini-
mize their hazardous waste disposal
costs and will conserve natural and fi-
nancial resources. Collecting products
such as paint for reuse and recycling,
however, might result in higher labor
costs (e.g., for paint consolidation). In
addition, communities will have to lo-
cate and secure markets for the materials.
• Removing from homes those wastes
considered most hazardous. Instead of
collecting all wastes, some communities
might want to collect specific wastes
that they consider to present an unac-
ceptable risk or to be a likely source of
environmental contamination, such as
oil-based paint and used motor oil. It
might be difficult, however, to educate
people to bring only those wastes to the
collection. In addition, environmental,
health, and safety problems could
result from uncollected wastes in the
community.
Educating the public about reducing
generation of HHW. Some program
sponsors might want to establish a
HHW program to provide information
to consumers about proper HHW man-
agement and alternative ways to reduce
generation of HHW. No matter how ef-
fective education is, however, collection
programs will still be needed for wastes
for which there are no alternatives (such
as car batteries) and for existing HHW
stored in homes.
Identifying goals will help collection pro-
gram organizers determine the basic type of
collection program (e.g., periodic drop-off,
curbside, or permanent), the amount of fund-
ing needed to collect and manage the wastes
and to educate the community about the pro-
gram, and the waste management practices
that the program will use.
10
-------
SECTION TWO
Selecting Wastes
and Collection
Methods
-------
SELECTING COLLECTION METHODS
w
hen initiating a collection program, the planning committee must decide who
may bring wastes to the collection, what types and quantities of waste will be
accepted, and how the waste will be collected.
Decide Who
May Bring Wastes
to the Collection
Program
Most collections are limited to wastes
generated by individuals at home and ex-
clude hazardous waste from commercial
and institutional generators. This is primar-
ily because programs are expensive, aver-
aging $100 per participant. In addition, by
limiting the number of participants it is
possible to limit the amount of wastes (al-
though it also reduces effectiveness).
Some HHW collections, however, are
open 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 CESQGs
under certain circumstances include flo-
rists, home repair businesses, gas stations,
and schools. CESQGs often are unaware
that they produce hazardous waste, and so
sometimes store and dispose of wastes im-
properly. A HHW program that includes
these generators can educate them about
environmentally sound ways to manage
their hazardous waste. Requirements that
must be followed if a HHW collection pro-
gram accepts wastes from these small busi-
nesses are explained in Appendix A. These
generators usually are charged based on
the cost of managing their wastes. The
charge for CESQG waste is less than what
generators would pay if they managed the
waste themselves.
Decide What Types
Of HHW to Accept
The two types of waste received most
often at HHW collections are used motor oil
and paint. Pesticides usually are the third
largest category. Programs also receive sig-
nificant numbers of car batteries. Over the
next few years, the types of wastes collected
might begin to change, and the volume of
certain types of HHW will probably de-
crease. For example, the proportion of latex
paint compared to oil-based paint will prob-
ably increase since sales of oil-based paint
have been decreasing. It will take a long
time, however, to remove stored materials
from all the homes in a community. (In San
Bernardino County, California, for example,
the paint brought to HHW collections is an
average of 10 years old.)
To minimize costs, some programs tar-
get only specific recyclable HHW, such as
used oil, car batteries, antifreeze, and latex
paint. In addition, HHW collections often
exclude certain wastes that the contractor
is not licensed to receive or does not have
the necessary equipment to identify or han-
dle. Certain wastes also might be excluded
if 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 medical
wastes. In New Jersey, however, some pro-
grams have begun to collect medical waste
using a hauler licensed to handle such
wastes.
12
-------
SELECTING COLLECTION METHODS
Decide Whether to
Limit the Amount
OfHHW
A few programs limit the amount of
HHW that each participant may bring to the
collection. 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 quantity generators
(SQGs) (see Appendix A) 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 pro-
gram 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
amounts accepted or charge a participation
fee so that the program will not be over-
whelmed by disposal costs. Allowing drop-
off "by appointment only" will prevent the
collection site from being overwhelmed by
too many CESQGs.
Select a Collection
Method
To maximize participation, many commu-
nities are experimenting with a variety of
collection methods. Some use a combination
of collection methods. Common collection
methods include one-day, permanent facil-
ity, mobile facility, door-to-door pickup,
curbside, and point-of-purchase. Although
this manual focuses on one-day drop-off pro-
grams, the next section briefly introduces
each of the major types of HHW collection
programs.
One-Day Drop-Off
Most 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 limited
by summer vacations and winter weather in
much of the country. One-day drop-off col-
lections typically are held on Saturday, with-
out appointments, starting in the morning
and ending in the afternoon.
A potential limitation of drop-off pro-
grams is finding a date for the collection on
which the hazardous waste contractor will
13
-------
SELECTING COLLECTION
METHODS
be available. It is important to confirm the
date with the contractor as early as possible
(six months in advance is recommended), es-
pecially if HHW collections are scheduled
on the weekend. Weekend HHW collections
in the spring and fall are very popular, and
these dates fill up quickly.
Another potential limitation of one-day
programs is that the chosen day might not
be convenient for some residents. To ad-
dress this concern, some communities hold
drop-off collections on more than one day—
for example, a Saturday and Sunday-or on
two successive weekends. The selected
HHW collection date(s) should not conflict
with other major events in the community.
Holding collections in more than one loca-
tion within the community also can increase
participation.
Still another potential limitation is that
participants sometimes must wait an hour or
more to drop off their wastes. Organizers of
drop-off collection events need to plan ways
to avoid long waits. Strategies for reducing
waiting time include using express lanes for
certain wastes (see Section 7), holding the
collection in several different locations,
holding the collection over several days, and
implementing a two-phase program (for ex-
ample, accepting paint and oil one day and
other wastes the next).
Permanent Drop-Off
If the limitations of one-day collections
prove too great, a community might want to
consider instituting a permanent drop-off
program. The community must anticipate a
number of needs that accompany permanent
drop-off programs, including:
Managing the increased annual quantity
of HHW and increased participation
rates.
Ongoing public education and publicity.
• A facility for onsite storage of HHW.
Training local staff to perform many of
the responsibilities usually assumed by
the hazardous waste contractor atone-
day collections.
An institutionalized, predictable funding
source.
Compliance with additional state and lo-
cal regulatory requirements that might
apply 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 use
their own employees instead of contractors,
often resulting in lower costs.
Drop-Off at a
Mobile Facility
Most surveys show that the average col-
lection day participant travels five miles or
less to the site. Sponsors can purchase a mo-
bile facility and equipment to provide peri-
odic collections on a regular schedule at
different sites within a county or large com-
munity. This is an effective method for pro-
viding service to geographically large and
diverse regions. Like permanent programs,
these mobile collection programs might cost
more than one-day programs in the begin-
ning, but they probably will reduce costs per
participant over the long term.
Door-to-Door Pickup
Door-to-door pickup by appointment is
expensive, but it is more convenient for par-
ticipants than drop-off The personnel who
collect materials must be trained in handling
hazardous waste, including how to pack and
separate the waste in the collection vehicle.
It also allows participation by housebound
individuals and others who cannot travel to
a collection site. Sometimes the programs
14
-------
SELECTING COLLECTION METHODS
are offered to certain individuals in addition
to the one-day event.
Curbside Collection
Curbside 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
because leaving highly toxic or incompat-
ible wastes at the curb can be dangerous,
and because collecting and transporting
a variety of hazardous materials in residen-
tial neighborhoods presents logistical
difficulties.
The most common type of waste
collected at curbside is used oil. More than
115 communities have set up programs to
357-445 O - 93 - 2 : QL 3
IS
-------
SELECTING COLLECTION METHODS
collect recyclable used oil at curbside. Other
communities collect household batteries and
paint at curbside.
Point of Purchase
In some communities, a few types of
HHW can be returned to retail stores.
community HHW program planners can
publicize these point-of-purchase programs
as part of an overall HHW management
strategy.
Retailers have implemented some point-
of-purchase programs voluntarily, in New
Hampshire andVermont for example, some
hardware and jewelry stores collect custom-
ers' spent household batteries in buckets or
specially 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 in
Connecticut, Minnesota, and Oregon ban
car batteries and used oil from landfills
and/or require deposits and retailer redemp-
tion.
Regulations regarding proofs of pur-
chase, deposits, and surcharges for returns
are different in each state. Massachusetts
used oil law, for example, requires proof of
purchase. Auto battery regulations usually
require retailers to post a notice informing
customers that they may return their batter-
ies and stating how many may be returned at
one time.
16
-------
SECTION THREE
Selecting Waste
Management
Methods
17
-------
SELECTING MANAGEMENT METHODS
In designing a collection program, it is important to determine what will happen to the
wastes 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 of
any facility where the waste will end up-
particularly if CESQG waste is accepted
(see Appendix A). The planners should ask
potential contractors about the methods they
will use to manage the wastes, and they
should also ask for copies of the permits for
the hazardous waste facilities that are to be
used. Planners can also contact the state haz-
ardous waste agency (see Appendix B) to
find out if a facility is properly permitted.
Reduce through Use
Reusing materials brought to HHW col-
lections can reduce the amount of HHW that
the contractor must manage, often signifi-
cantly lowering program costs. Some com-
munities have set up waste exchanges to
make materials available for other partici-
pants' use. These exchanges can take place
at a HHW drop-off site or through
telephone/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 and
blended for use by people or institutions
who request the paint. This "second-hand"
paint is readily accepted by the public, com-
munity groups, religious and recreational
centers, graffiti removal programs, and
'Duxbury, Dana and Philip Morley. 1990. Overview of
collection&management methods. Proc. of the Fifth
National Conference on Household Hazardous waste
Managements, November 5-7, 1990, San Francisco,
California, pp. 251-274.
schools. Experience shows that paint
exchanges can reduce the amount of paint
being disposed of at HHW collections by as
much as 90 percent.'
•Managing Latex Paji
EPA recently prohibited mercury in indoor latex paint. Latex paint
exchange programs and disposal, however, still must be carefully
managed.
Interior latex paint manufactured before August 20,1990, might
contain mercury. For this reason, all latex paint in a paint exchange or
"drop-and-swap" program should be assumed to contain mercury
and labeled "FOR EXTERIOR USE ONLY." Using interior paint
outside will substantially reduce the risk from exposure to mercury.
Interior paint used outside, however, might not hold up as well as
paint originally manufactured for exterior use. Alternatively, interior
latex paint may be swapped for interior use if mercury levels of less
than 200 parts per million (ppm) can be confirmed. This can be done
in 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 less
than 200 ppm of mercury.
• The date of manufacture might appear on the label; no interior
latex paint manufactured after August 20,1990, contains
mercury. No paint manufactured after September 30,1991, may
contain mercury.
Usable latex paint can be consolidated and then might or might
not be reprocessed. The consolidated paint should be tested for
mercury. If it contains more than 200 ppm, it must be labeled "FOR
EXTERIOR USE ONLY."
Unusable latex paint (such as paint that is frozen or solidfied) that
contains more than 200 ppm of mercury should be managed as
hazardous waste.
18
-------
SELECTING MANAGEMENT METHODS
Other materials suitable for reuse can
include unwanted pesticides, cleaning prod-
ucts, and automotive products. These materi-
als often can be used by the sponsoring
municipality for its buildings and vehicles.
Communities should offer products only if
they 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.
Recycling
A significant percentage of HHW can be
recycled. For example, used oil can be
rerefined for use as a lubricant. It also can
be reprocessed for burning as a supplemen-
tal fuel (as can oil-based paint and ignitable
liquids). EPA has issued several publications
to help communities safely collect and recy-
cle used oil (see Appendix C, Project
ROSE).
Other recyclable HHW includes:
• Antifreeze.
• Latex paint. (Up to 50 percent of latex
paint can be recycled by filtering, bulk-
ing, and blending it for reuse.)
• Lead acid batteries. Lead used in dental
x-rays.
• Mercury-oxide, mercury-silver, silver-
oxide, and nickel-cadmium household
batteries. Several firms in the United
States take these batteries for a fee; the
contractor can be required in the con-
tract to investigate the option of ship-
ping used batteries to one of these firms
for 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 the
amount of waste that the contractor has to re-
ceive, package, and process. Recycling days
save money because they often are staffed
by the sponsor. Communities that send
HHW off site for recycling should contact
their state environmental regulatory agen-
cies to identify recyclers and to verify that
the recycler is reputable (see Appendix B
for a list of state regulatory agencies).
The results of the State of Florida's
"Amnesty Days" show the great potential
for recycling HHW received at one-day
Recycling Used OM|
Project 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 most
widely 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
-------
SELECTING MANAGEMENT METHODS
collections. Thirty-six percent of the HHW
collected at 107 Amnesty Days (984,655
pounds 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 are
dictated by the types of waste, proximity to
treatment 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 sent
off site for treatment, the contractor should
provide the sponsor with documentation
verifying the waste's final destination.
Landfill
As a result of current and pending bans
on land disposal of certain hazardous wastes
and the efforts of communities to reduce the
amount of HHW sent to municipal solid
waste landfills, more HHW is being reused,
recycled or treated. As with waste destined
for offsite treatment the hazardous waste
hauler should provide the sponsor with
manifests, state-approved shipping docu-
ments, or similar documentation verifying
the waste's final destination and showing
that the hazardous waste landfill is properly
permitted.
Procedures for
Excluded Wastes
HHW program planners and contractors
often exclude certain wastes from collection
programs. Frequently excluded wastes in-
clue radioactive materials, explosives,
banned pesticides, and compressed gas
cylinders. Program organizers must let par-
ticipants know which wastes will not be ac-
cepted and must give them other options
and instructions for managing the excluded
wastes. For example, the police usually will
arrange for pickup of explosives. Smoke de-
tectors, which often contain a minute quan-
tity of radioactive material, are accepted by
some manufacturers (see product labeling
for instructions). If participants are not pro-
vided with alternative management options,
they often discard these wastes in the near-
est trash can.
Where to Get More Informati
Information is available through EPA-sponsored environmental
outreach programs
• Informational materials on recycling reuse, disposal, and
collection program design are available through: RCRA
Hotline 800424-9346; the Waste Watch Center
508470-3044 and the Solid Waste Information
Clearinghouse 800-67 SWICH.
• With EPA support the International City Managers
Association (202-962-3672) and the Solid Waste Association
of North America (301-585-2898) provide technical
assistance 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
-------
SECTION FOUR
Minimizing Liability
21
-------
MINIMIZING LIABILITY
Communities 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 transportation
of HHW from the collection site to the disposal site. The following recommendations
can help communities minimize potential liability.
Become Familiar
With National,
State, and Local
Hazardous Waste
Regulations
Planners of community HHW
programs must know the laws that govern
their collection activities. Planners also
should be aware that their state might have
requirements that are more stringent than
those set by the federal government.
In addition, program planners should be
familiar with regulations governing manage-
ment of specific wastes. For example, con-
solidated oil-based paint must be tested for
polychlorinated biphenyls (PCBs) before it
is sent to a supplemental fuel-burning facil-
ity. Paint that contains more than 50 parts
per million of PCBs must be sent to an incin-
erator permitted to burn PCBs under the
22
-------
IN IM IZING LIABILITY
Toxic Substance Control Act. Latex paint
usual] y is not considered a hazardous waste.
Several states recommend treating it as a
hazardous waste, however, because of the
levels of heavy metals found in some brands
and formulations.
While hazardous waste regulations might
seem complex at first, program planners
should remember that there is potential li-
ability associated with taking no action at all
to manage HHW. By complying with the re-
quirements set out in federal, state, and local
laws, communities can reduce their overall
liability. Appendix A summarizes the federal
requirements that apply to HHW programs.
Develop a Safety Plan
Well in advance of collection day, the
sponsor (or contractor) should develop a
safety, accident prevention, and contingency
plan. Hazardous waste management firms
experienced in servicing HHW collections
can provide a sample plan. The plan should
include steps for preventing spills, a contin-
gency plan in the event of a spill or acci-
dent and a list of the health and safety
equipment available on site. The plan also
should specify when an evacuation would
be necessary, the evacuation routes and
methods, and who would be in charge of an
evacuation. For example, primary emer-
gency authority should be designated to a
specific police and fire department if more
than one department has jurisdiction. Police
and fire departments should be involved in
the planning and provided with the layout of
the collection site, information about the
wastes that will be handled, and possible
evacuation routes.
A copy of the safety plan should be avail-
able at the collection program. One person
should be designated to control any emerg-
ency operation.
Make Training and
Public Education a
High Priority
Proper training of the sponsor's in-house
staff and volunteers is essential for minimiz-
ing potential problems on collection day.
Section 8 discusses training requirements in
greater detail. Public education and public-
ity also can help ensure a safe operation.
Publicity should inform participants about
how 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 the
Necessary Insurance
The sponsor should ensure that the
program has adequate insurance to cover
general, employee, transportation, and envi-
ronmental liability, Some communities will
choose to self-insure for any HHW collec-
tion liability, especially when a contractor
has most of the responsibility. The minimum
insurance required includes:
• General Liability Insurance. Contrac-
tors managing all collection site opera-
tions and activities usually provide $1
million to $2 million of general liability
insurance for damage to property or for
bodily harm at the collection site caused
by actions of the contractor's staff. This
coverage does not apply to property
damage or bodily harm caused by the
sponsor's staff or volunteers.
• Motor Vehicle Insurance The contrac-
tor needs insurance to coverall drivers
and vehicles transporting the collected
waste.
• In-Transit Insurance. In-transit insur-
ance is required by the Department of
Transportation for interstate movement
23
-------
MINIMIZING LIABILITY
of hazardous materials or waste. The
contractor's coverage, up to $5 million,
will vary according to the types of mate-
rials transported. This insurance covers
environmental restoration of property or
compensation for bodly harm.
• Indemnification Clause. The contract
with the hazardous waste firm should in-
clude an indemnification clause stating
that the sponsor is blameless in the
event of contractor negligence, acts of
omission or wrongdoing. Similarly, the
contractor can request indemnification
by the sponsor for any costs incurred by
the sponsor's negligence.
• Workers' Compensation Insurance
The sponsor should obtain coverage for
any staff or volunteers working at the
collection day who are not provided by
the contractor.
The sponsor also can require additional
protection from the contractor to help mini-
mize liability, including:
• A "bid bond" to cover the sponsor for
time and expenses for the bid period in
the event that a contractor turns down
the 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" from
the contractor's insurance company,
and a clause in the contract requiring
that the sponsor be given notice in the
event of cancellation of the contractor's
policy.
In addition, the sponsor should ask to see
a copy of the TSDF's environmental impair-
ment liability insurance. These facilities
need this insurance to cover lialility under
the Resource Conservation and Recovery
Act (RCRA), the federal law covering haz-
ardous waste management. The insurance is
not available to HHW collection programs.
24
-------
FUNDING THE PROGRAM
A
nticipating and reducing costs of a HHW program, as well as locating funding
sources, are major concerns for program planners. However, many communities
have found creative ways to finance their programs and effective ways to cut costs.
HHW program costs generally increase
as 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 result
in much greater costs.
Factors that Affect
costs
A review of the data on approximately
3,000 collection programs held since 1980
indicates that costs for a one-day HHW
collection range from as little as $10,000
to more than $100,000. The final cost of a
HHW collection is difficult to predict be-
cause many variables cannot be estimated
or controlled easily. These variables in-
clude the number of households that par-
ticipate, the types and amount of waste
collected, and the waste management
methods used. Major urban multi-site
collection events, targeted farm pesticide
collections, and collections in communi-
ties located a long distance from hazard-
ous waste disposal facilities will
experience higher costs. See box for devel-
oping a rough cost estimate for a one-day
HHW collection. This formula is based on
1991 estimates of disposal costs. These
estimates might need to be adjusted if
waste management costs change. This
formula is based on much of the work be-
ing done by a contractor. Programs that
use less contractor help and that rely more
on recycling and reuse for waste manage-
ment will greatly reduce the cost.
Participation
On average, each participant brings 50 to
100 pounds of HHW to a collection, at a
cost to the sponsor ranging from $50 to
slightly more than $100 per participant.
Participation rates usually range from one to
three percent of eligible households and can
be as high as 10 percent. Suburban commu-
nities, especially those with a hazardous
waste problem or a solid or hazardous waste
facility, experience high rates of participa-
tion. Extensive education or publicity pro-
grams also can increase participation rates.
Waste Management
Methods
Waste management costs are the largest
item in the HHW program budget. The over-
all waste management costs will depend on
the types of waste collected and the waste
management methods that are used. For ex-
ample, programs that accept only recyclable
materials or provide a "drop-and-swap" area
will experience much lower waste manage-
ment costs and lower personnel costs as
well. Reusing or recycling HHW or burning
it as a supplemental fuel is less expensive
than incinerating the waste at a hazardous
waste facility. Pesticides, especially those
containing dioxin, and solvent paints and
other materials containing PCBs can be very
expensive to manage ($850 per 55-gallon
drum in 1991). Burning used oil and solvent-
based paint as supplemental fuel typically
costs the sponsor $175 to $250 in manage-
ment fees. In 1991, the cost of sending most
26
-------
SECTION FIVE
Funding the
Program and
Controlling Costs
25
-------
other wastes to a hazardous waste incinerator
or land disposal facility ranged from $350 to
$500 per drum. These costs can vary and
might increase over time; the hazardous waste
contractor or appropriate state agency can pro-
vide current rate schedules.
Other factors will affect waste manage-
ment costs as well. For example, contractors
who own and operate their own TSDFs or
have access to facilities close to the collec-
tion site might be able to charge less for a
collection than other contractors. Communi-
ties that are located closer to hazardous
waste management facilities also might
benefit from lower costs.
FUNDING THE PROGRAM
Collection Methods
The program's collection method also
affects the overall cost. For example, col-
lecting HHW door-to-door is more expen-
sive than holding a drop-off collection
day. Permanent programs might be more
cost effective than one-day collections.
The number of participants might increase
with a permanent program; however, in a
permanent program, there are often more
opportunities to arrange for recycling or
reuse of collected materials, resulting in
less waste per participant to be disposed of
as 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:
_(low estimate)
. (high estimate)
.01 H (low participation) x $350 + $5,000=$
8 (consolidation)
.03H (high participation) x $350 +$5,000=$
4 (no consolidation)
• 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 of
55-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
-------
FUNDING THE PROGRAM
Ways To Minimize
Costs
program sponsors continue to find ways
to reduce both overall costs and the average
cost per participant. For example:
• Consolidating instead of lab-packing
HHW reduces costs by allowing for
much more waste per drum. (A lab-pack
consists of a large container that holds
several smaller containers.) Paint used
oil, and antifreeze are frequently
consolidated.
• Some programs reduce costs by using
volunteers (only for low hazard items)
or city or county personnel to receive,
consolidate, and package the waste,
rather than using contractor staff for
these functions.
• The sale of some recyclable items, such
as silver-oxide button and lead-acid bat-
teries, can help defray a program's costs.
Of course, one of the best cost-cutting
measures is to educate the public about how
to reduce HHW generation and how to mana-
ge existing HHW without bringing it to a
collection center. For example, consumers
can bring used Oil and antifreeze to some
service stations. In addition, wastewater
treatment plants in some communities take
used oil to discourage improper disposal of
this waste and prevent damage to the treat-
ment plant. Generally, car batteries can be
returned to the point of purchase.
Obtaining Funding
HHW management program sponsors
have obtained funding from a wide variety
of 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 of
volunteers.
State and Local
Governments
The majority of funding for local govern-
ment programs comes form municipal solid
waste budgets. In addition, county and local
agencies that benefit from HHW collection
days often contribute a portion of their budg-
ets to HHW management programs. Among
the agencies that benefit from HHW collec-
tions are water and sewer departments, since
less HHW is poured down drains; fire and
health departments, since less HHW is
stored in homes; and public works &part-
ments, since less HHW is discarded with
municipal trash. Some state environmental
agencies, such as departments of natural re-
sources or the environment also provide
funds for HHW management programs.
Sources of state funding have included state
Superfund budgets, oil overcharge funds,
surcharges on environmental services or haz-
ardous products, and special environmental
bond issues and trust funds.
Fees and Taxes
Many communities increase landfill tip-
ping fees, property taxes, or water/sewer
fees to create a fund for managing HHW.
Some communities also have imposed user
fees, but these might be a deterrent to partici-
pation in the collection program, since
household residents in most states legally
can throw HHW in their trash.
Some states have instituted specific taxes
for HHW programs. For example, the State
of Washington has imposed a tax on the first
use of certain chemicals by manufacturers
or wholesalers. The tax will be used in part,
to fired county HHW collections. Retailers
in Iowa selling prducts covered under the
shelf labeling law pay a $25 registration fee.
In New Hampshire, a tax on hazardous
28
-------
FUNDING THE PROGRAM
waste generators funds matching grants to
communities for HHW collection programs.
In Florida, local governments receive three
percent of the gross receipts from permitted
waste management facilities.
Contributions,
In-Kind Donations,
And Volunteers
Donations of money, materials, and labor
are the lifeblood of many community HHW
programs. These donations can come from
many different sources:
Cities counties, civic groups, environ-
mental organizations, and corpora-
tions often provide seed money or
matching grants for collections.
Hazardous waste contractors some-
times donate collection and transporta-
tion services.
Local industries or businesses that pro-
duce or distribute household products
that can become HHW sometimes con-
tribute money or services to HHW man-
agement programs because they
recognize the importance of product
stewardship. In some communities, lo-
cal printers have donated services for ad-
vertising or education materials.
E'
.
Metrocenter YMCA:
Community-Wide Funding for HHW Collection;
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
-------
FUNDING THE PROGRAM
• Civic and environmental organizations
can provide volunteers to help plan, publi-
cize, or staff the HHW collection. Volun-
teers can be used to direct traffic, hand out
literature, fill out questionnaires, and han-
dle nonhazardous waste.
• State and municipal agency staff and
local fire and police departments often
provide supervision and traffic control.
Programs can attract direct financial
contributions, in-kind donations, and vol-
unteer services by giving donors positive
recognition, such as a mention in flyers,
an award, or a recognition ceremony. A
publicly acknowledged donation from one
group or company often encourages others
to contribute or participate in some other
way.
30
-------
SECTION SIX
Publishing the
Request for
Proposals and
Signing the Contract
31
357-4450 -93- 3:QL3
-------
RFPs AND CONTRACTS
If a contractor is to be used to do some or all of the collection work, the HHW collection
program 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 for
issuing RFPs. A contractor should be selected based on the proposals received in response to
the 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 reasonable
cost, and that the roles of everyone involved in the collection event are clearly defined. This is
the only way to ensure proper management of the waste.
Issue the RFP
A good RFP provides a comprehensive
description of the services to be provided so
that prospective contractors can bid on the
cost of delivering those services. The more
specific and clear the RFP, the better the
chances of obtaining complete proposals
and realistic bids.
An RFP can include the following
information:
• A detailed narrative description of the
sponsor's goals for the program.
• The proposed collection site(s) and
date(s).
• The size of the targeted population and
types of generators (e.g., households,
farmers, and/or schools).
• The size and relevant characteristics,
such as community demographics, of
the 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 and
the 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 packaging
waste.
• 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 of
the sponsor, including the wastes that
the sponsor wants recycled.
• The ultimate destination for each waste
(when the sponsor has preferences).
• Proof of insurance.
• An "escape clause" to ensure that the
sponsor reserves the right to reject all
bids or to modify the plan.
• costs.
The RFP can be advertised in the local
press (this might be required by local
ordinance) and in waste management trade
journals. It also can be sent to the contrac-
tors on "bid lists" (lists of qualified
32
-------
contractors are available from state, local,
and EPA regional offices).
Select the Contractor
The program sponsor should base the se-
lection of the contractor on the following in-
formation requested in the RFP and supplied
in the proposal:
• Contractor's license. The contractor
must be licensed to handle hazardous
waste in the state where the HHW col-
lection will be held.
• Contractor's HHW experience and
references. The proposal should include
a narrative section describing the
RFPs AND CONTRACTS
contractor's qualifications and experi-
ence. It also should include a list of ref-
erences from any previous HHW
collection programs handled by the con-
tractor. (The sponsor should carefully
check 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/disposal
equipment: Awning or tent (if
needed 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/reflector
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
-------
RFPs AND CONTRACTS
Compliance record. (State and environ-
mental regulatory agencies also can pro-
vide the regulatory compliance/violation
records of contractors.)
Insurance/indemnification provided
by the contractor. A list of insurance
carriers and policy numbers should be
included.
Waste management services offered
and the immediate and ultimate desti-
nation of the collected waste. A con-
tractor might own waste management
facilities 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 be
used. The sponsor also should receive
copies of manifests or other shipping
documents confirming the receipt of the
wastes at the facilities identified by the
contractor.
Contractor costs. The proposal should
include itemized costs for site set-up, la-
bor, equipment materials, hazardous
waste training, transportation, and
disposal.
Available collection dates. Fall and
spring weekends are especially busy.
The contractor should have enough
equipment and personnel to operate at
the times the sponsor selects.
A list of wastes not accepted by the
contractor. If a community expects
large quantities of unusual wastes, this
might be a consideration in choosing the
contractor.
A list of wastes that will be consoli-
dated and those that will be lab-
packed in original containers.
Consolidation of high-volume wastes
can result in significantly reduced costs
to the sponsor.
A sample Contract The contractor usu-
ally provides a sample contract with the
proposal. (If the RFP contains a model
contract, the contractor can accept it or
modify it as necessary.)
• How recyclable materials, such as
used oil, batteries, paint and anti-
freeze, will be managed. This should
specify any offsite recycling facilities
that will process these materials.
• The number and level of training of
personnel proposed for the collection.
Highly trained personnel are more ex-
pensive and are not always needed. (For
example, they might not be necessary at
a recyclables-only event or a paint drop-
and-swap.)
• A health and safety plan. The proposal
should include a safety, accident preven-
tion, and contingency plan. (The spon-
sor also might need to be involved in
ensuring the availability and coordina-
tion of emergency services.)
• Cost per drum, per product, or per
unit of waste. It also must be clear how
much waste will be placed in each drum
or container.
Write the Contract
Once 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 contractor
will receive. The contract usually is based
on the contract in the original RFP or the
one supplied in the proposal. It usually is a
lengthy document, containing addenda with
copies 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
-------
RFPs AND CONTRACTS
The time, place, and duration of the • Any insurance and liability guarantees
work. and requirements.
The fee schedules for all thework to be • The procedure for amending provisions
done.
Submission of proof (manifests) of de-
livery of all wastes prior to payment to
the contractor.
The default guarantees and assurance
and bond provisions for the quality
and completeness of the work to be
performed.
of the contract.
The contractor's guarantee of compli-
ance with any applicable laws.
35
-------
RFPs AND CONTRACTS
• The data the contractor will provide to
assist in evaluating the program.
• A "savings" clause that protects the re-
mainder of the contract should any part
of 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 more
satisfactory the results will be. State hazard-
ous waste contacts (see Appendix B) usually
have current model contracts that cover all
federal and state requirements. The indemni-
fication and insurance clauses usually cause
the most difficulty. The contract should indi-
cate clearly which liabilities and hazards are
covered and to whom the indemnification
and insurance clauses apply (e.g., contrac-
tors, haulers, municipality and individual
departments, or volunteers). The sponsor's
legal advisors should review the contract
before it is signed.
36
-------
SECTION SEVEN
Selecting, Designing,
and Operating the
Collection Site
37
-------
SITE CONSIDERATIONS
Proper 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 collection
should be well known, centrally located,
and easily accessible. It also should be
well removed from residences, parks
where children play, and environmentally
sensitive areas, such as open bodies of
water, wells, faults, and wetlands. Local
zoning regulations might specify required
setbacks and buffer zones and might iden-
tify acceptable or restricted areas. Using
sites with an impermeable surface (e.g.,
pavement or concrete) helps to minimize
environmental risks. Onsite utilities should
include running water, fire hydrants, and
electric hookups (or generators) in case
lights are needed to pack and label the
HHW after dark.
Collection sites typically are located on
publicly owned land, such as stadium park-
ing lots, solid waste landfills or transfer sta-
tions, schools, fire stations, and public
works yards. A waste water treatment plant
is a good collection site because it also
offers the opportunity to educate the public
about water pollution problems caused by
improperly managed HHW.
Simple site plan for a one-day drop-off HHW collection program.
38
-------
SITE CONSIDERATIONS
Site Design and
Operation
A well-designed and well-operated HHW
collection site allows participants to move
through the collection area quickly and effi-
ciently. It includes areas for people who re-
quire special attention, and adequate space
for waiting lines. It also has staff on hand to
direct traffic, offer informational materials,
and answer questions.
The size of the site is critical to the effi-
ciency of the program; sponsors should plan
for traffic overflow. The site should beat
least 10,000 square feet.
Figure 1 shows one example of a site plan
for a one-day drop-off collection program.
The simple plan shown in Figure 1 might
not be adequate for all programs, however.
Depending on the design and goals of the
program, a more complex layout might be
required, such as the layout shown in Figure
2. Described below is a commonly used sys-
tem for designing the site layout. There are
many other ways an effficient collection can
be achieved.
Entrance
Collection staff or volunteers should
stand at the entrance or check-in station to
greet the participants and direct them to the
receiving area. Police officers or volunteer
personnel should be stationed just outside
n n n
Safety Gear
Check-Out
u u u
Unloading
Zone for
Oil&
Batteries
Unloading Zone for
Non-Hazardous
Wastes
'Escape Route
for Ineligible Vehicles
I I
Unloading Zone
Entrance
Check Identification
Traffic Flow & Traffic Holding Line
Legend (not to scale): O Drum
Table
Pallet
More complex site plan for a one-day drop-off HHW collection program.
39
-------
SITE CONSIDERATIONS
the entrance to manage traffic flow that can-
not be contained on the site.
Several unloading lanes with signs and
traffic cones can help control the flow of
traffic on and off the site. Separate express
lanes for the wastes received in the highest
volume (usually paint and used oil) can help
speed 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 the
wastes they have brought to the site. (A sam-
ple questionnaire is provided in Appendix
D.) 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 can
be completed while participants wait to en-
ter the receiving area.
Receiving Area
At the receiving areas, trained personnel
(usually the contractor's staff) screen each
vehicle for unknown, unacceptable, recycla-
ble, or nonhazardous waste. Participants
should not be permitted to remove any
wastes from their own cars and should be en-
couraged to remain in their cars. The staff
members unload recyclable materials and
take them to the recycling area. The recy-
clable should be handled and packaged ac-
cording to any instructions from the
recycling firm. They then take the rest of the
acceptable wastes to a sorting table. After re-
moving the HHW from the vehicle, the staff
members direct the participant to the exit.
Sorting Area
In the sorting area, staff members or con-
tractor personnel sort the wastes into hazard
categories and deliver them to the packing
area. They place empty containers and non-
hazardous waste in dumpsters located in the
sorting area. Arrangements can be made for
removing and replacing the dumpsters dur-
ing the day if necessary. A volunteer can flat-
ten boxes for recycling or to reduce the
amount of room the boxes take up in the
dumpster. Any unknown material needs to
be sorted as a hazardous material.
Packing Area
In the packing area, trained personnel
(usually contractor staff.) lab-pack the
wastes or bulk them into drums. They
then label all containers by hazard class
and load them onto the appropriate truck(s).
Consolidation of wastes (e.g., paint, motor
oil, or antifreeze) can be performed in this
area.
Temporary Storage
Area
Empty drums are kept in the temporary
storage area. Fully packed and sealed drums
can be placed in the storage area until they
are loaded onto a truck. To ensure that this
area stays dry and uncontaminated, it should
be covered, at least by an awning, and the
floor should be covered with chemically re-
sistant plastic.
Break Area
Staff and volunteers should have a break
area, separate from the waste-receiving area,
where they can eat, drink, rest, and use a
bathroom.
Parking Area
A special parking area is recommended to
accommodate people who need extra atten-
tion, such as those who bring in unidentified
wastes or have spilled a container in their ve-
hicle. Parking spaces also can be designated
for volunteer and staff vehicles.
40
-------
SECTION EIGHT
Training the
Collection Day Staff
-------
TRAININGTHE
STAFF
P
Hiesc
roper training of all personnel is essential to a safe and efficient collection. Training
required for the contractor's staff, volunteers, and the sponsor's in-house staff is
escribed below.
The Contractor's
Staff
The contractor is responsible for ensuring
that all of its technical and professional staff
are properly trained and certified. The con-
tract should specify the qualifications of the
professional personnel who will be present
at the collection.
If your state requires an operating permit
for HHW collection, staff training might
need to meet the requirements of the Occu-
pational Safety and Health Act, Section
1910.120. Check with your state agency to
determine training requirements. These regu-
lations specify the content and length of
training required for personnel at hazardous
waste operations. The level of training re-
quired for each employee depends on his or
her job functions and responsibilities. Topics
that must be covered include the names of
personnel responsible for site safety and
health, the hazards present at the site, the
use of personal protective equipment, work
practices that can minimize risks, the safe
use of engineering controls and equipment
on the site, and medical surveillance require-
ments. In any case, this training is recom-
mended for all personnel who will be
handling the waste, even if it is not required.
The contractor's staff can include techni-
cians, chemists, and a manager. The
manager should receive training appropriate
for his or her involvement in the physical
operation of the program. Chemists should
have 40 hours of field chemist/technician
training to the Occupational Safety and
Health Administration's (OSHA'S) "Site
Emergency Responder" level. Technicians
should have eight hours of training to the
"First Responder Operations" level, since
they would have to evacuate everyone from
the site in the event of an emergency. The
contractor's staff also must be briefed on
any limitations of the permit or the facility,
including excluded materials and procedures
to be followed.
Reviews and drills of the emergency plan
should be conducted for all collection day
personnel by qualified instructors. For regu-
larly scheduled collections, the training pro-
gram should provide for update sessions to
reinforce safety procedures and provide up-
dated packing information.
42
-------
Volunteers and
In-House Staff
The volunteers and in-house staff who
will work at the collection site must also re-
ceive proper training. Because of accident
and liability concerns, the responsibilities of
the volunteers at a one-day collection are
usually limited to controlling traffic, con-
TRAINING THE STAFF
ducting participant surveys, and providing
general assistance, such as running errands,
emptying trash, and providing refreshments.
The sponsor's in-house staff can perform
other collection day tasks, such as unloading
cars, pouring used oil into consolidation
drums, or opening and scraping out paint
cans, depending on the volunteers' training
and qualifications. All these tasks must
43
-------
TRAINING THE STAFF
be performed under the contractor's
supervision.
In some cases, the state or municipality
will provide professional staff to carry out
some of the more technical work. The state
hazardous waste contact (Appendix B) can
provide information about appropriate
training for these personnel (such as OSHA's
40-hour, 20-hour, and 8-hour courses).
The sponsor's project coordinator and the
contractor should explain to volunteers and
in-house staff what they may and may not
do on collection day; the procedures for re-
ceiving participants, controlling traffic, and
handling waste; and what their roles would
be in the event of an accident or spill.
Before the collection date, the sponsor
should hold an orientation session with the
contractor for all volunteers and in-house
staff who will be working at the collection
site. This session should inform the volun-
teers about the operating procedures and
emergency plan. Police and other emer-
gency personnel who will be on site or on
call should participate in the planning and
orientation.
44
-------
SECTION NINE
Education and
Publicity
-------
EDUCATION AND PUBLICITY
AHHW collection program cannot succeed without a strong public education effort
that provides general information about HHW and specific instructions about how
to 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. At
current collection program participation rates, it will be some time before the stored waste is
cleaned out of a community. It is likely, though, that the amount of waste per participant will
decrease in communities with regular or permanent collection programs. Many examples of
well-planned education programs are available. Sources for these materials are listed in
Appendix C.
Target the Audience
Residents are the most important target of
a HHW education program. Information
about 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 an
especially important vehicle; media under-
standing of HHW issues helps ensure accu-
rate and responsible reporting. Educators
need resources to develop and communicate
a strong understanding of the issue to the
people they teach. Manufacturers, retail
stores, school chemistry departments, hospi-
tals, agricultural extension services, and
farmers also can benefit from education
about HHW.
Determine the
Message and Select
Educational Methods
Public education about HHW is a good
idea even if a HHW collection event is not
yet planned. The scope of this effort will
depend on the finds and personnel avail-
able. Early education can focus on:
• What products contain hazardous con-
stituents.
• How household generation of hazardous
waste can contribute to pollution.
• Why source reduction is a major goal of
a HHW management program. (Source
reduction is defined as the design, manu-
facture, purchase, or use of materials or
products to reduce their amount or toxic-
ity before they enter the solid waste
stream.)
• What products contain fewer or no haz-
ardous constituents.
• How to shop "smart" (e.g., buying only
what is needed).
• How to reduce the amount of HHW gen-
erated (e.g., using up household prod-
ucts or giving away what cannot be
used).
• How to use products in a way that mini-
mizes harm to the environment.
• How to properly store and handle prod-
ucts containing hazardous constituents
in the home.
Public education before a planned collec-
tion day should not only focus on identify-
ing HHW and helping people understand the
hazards associated with HHW, but also
should present the sponsor's plans for ad-
dressing HHW management. Public educa-
tion efforts also should communicate the
individual's role in the HHW management
program, including what to bring to a collec-
tion and how to transport it safely. This
phase of the education program should be-
gin at least six months before the collection
day. Intensified education in the final two
weeks before a collection day can have a
major impact on participation rates.
Publicity, a component of public educa-
tion, focuses on a single goal-bringing the
46
-------
EDUCATION AND PUBLICITY
Public Education Methods and Techniques
Education through the media. Well-prepared media
handouts-feature articles, public service announcements, and
other materials for the press—m inexpensive options and
require less staff time than many other educational methods.
Information about HHW can be presented in a variety of
ways. For example, a radio broadcast might feature a
hazardous waste expert who can answer phone-in questions
on HHW. A local television station can cover a tour through
a home with an environmental expert, who can discuss the
products that can become HHW and how to manage them
safely.
Information and referral services. A publicly
advertised local telephone hotline can encourage people to
call for information about managing HHW, and also can
facilitate a waste exchange/referral service. These services
can be effective but require telephones, office space, training,
and personnel.
Mailings and mailing inserts. Utilities, banks, toilers,
and advertisers may be willing to include HHW
announcements and informational literature in their regular
mailings. Inserts mailed with water bills, garbage bills, or tax
bills not only provide information about HHW, but also can
educate the public about the links between HHW generation,
waste management ground-water protection, and
water/garbage rates. Community groups can include
educational information about HHW management in their
mailings or newsletters. HHW program sponsors can send
direct mailings to people who participated in previous HHW
collections.
Posters, handouts, and brochures. Flyers and
posters often are displayed or handed out at schools,
libraries, community centers, and senior citizen centers.
Businesses can post signs and notices for shoppers and
customers on how to safely manage household products that
might become HHW. Real estate agents can offer their clients
information about HHW with their other community
resource materials. Solid waste facility personnel at drop-off
landfills, transfer stations, and recycling centers can discuss
HHW and provide written information when residents drop
off waste or recyclable. Handouts can include HHW
"wheels" that highlight the potential hazards of household
products and suggest less hazardous substitutes (see
Appendix c).
Garbage can labeling. Some communities distribute
plastic adhesive labels that residents can put on their trash
cans. The labels alert people to the potential hazards of
mixing HHW with their trash, list products containing
hazadous constituents, and advertise whereto dispose of
HHW properly.
Street banners. Banners announcing the place and time
of collection have worked well for some communities.
Displays/exhibits/audiovisual presentations. Public
education staff can use slide shows, video presentations, and
hands-on exhibits at community group meetings, county fairs
or other special events, public information sessions/
workshops, shopping malls, and other public forums. For
example, the League of Women Voters of Martha's Vineyard,
Massachusetts, bought a video on managing HHW and
offered it free to any group on the island who would show it
at a meeting. (Slide shows available for rental or purchase are
listed in Appendix C.) The local public library also might be
willing to set up a HHW resource center.
Speaker bureau. Municipal departments usually have
access to knowledgeable speakers who can make
presentations to local groups at a nominal fee or free of
charge. Sources for community education experts include
cooperative extension services, soil and water conservation
districts, and health and solid/hazardous waste administrators.
Formal education. Presentations in schools and special
curricula can educate students (and their parents) about
managing HHW. A number of organizations have developed
school curricula on HHW (see Appendix C).
Point-of-purchase information. Information about
the potential hazards of household products can be
distributed where the products are sold. For example,
hardware stores can distribute handout on what to do with
used motor oil, paints or varnishes. An Iowa law requires
stores that sell products covered under the shelf labeling law
to provide HHW content and hazard information through
shelf labeling and informational materials. A hardware store
chain in San Diego, California voluntarily initiated a similar
program.
Workshops and conferences. Workshops,
presentations, and conferences on managing HHW can bean
excellent way to bring information to citizens, HHW program
volunteers, local business groups, and community officials.
47
-------
EDUCATION AND PUBLICITY
desired number of participants (and HHW)
safely to a collection program. Good public-
ity explains:
• Why people should participate in HHW
collection programs.
• When and where the collection will be
held.
• Which materials will be accepted and
which will be excluded.
• What to do with excluded HHW.
• How to transport HHW to the collection
center.
To maximize participation in the collec-
tion program, publicity should begin as
soon 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, and
providing contacts for more information.
Advertising in local newspapers and
newsletters is a highly effective form of
publicity. The local press usually will pub-
lish articles, photographs, and letters to the
editor. 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 HHW
collection(s).
• Two or three short feature articles.
• Black and white photographs (with cap-
tions) of hazardous materials (in the
home, on store shelves, at collection
programs) that can either stand alone or
be used with news or feature articles.
• Press-ready ads publicizing the collec-
tion day. Newspapers and radio and TV
stations might run these ads free of
charge 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 with
publicity and outreach. A local advertising
agency or public relations firm might agree
to plan or produce the publicity campaign.
Invite the firm to participate on the planning
committee.
48
-------
SECTION TEN
Evaluating the
Program
49
-------
EVALUATING THE PROGRAM
Evaluation 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, the
quantities 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 determine
whether program goals have been met. The sponsor's contract with the hazardous waste
company should specify what data the sponsor needs from the contractor for post-collection
evaluation.
In addition, sponsors can ask contractors
and participants for input on flaws in the
Program, such as inconvenient operating
hours and locations or inefficient collection
methods. This information allows programs
to adapt to meet the needs of the public.
Public satisfaction with the HHW man-
agement program can be measured through
questionaires published in newspapers or
filled out when participants arrive at the col-
lection site (see Appendix D for a sample on-
site questionnaire), and by requests for
feedback 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, if
pre-collection data also are available. This
might indicate changes in disposal practices.
Finally, followup is important after a
HHW collection event, especially for spon-
sors who hope to maintain and institutional-
ize the program. Local media should be
provided with followup stones of the event,
such as a report about the amount of HHW
collected. A summary report should be
prepared to document the results of the
program.
50
-------
SECTION ELEVEN
Case Studies
51
-------
CASE STUDIES
Raleigh, North Carolina
In October 1989, the Raleigh, North Carolina Public Utilities Department (the city's water
and 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 recycle
some 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 drew
an extraordinary number of participants for
a first-time drop-off HH W collecton-a to-
tal of 1,149, or 1.4 percent of the targeted
80,000 households.
Planning the
Collection
The collection was planned by a HHW
steering committee that included repre-
sentatives from the public utilities depart-
ment the Governor's Waste Management
Board; the North Carolina Hazardous Waste
Branch; the Institute for Environmental
Studies at Chapel Hill; the City of Raleigh's
Environmental Quality Advisory Board; the
city's public works, fire, transportation,
police, and safety departments; and others.
The committee began planning for the
collection day a full year before the event
was held.
Publicity
Advertising for the October collection
started at the beginning of January. A variety
of publicity and public education methods
were used:
• More than 40 press releases were pre-
pared for newspapers, TV, and radio.
• Five hundred letters were mailed to
civic organizations.
• Presentations with videotapes were de-
livered at civic group meetings.
• Bright yellow inserts were placed in
every Raleigh water bill approximately
six weeks before the collection.
• A member of the Environmental
Quality Advisory Board sponsored an
entire afternoon on a classical music
radio station that included repeated
announcements about the HHW
collection.
• Raleigh's cable television station aired
an informational program on HHW
several times.
52
-------
CASE STUDIES
Graduate students from a local university
surveyed the collection participants to find
out how they heard about the collection. The
results are shown below. (Note: The total
percentage exceeds 100 because some peo-
ple heard about the collection program from
more than one source.)
Newspaper
Water bill inserts
Radio
Television
48%
34%
16%
14%
Other forms of advertising 8%
Civic groups 3%
Among the factors credited for the re-
markable turnout at the collection was the
steering committee's ability to personalize
the issue when presenting it to the commu-
nity. The program manager focused her ad-
vertising efforts to ensure that people
understood that HHW management is an en-
vironmental issue that literally "hits home."
The highlight of this personalized effort
was a press conference held in a home-
owner's basement. This enabled the press to
actually see what HHW is, to recognize that
it is something most people have in their
own homes, and to take advantage of a
photo opportunity. Several major newspa-
pers ran feature articles about HHW follow-
ing this press conference. Television stations
also included the press conference in their
news reports.
Types of HHW
Collected and
Waste Management
Methods Used
The hazardous waste contractor for the
collection sent 355 drums of collected HHW
for hazardous waste treatment and/or
disposal. Three types of materials brought
to the HHW collection were identified for
recycling: good-quality latex paint, used
oil, and automobile batteries. More than
100 gallons of latex paint were donated to
the Raleigh Housing Authority for use in
its projects. An oil service company in
Raleigh accepted 2,800 gallons of motor
oil for processing as industrial-grade fuel
oil. A battery firm in Wilson, North
Carolina, took 105 automotive batteries
for recycling. Wastes not accepted at the
collection included radioactive, biologi-
cal wastes, explosives, ammunition, and
nonhazardous waste.
Funding and Costs
Except for a one-time $10,000 matching
grant from the state, Raleigh's program was
funded entirely from the city's Department
of 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 city
staff on site (police and fire) and the hours
spent by the HHW steering committee to
plan the program-totaled an additional
$26,017. City employees bulked used motor
oil, directed traffic, and were available for
emergency response.
Expanding the
Program
On April 7,1990, Raleigh and Wake
County held a collection open to the entire
county. This collection drew 1,778 partici-
pants. The cost of the event was $175,210.
It was funded by a separate line item on the
city water and sewer bill (40c7month), and
the county share was funded through the
landfill tipping fee.
An ad hoc group of Raleigh public
works, utility, and transportation employees
managed the program. The group was
responsible for expanding the program to
53
-------
CASE STUDIES
the full county and for developing a HHW
curriculum for local schools. The group also
is planning future collections.
The most effective publicity techniques
for the April 1990 collection were flyers
sent with water bills one month before the
event 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 a
goal of increased recycling. A local paint
company consolidated and blended 2,500
gallons of latex paint, charging only for the
five-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 Department
received 12 drums of pesticides from the
collection.
The collection organizers made several
other improvements over the 1989 event.
The two most frequent suggestions from
participants at the first collection were to
reduce waiting time and to ban smoking.
In response to these suggestions, organiz-
ers staffed two sites with 100 contractor
and local personnel, reducing the waiting
time at the second event to a maximum of
15 minutes. In addition, the sites now have
permanent signs that ban smoking. In
1990, Habitat for Humanity bulked the
good-quality latex paint at the collection
site and then used it to paint low-income
housing. The hazardous waste contractor
analyzed the bulked latex paint for heavy
metals. None of the bulk paint was
rejected.
Source: Cindy Kling, City of Raleigh, Public
Utilities Department.
54
-------
Monroe County, New York
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 250,000
households 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 because
of the long wait or because many were turned away at 2 p.m.
Planning the
Collection
Initial planning meetings began 18
months before the collection. A 12-person
volunteer subcommittee of the county's En-
vironmental Management Council (EMC)
conducted background research, and the
County unanimously accepted the EMC's
recommendations in January 1990.
Monroe County established a committee
of county professionals from the depart-
ments of solid waste, planning, health, and
firm, as well as legislative and legal repre-
sentatives, to plan and implement the collec-
tion event. The EMC coordinator was the
project manager for the event. The County
Division of Solid Waste carried out the de-
tails of site planning and provided the site
coordinator. Chemists from the County
Health Department sampled and handled the
used oil and automotive batteries. The haz-
ardous materials team was on site all day
and the bomb squad was on call. County
and municipal police and hospitals were no-
tified about the day's event.
Publicity
The Monroe County EMC Household
Hazardous Waste Committee was responsi-
ble for education for the event. The planning
committee arranged for publicity before the
collection day through newspapers, TV, ra-
dio, flyers, and slide shows. Eastman Ko-
dak, a local employer, also publicized the
event in its in-house newsletter and encour-
aged all employees to participate. Kodak
also purchased fill-page newspaper ads
about the company's recycling efforts and in-
cluded a quarter of a page in the ads about
the HHW collection.
55
-------
CASE STUDIES
Types of HHW
Collected and
Waste Management
Methods Used
The program collected 3,000 gallons of
used oil, 13,375 pounds of automotive bat-
teries, and 80,000 pounds of other types of
HHW. Used oil was reprocessed into fuel oil
by a local firm, and automobile batteries
were 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 Costs
To pay for the collection program, Mon-
roe County spent $62,000, the City of Roch-
ester contributed $5,000, and local
businesses 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 costs
by accepting 384 thirty-gallon drums and
135 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 Evaluation
The 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 available
for this on the collection day) and using vol-
unteers in shifts so that they can take breaks.
The only significant problem at the event
was that many potential participants had to
be turned away. Collection organizers do not
believe that increased staffing would have
solved 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 a
permanent HHW collection program. The
county hired an engineering firm to design a
permanent facility and selected a site for the
program. The facility opened in the spring
of 1992.
Source: Alice Young, League of Women Vot-
ers, Rochester Metro, Chair Monroe County
Environmental Management Council,
Household Hazardous Waste Committee.
56
-------
APPENDICES
A. Hazardous Waste Laws and
Regulations
B. State and Regional
Hazardous Waste Contacts
C. Information Resources
D. Sample Participant
Questionnaire
57
-------
APPENDIX A
Hazardous Waste
Laws and
Regulations
Federal
Requirements For
HHW Management
Programs
EPA has issued regulations governing haz-
ardous waste under the Resource Conserva-
tion and Recovery Act (RCRA) and the
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA
or Superfund). This Appendix generally
summarizes the regulations that may be ap
plicable to HHW collection programs man-
aging various types of hazardous wastes. It
is important for organizers to consult appro-
priate EPA regional and state personnel to
get abetter understanding of how these regu-
lations apply to HHW collection programs.
In addition, state laws maybe more strin-
gent than the federal regulations described
below. Therefore, it also is important that
HHW collection organizers familiarize them-
selves with and follow state hazardous
waste requirements. Consult your state solid
and hazardous waste agency (see Appendix
B) for further information.
The Resource Conservation and
Recovery Act (RCRA)
RCRA is the federal law requiring
safeguards and encouraging environmen-
tally sound methods for disposal of
household, 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 to
grave "-from the moment it is generated
until its ultimate disposal. These controls
include:
• A tracking system that requires a
manifest document to accompany
transported hazardous waste from the
point of generation to the point of final
disposal.
• An identification and permitting sys-
tem that enables EPA and the states to
ensure the safe operation of all facilities
involved in the treatment, storage, and
disposal of hazardous waste. Certain
generators, transporters, and treatment,
storage, and disposal facilities (TSDFs)
must obtain an EPA identification num-
ber. TSDFs also must obtain a permit to
operate, which ensures that they meet
the standards established under the
RCRA program for proper waste
management.
• A system of restrictions and controls
on the placement of hazardous waste on
or into the land.
RCRA requirements for hazardous
waste management vary depending on
whether the waste is HHW, condition-
ally exempt small quantity generator
(CESQG) waste, or small quantity
generator (SQG) waste. These require-
ments are described below.
Household hazardous waste
Household waste, including HHW, is
exempt from federal hazardous waste
regulations and liability under RCRA
Subtitle C. Therefore, HHW is not regu-
lated under RCRA as a hazardous waste
(see 40 CFR 261 .4(b)(l)). Programs that
collect HHW do not need a Subtitle C
58
-------
LAWS AND REGULATIONS
permit or EPA identification number, and
HHW can be transported without following
hazardous waste transportation regulations
(e.g., people can bring HHW to a collection
facility in their cars). No quantity of HHW
or length of time of accumulation triggers
the Subtitle C requirements.
To be defined as "household" waste and
thus be exempt from federal hazardous
waste regulations, the waste must be:
Generated by individuals on the prem-
ises of a residence for individuals (a
household).
and
Composed primarily of materials found
in the wastes generated by consumers in
their homes.
Even if waste generated by a commercial
or industrial establishment looks like house-
hold waste, it is not exempt from federal
hazardous waste regulations.
The household waste exemption applies
to HHW through its entire management cy-
cle. The waste collected through a HHW col-
lection program does not lose its exemption
by being consolidated with other household
waste. In summary, if a program accepts
only waste from households, there are no ap-
plicable federal hazardous waste regulations.
Conditionally exempt small quantity
generator (CESQG) waste
Some communities decide to run pro-
grams that collect CESQG waste as well as
HHW. Communities generally make this de-
cision to help small businesses keep hazard-
ous waste out of the municipal waste
stream. Hazardous waste generators are con-
ditionally exempt from the federal hazard-
ous waste regulations if they generate less
than 100 kilograms (approximately 220
pounds or about half of a 55-gallon drum) of
hazardous waste per month. Like HHW,
CESQG waste is exempt from most of the
federal hazardous waste requirements. No
Subtitle C permit or EPA identification num-
ber is needed, and CESQG waste can be
transported without following the federal
hazardous waste transportation requirements.
In general, CESQGs must comply with
two requirements. They do not store more
than 1,000 kilograms (about 2,200 pounds)
of hazardous waste at their facility at one
time, and they send their hazardous waste to
a recycling facility, a hazardous waste facil-
ity, or a facility permitted, licensed, or regis-
tered by the state to manage municipal or
industrial solid waste (usually, a municipal
landfill). These CESQGs may send their haz-
ardous waste to HHW collection programs
that are state-permitted, licensed, or regis-
tered to manage municipal or industrial
solid waste. Because CESQG waste is condi-
tionally exempt throughout its management
cycle, collection programs managing
CESQG waste are not covered by the fed-
eral hazardous waste regulations, but are
subject to requirements imposed by states
through their municipal or industrial waste
permit, license, or registration programs.
EPA encourages the collection and proper
management of CESQG waste. Community
collection programs can help meet this goal
by accepting CESQG waste from schools,
small businesses, farms, government agen-
cies, and other commercial and institutional
hazardous waste generators.
CESQGs are responsible for ensuring
that their waste is managed in compliance
with federal requirements. They may ask the
collection program for documentation of reg-
istration or licensing if required by the state.
CESQGs can refer to EPA's Understanding
the Small Quantity Generator Hazardous
Waste Rules: A Handbook for Small Busi-
ness for more information about the require-
ments that apply to them. Contact your
59
-------
LAWS AND REGULATIONS
regional EPA office for this publication or
for more information.
EPA recommendations for
programs that collect HHW and
CESQG waste
Although HHW and CESQG waste are
exempt from most federal hazardous waste
regulations, EPA recommends that sponsors
of HHW collection programs manage the
collected waste as a Subtitle C hazardous
waste-that is, it should be managed at a re-
cycling or licensed hazardous waste facility.
Given the effort and expense a community
has already put into its HHW collection pro-
gram, it makes sense to ensure the greater
level of environmental protection that will
result from the Subtitle C controls.
EPA also recommends that HHW
collection programs use licensed hazardous
waste transporters who will properly iden-
tify, label, manifest, and transport the col-
lected wastes for recycling, treatment, or
disposal. State hazardous waste agencies
(see Appendix B) can provide a list of li-
censed facilities and transporters.
Small quantity generator (SQG) waste
SQGs are those that generate more than
100 kilograms (220 pounds) and less than
1,000 kilograms (2,200) pounds) of hazard-
ous waste per month. SQGs must use speci-
fied packaging for their waste; use a fully
completed manifest form when shipping the
waste off site; use only hazardous waste
transporters; and send their waste to author-
ized hazardous waste management facilities
with 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 a
RCRA Subtitle C permit (or is a transporter
who stores manifested shipments of hazard-
ous waste at a transfer facility for a period
of 10 days or less). Therefore, sponsors
should be careful to limit participation in
their programs to households and CESQGs
to avoid the need to obtain a RCRA permit.
To ensure that a hazardous waste generator
is a CESQG and not a regulated SQG, pro-
gram sponsors should establish procedures
to differentiate between the two types of
generators. Some programs exclude SQG
waste by requiring pre-registration by
CESQGs. At the time of pre-registration,
program personnel can inquire about the
types and quantities of waste that the gener-
ator wishes to bring to the collection.
The Comprehensive
Environmental
Response, Compensation,
And Liability Act
(CERCLA/Superfund)
Congress passed CERCLA in 1980 to ad-
dress the cleanup of inactive and abandoned
hazardous waste sites. Under CERCLA, if
cleanup of a hazardous waste disposal site is
necessary, all sources of the waste, as well
as the owner or operator of the site, might
be potentially responsible parties (PRPs),
who are liable for the entire cleanup cost for
the site.
CERCLA does not exclude HHW from li-
ability, nor does it allow any exemption
based on the amount of waste generated. If
HHW contains a substance defined as haz-
ardous under CERCLA, potential liability
exists. The Agency, however, will generally
not notify generators or transporters of mu-
nicipal solid waste—including HHW collec-
tion programs—that they are considered
PRPs, 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
-------
LAWS AND REGULATIONS
waste from commercial or industrial proc-
esses or activities, and used or spent sol-
vents from private or municipally owned
maintenance shops. EPA makes decisions
about notifying PRPs on a case-by-case ba-
sis, and may, in exceptional situations, no-
tify parties who generated or transported
only household waste to a site. PRPs may
sue other parties that they believe share li-
ability. Citizen suits are unrestricted.
While CERCLA does not exempt HHW
collection programs from liability, it is im-
portant to realize that the potential for liabil-
ity might be greater if a community takes no
action to ensure proper disposal of HHW.
The additional safeguards provided by
HHW collection and Subtitle C management
can reduce the likelihood of environmental
and human health impacts, and thereby
might reduce potential CERCLA liability.
For more information about federal
laws pertaining to HHW, you can call the
RCRA/Superfund Hotline at 800-424-9346.
In Washington, DC, please call 703-412-
9810. The Hotline is open Monday through
Friday, 8:30 a.m. to 7:30 p.m. EST. For
the hearing impaired, the TDD number is
800-553-7672. Alternatively, you can contact
your EPA regional office (see Appendix B).
State and Local
Requirements
Some states have regulations or guide-
lines for HHW management programs or
permanent HHW management facilities that
are more stringent than the federal require-
ments. These may include requirements for
a permit, permit variances, or a plan for the
collection day.
Some states do not have an exemption for
CESQGs; others might use a lower cut-off
than 100 kilograms per month or have differ-
ent management requirements. States also
might have CERCLA-type legislation allow-
ing recovery of the costs of hazardous waste
site cleanup. Organizers of HHW manage-
ment programs must check with their state
environmental officials (see Appendix B) to
learn about applicable regulations. In addi-
tion, local zoning, building, and fire codes
might apply to HHW collections; the appro-
priate local agencies must be contacted to
ensure compliance.
61
-------
APPENDIX B
State and Regional
Hazardous Waste
Contacts
State Contacts
Alabama
Land Division
Alabama Department of Environmental
Management
1751 Cong. William L. Dickinson Drive
Montgomery, AL 36130
205-271-7730
Alaska
Solid and Hazardous Waste
Management Section
Alaska Department of Environmental
Conservation
410 Willoughby Avenue, Suite 105
Juneau, AK 99801-1795
907-465-5150
American Samoa
Environmental Quality Commission
Government of American Samoa
Pago Pago, American Samoa 96799
Overseas Operator: 684-663-2304
Arizona
Office of Waste Programs
Arizona Department of Environmental
Quality
3033 N. Central Avenue
Phoenix, AZ 85012
602-207-4108
Arkansas
Hazardous Waste Division
Arkansas Department of Pollution
Control and Ecology
P.O. BOX 8913
Little Rock, AR 72219-8913
501-562-7444
California
Department of Toxic Substances Control
Hazardous Waste Division
P.O. Box 806
400 P Street
Sacramento, CA 95812-0806
916-324-1826
Colorado
Hazardous Materials and Waste
Management Division
Colorado Department of Health
4210 E. llth Avenue
Denver, CO 80220
303-331-4830
Commonwealth of Northern Mariana
Islands
Division of Environmental Quality
Department of Public Health and
Environmental Services
Commonwealth of the Northern
Mariana Islands
Saipan, Mariana Islands 96950
Overseas Operator: 670-234-6114
Cable Address: Gov. NMI Saipan
Connecticut
Bureau of Waste Management
Department of Environmental Protection
State Office Building
165 Capitol Avenue
Hartford, CT 06106
203-566-8476
62
-------
HAZARDOUS WASTE CONTACTS
Delaware
Division of Air and Waste Management
Department of Natural Resources and
Environmental Control
P.O. Box 1401
89 Kings Highway
Dover, DE 19903
302-739-4764
District of Columbia
Pesticides and Hazardous Materials
Division
Department of Consumer and
Regulatory Affairs
2100 Martin Luther King Avenue, SE.
Suite 203
Washington, DC 20020
202-404-1167
Florida
Division of Waste Management
UST
Department of Environmental
Regulations
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, FL 32339-2400
904-487-3299
Georgia
Land Protection Branch
Floyd Towers East/Room 1154
205 Butler Street, SE.
Atlanta, GA 30334
404-656-2833
Guam
Hazardous Waste Management program
Guam Environmental Protection Agency
IT& E Harmon Plaza
130 Rojas Street, Unit D-l
Harmon, Guam 96911
Overseas Operator 671-646-8863
Hawaii
Solid and Hazardous Waste Branch
Department of Health
5 Waterfront Plaza, Suite 250
500 Ala Moana Boulevard
P.O. Box 3378
Honolulu, HI 96813
808-586-4226
Idaho
Hazardous Materials Bureau
Water Quality Bureau, Division of
Environmental Quality
1410 North Hilton Street
Boise, ID 83706
208-334-5860
Illinois
Division of Land Pollution Control
Illinois Environmental Protection
Agency
2200 Churchill Road
Springfield, IL 62794-9276
217-785-8604
Indiana
Hazardous Waste Management Branch
Indiana Department of Environmental
Management
105 S. Meridian Street
Indianapolis, IN 46206-6015
317-232-3292
Iowa
Air Quality and Solid Waste Section
Department of Natural Resources
900 East Grand Avenue
Des Moines, IA 50319-0034
515-281-8852
Kansas
Air and Waste Management
Department of Health and Environment
Forbes Field, Building 740
Topeka, KS 66620
913-296-1593
63
-------
HAZARDOUS WASTE CONTACTS
Kentucky
Division of Waste Management
Department of Environmental Protection
18 Reilly Road
Frankfort, KY 40601
502-564-6716
Louisiana
Hazardous Waste Division
Louisiana Department of Environmental
Quality
P.O. Box 82178
7290 Bluebonnet Drive
Baton Rouge, LA 70884-2178
504-765-0355
Maine
Bureau of Hazardous Materials Control
and Solid Waste Control
Department of Environmental Protection
State House, Station #17
Augusta, ME 04333
207-289-2651
Maryland
Hazardous and Solid Waste
Management Administration
Maryland Department of the
Environment
2500 Browening Highway
Baltimore, MD 21224
410-631-3304
Massachusetts
Divison of Solid and Hazardous Waste
Massachusetts Department of
Environmental Protection
One Winter Street, 7th Floor
Boston, MA 02108
617-292-5853
Michigan
Waste Management Division
Department of Natural Resources
608 W. Allegan Street
Box 3338
Lansing, MI 48933
517-373-2730
Minnesota
Hazardous Waste Division
Minnesota Pollution Control Agency
520 Lafayette Road, North
St. Paul, MN 55155
612-297-8502
Mississippi
Division of Hazardous Waste
Management
Department of Natural Resources
P.O. Box 10385
Jackson, MS 39289-0385
601-961-5171
Missouri
Waste Management Program
Department of Natural Resources
Jefferson Building
205 Jefferson Street
P.O. Box 176
Jefferson City, MO 65102
314-751-3176
Montana
Solid and Hazardous Waste Bureau
Department of Health and
Environmental Sciences
Cogswell Building
Helena, MT 59620
406-444-2821
Nebraska
Department of Environmental Control
P.O. Box 98922
301 Centennial Mall S.
Lincoln, NE 68509-8922
402-471-4210
Nevada
Waste Management program
Division of Environmental Protection
Department of Conservation and
Natural Resources
Capitol Complex
123 West Nye Lane
Carson City, NV 89710
702-687-5872
64
-------
HAZARDOUS WASTE CONTACTS
New Hampshire
Office of Waste Management
Department of Environmental Services
6 Hazen Drive
Concord, NH 03301-6509
603-271-2900
New Jersey
Division of Hazardous Waste
Management
Department of Environmental Protection
401 East State Street/CN 028
Trenton, NJ 08625
609-292-1250
New Mexico
Hazardous and Radioactive Waste
Bureau
Environmental Department
525 Camino de los Marquez
P.O. Box 26110
Santa Fe, NM 87502
505-827-4308
New York
Division of Solid and Hazardous Waste
Department of Environmental
Conservation
50 Wolf Road
Albany, NY 12233
518-457-6603
North Carolina
Solid and Hazardous Waste
Management Branch
Division of Health Services
Department of Human Resources
P.O. Box27687
Raleigh, NC 27611-7687
919-733-2178
North Dakota
Division of Waste Management
Department of Health Management and
Special Studies
1200 Missouri Avenue, Room 302
Bismarck, ND 58502-5520
701-221-5166
Ohio
Division of Solid and Hazardous Waste
Management
Ohio Environmental Protection Agency
P.O. Box 1049
Columbus, OH 43266-0149
614-644-2958
Oklahoma
Hazardous Waste Management Service
Oklahoma State Department of Health
1000 Northeast 10th Street
Oklahoma City, OK 73117-1299
405-271-7052
Oregon
Hazardous and Solid Waste Division
Department of Environmental Quality
811 Southwest 6th Avenue, 8th Floor
Portland, OR 97204-1390
503-229-5913
Pennsylvania
Division of Hazardous Waste
Management
Pennsylvania Department of
Environmental Resources
P.O. Box 2063
Fulton Building
Hamsburg, PA 17105-2063
717-787-9870
Puerto Rico
Environmental Protection Agency
1413 Fernadez Juncos
Santurce, PR 00909
809-729-6920
Rhode Island
Air and Hazardous Materials Program
Department of Environmental
Management
291 Promenade Street
Providence, RI 02908
401-277-2797
65
-------
HAZARDOUS WASTE CONTACTS
South Carolina
Bureau of Solid and Hazardous Waste
Management
Department of Health and
Environmental Control
2600 Bull Street
Columbia, SC 29201
803-734-5200
South Dakota
Office of Air Quality and Solid Waste
Department of Water and Natural
Resources
523 E. Capitol
Foss Building, Room 416
Pierre, SD 57501
605-773-3153
Tennessee
Division of Solid Waste Management
Tennessee Department of Public Health
701 Broadway
Customs House, 4th Floor
Nashville, TN 37219-5403
615-741-3424
Texas
Industrial and Hazardous Waste Division
Texas Water Commission
P.O. Box 13087
Austin, TX 78711-3087
512-908-2334
Utah
Bureau of Solid and Hazardous Waste
Management
Department of Environmental Quality
288 North 1460 West
Salt Lake City, UT 84114-4880
801-538-6170
Vermont
Hazardous Waste Management Division
Agency of Environmental Conservation
103 South Maine Street
Waterbury, VT 05761-0404
802-244-8702
Virgin Islands
Department of Planning and Natural
Resources
Suite 231, Nisky Center
45-A Estate Nisky
St. Thomas, VI 00802
809-774-3320
Virginia
Hazardous Waste Division
Virginia Department of Waste
Management
Monroe Building, llth Floor
101 North 14th Street
Richmond, VA 23219
804-225-4761
Washington
Solid and Hazardous Waste
Management Program
Department of Ecology
P.O. Box 47600
Olympia, WA 98504-7600
206-459-6316
West Virginia
Waste Management Division
Commerce, Labor, and Environmental
Resources
1356 Hansford Street
Charleston, WV 25301
304-348-5929
Wisconsin
Bureau of Solid and Hazardous Waste
Management
Department of Natural Resources
P.O. Box 7921 /SW-3
Madison, WI 53707-7921
608-266-2111
Wyoming
Solid Waste Management Program
State of Wyoming Department of
Environmental Quality
122 West 25th Street
Herschler Building
Cheyenne, WY 82002
307-777-7752
66
-------
HAZARDOUS WASTE CONTACTS
EPA Regional Contacts
EPA Region 1
(Connecticut Maine, Massachusetts, New
Hampshire, Rhode Island, Vermont)
Contact:
Waste Managenent Division
90 Canal Street
Boston, MA 02 14
617-573-5707
EPA Region 2
(New Jersey, New York, Puerto Rico,
Virgin Islands)
Contact:
Hazardous Waste Compliance Branch
26 Federal Plaza, 10th Floor
New York, NY 10278
212-264-2301
EPA Region 3
(Delaware, District of Columbia,
Maryland, Pennsylvania, Virginia,
West Virginia)
Contact:
Waste Management Branch (3HW30)
841 Chestnut Street
Philadelphia, PA 19107
215-597-6633
EPA Region 4
(Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina, South
Carolina, Tennessee)
Contact
Residuals Management Branch
345 Courtland Street, NE.
Atlanta, GA 30365
404-347-7603
EPA Region 5
(Illinois, Indiana, Michigan, Minnesota,
Ohio, Wisconsin)
Contact:
RCRA Program Management Branch
77 W. Jackson Boulevard HRE-8
Chicago, IL 60604-3507
312-886-4434
EPA Region B
(Arkansas, Louisiana, New Mexico,
Oklahoma Texas)
Contact:
RCRA Programs Branch (6H-H)
First Interstate Bank Tower
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
214-655-6700
EPA Region 7
(Iowa, Kansas, Missouri, Nebraska)
Contact:
RCRA Branch
726 Minnesota Avenue
Kansas City, KS 66101
913-551-7051
EPA Region 8
(Colorado, Montana, North Dakota,
South Dakota, Utah, Wyoming)
Contact
Hazardous Waste Management Division
One Denver Place
999 18th Street Suite 500
Denver, CO 80202-2405
303-293-1720
EPA Region 9
(Arizona, California, Hawaii, Nevada,
Guam, Marianas)
Contact
Office of Waste Programs (T-2A)
75 Hawthorne Street
San Francisco, CA 94105
415-744-1500
EPA Region 10
(Alaska, Idaho, Oregon, Washington)
Contact:
Hazardous Waste Management
1200 Sixth Avenue, 11th Floor
Seattle, WA 98101
206-553-4973
67
-------
APPENDIX C
Information
Resources
Organizations
Agency of Environmental Conservation
(paint swaps)
103 S. Main Street, M Building
Waterbury, VT 05671-0407
802-244-7831
Bio-Integral Resource Center (BIRC)
P.O. Box 7414
Berkeley, CA 94707
510-524-2567
California Integrated Waste Management
Board
8800 Cal Center Drive
Sacramento, CA 95826
916-255-2200
Center for Safety in the Arts
5 Beekman Street, Suite 1030
New York, NY 10038
212-227-6220
Concern, Inc.
1794 Columbia Road, NW.
Washington, DC 20009
202-328-8160
Ecology Center of Ann Arbor
201 Detroit Street
Ann Arbor, MI 48104
313-761-3186
Environmental Hazards Management
Institute (EHMI) (HHW wheels)
10 Newmarket Road, P.O. Box 932
Durham, NH 03824
603-868-1496
Environmental Health Coalition
1717 Kettner Drive #100
San Diego, CA 92101
619-235-0281
Household Hazardous Waste Project
1031 East Battlefield, Suite 214
Springfield, MO 65807
417-889-5000
Metrocenter YMCA
909 Fourth Avenue
Seattle, WA 98104
206-382-5013
Minnesota Office of Consumer Policy
NCL Tower, Suite 1400
445 Minnesota Street
St. Paul, MN 55101-2131
612-296-7575
Minnesota Pollution Control Agency
520 Lafayette Road, North
St. Paul, MN 55155
612-296-6300
National Coalition Against the Misuse of
Pesticides
701 E Street, SE., Suite 200
Washington, DC 20003
202-543-5450
National Recycling Coalition
1101 30th Street, NW.
Suite 305
Washington, DC 20007
202-625-6406
Nuclear Regulatory Commission (smoke
detectors)
Washington, DC 20555
301-504-2240
68
-------
INFORMATION RESOURCES
Office of Solid Waste
U.S. EPA
401M Street, SW. (OS-305)
Washington, DC 20460
EPA RCRA/Superfund Hotline:
800-424-9346
Project ROSE (used oil)
University of Alabama
P.O. Box 870203
Tuscaloosa, AL 35487-0203
205-348-4878
Solid and Hazardous Waste Management
Program
Washington Department of Ecology
P.O. Box 47655
Olympia, WA 98504-7655
206-459-6303
Solid Waste Information Clearinghouse
(SWICH)
800-67-SWICH
Toxicant/HHW Project
METRO
821 Second Avenue, Mail Stop 81
Seattle, WA 98104
206-684-1233
University of Wisconsin Cooperative
Extension
Environmental Resources Center
1450 Linden Drive
Madison, WI 53706
608-262-0020
Washington Toxics Coalition
4516 University Way, NE
Seattle, WA 98105
206-632-1545
Waste Watch Center
16 Haverhill Street
Andover, MA01810
508-470-3044
Books and Pamphlets
Alternatives (a series of fact sheets),
Washington Toxics Coalition.
(EPA/53 O-SW-88-014).
Bibliography on Household Hazardous
Wastes, U.S. Environmental Protection
Agency. Available through the
RCRA/Superfund Hotline, 800-424-9346.
Chemicals in Household Products, Bradley
C. Clark, Ingham County Health
Department, 5303 S. Cedar, P.O. Box
30161, Lansing, MI 48909.
Decision Makers Guide to Solid Waste
Management (1990), U.S. Environmental
Protection Agency. Available through the
RCRA/Superfund Hotline, 800-424-9346.
(EPA/53 O-SW-89-072).
Disposal—Do It Right, Household Products
Disposal Council, 1201 Connecticut
Avenue, NW., Suite 300, Washington, DC
20036,202-659-5535.
The "Environmentally Friendly" Consumer
Office of the Minnesota Attorney
General, Consumer Services Division,
1400 North Central Life Tower, St. Paul,
MN 55101,612-296-3353.
Fire Protection Guide to Hazardous
Materials (1990), National Fire
Protection Association, 1 Batterymarch
Park, P.O. Box 9101, Qurncy, MA
02269-9101,800-344-3555.
Guide to Hazardous Products Around the
Home (1989), Household Hazardous
Waste Project, Springfield, MO.
Hazardous Wastes from Homes, Enterprise
for Education, 1320 A Santa Monica
Mall, Santa Monica CA 90401,
213-394-9864.
Home Safe Home, Washington Toxics
Coalition.
Household Batteries in Minnesota, Karen
Arnold et al., Minnesota Pollution
Control Agency.
69
-------
INFORMATION
RESOURCES
Household Hazardous Waste: Guidelines
for Conducting Collection Events (1989),
Washington Department of Ecology.
Household Hazardous Wrote: Solving the
Disposal Dilemma, Gina Purin et al.,
Local Government Commission, 909
12th Street, Suite 205, Sacramento, CA
95814,916-448-1198.
Household Hazardous Waste Management
Planning (1990), Donald Seeberger,
Hennepin (MN) County Environment and
Energy Division/Urban Consortium
Ninth Year Energy program.
Household Hazardous Waste Wheel, EHMI,
Durham, NH.
Household Hazardous Wastes: Feasibility of
Operating a Collection and Disposal
Assistance Program, (1989), Illinois
Environmental Protection Agency
(IEPA/ENV/99-066).
Household Hazards: A Guide to
Detoxifying Your Home (1991), League
of 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 Collection
Day, Department of Environmental
Protection, Hartford, CT.
How to Set Up a Local Program to Recycle
Used Oil (1989), U.S. Environmental
protection Agency
(EPA/530-SW-89-039a).
The Merck Index: An Encyclopedia of
Chemicals and Drugs, Merck and
Company, Rahway, NJ.
Proceedings of the Sixth National
Conference on Household Hazardous
Waste Management, Dana Duxbury &
Associates, 1991. Summaries of the First
(PB89-179-501), Second (PB89-179-519),
and Third (PB89-179-527) National
Conferences also are available from the
Center for Environmental Management,
Tufts University. Proceedings from the
Fourth (PB90- 163-189) and Fifth
(PB91-206-607) National Conferences
are available from the National Technical
Information Service, Springfield, VA
800-553-6847 or Waste Watch Center
508-470-3044.
Recycling Used Oil: What Can You Do?
(EPA/530-SW-89-039B), Recycling Used
Oil: 10 Steps to Change Your Oil
(EPA1530-SW-89-039C), Recycling Used
Oil: For Service Stations and Other
Vehicle Service Facilities
(EPA/530-SW-89-039d), U.S.
Environmental Protection Agency. These
pamphlets are available through the
RCRA/Superfund Hotline,
800-424-9346.
States' Efforts to Promote Lead-Acid Battery
Recycling (PB92-119-965), U.S.
Environmental Protection Agency.
Available from the National Technical
Information Service, 800-553-6847.
A Survey of Household Hazardous Wastes
and Related Collection Programs, U.S.
Environmental Protection Agency.
Available through the RCRA/Superfund
Hotline, 800-424-9346
(EPA/530-SW-86-038).
Take Me Shopping: A Consumer Guide to
Using Specific Materials, Techniques,
and Substitutes for HHW Santa Clara
County Hazardous Waste Management
Program, 408-441-1195.
Used Oil Recycling (newsletter), U.S.
Environmental Protection Agency.
Available through the RCRA/Superfund
Hotline, 800-424-9346.
Periodicals
BioCycle
419 State Avenue, Second Floor
Emmaus, PA 18049
215-967-4135
70
-------
INFORMATION RESOURCES
Garbage
2 Maine Street
Gloucester, MA 01930
508-283-3200
Household Hazardous Waste Management
News
The Waste Watch Center
16 Haverhill Street
Andover, MA01810
508-470-3044
Resource Recycling
P.O. Box 10540
Portland, OR 97210
800-227-1424
Wanner Bulletin
The World Resource Foundation
83 Mount Ephraim
Tunbridge Wells, Kent UK TN4 8BS
0892-24626
Waste Age
1730 Rhode Island Avenue, NW.
Suite 1000
Washington, DC 20036
202-861-0708
World Wastes
Communications Channels, Inc.
6255 Barfield Road
Atlanta, GA 30328
404-256-9800
Audiovisual Materials
Videotapes and other audiovisual materials
are available from:
Ecology Center of Ann Arbor
417 Detroit Street
Ann Arbor, MI 48104
313-761-3186
Environmental Health Coalition
1717 Kettner Blvd. #100
San Diego, CA 92101
619-235-0281
HHW Project
Washington Department of Ecology
P.O. Box47655
Olympia, WA 98504-7655
206-459-6303
Massachusetts League of Women Voters
133 Portland Street
Boston, MA 02114
617-523-2999
Prevention Program
Contra Costa County Health Services
75 Santa Barbara Road
Pleasant Hill, CA 94523
510-646-6511
Refuse Industry Products, Inc.
P.O. Box 1011
Grass Valley, CA 95945
916-274-3092
San Bernardino County DHS
HazMat Risk Assessment & Planning
385 N. Arrowhead Ave.
San Bernardino, CA 92415-0160
714-387-4629
The Video Project
LMV of California
926 J Street, Suite 1000
Sacramento, CA 95814
916-442-7215
HHW Curricula for
Schools
(compiled from information provided by
the Household Hazardous Waste Project,
Springfield, MO)
Activities for Teaching about Hazardous
Materials in the Home (1989). Grades:
K-3, 4-6,7-9, 10-12. ERIC Science,
Mathematics, and Environmental
Education Clearinghouse, The Ohio State
University, 1200 Chambers Road, 3rd
Floor, Columbus, OH 43212,
614-292-6717.
71
-------
INFORMATION RESOURCES
Bags, Beakers, and Barrels: An Action
Curriculum Toward Resolving Hazardous
Materials Issues (1987). Six units and 35
activities. Grades: Middle and High
School. Industrial States Policy Center,
17 Brickel Street, Columbus, OH 43215,
614-224-4111.
CHEM: Chemicals, Health, Environment,
andMe (1990). Ten teaching units.
Grades: Middle or High School.
Chemical Education for Public
Understanding Program (CEPUP),
Lawrence Hall of Science, University of
California, Berkeley, CA 94720,
510-642-8718.
Garbage in America (1988). Recycling and
environmental curriculum, including
video. Grades: K-6, Junior High, Senior
High. Refuse Industry Productions, P.O.
Box 1011, Grass Valley, CA 95945,
916-274-3092.
Hazardous Waste Education Kit. Kit with 5
workbooks and a resource section.
Grades: 7-9. Federation of Ontario
Naturalists, 355 Lesmill Road, Don Mills
ON, M3B 2W8 CANADA,
416-444-8419.
Hazardous Wrote School Curriculums.
Grades: K-12. State of Alaska,
Department of Environmental
Conservation, PO. Box 0, Juneau, AK
99811-1800,907-465-2671.
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 and
Labels: A Reference for Teachers (1986).
Book and worksheets. Grades: Middle
School. East Michigan Environmental
Action Council, 21220 West
Fourteen-mile Road, Birmingham, MI
48010,313-258-5188.
Household Hazardous Materials: Pollution
Solutions Start at Home (1989). Three
5-day units. Grades: Middle School.
Environmental Health Coalition, 1717
Kettner Blvd. #100, San Diego, CA
92101,619-235-0281.
Household Hazardous Waste Educational
Program Kit (1986). Handbook and
instructional materials. Grades: K-6. San
Bernardino County, Department of
Environmental Health Services,
Environmental Education Program, 385
N. Arrowhead Avenue, San Bernardino,
CA 92415-0160,714-387-4639.
Household Hazardous Waste Learning
Stations (1990). Ten learning stations and
a video. Grades: 4-6. Minnesota
Pollution Control Agency, 520 Lafayette
Road North, St. Paul, MN 55155,
612-297-8324. Will distribute only in MN.
Household Toxics (1988). Grades: 4-6. Six
lesson plans with activities and games.
Environmental Health Coalition, 1717
Kettner Blvd. #100, San Diego, CA
92101,619-235-0281.
Household Toxics (1 989). Interdisciplinary
with 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 Guide
to Household Hazardous Substances and
the Classroom. Video with activities and
resources. Grades: Middle and High
School Teachers. Ecology Center of Ann
Arbor, 201 Detroit Street, Ann Arbor, MI
48104,313-761-3186.
A Manual for the Household Hazardous
Materials Audit (1987). Booklet and
survey. Grades: Middle Schools through
Adults. Alaska Center for the
Environment, 519 W 8th Avenue, Suite
201, Anchorage, AK 99501,
907-274-3621.
72
-------
INFORMATION RESOURCES
Project Erase Waste (1991). Ten lessons
about solid waste management with
activities. Grade: 6. Kern County Waste
Management 2700 "M" Street, Suite 500,
Bakersfield, CA 93301,805-861-2159.
SLEUTH: Strategies and Lessons to
Eliminate Unused Toxicants, Help!
(1982). Teaching unit that presents HHW
issues. Grades: 4-12. METRO, Water
Resources Section, HHW Project, 821
Second Avenue, MS 81, Seattle, WA
98104-1598,206-684-1233. This
document is only available on a
check-out basis.
Too Close for Comfort: Reducing
Household Toxics. Video on health and
environmental problems associated with
common household products. Grades: 4
through Adult. Prevention Program, 75
Santa Barbara Road, Pleasant Hill, CA
94523,510-646-6511.
Tools for the Environmental Teacher (1992).
Inventory, worksheets, and a game.
Grades: Junior and Senior High
School. Household Hazardous Waste
Project, 1031 East Battlefield, Suite
214, Springfield, MO 65807,
417-884-5000.
Toxics in My Home? You Bet! (1984).
One-week curriculum available in
English and Spanish. Grades: K-12.
Local Government Commission, Inc.,
909 12th Street, Suite 205, Sacramento,
CA 95814,916-448-1198.
73
GOVERNMENT PRTKPTTNR (TPPTrE • 1OQ1 n -
-------
APPENDIX D
Sample Participant
Questionnaire
Do you own or rent your home?
O Rent DOwn
2. Ageunder25
3. Sex
O 26-40
Female Q Male
O 41-65
O Over 65
4.
5.
6.
City.
Zip Code.
8.
9.
10.
12.
13.
14.
This waste is left over from what type of operation?
Q Household Q Farming/ranching Q Commercial/business
Please check the type of hazardous waste you brought:
Q Used oil D Medications Q paint [
D Solvents LI Pesticides LI Battenes
Are the wastes you brought from more than one household?
Dves G No
How many households?
How long have you had the wastes?
How far did you drive to come to today's collection event?
Ql-5miles H 6-10miles 13 11-15miles
016-20 miles C Over 20 miles
How far would you be willing to drive?
How did you hear about the collection day?
Q Poster LI Billboard LI Radio
Q Television Q Insert with utility bill Q Newspaper article
Q Newspaper ad Q School/children Q Grocery store flyer
Cbther
Q Unlabeled Containers
Q Other Wastes
Q Brochure delivered to home
Q Word of mouth
Have you ever been to a household hazardous waste collection before?
Dves DN 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.
D Nothing D $5/month $ (fill in amount)
How often would you use a household hazardous waste collection in your area?
Q/lonthly D Twice a year D Once a year D Once every 2 years
If this collection event had not been held, what would you have done with your
household hazardous waste?
Source Dakota County Household Hazardous Waste Collection Inventory and Data Sheet; San Francisco Household Hazardous Waste Collection Facility
Participant 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 experts
not employed by the Environmental Protection
Agency, and by appropriate offices within the Agency.
------- |