United States
            Evironmental Protection
            Solid Waste and
            Emergency Response
August 1993
Household Hazardous
Waste Management

A Manual for One-Day
Community Collection Programs
                            ' Printed on paper that contains at least 50% recycled fiber

         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

Household Hazardous
Waste Management
A  Manual for One-Day
Community Collection  Programs
                           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

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

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

   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.

                        better understanding of waste issues in

                           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
           1980   1981   1982   1983   1984   1985   1986   1987   1988   1989   1990   1991

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

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

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
    Developing Requests for Proposals
    (RFPs) and contracts with a licensed
     hazardous waste contractor.
    Recruiting, managing, and delegating  re-
    sponsibilities to  supporting agencies and
    Involving community leaders and resi-
    dents in planning and implementing the

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

The Planning

   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
    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
• Properly training its collection staff.
•  Obtaining necessary insurance.
•  Consulting with the program planners
     about waste management methods to be
• Identifying appropriate hazardous waste
• 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
  •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
  •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

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
•Publicize results
•Thank  participants and volunteers
   through the media
•Write  summary report
•Prepare for future events

Involve the
  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
  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-

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
•  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

Establish Goals
   Every HHW management program needs
clear, realistic  goals and feasible  ways of
achieving  them.  Typical program goals
• 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

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
                                                  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.

Selecting Wastes
 and Collection

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
   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

                       SELECTING   COLLECTION   METHODS
Decide Whether to
Limit the Amount
  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
  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

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

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
   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
    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
    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

                                              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

   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

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
   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-

   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.

Selecting Waste

   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
    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
    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.

                     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.

   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
   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
•  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.

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  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.

   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
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).

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

  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

                                             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
• In-Transit  Insurance.  In-transit insur-
   ance is required by the Department of
   Transportation  for  interstate  movement


    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

   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.

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

   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.

                                      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
                                      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

   Funding the
  Program and
Controlling Costs

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.

Ways To Minimize
   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
•  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
State and Local
  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

                                             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.
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.

                 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.


• 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

            SECTION SIX
          Publishing the
           Request for
          Proposals and
       Signing the Contract
357-4450 -93- 3:QL3

    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
•  A detailed narrative description of the
     sponsor's goals for the  program.
•  The proposed collection site(s) and
•  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-
•   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
    •  testing unknown wastes.
    •  labeling wastes.
    •  combining materials for reuse (e.g.,
       paint consolidation).
    •  filling out hazardous waste forms
    •  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

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
     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.)
     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
     •  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.

    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
    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  costs. The proposal should
    include itemized  costs for site set-up, la-
    bor, equipment materials, hazardous
    waste training, transportation, and
    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
    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-
•  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

                                          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
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
of the contract.
The contractor's guarantee of compli-
ance with any applicable laws.


• 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.

Selecting, Designing,
 and  Operating the
   Collection Site

         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.

                                                                    SITE    CONSIDERATIONS
                         Site Design and

                           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.


                    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
                            u  u  u
                                                                               Zone for
                                Unloading Zone for
                     'Escape Route
                   for Ineligible Vehicles
                   	I    I	
                Unloading Zone
              Check Identification
Traffic Flow & Traffic Holding Line
                              Legend (not to scale):  O Drum
More complex site plan for a one-day drop-off HHW collection program.

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

Temporary Storage
   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
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.

    Training the
Collection Day Staff

   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
   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.

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-

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

be performed under the  contractor's
   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

Education and

         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-
• 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
•  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
•  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

                                                            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

   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

   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
   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.

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
•  Which materials will be accepted and
    which will be excluded.
•  What to do with excluded HHW.
•  How to transport HHW to the collection

   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
• 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

Evaluating the

       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
   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

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
   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.
   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
•   Raleigh's cable television station aired
    an informational program on HHW
    several times.

                                                        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.)
    Water bill inserts
    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
   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


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
   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
Source: Cindy Kling, City of Raleigh, Public
 Utilities Department.

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
   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.

  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.

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.

A. Hazardous Waste Laws and
B. State and Regional
   Hazardous Waste Contacts

C. Information Resources

D. Sample Participant

    Hazardous Waste
           Laws  and
Requirements  For
HHW  Management
  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
•  A tracking system that requires a
   manifest document to accompany
   transported hazardous waste from the
   point of generation to the point of final
•  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
• 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

                                       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
    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

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
Response,  Compensation,
And  Liability Act

  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

                                      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

   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.

   State  and  Regional
   Hazardous   Waste
State Contacts

   Land Division
   Alabama Department of Environmental
    1751 Cong. William L. Dickinson Drive
   Montgomery, AL 36130

   Solid and Hazardous Waste
      Management Section
   Alaska Department of Environmental
   410 Willoughby Avenue, Suite 105
   Juneau, AK 99801-1795

American Samoa
   Environmental Quality Commission
   Government of American Samoa
   Pago Pago, American Samoa 96799
   Overseas  Operator: 684-663-2304

   Office of Waste Programs
   Arizona Department of Environmental
   3033 N. Central Avenue
   Phoenix, AZ 85012
   Hazardous Waste Division
   Arkansas Department of Pollution
      Control and Ecology
   P.O. BOX 8913
   Little Rock, AR 72219-8913

   Department of Toxic Substances Control
   Hazardous Waste Division
   P.O. Box 806
   400 P Street
   Sacramento, CA 95812-0806

   Hazardous Materials and Waste
      Management Division
   Colorado Department of Health
   4210 E. llth Avenue
   Denver, CO 80220

Commonwealth  of Northern  Mariana
   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

   Bureau of Waste Management
   Department of Environmental Protection
   State Office Building
    165 Capitol Avenue
   Hartford, CT 06106

                           HAZARDOUS   WASTE   CONTACTS
    Division of Air and Waste Management
    Department of Natural Resources and
      Environmental Control
    P.O. Box 1401
    89 Kings Highway
    Dover, DE 19903

District of Columbia
    Pesticides and Hazardous Materials
    Department of Consumer and
      Regulatory Affairs
    2100 Martin Luther King Avenue, SE.
    Suite 203
    Washington, DC 20020

    Division of Waste Management
    Department  of Environmental
    Twin Towers Office Building
    2600 Blair Stone Road
    Tallahassee, FL  32339-2400

    Land Protection  Branch
    Floyd Towers East/Room 1154
    205 Butler Street, SE.
    Atlanta, GA 30334

    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
    Solid and Hazardous Waste Branch
    Department of Health
    5 Waterfront Plaza, Suite 250
    500 Ala Moana Boulevard
    P.O. Box 3378
    Honolulu, HI 96813

    Hazardous Materials Bureau
    Water Quality  Bureau, Division of
      Environmental  Quality
    1410 North Hilton Street
    Boise, ID 83706

    Division of Land Pollution Control
    Illinois Environmental Protection
    2200 Churchill Road
    Springfield, IL 62794-9276

    Hazardous Waste  Management Branch
    Indiana Department of Environmental
    105 S. Meridian Street
    Indianapolis, IN 46206-6015

    Air Quality and Solid Waste Section
    Department  of Natural Resources
    900 East Grand Avenue
    Des Moines, IA 50319-0034

    Air  and Waste Management
    Department  of Health and Environment
    Forbes Field, Building 740
    Topeka, KS 66620

   Division of Waste Management
   Department of Environmental Protection
    18 Reilly Road
   Frankfort, KY 40601

   Hazardous Waste Division
   Louisiana  Department of Environmental
   P.O. Box 82178
   7290 Bluebonnet Drive
   Baton Rouge, LA 70884-2178

   Bureau  of Hazardous Materials Control
      and Solid Waste  Control
   Department of Environmental Protection
   State House, Station #17
   Augusta, ME 04333

   Hazardous and Solid Waste
      Management  Administration
   Maryland Department of the
   2500 Browening Highway
   Baltimore, MD 21224

   Divison of Solid and Hazardous Waste
   Massachusetts Department of
      Environmental Protection
   One Winter Street,  7th Floor
   Boston, MA 02108

   Waste Management Division
   Department of Natural Resources
   608  W. Allegan Street
   Box 3338
   Lansing, MI 48933
   Hazardous Waste Division
   Minnesota Pollution Control Agency
   520 Lafayette Road, North
   St. Paul, MN 55155

   Division of Hazardous Waste
   Department of Natural Resources
   P.O. Box 10385
   Jackson, MS 39289-0385

   Waste Management Program
   Department of Natural Resources
   Jefferson Building
   205 Jefferson Street
   P.O. Box 176
   Jefferson City, MO 65102

   Solid  and Hazardous Waste Bureau
   Department of Health and
      Environmental Sciences
   Cogswell Building
   Helena, MT 59620

   Department of Environmental Control
   P.O. Box 98922
   301 Centennial Mall S.
   Lincoln, NE 68509-8922

   Waste Management program
   Division of Environmental  Protection
   Department of Conservation and
      Natural Resources
   Capitol Complex
    123 West Nye Lane
   Carson City, NV 89710

                          HAZARDOUS   WASTE   CONTACTS
New Hampshire
    Office of Waste Management
    Department of Environmental  Services
    6 Hazen Drive
    Concord, NH 03301-6509

New Jersey
    Division of Hazardous Waste
    Department of Environmental  Protection
    401 East  State Street/CN 028
    Trenton, NJ 08625

New Mexico
    Hazardous and Radioactive Waste
    Environmental Department
    525 Camino de los Marquez
    P.O. Box 26110
    Santa Fe, NM 87502

New York
    Division of Solid and Hazardous Waste
    Department  of Environmental
    50 Wolf Road
    Albany, NY 12233

North Carolina
    Solid and Hazardous Waste
      Management Branch
    Division of Health Services
    Department  of Human Resources
    P.O. Box27687
    Raleigh, NC 27611-7687

North Dakota
    Division of Waste Management
    Department  of Health Management and
      Special Studies
    1200 Missouri Avenue, Room 302
    Bismarck, ND 58502-5520
   Division of Solid and Hazardous Waste
   Ohio  Environmental Protection Agency
   P.O. Box 1049
   Columbus, OH 43266-0149

   Hazardous Waste Management Service
   Oklahoma State Department of Health
    1000 Northeast 10th Street
   Oklahoma City, OK 73117-1299

   Hazardous and Solid Waste Division
   Department of Environmental Quality
   811 Southwest 6th Avenue, 8th Floor
   Portland, OR 97204-1390

   Division of Hazardous Waste
   Pennsylvania Department of
      Environmental  Resources
   P.O. Box 2063
   Fulton Building
   Hamsburg, PA 17105-2063

Puerto Rico
   Environmental Protection Agency
    1413 Fernadez Juncos
    Santurce, PR 00909

Rhode Island
   Air and Hazardous Materials Program
   Department of Environmental
    291 Promenade Street
   Providence, RI 02908

South Carolina
    Bureau of Solid and Hazardous Waste
    Department of Health and
      Environmental  Control
    2600 Bull Street
    Columbia,  SC 29201

South Dakota
    Office of Air Quality and Solid Waste
    Department of Water and Natural
    523 E. Capitol
    Foss Building, Room 416
    Pierre, SD 57501

    Division of Solid Waste Management
    Tennessee Department of Public  Health
    701 Broadway
    Customs House, 4th Floor
    Nashville,  TN 37219-5403

    Industrial and  Hazardous Waste  Division
    Texas Water Commission
    P.O. Box 13087
    Austin, TX 78711-3087

    Bureau of  Solid and Hazardous Waste
    Department of Environmental Quality
    288 North  1460 West
    Salt Lake City, UT 84114-4880

    Hazardous Waste Management Division
    Agency  of Environmental  Conservation
    103 South Maine Street
    Waterbury, VT 05761-0404
Virgin Islands
    Department of Planning and Natural
    Suite 231, Nisky Center
    45-A Estate Nisky
    St. Thomas, VI 00802

    Hazardous Waste Division
    Virginia Department of Waste
    Monroe Building, llth Floor
    101 North 14th Street
    Richmond, VA 23219

    Solid and Hazardous Waste
      Management  Program
    Department of Ecology
    P.O. Box 47600
    Olympia,  WA 98504-7600

West Virginia
    Waste Management Division
    Commerce, Labor, and Environmental
    1356 Hansford Street
    Charleston, WV 25301

    Bureau of Solid and Hazardous Waste
    Department  of Natural Resources
    P.O. Box 7921  /SW-3
    Madison, WI  53707-7921

    Solid Waste Management Program
    State of Wyoming Department of
      Environmental Quality
    122 West 25th Street
    Herschler Building
    Cheyenne, WY 82002

                          HAZARDOUS   WASTE   CONTACTS
EPA  Regional  Contacts

EPA Region 1
    (Connecticut Maine, Massachusetts, New
      Hampshire, Rhode Island, Vermont)
    Waste  Managenent Division
    90 Canal Street
    Boston, MA  02  14

EPA Region 2
    (New Jersey, New York, Puerto Rico,
      Virgin Islands)
    Hazardous Waste Compliance Branch
    26 Federal Plaza, 10th Floor
    New York, NY 10278

EPA Region 3
    (Delaware, District of Columbia,
      Maryland, Pennsylvania, Virginia,
      West Virginia)
    Waste Management Branch (3HW30)
    841  Chestnut Street
    Philadelphia, PA 19107

EPA Region 4
    (Alabama, Florida, Georgia, Kentucky,
      Mississippi, North  Carolina, South
      Carolina,  Tennessee)
    Residuals Management  Branch
    345  Courtland Street,  NE.
    Atlanta, GA 30365

EPA Region 5
    (Illinois, Indiana, Michigan, Minnesota,
      Ohio, Wisconsin)
    RCRA Program Management Branch
    77 W. Jackson Boulevard HRE-8
    Chicago, IL 60604-3507
EPA Region B
    (Arkansas, Louisiana, New Mexico,
      Oklahoma Texas)
    RCRA Programs Branch (6H-H)
    First Interstate Bank Tower
    1445 Ross Avenue, Suite 1200
    Dallas, TX 75202-2733

EPA Region 7
    (Iowa, Kansas, Missouri, Nebraska)
    RCRA Branch
    726 Minnesota Avenue
    Kansas City, KS 66101

EPA Region  8
    (Colorado,  Montana, North Dakota,
      South Dakota, Utah, Wyoming)
    Hazardous  Waste Management Division
    One Denver Place
    999 18th Street Suite 500
    Denver, CO 80202-2405

EPA Region 9
    (Arizona, California, Hawaii, Nevada,
      Guam,  Marianas)
    Office of Waste Programs  (T-2A)
    75 Hawthorne Street
    San Francisco, CA 94105

EPA Region 10
    (Alaska, Idaho,  Oregon, Washington)
    Hazardous Waste Management
    1200 Sixth Avenue, 11th Floor
    Seattle, WA 98101


Agency of Environmental Conservation
  (paint swaps)
103 S. Main Street, M Building
Waterbury, VT 05671-0407

Bio-Integral Resource Center (BIRC)
P.O. Box 7414
Berkeley, CA 94707

California Integrated Waste Management
8800 Cal Center Drive
Sacramento, CA 95826

Center for Safety in the Arts
5 Beekman Street,  Suite 1030
New York, NY 10038

Concern, Inc.
 1794 Columbia Road, NW.
Washington, DC 20009

Ecology Center of Ann Arbor
201 Detroit Street
Ann Arbor, MI 48104

Environmental Hazards Management
   Institute (EHMI) (HHW wheels)
 10 Newmarket Road, P.O. Box 932
 Durham, NH 03824
Environmental Health Coalition
1717 Kettner Drive #100
San Diego, CA 92101

Household Hazardous Waste Project
1031 East Battlefield, Suite 214
Springfield, MO 65807

Metrocenter YMCA
909 Fourth Avenue
Seattle, WA 98104

Minnesota Office of Consumer Policy
NCL Tower,  Suite 1400
445 Minnesota Street
St. Paul,  MN 55101-2131

Minnesota Pollution Control Agency
520 Lafayette Road, North
St. Paul,  MN 55155

National  Coalition Against the Misuse of
701 E Street, SE., Suite 200
Washington, DC 20003

National  Recycling Coalition
 1101 30th Street, NW.
 Suite 305
 Washington, DC 20007

 Nuclear  Regulatory Commission (smoke
 Washington, DC 20555

                                   INFORMATION    RESOURCES
Office of Solid Waste
401M Street, SW. (OS-305)
Washington, DC 20460
EPA RCRA/Superfund Hotline:

Project ROSE (used oil)
University of Alabama
P.O. Box 870203
Tuscaloosa, AL  35487-0203

Solid and Hazardous Waste Management
Washington Department of Ecology
P.O. Box 47655
Olympia, WA 98504-7655

Solid Waste Information Clearinghouse

Toxicant/HHW  Project
821 Second Avenue, Mail Stop 81
Seattle, WA 98104

University of Wisconsin Cooperative
Environmental Resources  Center
 1450 Linden Drive
Madison, WI 53706

Washington Toxics Coalition
4516 University Way, NE
Seattle, WA 98105

Waste Watch Center
 16 Haverhill Street
Andover, MA01810
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
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
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,
Home Safe Home,  Washington Toxics
Household Batteries in Minnesota, Karen
   Arnold et  al., Minnesota Pollution
   Control Agency.

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
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
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
 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
                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,
                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
                 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.


                 419 State Avenue, Second Floor
                 Emmaus, PA 18049

                                  INFORMATION   RESOURCES
2 Maine Street
Gloucester, MA 01930
Household Hazardous Waste Management
The Waste Watch Center
16 Haverhill Street
Andover, MA01810
Resource Recycling
P.O. Box 10540
Portland, OR 97210
Wanner Bulletin
The World Resource Foundation
83 Mount Ephraim
Tunbridge Wells, Kent UK  TN4 8BS
Waste Age
1730 Rhode Island Avenue, NW.
Suite 1000
Washington, DC 20036
World Wastes
Communications  Channels, Inc.
6255 Barfield Road
Atlanta, GA 30328

Audiovisual Materials

Videotapes and other audiovisual materials
are available from:

Ecology Center of Ann Arbor
417 Detroit Street
Ann Arbor, MI 48104
Environmental  Health Coalition
 1717 Kettner Blvd. #100
San Diego, CA 92101
HHW Project
Washington Department of Ecology
P.O. Box47655
Olympia, WA 98504-7655
Massachusetts League of Women Voters
133 Portland Street
Boston, MA 02114
Prevention Program
Contra Costa County Health Services
75 Santa Barbara Road
Pleasant Hill, CA 94523
Refuse Industry  Products, Inc.
P.O. Box 1011
Grass Valley, CA 95945
San Bernardino County DHS
HazMat Risk Assessment & Planning
385 N. Arrowhead Ave.
San Bernardino, CA 92415-0160
The Video Project
LMV of California
926 J Street, Suite 1000
Sacramento, CA 95814

HHW  Curricula  for

(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,

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,

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,

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,

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,

Hazardous  Wrote School Curriculums.
   Grades: K-12.  State of Alaska,
   Department of Environmental
   Conservation, PO. Box 0, Juneau, AK

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
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
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

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,

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

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,

                                    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
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,
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.
                                 GOVERNMENT PRTKPTTNR (TPPTrE • 1OQ1 n -

       APPENDIX  D
   Sample  Participant
                                            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

Zip Code.
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
                                                                  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.

his publication was reviewed by professional experts
not employed by the Environmental Protection
Agency, and by appropriate offices within the Agency.