fife 8MMI
A Survey of

Household Hazardous Wastes

and Related Collection Programs
                    S, Liferaiy (PL-12JI
                77 Wist Jackson Boulevard. 12ft How

                                                   ' $7  •
     This  report  was prepared for the Special  Wastes  Branch,  Office  of  Solid
Wasta,  United  States Environmental  Protection  Agency  by  SCS   Engineers  under
contract  68-01-6621.   The EPA Project Manager was  Gerri Dorian.   SCS  personnel
involved  with this project were Gary L.  Mitchell,  Deana M.  Demichelis,  Jeffrey
D. Marshall, and Sabra F.  Flaherty.

     This  report  has  been  reviewed  by the  Office  of  Solid  Waste,  U.S.
Environmental  Protection Agency, and approved for publication.  Approval  does
not signify that the contents necessarily reflect the views and policies of the
U.S.  Environmental  Protection  Agency,  nor does mention of  trade  names  or
commercial products constitute endorsement or recommendation for use.

                               TABLE OF CONTENTS
Section 1 - Executive Summary	   1- 1
    Definition	   1- 2
    Presence in Wastestream	   1- 2
    Impacts	   1- 3
    Collection Programs	   1- 3

Section 2 - Analysis Methodology	   2- 1
    General Purposes and Project Constraints	   2- 1
    Definition	   2- 2
    Presence in Wastestream	   2- 3
    Impact on Sol id Waste Management	   2- 4
    Local and State Collection Programs and Case Studies	   2- 5
    Summary	   2- 6

Section 3 - Definitions	   3- 1
    Background	   3- 1
    Definition of Household Hazardous Wastes	   3- 2
    Criteria for Household Hazardous Wastes	   3- 3
    Other Definitions of Household Hazardous Wastes	   3-13
    References	   3-17

Section 4 - Presence in Wastestream	'.	   4- 1
    Residential Waste Generation and Composition	   4- 1
    Household Hazardous Wastes	   4- 6
    References	   4-11

Section 5 - Impacts on Solid Waste Management
              and the Environment	   5- 1
    Storage and Collection	   5- 1
    Hauling and Disposal	   5- 4
    Environmental Impacts	   5- 5
    References	   5- 7

Section 6 - Special Collection Programs	   6- 1
    Goal s and Types	   6- 1
    Local Programs	   6- 1
    References	   6- 6

Section 7 - State Programs	   7- 1
    Vermont	   7- 1
    Connecticut	   7- 2
    Florida	   7- 2
    Rhode Island	   7- 4
    Washington	   7- 5
    Minnesota	   7- 5
    References	   7- 6

Section 8 - Major Issues	   8- 1
    Liability	   8-1
    Degree of Regulation	   8- 3
    Reference	   8- 3

Appendix A - 40 CFR Parts 261.33 (e) and (f)	   A- 1

Appendix B - 40 CFR Parts 261.21 Through 261.24	   B- 1

Appendix C - Directory to Programs	   C- 1

Appendix D - Case Studies of Household Hazardous Waste
               Collection Programs.	   D- 1
    Albuquerque, New Mexico	   D- 2
    Fairfax County, Virginia	   D-14
    State of Florida	,	   D-26

Appendix E - Memoranda and Letters Related to Liability of
               Collection Programs	   E- 1

                               LIST OF EXHIBITS
Section 3 - Definitions
     Exhibit 3-1 - Household Hazardous Wastes and Their
                     Hazardous Components	    3- 5
     Exhibit 3-2 - Other Household Items That May
                     Be Hazardous	   3- 9
     Exhibit 3-3 - Comparison of Household Hazardous
                     Waste Lists	   3-14
     Exhibit 3-4 - Example Wastes Identified for Community
                     Collection Day Programs	   3-16

Section 4 - Presence in Wastestream
     Exhibit 4-1 - Residential Waste Generation Rates	   4- 1.
     Exhibit 4-2 - Residential Waste Composition	   4- 4
     Exhibit 4-3 - Albuquerque, NM Residents' Perceptions
                     of the Hazards Associated with
                     Selected Toxic Substances	   4-10

Appendix D - Case Studies of Household Hazardous Waste
               Collection Programs
     Albuquerque, New Mexico
          Exhibit 1 - Example of Albuquerque, New Mexico's
                        Publicity Materials	   D- 4
          Exhibit 2 - Diagram of Albuquerque, NM Household
                        Hazardous Waste Collection Site	   D- 8
          Exhibit 3 - Participation and Results, Albuquerque, NM..   D-12
          Exhibit 4 - Cost Summary, Albuquerque, NM	   D-13
     Fairfax County, Virginia
          Exhibit 1 - Example of Fairfax County, Virginia Flyers..   D-15
          Exhibit 2 - Typical Site Plan, Fairfax County,  VA	   D-18
          Exhibit 3 - Summary of Fairfax County, Virginia	   D-21
          Exhibit 4 - Participation and Results,
                        Farifax County, VA	   D-23
          Exhibit 5 - Cost Summary Fairfax County, Virginia	   D-24
     State of Florida
          Exhibit 1 - Example Publicity Materials,
                        State of Florida	   D-27
          Exhibit 2 - Typical Collection Site, State of Florida...   D-31
          Exhibit 3 - Collection Period Costs	   D-34
          Exhibit 4 - Daily Operations Costs for Florida
                        Collection Sites	   D-35
          Exhibit 5 - "Amnesty Day" Collection Totals
                        (May 1984 - June 1985)	   D-37

                                  SECTION 1
                              EXECUTIVE SUMMARY
     This  report  contains  the  results   of  the  only  known  comprehensive
nationwide  study of household hazardous waste (HHW).  The study was  conducted
to  identify existing information on the types and quantities of HHW present  in
the  residential wastestream.  A proposed definition for HHW was developed when
none  were found (other than open-ended lists used in HHW collection programs).
Existing  collection  programs  operating  at   State  and  local  levels  were
identified  and  described.    Detailed lists of programs are  included  in   an
appendix  as are case studies of three collection programs.  This report refers
to safeguards associated with waste disposal rather than the degree to which  an
item may injure someone or affect their health while the item is in the home.

     Interest  in  HHW began in 1981 and 1982.  Virtually all activity on  this
topic  has  been  related  to  collection  programs.    These  programs  enlist
homeowners'  cooperation  in taking HHW to collection centers where the  wastes
are identified, packaged, and transported to permitted hazardous waste disposal
facilities.   A major element of all programs has been public education related
to  identification  of  HHW and developing an awareness  of  the  environmental
consequences of improper disposal.

     These  collection programs are very similar to early recycling efforts   in
the  1970's.   They are inspired by similar  environmentally-related  concerns.
They rely on public cooperation and include public education elements.  Overall
participation  is  low and costs for recovery of each pound of hazardous  waste
are high when all costs are included.

     Collection  programs  provide  many  benefits beyond  the  collection  and
disposal  of  HHW.    All include public education elements that  identify  HHW.
Additionally,  proper  ways to store the wastes are often presented along  with
identification  of less hazardous substitutes.  The potential environmental and
safety  impacts of improper use and disposal are also highlighted.    Collection
programs increase the public's awareness of HHW in the home and encourage safer
use  and  proper  disposal.  Although not quantifiable at present,   the  public
certainly  is  more aware of HHW and likely is disposing of these materials   in
more environmentally acceptable ways now than prior to collection efforts.

     Current  Federal  regulations  exempt household hazardous waste  from  the
regulations  applicable to other types of hazardous waste.  Refuse from  homes,
apartments,  motels,  and  hotels may contain wastes that  would  otherwise   be
considered  hazardous;  however,  current regulations allow them to be  disposed
with  mixed municipal (non-hazardous) waste.  New attention was focused on  HHW
with the passage of the Hazardous and Solid Waste Amendments of 1984 (HSWA).  In
these  amendments,  Congress recognized that homes, along with small  commercial
generators,  may be sources of hazardous constituents that have and will  enter
municipal  sanitary  landfills.  The interest in the potential impact of  these
waste and constituents was expressed in several  sections of the HSWA.


     During  the  course of this project, no rigorous definition  of  household
hazardous wastes was found.  The  only  approach  to  identifying  these wastes
consisted  of  lists  of generic products used by sponsors  of  HHW  collection
programs.  A definition of household hazardous wastes was developed as follows:

        Household    Hazardous  Wastes:  Solid wastes discarded from  homes  or
        similar  sources  as  listed  in 40 CFR 261.4 (b)(l)  that  are  either
        hazardous  wastes as listed by EPA in 40 CFR, Parts 261.33 (e) or  (f),
        or  wastes that exhibit any of the following characteristics as defined
        in  40  CFR  Parts 261.21 through 261.24:   ignitability,  corrbsivity,
        reactivity, and EP toxicity.

     Lists  of  household products that are hazardous or may be hazardous  were
prepared  based on the above definition.  The lists were developed without  the
benefit of laboratory testing.  Products considered household  hazardous wastes
include the following:

        Drain openers
        Oven cleaners
        Wood and metal cleaners and polishes
        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
        Fungicides/wood preservatives

It  should  be  noted  that not all examples of the above  products  should  be
considered  hazardous or even suspected as being hazardous.  For example,  some
oven  cleaners were considered to fail the corrosivity test while  others   may
or may  not fail that  test, while still other oven cleaners would probably not
fail any of the tests.  The above list should not be considered complete.


     There  is  very  little  knowledge  about  the  presence  of  HHW  in  the
residential  wastestream.    Only three attempts at quantifying HHW  have  been
identified.    One  was based on a public opinion survey and two  were  limited
waste  characterization projects.  Results indicate that HHW is a small portion
of  all  residential  waste, less than 1 percent.  However, the  projects  vary
widely  in  their actual estimates.  The public opinion survey resulted  in  an
estimate of 1 percent (1,000 ppm), while the characterization studies indicated
as  little as 15 ppm.  None of the quantification projects could be  considered
statistically valid.

                 Federal  Register / Vol. 51.  No. 215  /  Thursday.  November 6.  1986 / Notices

National Board of the Fund for the
Improvement of Postsecondary
Educational: Meeting

AGENCY: National Board of (he-fund for
tlie Improvement of Postsecondary
Education. ED.
ACTION: Notice of meeting.

SUMMARY: This notice sets forth the
proposed agenda of a forthcoming
meeting of the National Board of the
Fund for the Improvement of
Postsecondary Education. This notice
also describes the functions of the
Board. Notice of this meeting is required
under the Federal Advisory Committee
Act (Pub. L. 92-463), section 10{a)(2)).
DATE: December 4,1986 at 9:00 a.m.
through December 6,1986 at 12:00 p.m.
ADDRESS: Washington Hilton. 1919
Connecticut Avenue, NW., Washington,
DC 20009.
Charles Karelis, Director, Fund for the
Improvement of Postsecondary
Education, 7th & D Streets. SW.,
Washington. DC 20202 (202) 245-8091.
National Board of the Fund for the
Improvement of Postsecondary
Education is established under section
1003 of the Higher Education
Amendments of 1980, Title X (20 U.S.C.
1135a-l). The National Board of the
Fund is established to "advise the
Secretary and the Director of the Fund
for the Improvement of Postsecondary
Education ... on the selection of
projects under consideration for support
by the Fund in its competitions."
  The meeting of the National Board
will be open to the public. The proposed
agenda includes:
—An orientation and introduction of
  new Board members;
—A discussion and review of the past
—Development and discussion of
  policies and priorities for the coining
—Observation and participation in the
  Fund for the Improvement of
  Postsecondary Education Annual
  Project Directors' Meeting.
  Records shall be kept of all Board
proceedings, and shall be available for
public inspection at the Fund for the
Improvement of Postsecondary
Education, 7th & D Streets, SW.. Room
3100, Washington, DC 20202 from the
hours of 8:00 a.m. to 4 30 p.m. weekdays,
except Federal Holidays.
C. Ronald Kimberling,
Assistant Secretary for Postsecondary
[FR Doc 86-25098 Filed 11-5-86; 8:45 am]
ACTION: Notice of availability, of r>jr':r:=;
on household hazardous w -iste and s' r.e
solid waste (subtitle D'

Energy Information Administration

Renewal of the Charter of The
American Statistical Association
Committee on Energy Statistics

  Pursuant to the Federal Advisory
Committee Act (Pub. L. 92-163), I hereby
certify that the renewal of the charter of
the American Statistical Association
Committee on Energy Statistics is in the
public interest in connection with the
performance of duties imposed on the
Department of Energy by law. This
determination follows consultation with
the Committee Management Secretariat
of the General Services Administration,
pursuant to 41 CFR Subpart 101-6.1007.
  The purpose of the committee is to
provide advice on a continuing basis to
the Administrator of the Energy
Information Administration (EIA),
  1. Periodic reviews of elements of EIA
information collection and analysis
programs and the provision of
  2. Advice on priorities of technical
and methodological issues in  the
planning, operation, and review of EIA
statistical programs; and
  3. Advice on matters concerning
improved energy modeling and
forecasting tools, particularly regarding
their functioning, relevancy, and results.
  Further information concerning this
committee can be obtained from Gloria
Decker (202-252-8990).

  Dated: October 31,1986.
Charles Tiemey,
Advisory Committee Management Officer.

[FR Doc. 86-25127 Filed 11-15-88; 8:45 am]


Sottd Wast* Disposal; Household
Hazardous Waste; State Programs

AGENCY: Environmental Protection
SUMMARY: The U.S. Environmental
Protection Agency (EPA) is today
announcing the availability of two
reports. The first report is entitled "A
Survey of Household Hazardous Waste
and Related Collection Programs." This
report defines household hazardous
waste (HHW); summarizes existing
information regarding the presence of
HHW in residential waste;  and
discusses the impacts of HHW on
homeowners, solid waste collection and
disposal personnel, and the
environment. Information about HHW
collection programs conducted at the
State and local levels is also included in
the report. The second report is entitled
"Census of State and Territorial Subtitle
D Non-Hazardous Waste Programs."
This report summarizes the results of a
mail survey of State and Territorial non-
hazardous (solid) waste regulatory
programs. Data from all the States and
six Territories are reported. State
organization and available  resources for
Subtitle D programs are given. Numbers
and basic characteristics of landfills.
land application units, and surface
impoundments are included, as well as
information on regulations and
enforcement patterns.
ADDRESS: The reports are available for
viewing at all EPA libraries and in the
EPA RCRA docket room.  U.S.
Environmental Protection Agency. 401 M
Street, SW., Washington, DC 20460, from
9:30 a.m. to 3.30 p.m., Monday thru
Friday, except legal holidays; telephone:
(202) 475-9327. The  public may copy a
maximum of 50 pages of material from
any one regulatory docket at no cost.
Additional copies cost 20 cents per page.
Limited copies of the HHW report are
available, while supplies  last from the
EPA RCRA/Superfund Hotline at (800)
424-9346 ((202) 382-3000 in Washington,
DC). These documents are available for
purchase from the National Technical
Information Service (NTIS). U.S.
Department of Commerce, Springfield,
VA 22161. at (703) 487-4600: "A Survey
of Household Hazardous Waste and
Related Collection Programs" (EPA/ 530-
SW-86-03a NTIS No.: PB-87-108-072,
$18.95 hardcopy, $6.50 microfiche) and
"A Census of State and Territorial
Subtitle D Non-Hazardous Waste
Programs" (EPA/530-SW-86-039, NTIS
No.: PB-87-108-080, $24.95 hardcopy,
$6.50 microfiche).
For general information, call the RCRA
Hotline at (800) 424-9348  ((202) 382-3000
in Washington, DC). For technical

, 40334
Federal  Register / Vol.  51. No. 215  /  Thursday.  November 6. 1986  /  Notices
  iff '-Tid'.ion en 'h» HHW reoor' -or.'ir*.
  GL-"> Do-ian. Otf.ce of Solid Waste
  IWH-56V£,. U 5  E.iv.ronrr.p-'il
  Protection Au°nc\  401 M Street. SU .
  Washington. DC :0460, (202) 382-4688
  For information on the State Survey
  report, contact Allen Geswem. (202^"*"
  3S2-4C87. a: the barre address. ...^ '
  under the authonf, of sections
  1008|d)(3! and 4004(3) of Subtitle D of
  the Resource Conservation and
  Recovery Act (RCRA), EPA promulgated
  the "Criteria for Classification of Solid
  Waste Disposal Facilities and Practices"
  (40 CFR Part 257). These Criteria include
  environmental performance standards
  that are used for determining which
  solid waste disposal facilities and
  practices pose a reasonable probability
  of adverse effects on human health or
  the envircnment. Those facilities that
  violate the Criteria are deemed "open
  dumps." The Criteria are enforced by
  the States or through citizen suits.
    In 1984. Congress passed the
  Hazardous and Solid Waste
  Amendments (HSWA), which include
  several major provisions regarding the
  solid waste regulatory program. The
  Amendments, require EPA to submit a
  report to Congress by November 8,1987,
  that addresses whether the current
  Criteria (40 CFR Part 257) are adequate
  to protect human health and the
  environment, and whether additional
  authorities are needed to enforce the
  Criteria Further, EPA is required to the Criteria by March 31,1988, for
  facilities that may receive hazardous
  household waste or small quantity
  generator (SQG) hazardous waste.
  HWSA also requires the States to have
  a permit program for the existing
  Criteria by November 1987, and to have
  a revised permit program 18 months
  after the revised Criteria are
    In response to these statutory
  mandates, the Agency is currently
  gathering extensive data for both the
  report to Congress and the Criteria
  revisions. The two report* being made
  publicly available today are the result of
  two of these data collection.efforts.

  Household Hazardous Watte Report
    The report entitled, "A Survey of
  Household Hazardous Waste and
  Related Collection Programs," contains
  the results of a study of household
  hazardous waste that addressed the
  following topics: (1) The definition of
  HHW; (2) the quantities of HHW in the
  municipal waste of stream: (3) the
  impacts of HHW on homeowners, solid
  waste collection and disposal personnel.
  and the environmental: and (4) HHW
                      collection programs conducted at the
                      State and local le\ els Included :n 'he
                      re'. ?w of collection programs w ^s an
                      examination of the liability  of operators
                      and sponsors of HHW collection
                      programs under RCRA and  the
                      Comprehensive Environmental
                      Response. Compensation, and Liability
                      Act of 1980(CERCLA).
                        As  part of the study, a standard
                      definition of HHW was developed. Lists
                      of household products that may be
                      considered household hazardous
                      wastes, when discarded, were prepared
                      based on this definition. For example,
                      certain products within the  following
                      broad classes of materials could be
                      considered HHW when discarded: drain
                      openers, oven cleaners, wood and metal
                      cleaners and polishes, 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, pesticides and fungicides/
                      wood preservatives. The report
                      describes the criteria used in the
                      definition and the limitations of the
                      analysis. The study also found  that there
                      is very little data on the quantities of
                      HHW in residential wastes. However,
                      the limited studies conducted to date
                      indicate that HHW is a small portion of
                      all residential wastes.
                        The key results  regarding the impacts
                      of HHW on the environment, refuse
                      personnel, and homeowners are
                      summarized in the report. Although
                      homeowners are assumed to have been
                      injured due to the presence  of HHW  in
                      their homes, no data  were available to
                      show a direct correlation. However, a
                      number of communities across  the
                      nation have reported injuries to
                      sanitation workers that have been
                      caused by HHW. These indicences are
                      often associated with materials that
                      splash or spill during compaction,
                      containers that explode, or materials
                      that emit toxic fumes.
                        Much recent activity has focused on
                      HHW collection programs. These
                      programs enlist homeowners'
                      cooperation in taking HHW to collection
                      centers where the wastes are identified,
                      packaged, and transported to secure
                      waste disposal facilities. The number of
                      these programs has grown rapidly, with
                      over 30 States having conducted a
                      collection program. Information on these
                      programs, gathered from several
                      sources, is summarized in the report.
                        A major element of all programs has
                      been public education related to
                      identification of HHW and developing
                      an awareness of the environmental
                      consequences of improper disposal.
Problems current!) asscc a'-d \s  •'•>
those prosrarr.s ;ncludp rel  :;\
participation, high disposal cos's  irJ
sponsor liability concerns.

State Survey Report

  The report entitled, "Census of State
and Territorial Subtitle D Non-
Hazardous Waste Programs."
summarizes  the findings  of a mail
survey of State and Territorial non-
hazardous waste regulatory programs.
The survey focused on three key areas:
(1) State organization and resources: (2)
number and  characteristics of landfills.
land application units, and surface
impoundments;  and (3) characteristics of
the regulatory program (e.g., regulations.
inspections,  violations).
  The report is organized in six major
parts. Part I contains the introduction to
the report the study methodology, and  a
description of the statistical reliability of
the data.  Part II describes State
organizational structures and resources
for the Subtitle D program. Part III
provides  information on the total
number and  basic characteristics
(owership, acreage, amount of waste
received, monitoring systems, design
and operational controls) of Subtitle D
waste facilities. Part IV provides data
on Subtitle D regulatory programs.
including information on regulation and
enforcement patterns. Part V contains
information with respect to the number
and quantity of Subtitle D facilities that
receive exempted small quantity
generator hazardous waste. Part VI
provides  a summary and conclusions of
the report.
  There are four appendices to the  -
report Appendix A provides the
responses to a survey question
concerning Statewide landfill capacity
problems. Appendix B contains data
tables with estimates of landfill tipping
fees. The cover letters that accompanied
the questionnaire are in Appendix C.
Appendix D  is a copy of the
questionnaire used for the survey.
  Examples of some of the key survey
results contained in the report are as
  (1) Approximately 227,000 Subtitle D
facilities are located at 120,000
  (2) The total number of Subtitle 0
disposal facilities includes: 16,416
landfills (of which 9,300 are municipal
waste landfills), 18,889 land application
units (LAUs), and 191.822 surface
  (3) Roughly 16 percent  of all Subtitle D
facilities, or 36,000. are reported to
receive hazardous wastes from
households or small quantity generators;

                  Federal  R-gister / Vol. 51. No.  215 / Thursday, November 6,  1986 / Notices
  (4) Very few facil.ties have extensive
design and operational controls and
very few facilities have systems to
monitor releases, and
  (5) State Subtitle D regulations and
resources vary by State and Territory.
  Ddted October 27, 1986       *~
J.W. McGraw,              -:«-
 •\c!:ng Assistant Administrator- Office of
So.'iJ  Waste and Emergency Response.
(FR Doc 86-25101  Filed 11-5-66; 8 45 am]


Change in Bank Control Notice-,
Acquisition of Banks or Bank Holding

  The notificants listed in this notice
have applied for the Board's approval
under the Change in Bank Control Act
(12 U.S.C. 1817(j) and I 225.41 of the
Board's Regulation Y (12 CFR 225.41)  to
acquire a bank or bank holding
company. The factors that are
considered in acting on the  notices are
set forth in paragraph 7 of the Act (12
U.S.C. 1817(|)(7).
  The notices are available for
immediate inspection at the Federal
Reserve Bank indicated. Once the
notices have been accepted for
processing, they  will also be available
for inspection at the offices  of the Board
of Governors. Interested persons may
express their views in writing to the
Reserve Bank indicated for  that notice
or to the offices of the Board of
  Comments regarding these
applications must be received not later
than November 21,1986.
  A. Federal Reserve Bank  of St Louis
(Randall C. Sumner, Vice President) 411
Locust Street, St. Louis. Missouri 63166:
  1. The Citizens National Bank of
Bow/ing Green Employee Stock
Ownership Plan  and Related Trust,
Bowling Green, Kentucky; to acquirt
16.58  percent of the voting shares of
Trans Financial Bancorp, Inc.. Bowling
Green, Kentucky, and thereby indirectly
acquire The Citizens National Bank of
Bowling Green, Bowling Green,
  B. Federal Reserve Bonk of
Minneapolis (James M. Lyon, Vice
•President) 250 Marquette Avenue.
Minneapolis. Minnesota 55480:
  1. Arnold B. Chace, Jr., Malcolm G.
Chace, III. Malcolm G. Chace III Trust,
Malcolm G. Chace. Jr. Trust, Jane Chace
Trust, Jonathan Chace Clay Trust, Eliot
Chace Trust. Christian Nolen Trust,
Arnold B. Chace III Trust, Leigh Fibers,
Inc.. and William R. Oimeling to acquire
83.2 percent of the voting shares of
Escrow Corporation of America, Inc.,
Pennock, Minnesota, and thereby
indirectly acquire State Bank of
Pennock, Pennock. Minnesota;  and
Heritage Bank. National Association.
Willmar, Minnesota.
  2. David G. Smith, to acquire 51.13
percent, and Keith G. Eltreim, to acquire
48.87 percent of the voting shares of
Jasper Investment Company, Inc.,
jasper. Minnesota, and thereby
indirectly acquire Jasper State Bank,
Jasper, Minnesota.
  Board of Governors of the Federal Reserve
System. October 31,1986.
James McAfee,
Associate Secretory of the Board.
[FR Doc. 86-25064 Filed 11-5-86; 8:45 am)
BIUJNQ CODE «210-01-*

Public Health Service

National Toxicology Program, Board
of Scientific Counselors, Meeting

  Pursuant to Pub. L. 92-463, notice is
hereby given of a meeting of the
National Toxicology Program (NTP)
Board of Scientific Counselors,  U.S.
Public Health Service, in the Conference
Center, Building 101, South Campus,
National Institute of Environmental
Health Sciences, Research Triangle
Park, North Carolina, on November 25,
  The meeting will be open to the public
from 8:30 a.m. until adjournment on
November 25. The preliminary agenda
with approximate times are as follows:
8:30 a.m.-9:00 a.m.—Report of the
9:00 a.m.-9:30 a.m.—Overview of the
  NIEHS Intramural Research Program
9:30 a.m.-10:00 a.m.—Overview of the
10:15 a.m.-ll:45 a.m.—Review of
  Chemicals Nominated for NTP
  (Ten chemicals will be reviewed. Of
these, Five were reviewed by the NTP
Chemical Education Committee (CEC)
on April 29,1986, and listed in the
Federal Register, Volume 51, No. Ill, p.
21020, June 10.1986: (1) Cobalt
naphthenate; (2) Di(2-ethylhexyl)
sebecate: (3) Methylcyclopentadienyl
manganese tricarbonyl; (4) 2-
Methylquinoline; and (5) 4-
Methylquinoline. The remaining five
chemicals, which are benzodiazepine
drugs, were reviewed by the CEC on
September 16,1986, and listed in the
Federal Register, Volume 51, No. 197, pp.
36479-36480, October 10.1986: (1)
Chlordiazepoxide; (2) Clorazepate; (3)
Diazepam; (4) Flurazepam: and (5)
  12 30 p m.-t 45 p m —MEMS Ce",.. .:
and Genetic Toxicoiosv 3rdr.<-'- —5r "-
term Assay Evaluation
  I. Introduction.
  II. Comparison of//? Vitro Assav
Results with Rodent Carcmogenicity
  III, Comparative Evaluation of Short-
term In Vivo Assay.
  IV. Statistical Aspects.
  V. Strategies for Testing and Other
Implications of the Evaluation.
  The Executive Secretary, Dr. Larry G
Hart, Office of the Director, National
Toxicology Program. P.O. Box 12233.
Research Triangle Park, North Carolina
27709, telephone (919) 541-3971, FTS
629-3971, will have available a roster of
Board members and other program
information prior to the meeting and
summary minutes subsequent to the
  Dated: October 30.1986.
David P. Rail,
Director, National Toxicology Prog'-c-n
(FR Doc. 86-25087 Filed 11-5-tfO.  8 45 anj

  Pursuant to the Federal Advisory
Committee Act. Pub. L. 92-463 (5 L'.S C ,
Appendix 2). the Office of the Assistant
Secretary for Health announces the
reestablishment by the Secretary.
DHHS, with concurrence by the Genera!
Services Administration, of the
following advisory committees:
  Designation: Health Care Technology
Study Section.
  Purpose: The Study Section shall
advise the Secretary and make
recommendations to the Director,
National  Center for Health Services
Research and Health Care Technology
Assessment, on research grant
applications in medicine, technology
assessment, the information sciences,
decision sciences (operations research,
industrial engineering, health care
administration), communications
technology, bioengineering, and related
fields as applied to hospital-based
ambulatory, and community health care.
The members of this Study Section shall
survey, as scientific leaders, the status
of research in their fields.
  Designation: Health Services
Research and Developmental Grants
Review Committee.
  Purpose: The Committee shall advise
the Secretary and make
recommendations to the Director,
National  Center for Health Services
Research and Health Care Technology
Assessment, on research grant
applications of two general types. One


     Limited information indicates that HHW have been found in the environment.
Indirect  evidence suggests that HHW contributes to ground-water  contamination
detected at a number of municipal disposal sites.

     Although  people  certainly  have  been injured due  to  the  presence  of
hazardous  waste in their homes, no data were available to show a  correlation.
Impacts  on  refuse collectors and disposal personnel are easier  to  document.
Several  communities  across  the nation have reported injuries  to  sanitation
workers  that  have  been  caused  by HHW.  These  are  often  associated  with
materials  that splash or spill during compaction, containers that explode,  or
emission  of toxic fumes.  Household hazardous wastes are considered as a prime
suspect in fires on collection trucks or at landfills.


     Collection programs for household hazardous waste are operated at both the
local  and state levels.  Beginning only 3 to 4 years ago these activities have
grown  rapidly  in  popularity.   A directory  of  100  communities  that  have
conducted  programs is appended to this report.  Nearly 200 collection programs
may  be  operated in 1986.  Collection programs have many positive  attributes.
Education"  of  the public and increased awareness of the presence of  hazardous
materials  in  the home are major assets of these programs.  Removal  of  these
wastes  from  long term, improper storage certainly reduces the  potential  for
injury  or accident.  The disposal of these wastes in permitted hazardous waste
facilities reduces potential impact on the environment.

     Participation  rates  in  HHW  collection programs have  been  low.    Few
programs  can  boast  participation  of even 1 percent  of  households  in  the
community,  and  several programs report participation less than  0.2  percent.
Quantities  collected   typically range from 20 to 40 pounds  per  contributing
household.  This  may  represent  several  years  accumulation of wastes.  Thus
future  collection efforts in the same area may result in even lower quantities
per participant household, assuming the same households participate.

     Unit  costs for these collection programs  are extremely high.  Cost  data
are  scarce  and  most  program  sponsors do not  include  factors  for  fringe
benefits,  overhead, and other indirect costs or donated materials or services.
Relatively  complete  cost  estimates  (although based  on  several  estimates)
indicate that a well publicized program with high participation costs well over
$2.00  per  pound  of HHW collected.   Programs with limited publicity  and  low
participation may cost over $9.00 per pound ($18,000 per ton).

                                   SECTION 2
                             ANALYSIS METHODOLOGY

     The overall purpose of this project was to conduct a survey of information
related  to the topic of household hazardous wastes (HHW).  This report  refers
to safeguards associated with waste disposal rather than the degree to which an
item  may injure someone or affect their health while the item is in the  home.
The  information collected was to be reviewed and summarized to provide general
information  and  some  specific  examples of activities on this  topic.    The
project was not intended to be a complete compilation of all information on the
topic,  nor  a  listing and discussion of all known  collection  or  regulatory
programs.  Four general areas were to be addressed in the project, as follows:

     t  Definition - What are household hazardous wastes and how are they/could
        they be defined?

     •  Quantities - How much household hazardous waste is generated?

     a  Impacts  -  What  are the safety and environmental impacts  related  to
        management of household hazardous wastes?

     •  Collection  programs - What are some of the ways that local communities
        and states are regulating and collecting these wastes?

     The  project had some limitations and constraints.  These could  generally
be  described as funding and time.  During conduct of the project it was  found
that  interest  and  .activities in HHW were growing rapidly.  Interest  at  the
local,  state,  and Federal level was expanding and more and more  states  were
becoming  interested  in   potential collection programs and  legislation.  The
number  of local collection programs also greatly accelerated,  thus during  the
time  frame  of the project, the topic area was expanding so rapidly  that  the
project  and this resulting report could not keep pace.  Information collection
efforts  had  to cease at some point, even though new developments in the  area
were continually being identified.

     The project was a survey, with little provision made for original  research
work.    Thus,  efforts  primarily  focused   on  the  collection  of  existing
information  either through printed materials or interviews with people  active
in  household  hazardous  wastes.   The general  purpose of  the  project  added
constraints  that should be clearly identified.   These may be best described as
the things that the project and this report are not:

     •  It  is  not  a complete discussion of (or even identification  of)   all
        state or local  HHW collection programs.

     •  It  is  not a compendium of conclusions  and  recommendations from  these
        collection  programs.   •

     •  It  is  not  a  how-to-do-it manual  to  aid  organizers  of  collection

     •  It is not related to impacts on health or safety in the home.

     The  remainder of this section is devoted to presenting the  methodologies
used throughout the project.  It is divided  generally in the same manner as the
entire  report.   Descriptions of what was done,  quality assurance  (follow-up)
measures that were used, and rationale are discussed.


     One of the purposes of the project was  to develop a recommended definition
for  household hazardous wastes.  Initial  steps in this effort were the  review
of  previously  developed definitions and  the EPA regulations related  to  HHW.
Early definitions were associated with local  collection programs and were found
to  not  be  true  definitions, but essentially lists  of  household  materials
accepted  and  therefore considered hazardous.  Federal regulations related  to
the  definition  of hazardous waste and the  exclusion of household  waste  were
studied  to  provide  precedents  for  a definition.     State  regulations  and
definitions were not identified nor reviewed.

     The  definition,  developed and presented in Section 3, was based  on  the
EPA's  definitions of listed and characteristic hazardous wastes in 40 CFR 261.
This  approach  was considered consistent  with the identification of  hazardous
wastes  from  commercial   generators.         Additionally,  use  of  the  EPA
characteristics  (corrosivity, reactivity, ignitability, and EP toxicity) allow
the  incorporation  of  the  related tests as the criteria  against  which  the
household wastes could be tested.

     In  order  to provide more specific examples of the  definition,  attempts
were  made  to identify categories of household materials that would  meet  the
definition.  The approach involved the application of the knowledge of chemical
and  environmental  engineers  to    readily  available  information  regarding
household  products.  Engineers visited grocery,  drug, automotive, and  variety
stores  to obtain information about the composition of products that might  fit
the  definitions.  Product labels were reviewed to identify major components of
these  products.    The components were compared against EPA  listed  hazardous
wastes  (discarded  commercial  chemical products, etc.) as listed  in  40  CFR
261.33.  Chemical  engineers applied their knowledge of the EPA  characteristic
tests to the known ingredients to identify those products that almost certainly
or  possibly would fail any one.  Product labeling often provided little or  no
information.   Commonly only one or two ingredients were listed and usually  no
percentage  of  composition was reported.   This lack of label  information  was
supplemented by chemists' knowledge of the general formulation of such products
as  paint  thinners,  drain openers, and engine additives.    Where  necessary,
information  about these ingredients was obtained through standard chemical and
chemical engineering reference books.

     Identification  of  types of household products considered  hazardous  was
strictly  based upon best scientific judgement. Funding and time constraints of
the  project precluded laboratory testing.  Likewise, due to these constraints,

 no   effort   could  be made  to  contact  individual manufacturers of  a   product   or
 group  of products  to determine  if the products had been tested against  any   of
 the  characteristic hazardous   waste  tests    or  to  obtain  other  specific

     The lack  of information  about some types of materials  put them  into  a gray
 area.    These materials that may be  hazardous wastes are separately listed   in
 Exhibit  3-2.    This  second category was necessary    solely  due   to   project
 constraints  against actual testing.  However, any testing program to completely
 identify  all  materials meeting  the hazardous household wastes definition would
 be prohibitively expensive.


     The  next major element  of  the project involved identification  of informa-
 tion  reporting  the quantity of the  household hazardous waste  in   residential
 wastes.  No  actual  measurements  of HHW quantitites were  conducted  in  this
 project.  Reports   on  previous  SCS Engineers'waste composition   projects  were
 reviewed;  however,  no  information  was found in  them  related  to  specific
 identification of HHW.

     Known   leaders  in HHW collection efforts were contacted  for   information
 about  the   presence of HHW in residential wastes.  Through these contacts  and
 attendance of  an EPA-sponsored solid waste conference, three organizations were
 recognized   as having  past  or present involvement   with  identifying  these
 wastes.  Contact was made with each to fully understand their approach. Written
 material  was  obtained from  the organizations to the degree possible  and  was
 reviewed  thoroughly.  To  acquire additional  information,   personnel  directly
 involved  with household waste characterization were interviewed by  telephone.
 The limited  amount of information and resultant small  number of data points led
 to the decision to visit each of these organizations.

     Interviews  were  conducted in person with representatives of each of  the
 three  groups.     One  organization  was  the  Los  Angeles  County  Sanitation
 Districts.    The Districts had conducted two  quantification projects that were
 related to identifying hazardous waste coming to disposal  sites.   The data were
 not  directly  related to residential  sources;  however,  some inferences could be

     The second organization was the Environmental  Health  and Energy Department
 of  the City of Albuquerque, New Mexico.   The Department had conducted a public
 opinion survey regarding household hazardous waste.   Estimates of the types and
 quantities   of these wastes in Albuquerque were based  almost exclusively on the
 opinions of the residents surveyed.

     The  third organization was the Anthropology Department at the  University
of  Arizona.     Members    of   the    Department  have   been  conducting  waste
characterization  studies  for several years.   In the  last  2  years,   household
hazardous wastes have been  identified  and  their presence has  been noted in the
composition   studies.    No  quantitative data were available at the time of  the

     Essentially  no defendable data were available relating the quantities  of
hazardous wastes coming from homes and similar sources.   The Los Angeles County
and  Albuquerque  projects resulted in estimates that could only put  the  data
into  the broadest of perspectives.   The Albuquerque data indicated  household
hazardous  waste was likely less than 1 percant of the residential   wastestream
while  the Los Angeles County information pointed toward a much smaller  number
(approximately  0.00147  percent).    Although these numbers  are    orders  of
magnitude  different from one another, it was inferred that they indicate  that
HHW  are likely a small (and probably a very small) percent of the  residential
wastestream.    The data were considered to be so tenuous that no  attempt  was
made to project nationwide quantities.

     The  interest  in household hazardous waste has resulted in current  waste
composition  studies, including these waste types.  The University of Arizona's
Department  of Anthropology is continuing its work; the resulting  quantitative
data  should  be  available in the near future.  Similarly,  SCS  Engineers  is
conducting  a waste composition study at six locations throughout the State  of
Michigan.  The definition of household hazardous waste developed in this report
is  being used and these wastes are being identified throughout the conduct  of
this  project.  These data will also likely  be available at the conclusion  of
the Michigan project.


     Collection  of  information related to the impacts of household  hazardous
waste  on  overall solid waste management, and on the environment, as  well  as
information  about the HHW collection programs was initially obtained through a
series  of  telephone contacts.  Organizational leaders of collection  programs
were  contacted and requests made for any reports related to the topic. Program
sponsors  and  others involved with household hazardous waste  enthusiastically
responded  providing reports and also providing the names and telephone numbers
of  other  involved  individuals.   This approach  of  contacting  one  person,
obtaining  the information that they had available, and then asking for another
lead  was  used  with  good success.   Frequently,
directed back to a small group of key individuals.
contacts,  fewer  and  fewer  new names were being
indicated  that  the  truly significant individuals
hazardous wastes nationwide had been contacted.
 After a
added to
 interviewers  were
number of telephone
 the  list.    This
area  of  household
     The  reports and other written information as well as information provided
verbally  was reviewed.  Any reports that associated household hazardous  waste
with  injuries  or other impacts on homeowners, sanitation workers, or  on  the
environment  were noted.  Follow-up telephone calls were used in some instances
to  clarify  the written materials and to provide details and  up-to-the-minute

     Information  on environmental impacts was particularly scarce.   Telephone
contacts with authors or others identified in these reports were used to obtain
all  pertinent  information.   Even then only a very small  number  of  reports
associated  with potential environmental impacts could be identified.  This  is
likely  because  there  appears  to be no nationwide reporting network, nor any

other  organized means of  identifying environmental, safety, or health   impacts
associated with household  hazardous wastes.


     Initial  efforts  of  information collection  focused on obtaining as  many
written  reports,  news  articles, and similar items as possible.   Often  this
included  the names of people actively involved with household hazardous  waste
collection efforts.  Key individuals were contacted by telephone to obtain more
detailed  information  about  specific programs.   The  information  collection
effort  identified  the  rapidly  changing  and  growing  nature  of  household
hazardous  waste programs.  The number of states and communities interested  in
this  topic  seem to be growing exponentially.  Thus, information  about  every
state  program and all the variations on local collection efforts could not  be
included.  Consequently, for this report,  early state and local programs  were
selected  to  provide some insight related to the history of interest  in  this
topic.  Similarly, programs that represented typical approaches were highlight-
ed  and  described in order to provide information about the majority of  these

     Detailed  case  studies  of  three programs  were developed.    One  state
program    (Florida)  and two  local collection programs (Albuquerque,  NM  and
Fairfax County, VA) were prepared.  The Florida case study was based on written
reports  and  extensive  telephone   contact   supplemented  by  collection  of
population data for Florida that were used in estimating participation rates.

     The  two local collection program case studies involved direct observation
of  the collection efforts.  Project personnel coordinated with Albuquerque and
Fairfax  County  staff.    All available written materials  were  obtained  and
reviewed  prior  to  the site visits.  During the collection  efforts,  project
personnel  were on hand to observe all aspects. Data were obtained from project
sponsors  as  available regarding numbers of participants, quantities of  waste
collected,  results  of  public opinion surveys, and program costs.    In  some
instances,  these  data  were not available or only partially supplied.    Best
engineering economic judgement was used to estimate missing cost elements.

     Efforts  were made to include estimates for all elements of the case study
collection  programs.    This  included items that are  often  not  considered,
especially  when a governmental organization is involved.   Therefore, estimates
were  included for cost factors such as personnel  overhead and fringe  benefits
and the reasonable value of donated services and equipment.

     A  major  weakness  in the evaluation of the two  local case  studies  and
other  local   programs is the lack of information concerning the  effectiveness
and  impact  of public education.   Public education is a major element  of  all
household hazardous waste collection programs.  It certainly contributes to the
participation  in the collection effort itself, and the degree of participation
is one measure of its effectiveness.   However, there are many more, potentially
far-reaching  benefits from these  educational  efforts.   These benefits include:
safer  management  of  household products prior to disposal; shifts  in  buying
habits  from hazardous products to those that  are  non-hazardous;  and  a general
increased  awareness of the environmental  impact of home activities.   Review of

information  regarding the case study locations and contacts with other program
sponsors  nationwide  indicated that there was no known effort to assess  these
less tangible benefits.


     The  methodology  of  this  project essentially  consisted  of  collecting
currently  available  published  and unpublished information on  the  topic  of
household hazardous waste.  Scientific judgement was applied to EPA regulations
resulting  in a definition of household hazardous waste. Knowledge of chemistry
was  used  to evaluate numerous types of household products to  identify  which
groups  should  be  included in the category.   No testing was possible  due  to
funding and time constraints.

     Similarly,  existing information was collected and reported as it  related
to  the impact of household hazardous waste and the approaches used to  improve
their  management  and collection.  Information available from written  reports
and collected through the conduct of case studies was used to develop estimates
of  quantifiable  aspects  of  these  programs  such  as  participation  rates,
quantities  recovered per participant, and collection costs.   Non-quantifiable
benefits were only identified.

                                  SECTION 3

     What  are  household hazardous wastes?  The  Environmental  Protection Agency
(EPA)  has not  officially  or  completely defined  the term  in  any regulations   or
publications to date.  Materials that are excluded from regulation  as  hazardous
wastes are identified  in 40 CFR 261.4.  One category  is identified  as  household
waste.  The regulations define household waste as including  any waste  materials
derived  from   households,  including single and multiple  residences,  hotels,
motels, and other  similar  sources (40 CFR 261.4  (b)(l)).  In  the preamble to the
proposed  hazardous waste  regulations, EPA stated that "this exemption is based
on  Congressional  intent  to  exempt from the hazardous waste regulations  those
wastes  generated  by  consumers in their households,  and not on the absence   of
hazard from the waste."  In fact, in the preamble to  its final rule, EPA stated
that  it  was not  attempting  to pass judgement on the health and  environmental
risks associated with  these wastes.
     On  a  related topic, the Agency discusses residues of  hazardous  waste   in
empty  containers  (40  CFR 261.7).  That regulation  indicates  that   hazardous
wastes  remaining  in  "empty" containers (residues up to one inch deep  in  the
bottom  of the  container)  are not subject to regulation under Parts 261 through
265  and  other parts of  40  CFR associated with the  management  of   hazardous
waste.   Thus,  no  regulations identify any household wastes as being   hazardous
requiring  regulated  management   from   the    point  of  generation  through
transportation  and  on  to   final  disposal at  a  permitted  hazardous  waste

     However,   several commonly-used household products would be classified   as
hazardous wastes if they were generated by a commercial operation that exceeded
the  small quantity generator limitation (i.e. less than 100 kg per month).   In
other  words,   these  materials  are legally not  hazardous  because   they  are
generated  in   homes and in locations very similar to homes such as hotels  and
motels.   The same materials discarded from a large manufacturing or commercial
facility  would  be  hazardous wastes and subject to all  EPA  RCRA  Subtitle  C
regulatory requirements.

     Several   organizations have attempted to define household hazardous wastes
(HHW)  by listing  items considered hazardous.  These efforts have most commonly
been  associated  with  community  efforts to  collect  hazardous  wastes  from
homeowners.  During these programs,  which are discussed in more detail later  in
this  report,   organizing personnel  have used their best judgement and that   of
preceeding  similar  programs  to identify,  for potential   participants,  those
types of household items considered hazardous. These lists or definitions often
may have been developed primarily to collect materials that could be harmful  to
homeowners with secondary considerations given to environmental protection.

     Impressions of what household items are and are not hazardous vary widely.
Householders   often are ignorant of or underestimate the types  and  quantities

of  hazardous  waste generated in homes.  The City of Albuquerque  conducted  a
house-to-house  residential  survey  in 1982.  A total of 386  households  were
visited to determine public awareness of HHW (1).  One of the initial questions
requested  the  respondent to name as many different types of HHW as  possible.
Twelve  percent  could  not  name any and therefore  apparently  felt  that  no
household  items  were considered hazardous.  Forty percent of the  respondents
could  not  name more than one type of material.  In a follow-on question,  the
respondents  were asked to indicate the degree of hazard presented by  specific
named  types  of household items.  In addition to wastes such as drain  openers
and paint thinner, the list included shampoo, mouthwash, and sawdust.  At least
1  percent  of homeowners identified these three items as extremely  hazardous;
while three percent said poisons and pesticides were not hazardous.

     Until  now,  there  has been no known attempt to write a definition  of  a
household  hazardous  waste.  The lists developed by  organizations  conducting
collection  programs are a form of definition; however, they vary from place to
place  and at best are educated guesses as to what materials should be included
in  the  universe  of household hazardous waste.  Although use of  the  listing
approach  expedites identification of the wastes, providing helpful service  to
the  homeowners,  it  does  not address the  generic  definition  of  household
hazardous waste.  In this report, development of such a definition is necessary
to understand the nature and scope of household hazardous waste management.


       In  an  attempt to define hazardous materials that could be disposed  by
households,  a fairly thorough investigation of products and their  ingredients
was  performed.   This investigation consisted of visits to supermarkets,  drug
stores,  variety  stores, and specialty stores (e.g., automotive supply,  photo
supply)  followed  by  qualitative evaluations by  chemical  and  environmental
engineers.    Laboratory  testing was not performed because the wide  range  of
products  and  constituents  would require a  prohibitively  expensive  testing
program.    Results  of the investigation indicated  that  commercial  products
generally fall into one of the following three categories:

     •  Items that are obviously hazardous;

     t  Items that are suspected to be hazardous; or

     t  Items that are obviously non-hazardous.

     A definition of household hazardous waste was developed primarily based on
the  EPA definition of household waste and the EPA classifications of hazardous
waste  in  the  Resource Conservation and Recovery Act  (RCRA)  and  associated
regulations.   The definition is as follows:

        Household    Hazardous  Wastes:  Solid wastes discarded from  homes  or
        similar  sources  as  listed  in 40 CFR 261.4 (b)(l)  that  are  either
        hazardous  wastes as listed by EPA in 40 CFR, Parts 261.33 (e) or  (f),
        or wastes that exhibit any of the following characteristics as defined

        in  40  CFR  Parts 261.21 through 261.24:   ignitability,  corrosivity,
        reactivity, and EP toxicity.

The following section discusses the criteria for household hazardous wastes and
presents  examples  of products that meet the above definition.  Note that  the
above definition is based solely on Federal regulations and definitions. States
may  have more stringent regulations.  In those situations, any existing  local
regulations and/or definitions should be applied.


     As  stated in the definition, a household waste is considered hazardous if
it  is  a listed hazardous waste (discarded commercial  product, etc.) or if  it
exhibits any of four hazardous characteristics.  The applicable hazardous waste
lists  appear  in  40 CFR Parts 261.33 (e) and (f).  Copies of  the  lists  are
included  as  Apendix  A.  Compounds appearing in 40 CFR 261.33 (e)  have  been
listed  by  EPA because of their acute toxicity, unless otherwise indicated  on
the  list by the letters T (toxicity) or R (reactivity).  This list is commonly
referred  to  as the "acute" list or the "P" list because the  hazardous  waste
number for each of the compounds begins with the letter P.

     Compounds  appearing  in 40 CFR 261.33 (f) are listed for toxicity  unless
otherwise designated.  This is commonly referred to as the "U" list because the
hazardous waste number for each of these materials begins with the letter U.

     In  accordance  with  the  guidelines for hazardous  wastes  (see  comment
following 40 CFR 261.33 (d)), a household waste is hazardous if "it consists of
the  commercially pure grade" of a compound appearing on the P list or U  list,
or if it consists of "any technical grades of the chemical that are produced or
marketed",  or if it is a "formulation in which the chemical is the sole active
ingredient."    This is particularly applicable to pesticides  and  herbicides.
While  these  products can be distributed in relatively concentrated forms  for
industrial purposes, the commercial formulations purchased by the homeowner are
often  diluted.  Because the pesticides are the sole active ingredients in  the
diluted formulations, these products are considered household hazardous wastes.
If  a  product  contains a listed chemical, but this chemical is not  the  sole
active  ingredient,  then the product is not considered hazardous  (unless  the
product also exhibits any of the characteristics).

     The  four  characteristics  that can result in a  waste  being  considered
hazardous  are ignitability, corrosivity, reactivity, and EP toxicity.  EPA has
developed  definitions  for each of these characteristics.   These  definitions
primarily  specify  standard  test methods to be used to determine if  a  waste
exhibits  one of the characteristics.  Appendix B contains the EPA  definitions
of  these  properties  from  40  CFR Parts 261.21  through  261.24.    A  waste
exhibiting  any  of  these  properties is commonly  called  a  "characteristic"
hazardous  waste.    Products exhibiting these  characteristics  often  display
warnings  on the labels such as "flammable",  "combustable", "poison", "skin and
eye  irritant", "injurious to eyes and skin",  "harmful  if swallowed", etc.   The
lack  of  such  a  label,   however,  is   no  guarantee  that  the  product  is

     Exhibit  3-1  presents the generic types of wastes that can be  considered
hazardous  in  accordance  with  the   definition  and  information  about  the
constituents  that make them hazardous.  If the product appears in Exhibit  3-1
because  it  exhibits  one   of     the  four  characteristic  properties,  the
characteristic  that  caused  the  product to be  classified  as  hazardous  is
indicated.    If a product is considered hazardous because it is composed of  a
listed compound, that is also noted in Exhibit 3-1.

     While  the  generic types of products appearing in Exhibit 3-1  are  those
that are most often hazardous, exceptions may exist.  For example, the majority
of  oven cleaners are hazardous due to their corrosivity.  A few specific types
of  oven  cleaners,  however,  are composed of compounds that  are  either  not
corrosive  or  are  not  present  in sufficient  concentration  such  that  the
commercial  product is corrosive in accordance with the EPA definition.   These
products  are  the  exception  and not the rule.  Exhibit  3-1  should  not  be
considered a complete list of the types of products that meet the definition of
household  hazardous waste.  Project schedule and funding limitations precluded
actual testing of any product, let alone all oven cleaners, etc.

     In  addition  to the generic classifications, e.g. drain openers, or  oven
cleaners,  the  specific  chemical  ingredient(s) that cause the  waste  to  be
hazardous  are  identified  in  Exhibit 3-1.  Also included  are  the  specific
hazardous waste numbers for compounds appearing on the P list or U list, and/or
the  property  that  causes  the compound to be a  characteristic  waste  (i.e,
ignitability, reactivity, corrosivity, or EP toxicity).

     It  must be realized that not all of the components listed in Exhibit  3-1
under a specific generic product type will exist in every product of that type.
For  example, not every paint thinner contains all nine components listed under
the  paint thinner category.  The listed components are all ignitable compounds
that  have  been found in one or more of a variety of paint thinners.  Each  of
the  listed  compounds  that  are components of particular  brand(s)  of  paint
thinner   will  contribute  to  the  ignitability  of the  product.  Sufficient
quantities of the components exist in most paint thinners that the mixture (the
product) is ignitable.

     In  reviewing  the results of the product survey, it was found  that  many
products  contain  compounds that, when pure, would undoubtedly  be  considered
characteristic  hazardous  wastes.    When  these  compounds  are  sufficiently
diluted,  they  no  longer meet the criteria (e.g., pH for  corrosivity,  flash
point  for ignitability) set forth in the EPA definitions.  Unfortunately,  few
commercial  products list complete compositions, including both the  components
and  percentages.    Usually, the label either lists components  in  descending
order  of  concentration  (without giving the concentration),  lists  only  the
primary  components,  or lists no information at all.  There are many  products
that  may be characteristic hazardous wastes because of the components that are
listed  on  product  labels  or are commonly known to be ingredients.    It  is
uncertain, however, if these components are present in sufficient concentration
for the product to be hazardous.  Exhibit 3-2 lists the generic types of wastes
that  fall into this category, and the characteristic(s) that they may exhibit.
Exhibit 3-2 also provides the characteristic components that are likely present
in sufficient concentration such that the product may be a hazardous waste.

                        AND THEIR HAZARDOUS COMPONENTS

      A.   Drain Openers; (C)*

                1.  Sodium Hydroxide; Lye; Caustic Soda; (C)

      B.   Oven Cleaners; (C)

                1.  Sodium Hydroxide; Lye; Caustic Soda; (C)

      C.   Wood and Metal Cleaners and Polishes; (I)

                1.  Petroleum Distillates; (I)
                2.  Petroleum Naptha; (I)
                3.  Turpentine; (I)
                4.  Isopropyl Alcohol; Isopropanol; (I)


      A.   Oil  and Fuel Additives; (I)

                1.  Xylene; Xylol, Dimethyl benzene; (I), (U239)
                2.  Petroleum Distillates; (I)
                3.  Mineral Spirits; (I)
                4.  Methyl  Alcohol; Methanol;  (I), (U154)
                5.  Ethyl Ether; (I), (U117)
                6.  Secondary Butly Alcohol;  Secondary Butanol; (I)

      B.   Grease and Rust Solvents; (I)

                1.  Petroleum Distillates; (I)
                2.  Cresylic Acid; Cresol; (I), (U052)

      C.   Carburetor and Fuel Injection  Cleaners;  (I)

                1.  Toluene; Toluol; (I), (U220)
                2.  Methyl  Ethyl Ketone; MEK;  Butanone; (I,T), (U159)
                3.  Methanol; Methyl Alcohol;  (I), (U154)
                4.  Methyl  Chloride; Chloromethane; (I,T),  (U045)
                5.  Xylene; Xylol; Dimethyl benzene; (I), (U239)
                6.  Acetone; (I), (U002)
                7.  Diacetone Alcohol; (I)

      D.   Air  Conditioning  Refrigerants; (Listed)

                1.  Freon 12; Dichlorodifluoromethane; (U075)

EXHIBIT 3-1 (continued)

      E.  Starter Fluids; (I or Listed)

                1.  Petroleum Distillates; (I)
                2.  Ethyl Ether; (I), (U117)


      A.  Paint Thinners; (I)

                1.  Mineral Spirits; (I)
                2.  Acetone; (I), (U002)
                3.  Petroleum Distillates; (I)
                4.  Methanol; Methyl Alcohol; (I), (U154)
                5.  Toluene; Toluol; (I), (U220)
                6.  Methyl Ethyl Ketone; MEK; Butanone;  (I,T),  (U159)
                7.  Turpentine;  (I)
                8.  Isopropyl Alcohol; Isopropanol;  (I)
•  '             9.  Methyl Isobutyl Ketone;  Isopropylacetone;  (I),  (U161)

      B.  Paint Strippers and Removers;  (I)

                1.  Acetone; (I), (U002)
                2.  Toluene; Toluol; (I), (U220)
                3.  Petroleum Distillates; (I)
                4.  Methanol; Methyl Alcohol; (I)

      C.  Adhesives;  (I)

                1.  Methyl Ethyl Ketone; MEK; Butanone;  (I),  (U159)
                2.  Petroleum Distillates; (I)
                3.  Acetone; (I) (U002)
                4.  Butyl Acetate,  (I)
                5.  Mineral  Spirits; (I)
                6.  Xylene,  Xylol;  Dimethyl benzene;  (I),  (U239)
                7.  Petroleum Naptha;  (I)
                8.  Tetrahydrofuran; (I), (U213)
                9.  Isobutylacetate; (I)
                10.  Toluene; Toluol; (I), (U220)
                11.  Acyrlic  Acid;  (I),  (U008)
                12.  Hexane;  n-Hexane;  (I)
                13.  Allyl  isothiocyanate; Ally!  isosulfocyanate;
                       mustard oil;  (I)
                14.  Cyclohexane;  (I) (U056)
                15.  Formaldehyde;  (I),  (U122)
                16.  Ethylene dichloride;  1,2-dichloroethane;  (I),  (U077)
                17.  Ethylidene  Dichloride;  1,1,-Dichloroethane;  (I),  (U076)

EXHIBIT 3-1 (Continued)

      A.  Herbicides; ( E or Listed)

                1.  2,4-D: (E), (D016)
                2.  Si 1 vex; (U233)
                3.  2,4,5-T; (U232)

      B.  Pesticides; (E or Listed)
                1.  Acrolein; (P003)
                2.  Aldicarb; (P007)
                3.  Aldrin; (P004)
                4.  Arsenic Acid; (P010)
                5.  Aziridine; Ehyleneimine; (P054)
                6.  Chlordane; (U036)
                7.  Creosote; (U051)
                8.  2,4-D; (E), (D016)
                9.  ODD; (U060)
               10.  DDT; (U061)
               11.  Dieldrin; (P037)
               12.  Dimethoate; (P044)
               13.  Dinoseb; (P020)
               14.  Disulfoton; (P039)
               15.  Endosulfan; (P050)
               16.  Endrin; (P051)
               17.  Heptachlor; (P059)
               18.  Lindane; (U129)
               19.  Methoxychlor; (U247)
               20.  Methyl Parathion; (P071)
               21.  Parathion; (P089)
               22.  Pentachlorophenol; (U242)
               23.  Phorate: (P094)
               24.  Silvex; (U233)
               25.  2,4,5-T; (U232)
               26.  Toxaphene; (P123)
               27.  Trichlorophenol; (U230, U231)
               28.  Warfarin; (P001)

EXHIBIT 3-1 (Continued)
      C.  Fungicides/Wood Preservatives; (Listed)
                1.  Pentachlorophenol; (U242)
                2.  Trichlorophenol; (U230, U231)
    *I:        Ignitable per 40 CFR Part 261.21
     C:        Corrosive per 40 CFR Part 261.22
     E:        EP Toxic per 40 CFR Part 261.24
Listed:        Listed in 40 CFR Part 261.33 (e) or (f)
  D###:        EPA hazardous waste number for a specific constitutent failing
               the EP Toxicity Test, per 40 CFR Part 261.24
  P###:        EPA hazardous waste number for a specific acute hazardous waste
               appearing in 40 CFR Part 261.33 (e)
  U###:        EPA hazardous waste number for a specific hazardous waste
               appearing in 40 CFR Part 261.33 (f)
      Note:  Components listed must be present to such a degree that they  re-
             sult in the failure of a characteristic test by the generic  item.
       Important Note:  Not all examples of any generic type shown above are
                       considered hazardous household wastes, e.g. some oven
                       cleaners will not fail the corrosivity test.

                     EXHIBIT 3-2.  OTHER HOUSEHOLD ITEMS
                            THAT MAY BE HAZARDOUS

      A.  Drain Openers; (C)*

                1.  Sodium Hydroxide; Lye; Caustic Soda; (C)
                2.  Potassium Hydroxide; (C)
                3.  Sulfuric Acid; (C)
                4.  Hydrogen Chloride; Hydrochloric Acid; Muriatic Acid; (C)

      B.  Oven Cleaners; (C)

                1.  Sodium Hydroxide; Lye; Caustic Soda; (C)

      C.  Toilet Bowl Cleaners (C)

                1.  Hydrogen Chloride, Hydrochloric Acid; Muriatic Acid; (C)
                2.  Sodium Acid Sulfate; (C)

      D.  General  Purpose Cleaners; (C or I)

                1.  Oxalic Acid;  (C)
                2.  Sodium Hydroxide; (C)
                3.  Ethyl Alcohol; (I)

      E.  Disinfectants; (C or I)

                1.  Sodium Salt of 0-phenyl  phenol; Dowicide A; Natriphene;  (C)
                2.  Pine Oil; (I)
                3.  Isopropyl Alcohol; Isopropanol; (I)
                4.  Ethanol; Ethyl Alcohol;  (I)


      A.  Lubricating Fluids; (I  or E)

                1.  Petroleum Distillates; (I)
                2.  Lead; (E)

      B.  Radiator Fluids and Additives

                1.  Morpholine; Tetrahydro-l,4-oxazine; (I)

EXHIBIT 3-2 (Continued)
      C.  Waxes, Polishes and Cleaners; (I or C)
                1.  Petroleum Distillates; (I)
                2.  Phosphoric Acid; (C)
      D.  Grease and Rust Solvents; (C)
                1.  Phosphoric Acid; (C)
                2.  Potassium Hydroxide; Caustic Potash;  (C)
      E.  Body Putty; (I)
                1.  Toluene; Toluol; (I), (U220)
                2.  Butyl Acetate;  (I)
                3.  Styrene; Vinyl  Benzene;  (I)
      F.  Transmission Additives;  (I)
                1.  Xylene; Xylol;  Dimethyl benzene;  (I)
      A.  Paints;  (I)
                1.  Xylene; Xylol;  Dimethyl benzene;  (I),  (U239)
                2.  Toluene; Toluol; (I), (U220)
                3.  Propane; (I)
                4.  Vinyl Acetate;  (I)
                5.  Amyl Acetate;  (I)
                6.  Vinyl Toluene;  Methyl Styrene;  (I)
      B.  Paint Removers and Strippers;  (C)
                1.  Hydrogen Chloride;  Hydrochloric  Acid;  Muriatic Acid;  (C)
      C. ' Stains,  Varnishes, and  Sealants;  (I)
                1.  Mineral Spirits;  (I)
                2.  Petroleum Distillates;  (I)

EXHIBIT 3-2 (Continued)

      A.  Batteries; (C or E)

                1.  Sulfuric Acid; (C)
                2.  Mercury; (E)
                3.  Mercuric Oxide; (E)
                4.  Potassium Hydroxide; (C)
                5.  Sodium Hydroxide; (C)
                6.  Silver Oxide; (E)
                7.  Silver; (E)
                8.  Lead; (E).
                9.  Lead Peroxide; (E)
               10.  Lead sulfate; (E)

      B.  Fingernail Polish Removers; (I)

                1.  Acetone; (I), (U002)
                2.  Ethyl Acetate; (I), (U112)

      C.  Pool Chemicals; (R)

                1.  Sodium Dichloro-S-triazinetrione; (R)

      D.  Photo Processing Chemicals; (E, C, or I)

                1.  Silver; (E)
                2.  Selenium; (E)
                3.  Sulfuric Acid; (C)
                4.  Heptane; (I)

      E.  Electronic Items; (E)

                1.  Electrical  Solder

                         a.  Lead; (E)
                         b.  Silver;  (E)

                2.  Switches

                         a.  Mercury; (E)

EXHIBIT 3-2 (Continued)

      E.  Electronic Items; (E) (Continued)

                3.  Floodlights

                         a.  Mercury Vapor; (E)
        *I:     Ignitable per 40 CFR Part 261.21
         C:     Corrosive per 40 CFR Part 261.22
         E:     EP Toxic per 40 CFR Part 261.24
         R:     Reactive per 40 CFR Part 261-23
      U###:     EPA hazardous waste number for a specific hazardous waste
                appearing in 40 CFR Part 261.33 (f)

      Note:     Components listed are examples of those likely to be found in
                each generic type of item.  The percentages of these components
                in these items vary from one brand to another and thus the
                components may result in the item being hazardous.  However not
                all examples of each generic type listed contain the listed
                components (or other hazardous components) and these examples
                would not likely fail any of the characteristic tests.

     Again,  there  will be exceptions to the products listed in Exhibits  3-2.
For  example,  not all general purpose cleaners are considered to be  household
hazardous  wastes.   Also, not all general purpose cleaners  containing  oxalic
acid  are corrosive.  Some of these cleaners, however, may contain oxalic  acid
in  sufficient  concentrations  that they are corrosive according  to  the  EPA
definition.    Since  product  labels  seldom give  the  percentages  of  these
ingredients,  a cleaner containing an unknown concentration of oxalic acid  may
be a household hazardous waste.   In most cases where the product label supplies
the  composition, a more reliable decision can be made as to whether the  waste
exhibits any of the characteristics.

      A  review of Exhibits 3-1 and 3-2 indicates that there is some   overlap.
Some  drain  openers,  for  example, are known  to  contain  sufficient  sodium
hydroxide  to  be  corrosive.  This  is  known  because  the  label  gives  the
composition.    This  type of product is a household hazardous  waste  (Exhibit
3-1).    Other  drain  openers list sodium hydroxide, and a  variety  of  other
corrosive  ingredients,  but do not provide content  percentages.  Accordingly,
these appear on the list of items that may be hazardous, (Exhibit 3-2).

     These  exhibits should not be considered exhaustive lists of hazardous  or
possibly  hazardous household wastes.  They are based on the best judgement  of
chemical  and  environmental  engineers, the results of the  product  component
survey, and on the properties of  these components.


     Several  definitions of household hazardous wastes have been developed  by
the  organizations  conducting  waste  surveys   or  operating  HHW  collection
programs.   Invariably, these definitions are in the form of lists.  The  lists
usually  include  generic  types of materials followed  by  specific  examples.
Additionally,  the  collection programs often include a list of materials  that
are  not accepted.  These lists of non-acceptable items are often developed  to
reduce  the potential danger to the personnel conducting the program and to the
homeowners  transporting  the  materials to the collection center.    Materials
usually excluded are explosives, gas cylinders, and unknown materials.

     Exhibit 3-3 contains lists of generic household hazardous wastes and a few
examples  as  identified by organizations conducting household hazardous  waste
surveys.    The  definitions  contain  virtually  the  same  generic  types  of
materials.   These are related to household cleaning and maintenance, automotive
products,  paint  products,  pesticides,  and   miscellaneous  products.     The
University  of Arizona and the Los Angeles County lists (definitions) are  very
similar  to one another and are the most comprehensive of the first four shown.
They  both   were  used  in waste composition studies.   The thrust  of  the  Los
Angeles  County survey was primarily to identify industrial  or  commerical-type
products  that might be hazardous.  Some of the specific items identified  were
not  actually  considered  hazardous,  e.g.,  suntan oil and skin cream,  by  the
Sanitation  Districts.  The Albuquerque list was used in a house-to-house survey
and not in  a waste composition study.   The Mother Earth News list was developed
primarily  to advise its readers of potential chemical dangers to human  health
in  the  home.    . It was not directed toward wastes and it  was  restricted  to

                                 EXHIBIT 3-3.   COMPARISON  OF HOUSEHOLD HAZARDOUS  WASTE LISTS
University of
Arizona (1 )
Household and Laundry
Cleaners and Maintenance
- toilet bowl cleaners
- drain openers
- laundry and dish cleaners
- furniture, floor , and
metal cleaners and polish
- oven cleaner
Automotive Maintenance
- oil
- anti -freeze
- engine treatments
- degreasers and solvents
Paint and Glue
- oil -based paint
and thinner
- stains
- glue
- solvents and paint removers
Plant, Yard and Pet
- fertilizers
- pesticides and herbicides
- batteries
- nail polish and remover
Los Angeles County, CA
Sanitation Dist. (2)
Household and Cleaning
- bleach
- drain opener
- window cleaners
- metal polish
- oven cleaner
- charcoal lighter
- glue
Automotive Products
- motor oi 1
- oil filters
- radiator sealers
- anti -freeze
- brake fluid
Paint Products
- paint
- paint thinner
Insecticides, Pesticides
- insect sprays
- germicides
- weed killers
Personal Iten..
- butane fuel
- hair spray
- suntan oil
- deodorant
- Freon 12
- peroxide
City of Mother Wastes Listed in Exhibit 3-2
Albuquerque, Earth and Markedly Different from
NM (3) News (k) U of Az or LA County Lists
Household Products Utility Room
- cleaners " drain, toilet bowl
- polishes and window cleaners
- drain openers - oven cleaners
. glue - laundry products
- pesticides
Automotive ~ shoe care products
- motor oil " furniture polish
- anti -freeze - refrigerants
Paint ProHnchs Kitchen
- n*tr,t-* ~ preservatives
- Solvents and ' emulsifiers
thinners " flavoring/colorings
- pots and pans
- dinnerware
Plant, Yard and Pet
- weed killers fiathroom
- np
 materials   in  the  home  not  including maintenance, hobby, or yard-related  items.
 Interestingly,   it did  identify constituents of building materials,  such  as
 asbestos,  as being hazardous.

      It  is interesting to  note some of the items that were excluded from these
 lists.     Of the three  survey programs, none specifically  identified  swimming
 pool  chemicals  as  a hazardous waste even though these areas certainly have many
 home  swimming  pools.    Similarly, none specified  photographic  chemicals  or
 electronic equipment.    These three types of materials were  likely  excluded
 because  they   were overlooked  rather  than  because  they  were  consciously
 identified and then judged not to be hazardous.  Exclusion through neglect  is
 common  when  definitions are developed through the use of lists  or  examples.
 This  should not be considered a major defect of the survey programs and merely
 identifies a weakness in  the entire topic area of household hazardous waste. It
 is  primarily   due to  the  fact that researchers or  other  organizations  have
 become  involved with the topic independent of one another. While the resultant
 definitions  generally  concur  with  one another there  are  some  differences
 primarily  re-lated to  those types of materials that have been  excluded  just
 because they were  not considered as candidates.

      Probably   the most surprising group of materials to be included in most of
 the   lists are selected   personal  care items.  It is  unusual  to  think  of
 materials  that are applied directly to the body as being hazardous.   However
 through reviewing  product labels and through other research, some personal care
 items  have been listed and included in Exhibit 3-2.  The inclusion of personal
 care  items is  most often due to the presence of sufficient amounts of alcohols
 (or   other flammable volatiles) so that the product is  considered  ignitable.
 Fingernail  polish and polish remover were identified as a hazardous waste  by
 the   University of Arizona.    In its  house-to-house  survey,  the  City  of
 Albuquerque,  New   Mexico   included mouthwash and shampoo with at least  a  few
 respondents considering these items as hazardous to one degree or another and a
 small number even  considered these to be extremely hazardous.

      The   last  column  in  Exhibit 3-3 relates the list in Exhibit 3-2  to  the
 University of  Arizona  and  Los Angeles County lists.  The last column indicates
 additional  types   household items that may be hazardous  wastes, primarily  in
 the   areas  of  Automotive Products and the Other category.  The  only  deletion
 suggested  in the  last  column is latex paints.  Some surveys and possibly  some
 collection  programs  identify latex paints as hazardous.  However,  collection
 programs   usually   do   not  accept latex paints because  they  are  not  likely

     The   types  of  wastes accepted during selected  collection  programs  are
 listed  in  Exhibit  3-4.   Invariably,  these lists are shorter than  the  lists
 shown  in  Exhibit 3-3.   The lists may be shorter because they  were  primarily
developed by program sponsors who were not technically oriented or did not have
access to the survey lists shown in Exhibit 3-3.

     Most  collection  program sponsors indicate that they will   accept  nearly
anything  that  is delivered.   Usually the collection programs are operated  by
professional hazardous waste personnel  who are capable of  identifying and

                                                  EXHIBIT  3-4

         Fairfax County,  Virginia
                                  Albuquerque, New Mexico
                                     Andover. Massachusetts
CO ;
Solvents, spot removers


Oil-based paints and

Wood preservatives

Pool and photo chemicals

Chemistry sets

Flammable liquids including
  gasoline and kerosene

          -  Latex  paints
          -  Explosives
          -  Biologically  active  wastes
          -  Radioactive wastes
          -  Gas  Cylinders
          -  Asbestos
          -  Waste  oil
          -  Unkowns
Cleaning fluids, bleach,


Insecticides, herbicides,

Paint, thinner, stripper

Wood preservatives

Brake Fluid, anti-freeze

Swimming pool chemicals
                                  Anything else you would not
                                  want your child to get into.


                                  - Motor oil: direct to recycling
                                  - Biologicals
                                  - Explosives
                                  - Asbestos
Furniture Polish and

Paints and thinners


Pesticides, herbicides


Waste oil

Photo chemicals

                                     - None identified

properly handling a wide variety of waste materials.  Wastes that are obviously
nonhazardous are collected together and hauled to the municipal disposal site.


1.  Residential Hazardous/Toxic Waste Survey, City of Albuquerque Environmental
         Health and Energy Department, Albuquerque, NM, 1983.

2.  Stecher, P.G., Finkel, M.J., Siegmund, O.H., Szafranski, B.M., Editors, The
         Merck Index of Chemicals and Drums, Seventh Edition, Merck & Co., Inc.
         , Rahway, N.J., 1960.

3.  Weast, R.C., Editor, CRC Handbook of Chemistry and Physics, 60th Edition
         CRC Press, Inc., Boca Raton, Florida, 1979.

4.  National Fire Protection Association, Fire Protection Guide on Hazardous
         Materials, Seventh Edition, 1978, Sections FPI, 325M, and 49.

5.  Hammer, W., Occupational Safety Management and Engineering, Second Edition,
         Prentice Hall, Inc., Englewood Cliffs, N.J., 1981, page 402.

6.  Mother's Guide to Hazardous Household Substances, The Mother Earth News,
         May/June 1984.

7.  SCS Engineers, Disposal of Dilute Pesticide Solutions, EPA Contract No.
         68-01-4729, November 1978, pages 8-10, 23, 49.

8.  Davidson, J.M. et a!., University of Florida, EPA-600/2-80-124:
         Adsorption, Movement, and Biological Degradation of Large
         Concentrations of Selected Pesticides in Soils, Grant No. R803849,
         August 1980, page 10.

9.  SCS Engineers, Selected Biodegradation Techniques for Treatment and/or
         Ultimate Disposal of Organic Materials, EPA Contract No. 68-03-2479,
         March 1979, page 348.

                                  SECTION 4
                            PRESENCE  IN WASTESTREAM

 Generation Rates

     How  much solid waste does each person generate every day and what  is  the
 composition  of  that waste?  These questions have been asked since   the  early
 1970's  and  even  before  when interest  in solid  waste  management   increased
 dramatically.    To this day, neither question has been answered completely  or
 conclusively. To answer these questions,  much work remains to be done.   Reasons
 for ambiguous or differing answers include the fact that there is no  "standard"
 definition  of  residential wastes and the fact that refuse composition  varies
 from  one  season  to the next.  Similarly, there have been  changes   in  waste
 generation  practices over the past 10 to 15 years that likely have impacted on
 the amount and types of waste discarded.

     Estimates  of  waste  generation rates have varied widely.  In   the  early
 1970's,  a  commonly used figure was 5 pounds per person per day.  This  figure
 was  quickly  found  to  be too large.  It probably included  all  solid  waste
 collected  in  a  community divided by the population of that community.    The
 waste  quantity  thus  included  industrial  and  commercial  as  well   as  the
 residential refuse.  Other estimates of residential waste generation  rates fall
 to 1 pound per person per day.

     A  primary  difficulty  in  the estimation of waste  generation   rates  is
 defining  what  types  of waste should and should not be  included.   All  solid
 wastes  generated  by householders should be included.  Using that  definition,
 several  types of wastes would be counted that normally would be excluded  from
 consideration.   These include:  garbage  that is disposed by garbage   grinders;
 wastes  that  are disposed of on the owners' property such as grass   clippings,
 leaves,  and composted materials; and waste materials that are source  separated
 for  recycling.    Bulky wastes such as furniture and appliances  that  require
 special collection also should  be included.

     For  purposes  of  this report,  the wastes of concern should  include  all
 those  normally  collected  by  municipal  or private haulers  and  disposed  in
 sanitary  landfills or through similar means.  Essentially,  this means  that  the
 residential  wastestream  is whatever is put out in the trash can.     Even  this
 varies  across the country and throughout the year. Yard trimmings  is  a type of
 waste  with great variability.  Locations in the South generate much more  yard
 waste than in other parts of the country.  Around the year,  there are changes in
 waste  generation  rates.    Summer is normally the  time  with  highest  waste
 generation  due to landscaping work and a general  higher level  of  recreational
 and  other  activities.    Thus,  any survey to estimate waste  generation  rates
 should take into account seasonal  as  well  as geographic variations.

     The  results of several  waste generation surveys are shown in  Exhibit 4-1.
They  range in time from 1973 to 1985.   The data indicate a range of generation

Santa Clara County,
CA, 1977
San Francisco, CA
Alameda County, CA
Contra Costa County,
CA 1977
City of Tulsa, OK,
Milwaukee, WI, 1978
Marin County, CA, 1980
Tucson, AZ, 1973-1980
North Santa Clara
Ib/oerson/dav Comments
1.1 Based on 3.0 person/household.
Does not include yard waste.
1.3 Base on 3,0 person/household.
1.1 Based on 3.0 person/household.
1.8 Northern portion of Santa Clara
  County, CA  1983

Dorchester County, MD

Rural county.  Includes wastes
identified as residential or
institutional and hauled to
municipal landfill.
1.  Survey of Solid waste Quantity and Composition in the San Francisco Bay
    Area, SCS Engineers, Long Beach, CA, 1978.

2.  Municipal Solid Waste Generation in Tulsa, Oklahoma, SCS Engineers,
    Covington, KY, 1985.

3.  The Milwaukee Garbage Project, Dr. William L. Rathje and Dr. Barry
    Thompson, published by The Solid waste Council of the Paper Industry,
    American Paper Institute, Washington, D.C, 1981.

4.  Comprehensive Waste Characterization on a Quarterly Basis, J.C. Glaub and
    G.M. Savage, Cal  Recovery Systems, Inc., Richmond, CA, undated.

5.  Dorchester County, Maryland Solid Waste Management Plan, SCS Engineers,
    Reston, VA, 1980.

rates  from
included   in
1.1  to 3.5 Ibs per person per day.   All
refuse.    Thus, wastes from commercial
the calculation of the generation rates.
proport to  include  only
establishments  were  not
 Even the  most   closely
controlled  surveys  can include assumptions or data that are erroneous.    The
source  of  refuse is sometimes uncertain since haulers sometimes collect  both
commercial  and  residential waste using the same truck.  Likewise,  population
estimates  or  estimates of the number of persons per household are subject  to
error and even slight differences, particularly in the number of persons in the
household.    This can result in dramatic differences in calculated  generation

     The  National Solid Waste Management Association (NSWMA) reported-  average
residential waste generation in its "Technical Bulletin 85-6, Basic Data: Solid
Waste  Amounts,  Composition,  and Management Systems".  It estimates  a  solid
waste  generation  rate of 2.5 to 3.5 Ibs per person per day.  The  first  five
entries  in Exhibit 4-1 generally support that range.  The range of 2.5 to  3.5
Ib  per  person per day appears to be accurate enough for large-scale  planning
purposes  and  general  reports  covering wide geographic  areas.    Exceptions
definitely  occur  from  place  to place and throughout the  year  in  any  one

     Residential  waste  composition  data  are  •  scarce.    Most  reports  of
composition  are  based upon visual observations and intuition rather than  the
manual  sorting  and  weighing  of refuse and its components.    Even  weighing
programs  have  their limitations and the results are difficult to  extrapolate

     Until  the  early  1970's,  there  was  little  interest  in  solid  waste
composition.   Early waste composition waste studies were motivated by interest
in recycling.  Thus, the composition studies of the 1970's generally focused on
identifying  recyclable  materials.   These included various grades  of  paper,
glass,  usually  aluminum and other metals separately,  and sometimes  wood  and
plastics.  Other components were considered as "others".

     In  the  the late 1970's interests shifted toward the recovery  of  energy
from  municipal  waste  through  incineration.  This caused  a  change  in  the
approach  to  waste composition studies.  These studies stressed both the  size
and  general  characteristics  of the waste related to  their  energy  recovery
potential.    In  general, the solid wastes were categorized  as  combustibles,
magnetics, non-ferrous metals, glass, and others.  The presence of combustibles
gave incinerator planners information on the energy content of the refuse.  The
presence  of  metals  indicated  what  portions of  the  wastestream  could  be
separated  by  magnetic means or what waste portions might cause problems  with
incinerator  operations.   Likewise, glass was seen as a problem  material  for
incinerator operations and its presence was usually identified.

     Thus, the limited information bank on residential  waste characteristics is
not  consistent; nor are surveys easily comparable  to one another.  Exhibit 4-2
includes  waste  composition information from 10 locations.  The  studies  were

                                 EXHIBIT 4-2.  RESIDENTIAL WASTE COMPOSITION*
Santa Clara County
CA 19771
Santa Clara County,
CA 19842
San Francisco, CA
St. John's Landfill
Portland, OR 19793
Rossman's Landfill
Portland, OR 19793
St. Louis, MO 19814
Los Angeles, CA
Dearborn, MI
San Diego County
CA, 19817
Burbank, CA
Non- Ferrous
Metal (mostly
aluminum) .
Organ ics
*  Percent by weight
** Not Available

EXHIBIT  4-2  (continued)

1.   Survey of Solid Waste Quantity and Composition in the San Francisco Bay Area,  SCS Engineers,
     Long Beach, CA, 1978.

2.   Comprehensive Waste Characterization on a Quarterly Basis, J.C.  Glaub and G.M.  Savage, Cal
     Recovery Systems, Inc.

3.   Solid Waste Characteristics and Flow in the Portland Metropolitan Service District, SCS
     Engineers, Long Beach, CA  1980.

4.   Solid Waste Sampling Program St.  Louis Resource Recovery Project, SCS Engineers, Long
     Beach, CA, 1982.

5.   Unpublished Data, Bureau of Sanitation, City of Los Angeles, CA.

6.   A Comprehensive Municipal Refuse Characterization Program, Proceedings of the  1980 National
     Waste Processing Conferences, American Society of Mechanical Engineers, May 1982.

7.   An Applied Statistical Approach to Refuse Composition Sampling,   A Comprehansive Municipal
     refuse Characterization Program,  Proceedings of the 1980 National Waste Processing
     Conferences, American Society of Mechanical Engineers, May 1982.

8.   Municipal Waste Characterization, Burbank California, SCS Engineers, Long Beach, CA 1980.

conducted  over  the  timeframe  1977 through 1984.  .Although  other  data  are
available, some are prior to 1970 and most support the figures shown.  The data
seem to indicate fairly consistent composition from one location in the country
to  another and over the seven-year time span represented.  The most consistent
results include the following:

              Material                    Percent bv Weight

              Newsprint                          8-12%
              Corrugated                         4-6%
              Ferrous Metal                      3-5%
              Aluminum                             1%
              Glass                              7-8%
              Plastic                            5-7%

     The  remainder primarily consists of other organic wastes.  These  include
other  types  of  paper products, wood, yard debris,  food wastes,  rubber,  and
leather which make up some 65 percent of the entire residential wastestream.

     There  has  been a resurgence of interest in solid waste  composition  for
purposes  of  overall  solid  waste   management  planning  including  resource
recovery.   SCS  Engineers began an extensive solid waste composition  study  in
Michigan  in  February 1986.  Wastes delivered to six disposal sites are  being
manually  sorted.    The sites are located throughout the state  and  represent
urban  and rural areas'.  Composition surveys will be conducted four times in 12
months in order to account for seasonal variations.


      Only  three  attempts at quantifying amounts of hazardous  wastes  coming
from  households have been identified.  Each has used a different approach and,
not  surprisingly,  the  results of each are different from one another.    The
small  number of projects focusing on quantities of HHW reflects the relatively
recent  nature  of interest in this topic and the relatively large amount    of
effort required to conduct a waste composition program.

     The  Los  Angeles  County   Sanitation    Districts  conducted  a  limited
characterization  study in 1979 (1).  The purpose of the study was to  estimate
the types and quantities of industrial-type wastes including both hazardous and
non-hazardous  materials  received  at landfills and one  transfer  station  in
Southern  California.    The  first step in the effort was  to  identify  these
wastes.    The  Districts developed the list of items of i-nterest as  shown  in
Section  3.    Manual sorting and characterization of 155 tons of  refuse  were
included  in the program.  This program involved both a count of the number  of
containers  associated  with  HHW  and  measurement of the  quantity  of  their
contents.   More than 90 percent of the containers were considered empty.

     The  presence  of hazardous wastes from all sources was found to be  quite
low.    The Districts estimated that notably less than 1 percent of all  refuse
received  at these facilities was hazardous.  The majority of these wastes came
from  commercial/industrial-type  sources.  It  was estimated that less than 20

percent  of  all   hazardous  waste entering the  sites  came  from  residential

     In  a more recent effort, the Los Angeles County Sanitation Districts have
been systematically sorting loads of refuse to identify hazardous waste.  Since
California  has  a  zero  small  quantity generator  exemption,  all  commercial
sources  of hazardous waste are legally required to dispose of those wastes  in
permitted  hazardous  waste facilities.  Thus, the thrust of the program is  to
identify  commercial violators.   In 1984 and 1985, 5 to 6 refuse trucks per day
were  inspected for hazardous wastes.  The programs were conducted at four  Los
Angeles  County  landfills  and one transfer station.  The   inspectors    were
primarily  interested  in identifying commercial-size quantities  of  hazardous
wastes   and, therefore, typically looked for containers larger than one gallon
in  size  or for entire boxes full of hazardous wastes.  Nearly 3,500 loads  of
refuse  representing  some 15,000 tons of waste were searched in 1984.  Results
indicated  total  hazardous waste to represent only 0.00147 percent of the tota.l
amount  of  waste delivered to these facilities.(2)  Expressed in another  way,
total  hazardous  waste  was  about 15 parts per million in  the  entire  mixed
municipal waste stream including commercial as well as residential sources.

     The  Sanitation Districts caution against a comparison of results  between
the  1979 and 1984 projects.  In 1979, some 155 tons of refuse were sorted with
hazardous  waste  estimated  at  much less than 1 percent.   The  1984  sorting
involved  some  15,000 tons with hazardous waste estimated at 0.00147  percent.
Hazardous waste disposed 'at these municipal sites had not necessarily decreased
during  this period.  The data are too limited to draw any definite conclusions
regarding the exact presence of household hazardous waste, generation rates, or
trends  in  generation.    A   third approach  in  determining  composition  of
household  hazardous wastes is described subsequently as part of the discussion
of the Albuquerque, NM residential hazardous waste survey.

Composition of Household Hazardous Wastes

Los Angeles County--

     The  1979  project  conducted   in    Los  Angeles  County  involved  waste
characterization  to identify commercial and  industrial-type wastes that  might
be hazardous.  The  following  are general results from that survey:(1)

     •  Household and cleaning              40.0 percent

     •  Automotive  products                 30.1 percent
        (includes oil and antifreeze)

     •  Personal items                      16.4 percent

     •  Paint and allied                    7.5 percent

     •  Insecticides, pesticides            2.5 percent
        and herbicides

     t  Other                               3.5 percent

University of Arizona--

     The  Department of Anthropology at the University of Arizona in Tucson has
conducted  detailed  residential refuse characterization from 1973 through  the
present.  During the two most recent years, efforts were focused on identifying
HHW.  The types of items identified as hazardous were listed in Section 3.  The
primary thrust of the characterization studies have been to count the number of
containers  that  could  have or do contain hazardous waste. Future  work  will
involve determining the amounts of residue typically found in these containers.
One  of  the interesting results of this project is the estimate of  the  large
number  of such containers discarded by each household every year. The  project
was  conducted in both Tucson, AZ and Marin County, CA near San Francisco.  The
comparative results are as follows:(3)

                                        Tucson. AZ            Marin County, CA

     Number of individual pickups
       characterized                      1,345                      144

     Hazardous waste items                1,195                      160

     Tons of refuse not including
       yard waste                          13.1                      2.1

     Hazardous waste items per ton           91                       76

     The  University  of  Arizona  indicates that  about  100  hazardous  items
(containers)  are  discarded per household each year.  Thus, the  some  120,000
households in Tucson generate approximately 11 million of these hazardous items
annually.(3)    Again,  essentially no research has been done to  quantify  the
contents of these containers; just to count them.  The researchers caution that
their  samples  have  been small and that extrapolating the data is  crude,  at
best.  The  actual  degree  of hazard represented by these  materials  and  the
quantity  of  the  materials  going  into the  municipal  landfills  are  quite
uncertain.    As these hazardous materials continue to accumulate in  landfills
the issue of a safety threshold becomes an increasingly vital public concern. A
better  estimate  of the potential environmental damage awaits a more  thorough
determination of the presence of household hazardous waste as well as the types
and characteristics of these wastes.

City of Albuquerque, NM --

     Albuquerque  depends  entirely  upon ground water for its  muncipal  water
supply.    After  one  of its wells became  contaminated,  the  City  undertook
industrial  and  residential hazardous waste surveys attempting to identify the

source  of  contamination.   The residential  survey took an  entirely  different
approach from that used in  Los Angeles or by the Univeristy of Arizona.

     In  January  1983,  a   house-to-house   survey  was  conducted  to  obtain
information on waste generation habits.(4)  The City's Environmental Health and
Energy Department identified 386 households  to be included in the survey. These
households were divided amoung the four quandrants of the city in proportion to
population.  Three basic questions were asked:

     t  What are household  hazardous wastes?

     •  How hazardous are certain wastes?

     t  How  much  of each  of these wastes did you dispose last year,  and °how
        were they disposed?

     The  first  question  was asked in a completely unassisted  manner.    The
interviewer  asked  the  householder to identify as many of  general  types  of
household  hazardous  wastes as they could.  Twelve percent of  the  respondents
could  not  name  any household hazardous wastes and an additional  28  percent
could  only name one.  Thus, without prompting, 40 percent of the  householders
could  not  name  more than one hazardous household waste.  The  most  commonly
identified item was the group of household cleaners with over 60 percent of the
respondents identifying that type.(4)

     The  next question requested the householder to rate the degree of  hazard
associated  with selected items.  Twelve household items frequently  considered
hazardous  were  included  in  the list.  Additionally,  shampoo,  sawdust  and
mouthwash were included as  "ringers".  The respondents were asked to give their
opinion  of  an item's hazardous nature by responding in terms of a five  point
scale,  ranging from not hazardous to extremely hazardous.  The results of  the
survey are shown in Exhibit 4-3.

     Interestingly,  3  percent  of the respondents considered  pesticides  and
poisions not hazardous and  25 percent did not think motor oil was hazardous. On
the  other end of the scale, 1 percent of the surveyed population thought  that
mouthwash  was extremely hazardous and 2 percent thought that both shampoo  and
sawdust  were  extremely  hazardous.   The results indicate  a  wide  range  of
opinions  as  to  what  types of household items are  and  are  not  considered

     The  next step in the  survey was an attempt to quantify the amounts of  12
hazardous  items  generated and disposed of by homeowners in Albuquerque.   The
interviewer asked each person to estimate the quantity of each of 12 items that
they  disposed  during  the  past 12 months.    Additionally  respondents  were
questioned  about their method of disposal (e.g., putting the item out for city
refuse  collection,  pouring  the substance down the sewer, hauling it  to  the
landfill,  or  using other land disposal methods).  The results indicated  that
the  vast majority of HHW disposed in Albuquerque was automotive related. Waste
motor  oil and antifreeze combined amounted  to approximately 75 percent of the
total.(4) This is in  contrast to household cleaners and polishes that amounted
to only about 2 percent of the total.

                                  EXHIBIT 4-3

                         ALBUQUERQUE,  NM RESIDENTS'
                         SELECTED TOXIC SUBSTANCES
Household Cleaners
Household Pol ishes •
Drain Openers
Motor Oil
Weed Killers
Ferti 1 izers
Solvents or Thinners


Degree of

Extreme 1 y
Source:  Reference

     The  Albuquerque  survey included an estimate of HHW quantities  generated
each  year.  Survey results, extrapolated a city population of 96,300  dwelling
units,  yield  an  estimated 1.6 million pounds (800 tons) of HHW  annually.(4)
Assuming  3.0  persons  per dwelling unit and daily overall  residential  waste
generation  rates  of  2.5  to  3.5  Ib per person,  the  presence  of  HHW  in
Albuquerque residential waste was approximately 0.5 percent.

     The  reader  is cautioned not to interpret these results as indicative  of
nationwide trends or to make other projections based  on the results of the Los
Angeles or Albuquerque data.  While the Los Angeles programs involved weighing,
they  focused  on   commercial-size   containers    and,  therefore,  may  have
underestimated  the  proportion  of  total household waste that is  HHW.    The
Albuquerque  survey  was based entirely on residents' responses  and  memories.
Neither  could  be  called  statistically accurate for  numerous  reasons.  The
results should only be used to estimate, in the most general way, the types and
amounts  of HHW.  The lack of more substantial documentation of HHW  generation
is definitely a data gap.


1.   Hand Sorting Fact Sheet, Los Angeles County Sanitation Districts, Solid
          Waste Management Department, Whittier, CA, 1979.

2.   Unnannounced Search Summary 1984, Los Angeles County Sanitation Districts,
          Solid Waste Management Department, Whittier, CA 1984.

3.   Preliminary Results from Household Phase Research, Department of
          Anthropology, University of Arizona, Tucson, AZ, 1985.

4.   Residential Hazardous/Toxic Waste Survey, Environmental Health and Energy
          Department, City of Albuquerque, NM, 1983.

                                  SECTION 5

Impacts on the Public

     The  presence  of  HHW in the residential wastestream certainly  has  some
impact  on not only the householder but also on refuse collection and  disposal
personnel.  In the vast majority of instances, disposal of hazardous waste from
homes likely does not harm anyone directly.  However, there have been instances
across the country in which people have been injured by HHW.

     Homeowners  are  probably the group most often affected.   When  hazardous
household  products are misused or improperly stored or disposed, residents are
the  ones  most likely exposed to the dangers, and they will be subject to  the
longest  term exposure.  Children and pets are also often present and they  may
be particularly susceptable to the hazards posed by some household products.

     The nature of some HHW also increases their potential damage to homeowners
over  a period of time.  Materials that are used infrequently are often  stored
in  closets, basements, or garages for long periods of time.  Materials such as
paint  thinners,  solvents,  fertilizers,  and  others  may  react  with  their
containers over the years, causing the containers to deteriorate.  This further
increases the potential danger to homeowners.

     There  are  no  known studies or tabulations of injuries or  illnesses  to
homeowners  related  to HHW.  However, burns from acids,  respiratory  problems
from  volatile solvents, and other health impacts have certainly been caused or
aggravated  by  HHW.   These incidents are not specifically reported  as  being
associated  with  the  storage or disposal of hazardous waste  but  are  lumped
together in general categories such as household accidents.

     The  special  collection  programs  for   household  hazardous  waste  are
certainly  directed  in  part at reducing the potential hazard  to  homeowners.
Educational  aspects  of  the programs help the public  identify  HHW,  provide
guidance  related to the safe use of these materials, identify substitutes that
are less hazardous, and describe safe disposal methods.  The collection aspects
of  these programs result in removing pesticides, solvents, and other materials
that  may  be  stored improperly over long periods of time.    This  definitely
reduces  the  chance of illness or injury.  Of course, the  actions  associated
with  the  collection programs, i.e., homeowners collecting the  materials  and
transporting  them to the collection location, certainly increase the potential
for exposure.  However,  this is for a relatively short period of time.

Refuse Collection

     Refuse  collection  personnel   are also affected  by  household  hazardous
waste.   Little  has  been  done in  the way of documenting  injuries  to  refuse
collectors  associated   with  the handling of these materials;    however,   some

cities  and organizations are aware of the potential and are trying to  protect
sanitation  workers.    The   Governmental    Refuse  Collection  and  Disposal
Association  (GRCDA) has conducted a series of workshops across the country  to
alert  public waste management personnel to the presence of hazardous waste and
the  related dangers.  These workshops focus on both the presence of  hazardous
waste  from small commercial and industrial sources as well as from residential
sources.    Tips  have been provided as to how refuse collectors  can  identify
suspected hazardous waste and what to do when some of these material are found.

     Public  and  private  refuse haulers usually provide some form  of  safety
training to their employees.  Usually this is associated with safety around the
collection  vehicle  and potential injuries associated with routine  collection
activities.    However,  some cities are providing training  associated    with
hazardous waste.

   •  The City of Tempe, Arizona has implemented an extensive program related to
household  hazardous  wastes.(1)    The   program  involves  the  Public  Works
Department  and the Fire Department.  Public education, as well as planning for
hazardous  waste incidents are elements of the program.  The City is  providing
education  to  its citizens to increase their awareness of what  are  hazardous
wastes and what to do with them.  Announcements on cable television, the radio,
and  in  newspapers  list  commmon  types of HHW.    Suggestions  are  provided
regarding  what  not  to  do with them, e.g., mixing of  certain  materials  or
dumping them down the sewer.

     Additionally, Tempe provides a special pick-up service for HHW. Homeowners
who  think  they  might  have some hazardous wastes may call  for  the  pick-up
service.  In response to a call, a refuse supervisor and a fire inspector visit
the  home to identify the material.  If it is hazardous, it is removed, stored,
and eventually disposed via a hazardous waste contractor.

     Training  is also provided to City refuse collectors and street  personnel
regarding  hazardous  wastes.  This is conducted in conjunction with  the  fire
department  and  focuses  on hazardous spills as well as HHW.   Collectors  are
trained  to  detect  potential hazards and to respond appropriately.    When  a
suspicious  item is identified, refuse collectors radio the dispatcher who then
informs  the refuse and fire inspectors.  The inspectors identify the .material
and,  if it is determined to be hazardous, they  isolate it from residents  and
buildings  as  much  as  possible. If the waste is in one  of  the  residential
automated  collection  containers,  the entire container (up to  300  gal.)  is
placed  into  a  special  overpacked  drum the  City  has  available  for  such

     The  training  is  thorough and, periodically, all  personnel  go  through
refresher  training.  All new personnel receive the HHW training.  Monthly  and
quarterly  safety  meetings  are  used to update all  personnel.    To  further
reinforce  the  training,  the City periodically conducts  simulated  hazardous
waste  incidents.  Responses of personnel are evaluated and improved techniques
are developed and implemented. City personnel know of no other similar training
program in the country.

     The  training and response programs were developed to minimize the  impact
of  improper  storage and disposal of both household and  commercial  hazardous
wastes.    Tempe  personnel  were concerned that the  reduction  of  the  small
quantity  generator  exclusion to 100 kg. per month would encourage  owners  of
small  businesses to illegally dispose of their hazardous wastes in residential
containers.    This  may occur in Tempe where residential collection  is  fully
automated using 90 and 300 gallon containers.

     Refuse  collectors  have been injured by HHW.  The number and severity  of
accidents,  injuries,  or  health  impacts associated  strictly  with  HHW  are
difficult  to  identify.    The   information    is  often  vague  and  is  not
centrally-located.(2)  In  most instances, injuries related to HHW have  to  be
inferred.    However,  the Association of Bay Area  Governments  in  California
performed  a  study  on inappropriate disposal of hazardous wastes  from  small
quantity  generators and noted cases of injuries from inappropriate disposal of
HHW.(2)  Most  of  the injuries occurred while the waste was being  emptied  or
compacted. Some of the incidents that have affected refuse collectors include:

     •  Serious  injury  to one refuse collector has been directly  related  to
        HHW.  A  refuse worker in San Diego, CA lost his sight  when  hazardous
        waste  from a residence spilled on his face.  The hauling firm notified
        the  residents  of the injury and identified wastes that should not  be
        discarded  in  residential  waste. The San Diego  Environmental  Health
        Department  was barraged with phone
        A  task  force was formed that subs
 inquiries on how to dispose of HHW.
equently developed the current  City
        A  private  firm in Lemon Grove, CA reported a number of  incidents  in
        which  swimming pool chemicals splashed on collection personnel  during
        the  compaction  of residential refuse.  One worker lost 50 percent  of
        the use of his left eye.(2)

        Used motor oil caused severe eye irritation of three disposal personnel
        in Lemon Grove, CA. (2)

        Severe  eye irritation in one incident was caused by contact with paint
        thinner also in Lemon Grove, CA.(2)

        Some  42 incidents have been reported in Los Angeles County, CA related
        to  HHW.   Injuries to refuse collectors have been caused primarily  by
        oil, battery acids, swimming pool  chemicals, paints, and solvents.(4)

        A  refuse  collector  in  Sacramento County, CA  lost  his  sight  when
        splashed by swimming pool  acid during compaction.(4)

        At least three injuries per month  occur in San Francisco, CA, caused by
        exploding aerosol  cans.(4)

        A  caustic material in residential  refuse caused severe skin irritation
        to a refuse collector in Roscoe, IL.(2)

     •  A  sealed  container  of ammonia burst under compaction and  sprayed  a
        refuse collector's eyes and face in Boyne City,  MI.(2)


     Household  hazardous wastes can also have negative  impacts on the  hauling
and  disposal  of  refuse.  A number of these wastes,  particularly  automotive
products, are ignitable.  Therefore, it is certainly possible that some of them
have  caused fires in refuse collection trucks.  Fires in packer trucks are not
unusual.   Personnel from the City of Tempe, Arizona report  an  average of  five
such  fires in the City's residential packers each year.(l)   They believe there
are  only  two  likely  causes:  hot ashes from  barbecues  or  fireplaces,  or
chemicals  (HHW).    Investigations have not identified  the   numbers  of  fires
attributable  to each type of waste. However, if only one packer fire per  year
in  the city of 170,000 is caused by HHW and this number is  extrapolated to the
entire  country,  HHW are a significant source of property loss  and  potential
injury or health impacts.

     Personnel at a transfer station, landfill, or other disposal site may also
be  injured  by  HHW.  The activities of unloading, spreading,   and  compacting
refuse  often  cause containers to rupture and contents to be sprayed into  the
air.   Injuries and accidents at the disposal site have been reported for  both
haulers  and  landfill  personnel.   Again,  little  tabulated-  information  is
available.  However, reports from disposal site supervisory personnel indicated
that incidents related to hazardous wastes occur, but rather infrequently. This
relatively  low level of reported incidents may be  due to the perceived  minor
nature  of  these events when they occur.  Only accidents that require  special
care  such  as the use of a respirator or something more than simple first  aid
are  likely  to receive  recognition as being related to HHW.   Furthermore,  a
landfill  is a relatively accident-prone area and numerous cuts and burns occur
that are not related to hazardous waste.

     The  unusual  or  dramatic  events related to hazardous  waste  are  often
remembered.    Some  landfill  personnel report gas cylinders  in  refuse  that
rupture  when the dozer runs over them, blowing off the end of the cylinder and
propelling  it several yards.  Other incidents are often associated with people
hauling  their  own wastes and unloading the vehicles by hand.  Other types  of
concerns includes inhalation of dust and vapors from HHW.

     Some  specific incidents involving disposal personnel have been associated
with  HHW.   Many are fires in packer trucks or at landfills.  Although  it  is
difficult  to prove the relationship between these events and HHW,  intuitively
there is a connection.

     •   In  Ashland,  MA,  a  load  caught fire while  being  unloaded  at  the
        landfill. (2)

     •   In  Evansville,   IN,  a  load caused a fire that  took  four  hours  to

     •  A  collection  vehicle caught fire and was destroyed in  Michigan  from
        flammable waste in the load.(2)

     t  A  resource  recovery  facility was severely damaged by a fire  from  a
        small  container of flammable material in Wisconsin.(2)  Explosions  at
        refuse shredders are often blamed on solvents in the residential waste.

     •  Three persons were hospitalized with rashes and respiratory problems at
        a transfer station in Lexington, KY.(2)

     •  In Downers Grove, IL, chlorine tablets caused a fire in a truck.(4)

     It  is  impossible to designate HHW as the sole cause of the  injuries  to
refuse collectors, landfill operators, or to collection and landfill equipment.
Factors such as the wide range of waste collected and the lack of detail in the
reported  incidents preclude any definitive conclusions.  While the presence of
household hazardous waste has no reportable or measured association with worker
safety,  certainly  it has an impact.   Any steps to reduce the amount of  these
materials  being  handled  by haulers  or disposal personnel will  reduce  these
hazards to them.


     Does  household hazardous waste have any impact on the environment? During
the  conduct  of  this  project,   no    documented  cases  were  identified  of
environmental  impacts caused solely by HHW.  However, this does not mean  that
HHW do not impact the environment.  There appears to be no nationwide reporting
procedure that includes information relating HHW to the environment. Thus, only
a scattering of individual reports were obtained.

     HHW have been detected in surface water and in sewage in Seattle, WA.(5) A
study  of  urban streams in Seattle indicated that residents were disposing  of
pesticides  improperly  such that they were migrating into the  surface  water.
Concurrently, analysis of wastewater indicated that some contaminants were from
homeowners  disposing  of  HHW  via the sanitary sewer  system.    Although  no
environmental  impacts  were discovered, these incidents certainly  verify  the
presence of HHW in the environment and point to potential damage to ecosystems.
These  studies  led  to  implementation of the HHW collection  program  in  the
Seattle area.(6)

     Indirect  evidence  indicates  that  HHW may  contribute  to  ground-water
contamination.   More than 12 former municipal waste disposal sites are on  the
National  Priorities  (Superfund)  List of sites with  contamination  requiring
near-term  corrective  action.    In the past, these  sites  received  HHW  and
commercial/industrial wastes (likely including hazardous wastes) in addition to
household  refuse.    The  present ground-water  contamination  indicates  that
industrial (or HHW) chemicals are the  source of the problem.  However no direct
proof  exists that HHW are the only pollutants.  This same situation is  likely
present at many active municipal solid waste landfills.

     The  limited data from Los Angeles County and Albuquerque noted in Section
4,  indicate  that  HHW makes up much  less than 1 percent  of  the  residential

wastestream  and  it  may be as little as 15 parts per million.    Thus,  these
materials  are  relatively  rare  and their impact on the  environment  may  be
somewhat  insulated  by  the presence of non-hazardous refuse.    The  landfill
environment  may reduce the hazard of these materials.  The actions of disposal
likely  cause  dispersion and at least brief exposure to the atmosphere.   This
likely  leads  to evaporation of some liquids and the dispersion of the  wastes
throughout  a  greater  volume than in the closed container.   Both  situations
could  lead  to  accelerated  chemical  or  biological  activity  reducing  the
hazardous nature of some of the materials.

     Some  hazardous  constituents  will persist in the  environment  for  long
periods of time.  They are candidates for migration into the air, ground water,
and  surface  water.  Good management of a sanitary landfill will minimize  the
impact  of HHW on the environment.  However, there certainly is some  potential
for  negative  impact.   Constituents from hazardous wastes can be  leached  as
water  percolates through the refuse.  Some HHW are volatile.  The constituents
may  become a part of the landfill gas being generated through decomposition of
organic  materials.   The gas may migrate and pose a health threat if found  in
high enough concentrations.  Another possibility is contamination of the ground
water  through contact with landfill gas contaminated from household  hazardous

     In  summary,  there  appears  to  be  impacts  on  human  health  and  the
environment  from  household  hazardous waste.  These impacts  begin  with  the
homeowner  and  extend  to the refuse collection and  disposal  activities.  In
addition,  after  disposal  in a landfill environment, HHW  can  contribute  to
contamination  of  air, subsurface gas, ground water, and surface water.    The
number  and  severity  of accidents, injuries, or health impacts has  not  been
identified or tabulated. Intuitively, the overall impact of HHW is probably not
great.    The  amount of hazardous wastes in the residential  waste  stream  is
probably  small;  however,  even that is uncertain at this point.  Only  a  few
household  products are considered hazardous wastes as defined in Section 3 and
listed  in  Exhibit 3-1; granted, the list is not exhaustive.  The majority  of
suspected    household  hazardous wastes are not pure substances;  thus,  their
degree  of hazard is less and probably much less than the same quantity of  the
pure  hazardous  constituent,  i.e., those constituents  in  industrial  wastes
destined  for  management at a RCRA Subtitle C facility.  A better estimate  of
the  potential environmental damage awaits a more thorough determination of the
presence  of  hazardous waste in the residential waste stream as well   as  the
types  and  characteristics  of these wastes. Similarly  documentation  of  any
environmental  impacts  that  can  be  tied to HHW could  shed  light  on  this

     Possibly  the  greatest impact is on those in contact with  these  wastes.
This  ranges  from  the homeowner to disposal site personnel.   By  definition,
these materials are wastes, and therefore may not be  handled with extreme care.
Likewise  their  nature and the ways  in which they are used and stored lead  to
exposure and potential  injury.  Thus, any program designed to reduce the amount
of  HHW  from  generator to disposal  and to reduce the amount being  stored  by
homeowners should be beneficial to all concerned.


1.   Personal Communication, Ronald L. Ottwell, Construction and Operations
        Superintendent, Public Works Department, City of Tempe, AZ, October 29,

2.   Association of Bay Area Governments, "Evidence of Inappropriate Disposal
        of  Hazardous Waste From Small Quantity Generators", Technical Memo No.
        11 from L. Jackson Russel and N. Knappenberger, April 1984, p. 11.

3.   Personal Communication, Diane Takvorian, San Diego Department of
        Environmental Health, San Diego, CA, November 1, 1985.

4.   Household Hazardous Waste:  Solving The Disposal Dilemma, Golden Empire
        Health Planning Center, Sacramento, CA, 1984.

5.   Personal Communication, David Galvin, Seattle Metro, Seattle, WA,
       • November 12, 1985.

6.   White Hat Hazwaste Programs Target Homeowners, Small Shops, Waste Age,
        May 1984, pp 83-84.

                                  SECTION 6
                         SPECIAL COLLECTION PROGRAMS

     Programs  to  collect household hazardous waste are operated at the  local
and  state  level.  Both local and state-wide HHW programs generally have  five

     •  Increase  general public awareness of the hazardous materials found  in
        most  homes and how these materials may impact on human health and  the

     •  Educate residents as to the best methods of HHW disposal;

     •  Remove HHW from homes, thus reducing exposure and potential  injury;

     0  Reduce danger to refuse collectors and other sanitation workers; and

     •  Provide proper disposal for HHW.

     State-level programs are discussed in "the next section of this report. The
remainder  of  this  section  focuses on  locally-sponsored  and  operated  HHW
collection programs.


Public Education

     Public  education   is  an important aspect of every local  HHW  collection
program.  It focuses on  several aspects to:

     •  Make  the  public aware of the presence of hazardous materials   in  the
        home and consequences of  improper use and disposal;

     •  Identify substitutes  that are less hazardous;

     •  Encourage  better  home  management practices such as buying  only  the
        amount of  hazardous material that is needed at  any one time;

     t  Identify proper  storage and disposal methods; and

     •  Promote participation in HHW collection and recycling programs.

     The  impacts  of  the  educational  aspects  of  collection  programs  are
difficult  to assess.  Thus,  they may be overlooked.  Only the participation in
the  collection program  gives a quantitative indication of the effectiveness of
public  education  efforts.   Certainly, public health and safety  benefits  are
derived  from  these  programs;  however, no existing  method  to   identify  or
evaluate the improvement was  noted during this project.

     Public  education  takes  many  forms.    The  appended  case  studies  of
collection  programs  include  discussions   and   examples  of  publicity  and
educational  materials.    Some  of the techniques  that  have  been  effective

     •  Posters, handouts, and special lesson units in schools;

     •  Public service announcements on radio, TV, and cable TV;

     •  Inserts in utility bills;

     •  Meetings with civic organizations;

     •  Videotape and audio-slide presentations; and

     •  Endorsements and proclamations by local officials.

     Collection  program  participation appears to be directly proportional  to
the amount of publicity and educational material used.  The Albuquerque program
began  with  an  extensive  public education effort 6 months  prior  to  actual
collection.    Numerous  approaches  were used  including  many  meetings  with
citizens'   groups.    Albquerque had very good participation, as noted  in  the
appended  case  study.   In contrast, the Fairfax County,  Virginia  collection
program  was conducted only 6 weeks after official approval.  Public  education
was  limited,  and  participation was low.  Details are in  the  appended  case

     No  attempt has been made to assess the impact of public education related
to  HHW  on  the residents of Albuquerque or Fairfax County.   However,  it  is
intuitive  that  Albuquerque citizens are generally better informed  about  HHW
than  citizens of Fairfax County, and that the latter group know more about HHW
than residents of an area where a collection program has never been conducted.

Types of Collection Programs

     Over  the  past  three  years more than  100  locally-sponsored  household
hazardous  waste collection programs have been conducted.  In size, these  have
ranged from a town or city to an entire county.  Most of the local programs use
the collection site approach.  In this approach, participants are asked to haul
their HHW to the collection site for centralized identification, packaging, and
shipment  to  a permitted hazardous waste facility.  A few local programs  have
provided  service at the residents' homes.  These have included  community-wide
programs  in which all residents could request curbside or backdoor  collection
service and those programs that limited this level of service to the elderly or
handicapped as adjuncts to community collection site efforts.

Collection Sites

     The  collection  site  service  is  the   most  popular  approach  to  HHW
collection.  Basically,  this involves selecting one or more collection  sites,
setting a date, making the public aware of the service, and then conducting the

program.  The collection site approach requires the participating homeowners to
identify the HHW, haul the wastes to the collection site, and then   (sometimes)
unload the materials as directed.  This is nearly identical to the operation of
a recycling center with participants hauling recyclables to a central location.

     There  are several variations on numbers of sites and lengths of programs.
The  most  common is one site for one period of time (not repeated in the  near
future).    The  time period ranges from 1 to 5 days.  Examples of   the  single
location  approach  include many of the Massachusetts programs, Palo Alto,  CA,
and  Albuquerque, NM.(l)  This approach is most applicable to small  communities
and is less expensive than others.

     Another  variation involves using multiple sites either simultaneously  or
in  sequence.  Two or more collection sites are constructed and operated.  They
could  be  operated concurrently as was done in Fairfax, County, VA.(2)    They
could  be operated at different times from one another.  In Sacramento, CA,  an
urban  collection site was operated on one Saturday and a suburban site on  the
next.(3)    Multiple  sites are advantageous to large areas and  may  encourage
participation.    Multiple  sites   are    expensive,  especially  if  operated
simultaneously, because multiple, trained crews must be employed.

     Collection  site  programs  are  usually operated once.   Some  have  been
repeated.  The  City of Palo Alto, CA, is researching the implementation  of  a
permanent  collection  site  at  a  recycling service  center  located  near  a
municipal  landfill.  However, it would not be operated on a year-round  basis,
due  to the prohibitive cost.(3)  San Bernardino County, CA, started a 12-month
pilot collection program in November of 1984.  It involves continuous operation
of  collection sites at two fire stations.  If the program is judged successful
and  desirable,  it  may be expanded to 10 or more fire stations and  become  a
permanent county function.(4)(5)

Door-to-Door Collection

     Some  communities  have  opted to use a door-to-door or  curbside  pick-up
approach.  One community (Gresham, OR) attempted a one-day, curbside collection
of  HHW from all residents.  The approach was similar to curbside collection of
refuse  or  recyclables.    However,  the program  was  poorly  publicized  and
participation was minimal.(6)

     San Diego, CA,  is an example of a scheduled,  on-demand collection program.
The  City  scheduled  collection of HHW for specific days in  different  areas.
Householders  were  to  telephone  if  they  desired  service  and  a  specific
appointment was made.(7)

     There  are no known examples of continuous,  on-demand programs in which  a
resident may telephone at any time to schedule collection of HHW.   However, the
Albuquerque,  NM,  program provided on-demand collection in conjunction with the
collection  site operations.   The phone-in service was restricted to  residents
with  transportation problems,  the elderly,  or the disabled.(8)   Several   other
collection  site  programs  have provided this service,  but only as part  of  a
collection site operation.


     Some  communities  provide advice to residents concerning proper  disposal
methods  for HHW. Usually, this guidance is offered in the form of a  telephone
service  that  advises  residents as to whether or not a  particular  waste  is
hazardous.    In  addition, the service provides instruction  regarding  proper
disposal  methods,  and informs residents if any collection program is  planned
or  is in operation.  For example,  a telephone referral  service is provided  in
Cuyahoga  County,  Ohio  (Cleveland area).   Citizens use a  publicized  hotline
number  to  call  the County Council on Hazardous  Materials  for  instructions
concerning  the proper disposal of HHW.  If the waste in question is hazardous,
the  citizen is told to take it to a commercial hazardous waste management firm
contracted  by  the  Council to accept HHW.  The program will   operate  through
September 1986 on grant funds from the U.S. Environmental Protection Agency. If
local  resources are available, it will be extended.(9)


     Organizations  within  the local government often sponsor  the  collection
programs.    These  include departments or agencies  related  to  environmental
protection,  health,  sanitation,  or  energy.  The funds  for  these  programs
usually  come  from  allocations  of general funds  and  monetary  and  service
donations from the community.
      • •
     In addition, public interest groups sponsor some collection programs.  The
most  active  single  organization across the country is the  League  of  Women
Voters.   The League frequently acts as a community catalyst for the initiation
of  collection programs.  It has helped organize collection programs in over 80
towns  in Massachusetts alone and numerous other localities across the  nation.
Funds  for  programs sponsored by public interest groups come from  the  groups
themselves  and are often supplemented with donations from individuals or other
service  organizations.  Quite often, services are donated such as the use of a
collection  site,  the  use  of  equipment, or  the  availability  of  chemical
expertise  to  identify wastes.  Similarly, local governments will  often  make
allocations of funds to these programs.

     Private  firms also sponsor local collection efforts.  Sponsors have  most
frequently  included  commercial hazardous waste management firms and  chemical
manufacturers.  Programs sponsored by these organizations are usually developed
to  promote  the public image of the sponsor,  in addition to collection of  the
hazardous waste.  Funds are sometimes strictly those of the sponsoring company,
but  may  also  include donations of services  and monetary  contributions  from
public  service groups or even governments, public interest groups, and private

Brief History

     It   is  hard  to  pinpoi.nt the actual  "first"  household  hazardous  waste
collection  program.    Many programs seem to  have begun simultaneously.    The
first  exclusively  household hazardous waste  collection day resulted from  the
efforts  of  the  League of Women Voters in Lexington, MA.  It  took  place  on
October 30, 1982.  A total of 93 households participated in the collection day,

and  770  gallons  of HHW were collected at a cost of $1,600.  Since  then,  an
increasing number of communities in Massachusetts have held collection days. In
1983, 14 communities collected nearly 20,000 gallons of HHW. The total cost for
these  collection  days was about $37,000.  In 1984, 31  communities  collected
over  46,000 gallons of waste at an estimated cost of nearly $108,000.(10)   In
1985,  over  80  communities  in the State have or  will  hold  HHW  collection
days.(11)  The State of Massachusetts  Department of  Environmental  Management
has announced a $400,000 grant to sponsor a state-wide program.

     In  Seattle, WA, a program was also begun in 1982 and was sponsored by the
King  County Health Department.  This  county-wide  collection  program allowed
citizens    to  make  an  appointment to  bring in   pesticides  and  old  wood
preservatives.   County sanitarians conducted the program and were  responsible
for  receiving and manifesting the materials.  This has since become an ongoing

     Another  Seattle, WA, program was sponsored by Seattle-Metro in 1982.  The
results  of  a  study revealed that a large percentage of the  waste  that  was
contaminating  the  water  supply  was of  residential  origin.(12)(13)    This
prompted  Seattle-Metro to sponsor an educational program aimed at the  public,
governmental  agencies,  educational institutions, waste haulers, and  environ-
mental   groups.   Initially, participation in the collection program was  poor,
yielding  500  gallons  of  waste  annually.   Since  the  program  began  more
aggressive  publicity  of the collection efforts, participation has  increased.
Over 3000 gallons of waste were collected in 1985.(14)

     Probably  the  very  first  collection   program  that  included  HHW  and
commercial small quantity generator  waste was a program conducted by the State
of  Alaska  Department  of  Environmental Conservation  in  1982.  Wastes  were
collected  from  41  small businesses and government agencies  (small  quantity
generators)  and 48 households in Fairbanks and Anchorage.  The 7,000 pounds of
waste collected in the 12-day program was transported to Oregon and disposed in
a hazardous waste landfill.(6)

     As  early  as  1981, the Marion County Health Department in  Lebanon,  KY,
sponsored  a  program to collect pesticides from residents,  small  businesses,
schools,  and  agricultural firms during a 5-day program.  The  total  quantity
collected  amounted to 1,400 Ibs of solid chemicals and 500 Ibs of liquids at a
total  cost  of  $1,200.    Funding for this  project  was  provided  by  local
government sources.(12)   Other states and communities have followed, designing
programs  to  their  specific needs; (e.g, the State of  Virginia  sponsored  a
program  in 1983 to collect hazardous waste from community colleges, senior and
junior high schools).(15)

     The  State  of Oregon Department of Environmental Quality (in  conjunction
with  the  local  fire department) sponsored a unique door-to-door  program  in
Gresham,  OR,  in  1983.   Department of Environmental  Quality  personnel  and
firefighters  visited each home on a pre-designated day.  Because the community
was  not  notified as to the time of day the collection would take  place,  the
participation  rate was very poor.(6)  It was the first HHW collection  program
in which the wastes were collected from the residents at their homes.

     Many household hazardous waste collection day programs have been sponsored
by  various  organizations  throughout  California.   Between  1982  and  1984,
collection programs were conducted in several cities including Sacramento, Palo
Alto,  and   Red!and.  All of these programs required residents to deliver  the
wastes to a collection center.(12)

     Subsequent to these examples of early HHW collection efforts, similar pro-
grams  have  spread to many states and numerous communities.  Appendix C  lists
collection programs.  The list is not complete due to the rapidly changing num-
ber  of  programs and the lack of a central clearing house for data related  to

      The  idea  of household hazardous waste collection is not limited to  the
United States.  Other countries such as Canada and Denmark which have permanent
regional  collection  sites.   West Germany, and Australia also    have  become
involved  and aware of the potential environmental contamination from household
hazardous wastes.(11)


1.    Personal Communication, Loreen Russell, Associate of Bay Area
         Governments, Berkeley, CA, July 31, 1985.

2.    Personal Communication, Robin Byrd, Department of Public Works,
         Wastewater Treatment Dept., Fairfax, VA, September 26, 1985.

3.    Personal Communication, Miriam Gensemer, Southern California Association
         of Governments,  Los Angeles, CA, August 1, 1985.

4.    Personal Communication, Judy Orttung, San Bernardino County Health Dept.,
         San Bernardino,  CA, July 31, 1985.

5.    Personal Communication, Judy Orttung, San Bernardino County Health
         Department, San  Bernardino, CA, October 31, 1985.

6.    Household Hazardous Waste Solving the Disposal Dilemma - Program Design,
         Gina Purin, Golden Empire Health Planning Center, Sacramento, CA, 1985
         p. 8-24.

7.    Personal Communication, Diane Takvorian, San Diego Department of
         Environmental Health, San Diego, CA, September 5, 1985.

8.    Personal Communication, Donna Lacombe, City of Albuquerque, Environmental
         Health and  Energy Department, Albuquerque, NM, October 18, 1985.

9.    Personal Communication, Ken Westlake, U.S. Environmental Protection
          Agency  ,  Region V, Chicago, IL, February 20, 1986.

10.   Worksheet:  Massachusetts Household Hazardous Waste Collections for 1982,
         1983, and  1984,  Dana Duxbury, League of Women Voters, Boston, MA.

11.    Personal  Communication,  Dana Duxbury,   League of Women Voters, Boston,
         MA,  September 4,  1985.

12.    Examples  of Household and  Small  Business Hazardous Waste Disposal
         Programs Implemented  in the U.S.  and Canada,  K.P. Lindstrom and Golden
         Empire Health Planning  Center.

13.     Personal Communication, Susan Ridgely, Minnesota Pollution Control
          Department,  St.  Paul,  MN,  November 1, 1985.

14.    Personal  Communication,  David Galvin,  Seattle-Metro, Seattle, WA, March
          25, 1986.

15.     Personal Communication, Dana Duxbury, League of Women Voters, Boston,
         MA,  September 4,  1985.

                                   SECTION 7
                                STATE PROGRAMS
     Several  states have become involved in household hazardous wastes.  Up to
26  states  may  be in various stages of studying the issues  related  to  HHW,
drafting  legislation  or regulations, planning collection programs,  providing
grants    to  local   communities, or  establishing   state-level    collection
efforts  (1).  At  least four states are known to have active  programs.  These
include  Vermont, Connecticut, Florida, and Rhode Island.  These state programs
fall  into  two  categories:      grants    to  local  collection  efforts  and
state-operated  collection  programs.  These states are among the  earliest  to
become involved in the topic;  their  programs are some of the most mature, and
are  briefly described below.  Activities in Washington and Minnesota are  also

     Each of these state programs includes elements of public education and
publicity,  either  conducted  at the state level or by  the  local  sponsoring
organizations.    No information has been available as to the impact  of  these
programs,  other  than the resultant participation in the  collection  efforts.
However,  it is intuitive that safety and environmental benefits resulted  from
these programs.


     Vermont's  interest  in HHW started in its General Assembly.  It  directed
the    State's  Agency  for  Environmental Conservation  to  study  methods  of
collection  and to prepare a report.  During the study, the Agency identified  a
proposed  HHW  collection program in Hartford, VT and nearby Hanover, NH.   The
Agency decided to provide a grant to cover most of the program's costs.(2)

     Several  organizations  became  involved  with  the  program.    Each  was
responsible  for  various  aspects of the effort.   Participants  included  the

     •  Town of Hartford, VT - supplied the collection site;

     •  Upper  Valley  and Lake Seneca Council - provided overall  coordination
        including  planning, subcontracting, co-sponsor participation, and  any

     t  New  England  Marine Contractors, Inc. - served as the hazardous  waste
        disposal contractor;

     t  Upper  Valley Hazardous Waste Committee - was involved in the publicity
        and conducting the survey of participants; and

     •  Vermont  Department of Agriculture - provided technical  assistance  and
        personnel to inventory and assess pesticides.

     The  Agency  for  Environmental  Conservation assessed the results  of  the
Hartford  program.  Participation and cost data are presented in later sections
of  this  report.  The  Agency is  considering a grant for a program in another
area.    If that program is conducted and considered successful,  Vermont  will
assess the feasibility of a permanent HHW collection program.

     The outcome of the Hartford Collection Day represents the total efforts of
the  Vermont  program  to  date.  The grant from the  Agency  of  Environmental
Conservation  was  $4,300.     No estimate is available for  the  value  of  the
services provided by the Vermont Department of Agriculture and the other groups
noted above.  Participation and quantities recovered are listed below.

        Duration:  one day
        Number of participants:  110
        Number of households in area:  16,000
        Participation rate (110/16,000 x 100):  0.7%
        Weight of waste collected: ' 3,000 Ibs
        Amount of waste per participant:  27 Ibs
        Costs:  reported costs of $5,000
        Cost per pound of waste:  $1.67 based on reported cost of $5,000


     Connecticut's  program,  operated  by   its  Department  of  Environmental
Protection,  is  very  similar to Vermont's.  It was developed in  response  to
interest by several communities.  Funds for the grant project were appropriated
through  the  State of Connecticut legislature as a part of the  Department  of
Environmental  Conservation's  annual  budget.   It provides  grants  to  local
communities  that  operate  HHW collection projects.  The state grants  pay  50
percent of the collection and disposal costs.  All  other costs are borne by the
community  through  public funds or donations.  Communities must apply for  the
grants.    To date, 50 towns will receive grant funds for the first  collection
programs to be held in the spring of 1986 (3).

     Connecticut provides written guidelines pertaining to HHW collection days.
However, it does not want to get involved with regulation of HHW.  The expense,
difficulty  in  enforcement,   and  lack of  manpower are some of  the  reasons
cited (3).


     Florida  was the first state to fund and operate a HHW collection program.
Given the name "Amnesty Days", the Florida program involves more than just HHW.
It  includes small businesses and institutions as well as residential  sources.
The former sources may use the collection program without getting involved with
the legal requirements of manifests,  etc.

     The  collection  program  was  established   by  Florida's  Water  Quality
Assurance  Act of 1983.  It directed the Department of Environmental Regulation
to establish and conduct Amnesty Day programs throughout the State.  Funds come
from a Water Quality Assurance Trust  Fund.  Limitations on expenses include a 5
percent ceiling on administrative costs and the same limit on public education.

The  remainder pays for the actual collection and disposal activities which are

     Extensive  publicity  was used to inform Florida residents and  businesses
about  the Amnesty Day Program.  This included television announcements,  radio
public service announcements, pamphlets, films, newspaper ads, and electric and
water  bill  inserts.   Also many organizations such as the Florida  League  of
Cities, State Association of County governments, Florida Fireman's Association,
Gulf  Power  and other organizations enclosed Amnesty Day information in  their
newsletters.   As the first state-level program, Amnesty Day not only  received
intense  media  coverage  within Florida, but the program was also  covered  by
prestigious  publications such as the New York Times, The Wall Street  Journal,
and even the National Geographic.


     Two  mobile  collection facilities are used in Florida.  They  consist  of
semi-trailers  containing  small laboratories and storage space for the  wastes
collected.    A hazardous waste contractor provides the trailers and all  other
services  directly  related to the collections.  The contractor also hauls  the
wastes to permitted disposal facilities.

     The collection facilities are set up in two locations simultaneously. They
may  be in the same county if warranted by the population, or in two  different
counties.   Each facility is operated from 1 to 6 days at each location,  again
depending  on  population and anticipated participation from businesses.    The
entire Amnesty Day program is based on a three-year cycle with the provision of
at  least  one  collection  day per county during a three-year  period.    More
details about the Florida program are included in the appended case study.


     Amnesty  Days  had  completed  three phases through June  1985.    Summary
results of the three phases are noted below (4)(5).

     •  Average weight of waste collected: 701,400 Ibs = 351 tons

     •  Number of participants:  7,000  (includes businesses and institutions)

     •  Weight of waste per participant:  100 Ibs.

     •  Area  and  population  served:  28 counties with a 1980  population  of
        7,259,700  living in 2,787,800  households, representing  42 percent  of
        Florida's counties and 74 percent of its population.

     •  Household participation rates assuming each  "participant" represented  a
        household:  7,000/2,787,800 = 0.25 percent

     •  Range of household participation rates:  0.10 to 1.8 percent

     •  Estimated cost:  $2,200,000 (6)

     •  Cost per pound of waste:  $3.14


     Rhode  Island's program is similar to the one in Florida.(7)  It is called
Household  Toxic Cleanup Day and is sponsored by the Rhode Island Department of
Environmental   Management,  (DEM)  Air  and Hazardous  Materials  Section.    A
contracted  hazardous  waste management firm operates one-day Cleanup  Days  at
five  locations  in  the  State, and disposes of  the  collected  wastes.  This
program,  occurring annually over" the past two years, includes participation by
educational  institutions  and  local  government   agencies,  in  addition  to
households.    It is designed and operated by the DEM and is funded by  a  bond
issue.   The annual program will be repeated until the funds are exhausted.  At
that time, another bond referendum will be voted upon.

     There  is  also an on-demand program in Rhode Island.  Depending upon  the
situation,  as deemed by the DEM, a caller will either be told to store his HHW
until the next collection day or, in an emergency situation, DEM personnel will
collect  the  HHW from the home and dispose of it.   An emergency situation  is
declared  when  a  resident  moves out of state, or if the  type  of  waste  is
considered  too  dangerous  for household storage.   Such  dangerous  materials
include laboratory  chemicals, explosives, and radioactive waste. (6)


     The DEM completely funds, designs, and supervises the HHW collection days.
Only  the  handling,  packaging, transportation, and disposal of  the  HHW  are
performed    by a hazardous waste contractor.  The DEM identifies  the  program
locations  based on the number of requests from towns in the state.  Collection
sites  are  always  located  on state-owned property,  usually  at  schools  or
equipment yards.

     Personnel  at  all  of the collection sites consist of DEM  staff  or  the
contracted  disposal  firm  employees.    Volunteers are  not  used.    When  a
participant  enters  a site, a DEM employee obtains identification  information
about  the  participant and removes the waste from the vehicle.  The  waste  is
moved  to  the processing area where contractor personnel identify,  sort,  and
package the materials.

     The DEM accepts all HHW delivered to the site without a quantity limit.  A
unique  aspect  of  the  program   is    the  method  of  sorting  the  wastes.
Pharmaceuticals  are  given  to a drug control agency;  explosives  and  highly
reactive  wastes  are  given  to  the   local  fire  marshal!;  fertilizer  and
nonhazardous  pesticides are given to a local nursery for reuse; and  waste oil
is  recycled by the State at maintenance garages.  The State plans to  continue
this  program  format,  and has no plans for a permanent transfer  and  storage


     Results  of  the most recent collection day were available and  are  shown

     •  Number  of  participants:  350 (includes schools and  local  government
        Amount of liquid waste collected:  4600 gal  (est 34,500 Ib)
        Amount of solid waste collected:   300 Ibs
        Population served:  20,000
        Weight of waste per participant:   99 Ibs.
        Expendables, disposal:  $15,000 per day
        Cost per pound of waste:  $0.43

Note  that  the above costs do not include administrative costs of  the  entire
State program that should be allocated to this specific collection day, nor are
publicity costs included.


     One  continuous  HHW collection prcfgram is being conducted in the  Seattle
metropolitan  area  of  Washington.  (8)   Six permanent  storage  and  transfer
stations are located throughout the area.  Operations are on-demand.  Residents
telephone  a  local health department office and make arrangements to take  the
HHW  to the nearest location.  The resident is met at the site and the waste is
accepted,  identified,  and stored. Periodically, a contracted hazardous  waste
hauler  collects  the wastes and transports them to a permitted disposal  site.
Currently, the services of both the hauler and the disposal site are donated to
the program.

     The  Health Department assumes the role of generator.  Its personnel  fill
out  the  manifest and the department is responsible for the wastes until  they
leave  the collection site.  Participation in the program has been reported  as
light.   A total of only 4 to 5 hours is expended at all collection sites  each

     In  September  1985,  a law was passed in Washington State  that  requires
County  governments  to  develop and operate programs to manage  both  HHW  and
hazardous wastes from small quantity generators. Regulations for these programs
are  now  being  developed. Additionally, the State is setting up  a  telephone
hot-line to provide advice related to HHW.


     The  State  of  Minnesota is conducting a two-year study of HHW.(9)    The
study  will  be  conducted in three phases and will  assess the  operations  and
effectiveness  of  local  collection programs.  In the first phase,  the  State
provides  funds for local HHW collection  programs and may plan and operate some
programs.   At other locations State funds will be used by local  governments or
private firms to operate programs.  In addition, publicity and public education
portions  of  the  State's  HHW  program are funded  by  a  U.S.   Environmental
Protection Grant of $25,000 (under RCRA,  Section 8001 FY 1985 grant). Minnesota

will  conduct programs in urban, rural, and suburban areas.  Objectives of  the
two-year study are to:

     t  Identify the types of wastes brought to HHW collection days;

     •  Compare geographically the types and amounts of wastes, e.g.

        -  Urban vs rural and
        -  Geographic regions within the State;

     •  Identify  the types of people who participate in  HHW  collection days;

     •  Conduct before and after interviews to determine behavioral changes.

     In  the second phase, HHW collection programs will  be repeated in selected
locations.   Participation rates and waste quantitities will be identified  and
compared  to  initial programs.  Funding for repeated programs will  be  shared
between  the State and the local communities.  Data collected during the  first
two  phases  will be analyzed in the third phase. Results of the study will  be
presented  to  the  Minnesota  Legislature and used as  the  basis  for  future
decisions related to HHW collection programs.


1.   Personal Communication, Dana Duxbury, Tufts University Center for
        Environmental Managert, Medford, MA, February 18, 1986.

2.   Methods and Programs for the Collection and Disposal of Household
        Quantities of Hazardous Waste - January 10, 1985, State of
        Vermont Department of Environmental Conservation, Montpelier, VT.

3.   Personal Communication, Leslie Lewis, Connecticut Department of
        Environmental Protection, Hartford, CT, October 29, 1985.

4.   Amnesty Day Collection Totals, Florida Department of Environmental
         Regulation, Tallahassee, FL, 1985.

5.   County and City Data Book, 1983, U.S. Department of the Census, U.S.
         Government Printing Office, 1983.

6.   Personal Communication, Jan Keeman, Florida Department of Environmental
         Regulation, Tallahassee, FL, November 1, 1985.

7.   Personal Communication, John Hartley, Rhode Island Department of
         Environmental Management, November 5, 1985.

8.   Personal Communication, David Galvin, Seattle-Metro, Seattle, WA,
         November 6, 1985.

9.   Personal Communication, Susan Ridgely, Minnesota Pollution Control Agency,
         St. Paul, MN, November 1, 1985.

                                  SECTION 8
                                 MAJOR ISSUES

     Hazardous  waste  regulations  and liability are the  first  and  foremost
issues of concern to any organization contemplating a household hazardous waste
collection program.  Homeowners and others generating household hazardous waste
are  not  required  to  comply  with the  Federal  RCRA  regulations  regarding
manifesting  and  other activities associated with hazardous waste.    However,
State regulations may differ from Federal  regulations and compliance with local
restrictions is also a consideration for organizers of HHW collection programs.

     From  the  Federal  standpoint,  RCRA  does  not  address  HHW  collection
programs,  nor  are any limits set above which HHW become regulated  under  its
Subtitle  C (hazardous waste) regulations.  A memo interpreting RCRA and CERCLA
liability associated with HHW collection programs is included in Appendix E.
                      areas  of  concern  for  liability  associated  with  HHW

     t  General liability including
     There  are  two
collection programs:
        -  Collection program personnel;

        -  The public participating in the program;

        -  Property damage that might occur at the collection site; and

        -  Damage,  injuries,  or  other incidents that might occur  while  the
           waste is being transported from the collection site.

     t  CERCLA  liability  related  to potential future impacts caused  by  the
        ultimate disposal site.

General Liability

     Program  sponsors  usually  want  to minimize their  liability.    In  the
majority  of instances, a hazardous waste management contractor is utilized  to
operate  the  collection  site.  Thus, the contractor takes  on  the  liability
associated  with  operating  the  collection site at least in    terms  of  the
personnel and site being under its control.

                                                                        This is
     Some liability exposure usually remains with the program sponsor.   ,.,.-  ,„
often associated with liability for the actions of its employees or members and
liability  associated  with  the collection site if the site is  owned   by  the
sponsoring  agency, e.g., the  high  school parking lot used in the •-  ' "     ••"
                                                                    Fairfax,  VA

program.  These aspects of liability are usually protected by insurance carried
by the sponsor.

     For  programs  conducted  by  municipal    or  county  governments,  public
liability  insurance  provides  coverage  or is extended by  a  special  rider.
Counties  with programs covered by liability insurance include those in  Marion
County,  KY  and  Bernallio  County, NM as well as Fairfax County,  VA.     In  a
collection  program in Sacramento, CA,  the hazardous waste contractor added the
collection  program sponsors to its own liability insurance policy  that insured
the sponsors as well as the contractor against lawsuits.  Insurance costs are a
portion  of the overall program costs and are included in contractors'  bids. In
some  instances, the sponsoring agency does not have public liability insurance
that could be expanded to include collection day activities.

     Two  states  have  become involved in the question of liability.   In  the
program  operated  by  the State of Florida, the State  has  considered  itself
liable  only for its own employees.  Thus, the hazardous waste contractor  must
carry  public  liability  insurance  for any damage that  might  occur  at  the
collection  sites  or  during transport of the wastes.  In  Massachusetts,  the
Department  of  Environmental Quality requires that any community  planning  to
hold  a  HHW  collection  program  obtain   Department  approval  of  the  firm
transporting  the  waste with the transporter being required to be   liable  for
transportation accidents and spills.  The transporters must carry insurance for
bodily injury, property damage, and environments! restoration.

     In  general, collection program sponsors want to minimize their  liability
exposure.  Usually  this is done by hiring a waste contractor to which as  much
liability is transferred as is possible.  This approach minimizes the number of
organizations  potentially  involved with litigation and minimizes   the  direct
liability of the sponsoring agency.

CERCLA Liability

     An  issue of concern for many communities planning HHW collection programs
relates  to  long-term  liability related to  the  Comprehensive  Environmental
Response,  Compensation, and Liability Act (CERCLA or Superfund).   In  general,
if  a  waste  disposal  site  (hazardous or non-hazardous) is  identified  as   a
significant  source  of pollution and listed as a Superfund site for   clean-up,
sources  of  the  waste as well as the owner or operator of the site   could  be
liable   for clean-up costs.  HHW collection program sponsors thus could be  the
target   of related  law suits  including citizens' suits.  Some communities   have
cancelled plans  for collection programs because of this issue.(1)

     Concern   about  the potential  liability of HHW programs under  both  CERCLA
and  RCRA  led   to  preparation of a memo  from  the EPA Office of  Solid  Waste's
Waste    Management  and Economics  Division.   That memo and others  on  the   same
topic   are  included   in  Appendix  E.  The memo  content   relating  to  CERCLA
liability  is summarized briefly  in  the following paragraph.

     Household   wastes containing hazardous substances  as delineated in  CERCLA
Sections  101(14)   and  102(a)   are  considered  hazardous  under   CERCLA   and,.
therefore,  are   subject  to  CERCLA liability  (Section  107).    Similarly,  HHW

consisting  of  any of the substances listed in Table 302.4 of 40 CFR Part  302
definitely  would  be  classified as a hazardous substance.  Although  the  HHW
quantities  generated by collection programs are relatively small, as  compared
to  wastes  generated by SQGs and the larger commercial  sources, any amount  is
subject  to CERCLA liability.  This poses a problem for collection programs  in
that the waste sources, e.g. the communities, could become liable if a landfill
used  for  HHW  disposal  eventually  becomes a CERCLA  site.    EPA  is  still
evaluating its CERCLA enforcement policy regarding this issue (see Appendix E).


     Currently,  there appears to be a very low degree of regulation from State
and  local governments regarding household hazardous waste collection programs.
However,  as  the  collection  programs increase in  number,  their  visibility
increases.   More States are developing interests in HHW than previously and it
is  likely that State legislation and local ordinances will increase.  City and
county  governments  often pass resolutions establishing public HHW  collection
programs  or  at least acknowledging those planned by public service groups  or
private  organizations. This often does nothing more than identify the concept,
and  give  sanction to the use of public facilities, equipment,  and  personnel
during the program.

     The  State  of  Florida  has   passed  laws  specifically  addressing  the
collection  of  household hazardous waste.  This is done under the Amnesty  Day
Program  legislation  and is more fully described in the Florida case study  in
Appendix  D.   The Florida law requires that a State agency provide  collection
service  to  each county in the State within a three-year period.  This law  is
the  basis  for  the  appropriation of funds and  the  establishment  of  staff
positions  to manage this program.  Other States may have laws or  regulations,
including those directed at hazardous wastes, that indirectly regulate HHW.


1.   Personal Communication, Dana Duxbury, Tufts University Center for Envir-
        onmental  Managment, Medford, MA, February 18, 1986.

          APPENDIX A

40 CFR PARTS 261.33 (e)  AND (f)

                         } 261.33

                         I2C1.U  Diiordtd  canmcrcUl  chemical
                            producU, off-ipecincatlon •peclu, con-
                            Ulaer  reiUuci,  and  iplll   reiUuc*
                          The following maUrlaU or Itenu are
                         hazardous wastes when they are  dis-
                         carded or Intended to be discarded as
                         described In 1261.2UXJMI). when they
                         are burned for purposes of  energy re-
                         covery In lieu of their original Intend-
                         ed use. when they are used to produce
                         fuels in lieu of their  original Intended
                         use. when they are applied to the land
                         In  lieu of their original Intended  use.
                         or whet  the? are  contained in prod-
                         ucts  that are  applied  to the  land In
                         lieu of their original Intended use.
                          (a) Any commercial  chemical prod-
                         uct,  or manufacturing chemical Inter-
                         mediate   having   the  generic  name
                         listed  In paragraph  (e) or (ft of this
         40 CM Ch. I (7-1-iS Edition)

chemical Intermediates referred to In
paragraphs (a) through (d) of this sec-
tion, are Identified as acute hazardous
wastes (H) and are  subject to be  the
small  quantity  exclusion  defined  In
Environmental Protection Agency
                                S 261.33
tCommtxt: fat the convenience of the regu-
lated  community  the primary  huardoiu
properties of these materials have been Indi-
cated by the letters T (Toilcltyt. uul R (Re-
activity). Abience of a letter Indicate* that
the compound only I* luted for acute toxlcl-
  These wastes and their correspond-
ing EPA Hazardous Waste  Numbers
Mil .


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                                                      40 CFR Ch. I (7-1-U Edition)
                                                       Environmental Protection Agency
                                                                                                                          § 261.33
Pill .
PI 13
POM. .


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  (f) The commercial  chemical prod-
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diates, or off specification commercial
chemical products referred to In para-
graphs «n«<™«ly4 |H II
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S 261.33
                                                          40 Ctt Ch. I (7-l-M Cdlli.n)
                                                                                               Environmental Protection Agency

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                                                                                                                     StfMuni dhdkito IH.T)
                                                                                                           <4*  FR  7»63». 1*841.  Nov. J4.  1680. u
                                                                                                           amended at 4« FR 11411. May  20.  IMI: 4*
                                                                                                           FR ll»23. May 10. IBM: <9 FR CIS. Jan. 4.
                                                                                                           1M6: 60 FR 2000. Jan. 14. 1(161
                                                                                                             Erricrivi Dtn NOTE At 60 FR <6t, Jan.
                                                                                                           4.  IDlt. 128133 Introductory le«l  wu re-
                                                                                                           vlaed. effective July 6. l»86. At  60 FR 2000.
                                                                                                           Jan. 14.1N(. the table In paragraph (f) wu
                                                                                                           amended  by   revlalng  certain  haiardoua
                                                                                                           waate numbera, effective July 16. IDAS. For
                                                                                                           the convenience of the uier.  the aupeneded
                                                                                                           Introductory   lest  (publlahed  at  41  FR
                                                                                                           11010.  Sept.  91.  IBg4i.  and  enlrlei In the
                                                                                                           paragraph (f I table, are act out below:

                               § 261.33

                              I1CI.11  DUcanltl  rammcrcUl  ckeulol ftal-
                                 ucU. off-tpcclncftllon «p«cles. coMlaliMff resi-
                                 due! and iplll r««lduM (hereof.
                                The (allowing n»terl>U or llenu ue hu-
                              >rdou< wute* II utd when they »re dltetrd-
                              ed or Intended la be discarded unleu they
                              «re excluded under 11 JOT JO ind 2M.U «nd
                              Ibled In Appendix IX.
                              UU1  ............ PMnal
                              U2I2  ....... Ptand. IA4.I UtKNora-.
                              UJIJ    .... FlimA ».<.«Hd*)ro
                              U£K>  .......... . Ftaaol. 1.44 MtMof*

 |                             UZH ........ S*..,

                              t»32 ............  H 6-1
                              tail ....... .... »,<.«- MdJoo|
            APPENDIX B

40 CFR PARTS 261.21 THROUGH 261.24

                            9 MI.II
   (a> A solid waste exhlblU the charac-
 teristic of Ignltablllty If a representa-
 tive sample of the waste  has any of
 the following; properties:
   (I) It U a liquid, other than an aque-
 ous solution containing less than 24
 percent  alcohol  by volume and has
 flash  point less than «0'C (HOT), as
 determined   by   a  Pensky-Uartens
 Closed  Cup  Tester, using  the  test
 method  specified In ASTM  Standard
 D 93-19  or D »3 80 (Incorporated by
 reference, see 1 260.11). or a Setaflash
 Closed  Cup  Tester, using  the  test
 method  specified In A8TU  Standard
• D-3278-76 (Incorporated by reference.
 see 1 280. 1 1 >, or  as determined by an
 equivalent  test method approved by
 the  Administrator under procedures
 set forth In 1 1 260.20 and 260.21.
   (2)  It Is not a liquid and Is capable.
 under standard temperature and pres-
 sure,  of  causing  fire through friction,
 absorption of moisture or spontaneous
 chemical changes and, when Ignited,
 burns so vigorously  and  persistently
 that It creates a hazard.
   13}  It Is an Ignltable compressed gas
 as defined In 4* CFR  179.300 and as
 determined by the test methods de-
 scribed In  that regulation or equiva-
 lent test methods approved by the Ad-
 ministrator under il 260.20 and 260.21.
   (4)  It Is an oxldlzer as defined In 41
 CFR  173.151.
   (b) A  solid waste that exhibits the
 characteristic of Ignltablllty. but  Is not
 listed as a hazardous waste In Subpart
 D. has  the EPA Hazardous Waste
 Number of D001.
 146 FR Hill. May It, IM0. M amended at
 48 FR 3B147. July 7. 1MI1

 IMI.n   CharacUrlitleafcBmnlvlty.
   (a) A solid waste exhibits the charac-
 teristic of  corroslvlty If a representa-
 tive sample of the waste has either of
 the following properties:
   (1) It  Is aqueous and has a pU less
 than or equal  to 2 or greater than or
 equal to 12.S, as determined by  a pH
 meter  using  either   an  EPA  test
 method or an  equivalent test method
 approved by the Administrator  under
 the procedures set forth  In || 280.20
 and 260.21. The EPA teat method for
 pH U specified as Method 5.2 In  "Test
         40 C« Ch. I (7-1-15 fdilion)

Methods for  the Evaluation of Solid
Waste.* Physical/Chemical  Methods"
(Incorporated    by   reference,   see
  (2) It Is a liquid and corrodes steel
(8AE 1020) at a rate greater than 6.35
mm (0.350 Inch) per year at a test tem-
perature of 55'C <130't*> as determined
by the test method specified In NACE
(National Association of Corrosion  En-
gineers) Standard TM-01-6B as stand-
ardized In "Test Methods for the Eval-
uation  of  Solid  W:*te.  Physical/
Chemical Methods" (Incorporated by
reference, see 1260.11) or an equiva-
lent test method approved by the  Ad-
ministrator under the procedures set
forth In || 260.20 and 260.21.
   A solid waste that exhlblU  the
characteristic of corroslvlty. but Is not
listed as a hazardous waste In Subparl
D.  has  the  EPA Hazardous Waste
Number of D002.

141 FR 111 I*. May I*. ISM. u amended >l
4lHt3»347.Juiy1. till!

I UI.Z3 Cluneleriillc at rcacUtlly.
  (a) A solid waste exhlblU the charac-
teristic of reactivity If a representative
sample of the waste has any of the fol-
lowing properties:
  (1) It Is normally unstable and read-
ily undergoes violent change without
  (2) It reacU violently with water.
  (3) It forms potentially  explosive
mixtures with water.
  (4) When mixed with water, It gener-
ates toxic gases, vapors or fumes In a
quantity sufficient to present a danger
to human health  or the environment
  (ft) It Is a cyanide or sulflde bearing
waste which, when exposed to pH con-
ditions between 2 and 12.6, can gener-
ate'toxic gases, vapors or fumes In a
quantity sufficient to present a danger
to human health  or the environment
  (6) It Is capable of detonation or ex
plosive reaction If It  la subjected to a
strong  Initiating source or  If healnl
under confinement.
  (7) It  Is readily capable of delun*
tlon or explosive decomposition or ir
action at standard temperature  anil
  (8) It Is a forbidden explosive as dr
lined In 41 CFR  113.61. or a Class  A
explosive as defined In 4> CPR 173 S3
Environmental Protection Agency

or a Class B explosive as defined In 48
CFR 173.86.
  (b) A solid waste that exhlblU  the
characteristic of reactivity, but Is  not
listed as a hazardous waste In Subpart
D, has the  EPA  Hazardous  Waste
Number of D003.

I Ml M  CharaclerUlk of EP loiklly.
  (a) A solid waste exhlblU the charac-
teristic of EP toxlclty If. using the test
methods described In Appendix II or
equivalent  methods  approved by  the
Administrator under the  procedures
set forth In 11260.20 and 260.21.  the
extract from a representative sample
of the  waste contains any of the con-
tamlnanU listed In Table -I at a con-
centration equal to or greater than the
respective value given In that Table.
Where the waste contains less than O.B
percent  filterable solids,  the waste
Itself, after filtering. Is considered to
be the  extract for the purposes of this
  (b) A solid waste that exhlblU  the
characteristic of EP toxlclty. but Is not
listed as a hazardous waste In Subpart
D, has the  EPA  Hazardous  Waste
Number specified In Table I which cor-
responds  to the  toxic  contaminant
causing It to be hazardous.


                                                                                                                          Unlm (l.t 1.4.6.<*u«- <**»-
                                                                                                                                                       TABLE I—MAXIMUM CONCENTRATION of CON-
                                                                                                                                                         TAMINANTS  FOR CHARACIEHISTK or  EP
                                                                                                                                                                ».4.»1I>  b*»» (I.l.SIiicMa
                                  • 0
                                  • t
                                  • 4




                            DIRECTORY TO PROGRAMS
Sponsoring/Administrating Organization
Contact Name/No.
Waste Management
Emmelle, AL  35459

Alaska Department of Environmental
600 East 38th Street
Anchorage, AK  99508

League of Women Voters
132 Anita Court
Redlands, CA  92373

Golden Empire Health Planning Center
2100 21st Street
Sacramento, CA  95818

City of Palo Alto
Water Control District
2501 Embarcardero Mall
Palo Alto, CA  94303

San Diego Environmental Health
P.O. Box 8426
San Diego, CA  92102

Environmental Health Services
San Bernardino County
385 N. Arrowhead
San Bernardino, CA  92415

Department of Health (Tri-County Area)
Fort Collins, CA  80521

(Joint Funding with Department of
Environmental Protection)
Conservation Commission/Health Department
Mansfield, CT  06250

Conservation Commission
Ridgefield, CT  06877
Gordon Kinna
(205) 652-6721

Jim Sweeney
(907) 564-1336
Joan Dotson
(714) 793-1164

Gina Purin
(916) 731-5050
                                                              Pete Burnes
                                                              (415) 329-2117
                                                              Chris Walker
                                                              (619) 235-0281
                                                              Steve Van Stockum
                                                              (714) 383-7170
Danny Stubbs/GSX
(808) 251-1227

Leslie Lewis
(203) 566-3489
Steve Brown
(203) 438-8653

Lillian Willis
(203) 438-8653

 Sponsoring/Administrating Organization
Contact  Name/No.
Towns of Weston  and Westport
(joint venture)
Weston Board of  Selectman and
Westport Fire Department, CT 06880
                  Health Department
                  Town of Greenwich
                  Greenwich, CT 06830

                  Conservation Commission and Town of
                  (joint venture)
                  Ridgefield, CT  06877

                  Conservation Commission
                  Manchester, CT "06040

                  Conservation Commission
                  Farmington, CT  06032

                  Conservation Commission/League
                  of Women Voters
                  Southington, CT 06489

                  Bershire-Litchfield Environmental Council
                  Towns of Salisbury and Sharon, CT 06068
Northwest Connecticut Regional Planning
P.O. Box 198
Brooklyn, CT  06234
(special task force to sponsor an 8 town
program-still in planning stages)

Department of Environmental Regulation
Solid and Hazardous Waste Section
2600 Blairstone Road
Tallahassee, FL  32301
Helen  Speck
Bd. of Selectman
(203)  222-2682
Fire Department
(203)  227-4161

Bob Brown
(203)  222-7848
                                            Lillian Willis
                                            (203) 438-8653
Art Glaeser
(203) 647-3560

Steve Kushner
(203) 673-8237

Joanne Foster
(203) 628-2004

(203) 435-2004

Nancy Kriz
(203) 774-1253
Jan Kleman
(904) 487-3892
GSX Corporation, Inc.
Marion County, IN
Danny Stubbs/GSX
(800) 251-1227

Sponsoring/Administrating Organization
Contact Name/No.

6SX Corporation, Inc.
Zionsville, IN

Louisville Sewer District
4522 Algonquian Parkway
Louisville, KY  40211

Marion County Health Department
516 N. Spawlding
Lebanon, KY  40033
Danny Stubbs/GSX
(800) 251-1227

John Weil
(502) 587-0591
                                                              Keith Brock
                                                              (502) 692-3393


Dow Chemical Corporation
Plaquemine, LA  70764

GSX Corporation, Incorporated
Laurel, MD  20707

League of Women Voters
8 Winter Street
Boston, MA  02108

- Cape Cod (all 15 towns)
- Martha's Vineyard (all 6 towns)
- Cohassett
- Plymouth
- Mattapoisett
- Wareham
- Marshfield
- Duxbury
- Marion
- Brockton
- Easton
- Attleborough
- Westport
- Fairhaven
- Taunton
- Raynham
- Seekonk
- Dartmouth
- Northborough
- Southborough
- Marl borough
- Watertown
- Newton
- Lexington
Jerry Martin
(504) 389-1696

Mora Bartletti
(800) 638-4440

Dana Duxbury
(617) 475-8881

Sponsori ng/Admi ni strati ng Organi zati on
Contact Name/No.
- Concord
- Lincoln
- Westford
- Acton
- Andover
- Pepperell
- Hoi den
- Oxford
- Ashby
- Lunenburg
- Fitchburg
- Townsend
- Amherst
- Northampton
- Longmeadow
- Easthampton
- Pel ham
- Westfield
- Wilbraham
- Franklin County (all 26 towns)
- Dal ton
- North Adams
- Williamstown
- South Berskshire County (all 16 towns)

Dow Chemical Corporation
Midland Division
2020 HHD Center
Midland, MI  48640
Bobby Weaver
(517) 636-3413
                  6SX, Incorporated
                  Traverse City, MI
Danny Stubbs/GSX
(800) 251-1227
                  Kalamazoo County Department
                  Of Planning
                  201 W. Kalamazoo Avenue
                  Kalmazoo, MI  49007
                  Contractor:  Drug & Laboratory Disposal
                               Plainwell, Michigan  49080
                                            Dean Holub
                                            (616) 384-8112
                                            (616) 685-9824

Sponsori ng/Admi ni strati ng Organi zati on
Contact Name/No,
Kent County Department of Public Works
1500 Scribner Avenue, NW
Grand Rapids, MI  49504
Contractor:  Mid-America Environment
             Service, Inc.

Ingham County Health Department
5303 S. Cedar Street, Box 30161
Lansing, MI  48909
Contractor:  Drug & Laboratory Disposal
             Plainwell, MI  49080

Oakland County Health Department
1200 North Telegraph
Pontiac, MI  48053
Contractor:  Wayne State University
Environmental Health & Safety Department

Washtenaw County Health Department
P.O. Box 8645
Ann Harbor, MI  48107
Contractor: Wayne State'University
Environmental Health & Safety Department

Wayne County Health Department
3669 Metro Place Mall
Wayne, MI  48184
Contractor:  Wayne State University
Environmental Health & Safety Department
Curt Kemppainen
                                                              (312) 841-7020
                                                              Robert Godbold
                                                              (517) 887-6988
                                                              (616) 685-9824

                                                              Ron Grimes
                                                              (313) 858-1322
                                                              (313) 577-1200

                                                              Barry Johnson
                                                              (313) 992-2492
                                                              Bruce Davis
                                                              (313) 326-4900
                                                              (313) 577-1200
Minnesota Waste Management Board
123 Thorson Community Center
7232 58th Avenue
North Crystal, MN  55428
Wayne Sames
(612) 536-0816
Monsanto, State of Missouri, League of
  Women Voters
Missouri Environmental Coalition
League of Women Voters
6665 Del mar Room 304
St. Louis, MO  63130
Leonore Loeb
(314) 727-8674
New Jersey
New Jersey Hazardous Waste Advisement
Commission (pesticides only)
Shirley Schifmann
(609) 292-1250

Sponsori ng/Admi ni strati ng Organi zati on
Contact Name/No.
New Jersey
New Mexico
New York
North Carolina

Rhode Island
League of Women Voters
Bridgewater County, NJ

League of Women Voters
Flemington, NJ  08822

City of Albuquerque
Environmental Health and Energy
Hazardous Waste Program
P.O. Box 1293
924 Park Avenue, S.W.
Albuquerque, NM  87103

CECOS International, Incorporated
9303 Montgomery Road
Cinncinati, OH  45242
(collection held in Buffalo)

GSX, Incorporation
Reidsville, NC  27320

CECOS, International
9303 Montgomery Road
Cincinnati, OH  45242

League of Women Voters
2777 Blackfriar N. W.
Canton, OH  44708

Council on Hazardous Materials
4115 Bridge Avenue
Cleveland, OH  44113

Cuyahoga County
Division of Community Services
6100 W. Canal Road
Valley View, OH  44125

Department of Environmental Management
Air & Hazardous Materials
Cannon Building
75 Davis Street
Providence, RI  02908
Linda Patchept
(201) 649-4541

Kelly Martin
(201) 649-4541,

Donna Lacombe
(505) 766-7434

Jose B.R. Anglada
(505) 766-7434
Laura Evans
(513) 793-3090
Mark Johnson
(800) 334-5953

Laura Evans
(513) 793-3090
                                                              Patricia  Starr
                                                              (216)  400-3657

                                                              Bob Staib
                                                              (216)  961-4646
                                                               Floyd  Kincy
                                                               (216)  524-6320
John Hartley
(401) 277-2797

                  Sponsoring/Administrating Organization
                                                              Contact Name/No.
                  GSX, Incorporated
                  Greenbriar, TN  37073

                  Montshier Museum of Science
                  45 Lyme Road
                  Hanover, NH  03755

                  Department of Wastewater Treatment
                  Commonwealth of Virginia
                  County of Fairfax
                  Department of Public Works
                  10640 Page Avenue
                  Fairfax, VA  22030

                  GSX, Incorporated
                  Roanoke, VA

                  Washington Metro
                  821 Second Avenue
                  Seattle, WA  98104

                  Tacoma-Pierce County Health Department
                  3679 S. "D" Street
                  Tacoma, WA  98408

                  Seattle/King County Health Department
                  400 Yesler Building
                  Seattle, WA  98104
                                                              Danny Stubbs/GSX
                                                              (800) 251-1227

                                                              Margy Erdman
                                                              (603) 643-5672
                                                              Robin Byrd
                                                              (703) 691-3381
                                                              Nick Culian
                                                              (919) 342-6106

                                                              David Galvin
                                                              (206) 447-5878
                                                              Doug Pierce
                                                              (206) 591-6571
                                                              Wally Swofford
                                                              (206) 587-2722
                                                              Cheri Zehner
                                                              (206) 587-4632
                  Brown County Emergency Government
                  P.O. Box 1600
                  Green Bay, WI  54305
                  Contractor:  GSX

                  City of Kenosha
                  625 52nd Street
                  Kenosha, WI  53140
                  Contractor:  GSX

                  City of Madison Public Health Department
                  210 Monona Avenue
                  Madison, WI  53710
                  Contractor:  GSX
                                                              Colette Mesiter
                                                              (414) 436-3393
                                                              George Zimmer
                                                              (414) 8170
                                                              Jill Schmidt
                                                              (608) 266-4843

State             Sponsoring/Administrating Organization      Contact Name/No.

WisconsinDepartment of Natural ResourcesBarbara Zellmer
(continued)       Box 7921                                    (608) 266-7017
                  Madison, WI  53707

                  GSX, Incorporated                           Danny Stubbs/GSX
                                                              (800) 251-1227
                  - Madison County
                  - Kenosha County
                  - Marathon County
                  - Manitowak County
                  - Brown County

                  - Manitowoc County                          Jeff Beyer
                  - Solid Waste Department                    (414) 683-4085
                  - 1010 S. 8th Street
                  - Maniltowoc, WI  54220
                  - Contractor:  GSX

        APPENDIX D

                           ALBUQUERQUE, NEW MEXICO

     In  1980,  two  municipal  wells were shut down  by  the  Water  Resources
Department  in  the City of Albuquerque due to a high concentration of  organic
pollutants.(l)    Improper  disposal  of HHW was suspected as  a  cause.    The
Environmental  Health and Energy Department of the City of Albuquerque began  a
study  to  determine the possible causes of the pollution.  The results of  the
1982  residential portion of a hazardous waste study revealed that there was  a
need  for  increased public education on the subject of HHW.  This  became  the
main  goal of a HHW collection program.  In December of 1984, the City  Council
of  Albuquerque  passed  a  special appropriations bill to  fund  a  collection
program.(2)    Additional  monies  were   provided  by  the  Bernalillo  County

     The  collection  program  was scheduled for the five-day  period,  October
18-22,  1985.   This included one weekend to encourage participation.  A  local
chemical firm donated the use of its facility as the collection site.  The site
was  in an industrial portion of Albuquerque and had good physical security.  A
hazardous  waste management firm was contracted to identify, package, transport
and dispose of the wastes collected.


     The City began an extensive public education program on the hazards of HHW
and  the effect on the environment from improper disposal of these wastes.  The
efforts began nearly 6 months prior to the collection days, and required nearly
the  full-time  efforts of the program coordinator.  Publicity  involved  three
general approaches:

     t  Public presentations
     t  Printed material
     •  Radio and television announcements

     The  program  coordinator  developed   an  audio-slide  presentation  that
stressed  environmental  concerns  related to HHW,  helped  residents  identify
wastes,  and explained the planned collection program.  Although the slide show
was  based  on  one developed by the League of Women Voters  in  Massachusetts,
local  slides  and  a local news reporter as narrator were effective  steps  to
customize  the  material.  The presentation was given at meetings of  over  150
local  organizations  such as Lions and Women's Clubs.  Each attendee was  also
given  a  refrigerator  magnet as a reminder of the dates and location  of  the
collection program.

     Printed  material included the usual posters, flyers, and other    handout
materials.  Announcements were also posted on 40 municipal buses.  Inserts were
put  into water bills in both July and September.  Thus, virtually everyone  in
Albuquerque  was at  least  exposed to written  material announcing  the

 collection   effort.    Other  media  publicity  included radio and  public   service
 announcements.   A 60-second animated TV  spot was broadcast on  local  stations.
 Examples  of  the  publicity  materials  appear in Exhibit  1.

   '   The  City   gave   the  program  an official kick-off with a   news   conference
 covered   by   all local  television  stations and newspapers.   Additionally,   the
 mayor issued an executive order proclaiming October 18-22, 1985 as   "Hazardous
 Waste-Wise Days".(5)


      Each  prospective contractor was to submit a proposal by  April  6,   1985.
 Proposals  were  to include copies  of all  insurance coverage, state and   Federal
 registrations,   and  a detailed breakdown of all costs  associated   with  this
 program.  Criteria for the selection of the contractor included past  experience
 in  this  type   of  program   and   ability to  comply  with  State  and   Federal
 environmental  and transportation  laws, cost-effectivness of the management  of
 all areas of the project,  and proper insurance coverage.(4)


      The  contractor's  responsibilities  included all those services  needed  to
 collect,  analyze, package,  transport and dispose of the HHW.(4)  This included
 identification   of  an  unknown  substance  by appropriate  means.    Materials
 including  drums,  overpacks and absorbent were also the responsibility  of   the
 contractor.   Other equipment including  safety equipment for personnel,  first
 aid   equipment   and drum pumping equipment were also required.  The   contractor
 maintained   a  daily log of  all accepted wastes and any compatability or  other
 types of tests run on  the  HHW.

      The  City of Albuquerque provided the personnel  for reception,   inventory,
 public  information,    participant  interviews, and administration.    Others   not
 on-site,  but  aware   of   the  project in case of an  incident  were  the  Fire
 Department and the Police  Department.

      Equipment  provided   by  the  City included the  Environmental  Improvement
 Division's   Hazards  Van,  drum  handling equipment including  a  forklift   and
 operator,  labels,   eyewash  and   shower,   wooden  pallets,   emergency  spill
 materials, tables,  chairs, and traffic routing equipment.


     The site was located  at the Rinchem Corporation, a chemical transportation
 company  in  the northeast quandrant of the city.   A diagram of the  collection
 site  is in Exhibit 2.   Rinchem Corporation donated the use of its  property. The
 site  is  a  secure area surrounded by a tall  fence with a gate that was  locked
when  the  collection  site was not open.   This  eliminated the need to  hire  a
 security  guard.    It was also located far enough away from congested areas  to
minimize  traffic  hazards. Signs directing traffic to the site were placed  in
 such  a way that they were visible to any traffic approaching  the  site from any
conceivable  direction.  This  included all  cross streets as well  as  the  main

       pctfkldtt «ul Mh« koinekoM p«i*K»> CM po«uH
      l |iou«l«Uii| mttu It tram tnMn4»««( An nllnulcd I •
mma* pouMfa of kitudow wnM •>« keln| teneuMrf amuoV k»
kouMkoUi M AftwiuiHiu*. Abou) 1.4 «*)• Dounh ol Alt w«M m
b«li>| diipoinl ol (oiprafttilr Into Ike uolUfy bndkl and t»»t. truxnt.
of J.iojoi ml open IBXO. Ikui iiK»«lii« Ike IknM to p-J*c k*n«l» IM IMltl 14 IK »»..!«K lln-
                              timimiimrnl |IIWAI<| j tlrjn «*o*uitnnirnl lnrf.iv
     WHAT  ARE
HaiatdDut maleiiati bickio* conov>e. leacllve. lonilable and
•uHiuk dul CM pietcnl a dueal to pubk keakk and ufcly.
envkonmenl. You piulubV ka« tome In yow kom* - on tkefcn In
yow taiage. In Ike cabhteH. and • «oik and rtou«r ike*. lket« »4
be accepted al Ik* Afcuqueniu* HJIt-C r*+a
   • Canned o> on«iMled (ntecttcidn
                          *nd to.le
                           ly. »nd «w
                           tkefcn III
   • nnei 01 un«>MlcMU|tl 4t» MlMH
   • OU painl. DM* Dinnen
   • Wood picteivaNwn
   • Ink* iuJ Md MUlie«le
   • S»lmmln| pool ckrmlcM
   • CleMl«| luidt. Mcicket. Md immonU
 r«W m«l mokK oJ to • bcjl iMicknf M*
              WHY  IS
fiouet dhlioul (KOtnH polkilioii ol ik* 1*11 temlUv* en*.
okkk It tuiriplibb to froundMUi coMMitaWMi. Ov »»••*"*" *
tk* *»•/ «»l«f w kne, M M< kw* to k* »*nr twtickV* ol t). kn-
piopM dhpoul ol kauidout koiiKkold w.Mct - tuck M buiytnej «M
wan* - pietMn Ike poUMUl lx to»lc wkHMtn to i*«k ditoUnf

palm'pound down Ik* dial*. «ke» wukipted rtwuhmdl ol iinel »ve«.
pox a «neal to ** walei wppty fouling waue doM koutekoU dialm
ahml Ike m>>eilal H |ri Mo •>« t*»a(e Iwaknenl ptanl Of rou< tepM
lurt> and cvenwaly Into ftoundwalei. Sevna,* lieatmeM olanlt «* not
dettaned to Km kaiaidoul maMriah. Haiantoul mtttitit In kouKkuM
baik h laten to «S« landlll «kkk CM Jk~ to.k ckemkak) to icack
      . *K« Ik* landM h not dn!.ned kM kalMkwi matte dlipow!
        l Iveiy eftM tkouU be made to IdeMnV ** malenal

 and male tuie Ike Mt aie UtM II conulneii aie kiailnf, pack hi a
 lai|ei contain*! and vt* M aktoikeM nuWilal tuck M cat Mel to wak
 up leakt fw e.jmpto. plac* a oar-qfua conUkief In • cltin on* i»«o«
 paml CM availaMe al total palnl itoiet and unaund »«» abwiUnl
 nuleilal to»« » dMI*i*M
 or «•»*•»• nuttitek Mttlko. IM lonotMeiM uota|*. Mon m a cool
 diy plic* Many ckcnucah. eiprcully tmt In caidbnaid packa|u>i, CM
 akioib moiilui*
                                OCT  18-22  1985
                                9-6 DAILY
                                BINCHIM CO. It39 Hdllh Nf
                                •HOUSEHOLD HAZARDOUS
                                WASTE COLLECTION
                                                            REFRIGERATOR MAGNET

     EXHIBIT 1   (Continued)
                               HAZARDOUS WASTE IN MY HOME
                        HOW TO IDENTIFY A
                    HAZARDOUS WASTE PRODUCT
            1.  Why should I be concerned with household hazardous waste?
                       To protect your family and pets.
                       To protect our environment.
                       To reduce the amount of hazardous waste  generated.
            2.   What are household hazardous wastes?
                       Substances which  are  toxic,  corrosive, or  ftamable  and
                       capable  of causing  serious  Illness  or  hana  to  IUMHS,
                       domestic livestock, wildlife, or the environment.

                       While  Most packages  offer  adequate  instructions  on  the
                       storage  and use  of  these  potentially dangeroui Materials.
                       they rarely contain  instructions on how  to  dispose of the*.
            3.  What can  I do. . .
                 when buying  toxic Materials?

                        Read  the label carefully.
                        Buy only as much as you need.
                        Use up all the Materials for  their Intended purpose.
                        Keep  separate froM groceries, i.e., carry in car trunk.

                 in the event of spillage of toxic Materials?

                        Sweep or shovel dust and powders into a plastic bag.
                        Spread sand, sawdust, or cat  litter on liquids to absorb
                          spillage and then shovel Into plastic bag.
                 with unused toxic Materials?

                        Must not be  thrown in the trash.
                        Must not be  flushed down the drain or toilets.
                        Must not be  burned.
                        Store In safe place In the original labeled container.
                                             ENVIRONMENTAL SERVICES DIVISION  "
                                             tNVIRONMENTALKEALTH 8 tNERCY DEPARTMENT
                                             ALBUQUERQUE,  NEW MEXICO
Check  '.he  label  on the  container.   Look for key  words:   CORROSIVE.
OXIOIZER.  Federal law  requires  products to  be labelled with  their
contents and any  dangers about then.

The  following  Is a  partial  list of household  hazardous wastes  and
their toxic effects:
        Drain Openers	Corrosive
        Oven Cl eaners	Corros < ve
        Toilet Bowl Cleaners	Corrosive
        AMMnU  I Ammonia Based Cleaners	Corrosive
        Ly«	;	Corrosive
        Pool Acids	Corrosive
        Photographic Chemicals	Corrosive
        Floor ft  Furniture Polish	Flamiable
        Spot Remover/Ory Cleaning Fluids	Flainable
        Disinfectants	Flammable
        Rug/Upholstery Cleaner	FlaianabIe/Corrosive
        Air Freshener	Flamnable/Irritant
        Aerosols	Flamnable
        Automotive Waste Oil	Flammable
        Brake Fluid	Flanraable
        TranSMlsslon Fluid	Flamnable
        01 esel Fuel	Flanwabl e
        Enamel/Oil Base  Paint	Fl amnabl e
        Paint Solvents or Thlnners	Flamnable
        Glass Cleaners	Irritant
        Anti-Freeze	Poison
        Pesticides	,.Poison
        Chlorine	Oxldlzer
                        ALBUQUERQUE, NEW MEXICO

   EXHIBIT 1 (Continued)
                                          Why should I recycle used oil?
            Recycle  Your
         Used  Motor Oil.
            It makes good sense)
          Protects Our Environment
               Conserves Enerqy
It protects our environment OH dumped down
the sewer, in the trash, or on the ground can
eventually find its way Into our water supply
used oil contains many contaminants some
harmful to human health
                                          How difficult is it to collect
                                          used oil for recycling?
if s very simple. Drain your oil into a clean con-
tainer with a tight fitting cap (one gallon
plastic milk tug) Do not mix the recovered oil
with any other liquids Make sure it is free from
dirt leaves or other debris
                                      Where do I take my used oil to
                                      have it recycled?
                                                                                 Take your used oil to any location listed on this
                                                                                 Why do so many businesses
                                                                                 want used motor oil?
Used oil. the kind that is changed from autos
lawn mowers and motorcycles is a valuable
resource Every gallon recycled is one less gal
Ion that must be produced from a dwindling
world supply and one less that must be im
ported Recycling also saves energy Only about
half as much energy is required to rec vcle used
oil than is needed to produce new oil

      EXHIBIT  1  (Continued)

              Household Cleaners

              Drain Openers

              Oven Cleaners
              Toilet Bowl Cleaners
              F1oor/Furniture Polishers
              Amnonta A Armonl a-based
              Glass Cleaners

              Chlorine Bleach


              Rug S Upholstery Cleaners
Pour boiling Mater down the drain a couple
of   tines   a  week   as   a   preventatlve
measure.   Unclog  drains with  a metal snakt
or plunger.

Keep oven clean as you  use it.   Ovens can
be cleaned with diluted ammonia  or baking
soda.  Nix 3 tablespoons washing soda with
one quart of war* water.  Sprinkle salt on
spills when they  are warm then scrub.  For
baked on  grease,  put  1/4  cup  ammonia  in
oven overnight to  loosen,  then  scrub with
baking soda.

A general household cleaner or baking soda
can  be  used.  1/2  cup of bleach  can  be
used as  a cleaner  or  use a  pumice stone
for hard water spots.

Light,  soapy water  to clean  and  •  soft
cloth to  shine.   Melt  1 tbsp  of Carnauba
Hex  Into 2 cups mineral oil  or dissolve 1
tsp  lemon oil  into 1 pint of  mineral  oil
or rub crushed raw nuts on the woM for an
oily  polish.    Use  a  soft   cloth  and

Vinegar with salt and water Is a good
general  surface cleaner.  Dissolved baking
soda  does  well  in  the  bathroom  and  for
cleaning coffee  pots,  chrome,  copper and
tile.   Well-diluted  ammonia  is  a  good
general  household cleaner.

Warm  water  and   vinegar  in   an  8-to-1
solution.  Use cornstarch  and  water.  Use
lemon juice and dry with a  soft cloth.

Never mix  with ammonia  products.  Baking
soda and water is a safer cleaner.

Dilute bleach:  1/4 cup to  1 qt water.

Dry  cornstarch   sprinkled  on   rug  and
vacuumed up  or use soap-based non-aerosol
rug  shampoos.  Always wear  gloves.
Air Fresheners

Copper Cleaner

Silver Cleaner

Paint Products


Paint Solvents S Thinners


Ant Control

Bug Spray

Flea Repellent

Rat Poison

Snail/Slug Bait
                                                                                               Roach Spray
Houseplant Insecticides
An  open   box   of  baking   soda   In  thj
refrigerator.    Set  vinegar  out   In  opei

Pour vinegar and salt over copper and rub.

Soak silver in  1  qt warm water continuing
1 tsp baking soda, 1 tsp salt, and a piece
of aluminum foil.
Use   latex
or   water-based   paints   if
                                                                                                                          Latex   and  water-based   paints   do
                                                                                                                          require thlnners.
Sprinkle cream of  tartar In  front  of the
ant's path.

Place   screens   on  windows   and  doirs.
Brewers yeast tablets-taken dally give the
skin a scent that mosqultos  seem  to  avoid.

Place  eucalyptus  seeds  and  leaves  around
the  area  where  the  animal  sleeps.    A
bandana  soaked   in  penny  royal   tea  will
repel fleas.

Put    a   screen    over   drains.     Use
mechanical-snap  mouse traps.

Place  a  shallow  pan with   beer  In  the
Infested  area.   Overturn  claypots.   The
snails  will  take  shelter  In  them  during
the  sunny  days  and  they can  be  collected
and removed.

Chopped bay  leaves  and cucumber   skins, or
boric  acid,  or  1  part  borax and  1  part
brown sugar set  out In dishes.

Spread  newspapers  around  closets  or put
clothes  in  cedar  chests  or  place  cedar
chips around clothes.

Soapy water on leaves—then  rinse.
                                                                                                                             ENVIRONMENTAL SERVICES  DIVISION
                                                                                                                             ENVIRONMENTAL HEALTH 8  ENERGY DEPARTMENT
                                                                                                                             ALBUQUERQUE/  NEW  MEXICO

                                                 EXHIBIT  2.   DIAGRAM OF  ALBUQUERQUE, NM
                                                HOUSEHOLD HAZARDOUS WASTE COLLECTION SITE
                                                          HHW Staff—«-T~l
                                                           Trailer     [J
                                                                              SQC and  Institution
                                                                              Drop Off Area-r
CSX Supply — •— J
Trailer J
Sorting Table — J
SQG and n
Institution! J
                                                                               Vermiculite Storage
                                                                                                     Rinchem  Bldg.
                                                                                                  /  / /  / / ^-—Participant
                                                                                                / / / / / /      Parkin9
                                                                                                /   '   f  /  f  '       Area
Waste Oil
                                                                                     HHW Interviewer's
                                                                                     Seating Area
                                                                                              A A A AAA
                                               Empty Drums   '•Education Trailer
                                               >fsx.\-r*+~- •»• w^—  v**Ty^p^jy
                                                         HHW Staff-
                                                      Traffic and
                               Overflow Parking
                                                                                                                 HHW Staff
                                                                            HHW Staff-^
                                                                       Directing Traffic

      The  contractor's  facility  consisted of a single trailer with a canopy  over
 processing   tables.     Tables were  set up along the length of the  trailer   for
 processing   of  the HHW and  testing  any unknown substance.  Another table,   used
 for   reception   of the waste, prevented non-contractor personnel from- entering
 the   processing area.   Two  other trailers, one for contractor supplies and   the
 other  for  storage of  the bags  of vermiculite for waste packaging were  located

      Other  features  of the  collection site were a waste-oil tank located a  safe
 distance  from the processing area.  Only City personnel were permitted near it.
 The   education   trailer was located next to the processing  area.  Participants
 could safely view  overall  collection activities and get additional information
 on  HHW.    At one end  of the trailer a table contained flyers  and  information
 about  household hazardous  waste, including  information  about  alternative,
 non-hazardous   substitutions for household chemicals and cleaners.   Additional
 information concerning the  HHW   situation  as  it  pertains  to  Albuquerque
 including   oil  recycling together with a list of oil recycling locations in  the
 Albuquerque area  was  also  located on the table.  At the other  end  of   the
 trailer,  the   slide/tape   presentation  was shown 1;o  every  participant   that
 entered   the trailer.  Personnel were available in the trailer to  answer   any
 questions   relating  to HHW.    If a question could not  be  answered  by   the
 personnel   in   the trailer, an  attempt was made to locate someone  on-site   who
 could  answer   the question, or the participant was referred to the  agency  or
 person  that would  be able to assist him/her.  A sample  of  the  educational
 material  is in  Exhibit  2.   Also on-site was the EID (Environmental Improvement
 Division)   Hazards   Van with facilities to cleanup any spill that  might   have


      At   the entrance  to  the site,  a City employee  routed  traffic  to   the
 entrance  of the  collection area.  At that point,  another City employee gave  the
 participant some general printed information on  HHW and then directed  him/her
 to  a parking   area.    The participant was then  interviewed  and  the  waste
 inventoried.     A City  employee then removed the  waste from  the  participant's
 vehicle   and moved the  waste to the processing site.  The participant was  given
 the   option  of visiting the education/information van,  or leaving the site.  If
 a  participant had a large quantity of waste or was a small  quantity generator,
 he was routed directly  to the processing area. The wastes were inventoried  and
 the participant  was  interviewed.

      Small   commercial   generators   and     institutions  were  encouraged  to
 participate.   Receipt  and processing  of these wastes were completely  separate
 from  the   HHW areas.  Up to two 55-gallon drums  of wastes were accepted at  no
 charge  from  these  sources.  For more wastes, a  discounted fee was charged  by
 the contractor.(3)

     A  special   feature of the Albuquerque program was a call-in  service   for
 some  residents.   Those who were elderly,  handicapped,  or  had  transportation
difficulties  could  telephone  the City for a  special  pick-up.   City  employees
collected the wastes  and hauled them back to the  collection  site.


     Program  publicity identified the wastes that would be accepted and  those
that would not.  Accepted wastes included:(4)

        Household Cleaners and Polishes
        Drain Openers
        Wood Preservatives
        Furniture Strippers

Waste excluded from the collection program are as follows:

        Motor Oil
        Gas Cylinders

Facilities  were  available  on-site to process these wastes if  a  participant
brought them:(3)

     •  Radioactive  wastes were returned to manufacturers (e.g. stereo  record
        cleaner, smoke alarm).

     t  Explosives and ammunition were placed in a "bomb box" that was on-site.
        These were then given to the Police Department for disposal.

     t  Motor  oil  was put into a 550 gallon tank on-site.  An  oil  recycling
        firm provided the tank and emptied it when necessary.

     •  Aerosol  cans were packed to be transported to an appropriate  disposal


     Several  forms  of insurance were involved.  The owner of  the  collection
site  carried  public liability insurance for activities on the property.   The
contractor  carried its own insurance covering its employees during any  period
of  time that the waste was handled.  Also the contractor carried comprehensive
general  liability insurance for the equipment in use, including any  vehicles.
The  City of Albuquerque employees were insured by the City's insurance policy.
The  fact  that participants did not handle the wastes while at the  collection
site was an operational decision that reduced the possibility of an incident or


     Results of the Albuquerque collection program are shown in Exhibit 3. Over
1,000  households  participated  (about 0.8 percent of the  households  in  the
area).    Some  66 other generators also participated including  57  commercial
sources and nine schools.  Over 59 tons of waste were collected with 39 percent
coming from households and 61 percent from other sources.

     Each  household  contributed  about 46 Ib of waste while  each  commercial
source  brought  in nearly 1,100 Ibs.  This latter figure is the equivalent  of
about  146 gallons.  Thus, although the program was primarily directed  towards
homeowners, most of the waste came from other sources.

     Total  program costs were estimated at about $146,500 as shown in  Exhibit
4.  This  includes actual costs and estimated value of donations of the use  of
the  collection  site,  donated  labor, and volunteer labor.   Exhibit  4  also
includes  cost  factors for fringe benefits for City employees and for  overall
administration.    These  are costs that are often not included in  other  cost
estimates of HHW collection programs.

     Cost  per  pound of waste received was calculated as $1.24 based on  total
costs  and  total waste.  There was no separate accounting of costs related  to
HHW  and  the  other  generators.   However, the thrust  of  the  program  from
inception  was toward the homeowners.  The program would have cost  Albuquerque
nearly  the  same if only HHW were accepted.  If 90 percent of the  costs  were
associated  with HHW aspects, the cost to collect each pound of HHW would  have
been $2.85 ($146,525 x 0.9/$46,215 Ib).


(1)  Residential Hazardous/Toxic Waste Survey, City of Albuquerque
        Environmental Health and Energy Department, Albuquerque, NM, 1983.

(2)  Press Conference Announcement, Councilor Nadyne Bicknell,  City Council
        Albuquerque,  Albuquerque, NM, July 17, 1985.

(3)  Personal Communication, Donna Lacombe, Environmental Health and Energy
        Department, City of Albuquerque, Albuquerque,  NM, October 19,  1985.

(4)  Household/Small  Quantity Generator Hazardous Waste Collection Project
        Request for Proposal, Nubmer 85-1219-J,  City of Albuquerque,
        Albuquerque,  NM, April  5, 1985.

(5)  Executive Order, Mayor Harry E.  Kenney,  Mayor, City of Albuquerque, NM,
        October 18, 1985.

(6)  Personal Communiation, Donna Lacombe,  Environmental  Health and Energy
        Department, City of Albuquerque, Albuquerque,  NM, October 29,  1986.


     •  Duration:  5 days (October 18-22, 1985)

     •  Locations:  1

     •  Participants

             -- -Households:  1,005 (including 7 call  in for pick-up)
             --  Schools:  9
             --  Commercial  small quantity generators: 57

     •  Household Participation Rate:  0.77% (1,005/130,000 households in area
                                       x 100)

     •  Waste Collected

             -- Households:   46,215 Ib.
             -- Others    :   72,285 Ib.
             -- Total     :  118,500 Ib.
             -- Waste Oil :  750 gal.  (approx 4,500 Ib.)

     •  Waste per Participant

             -- Households:      46 Ib.
             -- Others    :   1,095 Ib.

     •  Total Costs:  $146,525

     •  Cost per Pound of Waste:  $1.24 (total costs/total  waste).
Source:  Reference  6

Hazardous waste contractor                                       $ 72,000
Salaries of City employees                                         48,000
Benefits for City employees (est) 20%                               9,600
Administration and overhead (est)                                   1,000
Publicity                                                          11,900
     Subtotal          "                                         $142,500
Volunteer labor (90 firs x $15/hr)                                $  1,350
Use of facility and forklift (est)                                  2,000
Donated labor (45 hrs x $15/hr)                                       675
     Subtotal                                                    $  4,025
TOTAL COSTS                                                      $146,525

Source:  Reference 6

                           FAIRFAX COUNTY,  VIRGINIA

     In  1983,  the  Fairfax  County Board of Supervisors  formed  a  Hazardous
Materials  Core Group to study the problem of household hazardous waste in  the
County.    After researching the current household hazardous  waste  management
alternatives,  the  concept  of  the  "clean-up day"  seemed  to  be  the  most
effective.    The Department of Public Works, Division of Wastewater  Treatment
was directed by the County Board of Supervisors, to coordinate a collection day
that was scheduled for October 26, 1985.(1)

     The  goals  of  the  "clean-up day" were to provide for  the  disposal  of
residential  household  hazardous  waste,   gather   information  on  types  and
quantities  of each waste from every participant  to determine the  feasibility
of  future  projects, to divert the disposal  of household hazardous waste  from
the  municipal  wastestream,  and   to     increase  public  awareness  of  the
environmental dangers of household hazardous  waste.

     The  County Board of Supervisors approved the implementation of a "Fairfax
County Household Hazardous Waste Clean-Up Day" on September 16, 1985 (about six
weeks  prior to the event). " GSX was selected as the hazardous waste contractor
to  collect and dispose of the household hazardous waste.(1)  Criteria used  in
the evaluation for the selection of the contractor included the following:(2)

     t  The contractor must have had previous experience in household hazardous
        waste collection days.

     •  The contractor must take the responsiblity as a generator.

     •  The contractor must show the existence of a safety plan.


     Publicity  for  the HHW collection day was managed by the  Fairfax  County
Office  of Public Affairs.  The County made a valiant effort to publicize  this
event.    Due to time contraints and missed deadlines, the advertising did  not
seem  to  reach a large part of Fairfax County.  Eleven different  groups  were
targeted  to receive flyers and posters.  These included libraries,  government
agencies,  retail outlets, and schools.  News releases were issued to the media
on  two  different  occasions prior to the collection day.   A  public  service
announcement  was  also  released  to   the  local  cable  television  station.
Additionally,  an article appeared in the Fairfax County (Government's)  Weekly
Agenda.  A number of community groups distributed flyers.  Flyers and brochures
were  also  distributed  by County staff at local social  events  and  farmers'
markets  throughout the area.(3)  Examples of the flyer and brochure appear  in
Exhibit 1.

Bring your leftover...

* Pesticides (chlordane.
  malathion. DDT. arsenic)

• Paint thinners and solvents

• Oil based paints (no latex)
  pour into one can and crush

• Chemistry sets
• Wood preservatives, stains and


• Photographic and pool

• Fertilizers

• Rodent and weed killers

?t*t Disposal for County Rasidjmts

CALL 451-7783. Health Dtpt
Fairfax County





   Rain or Shine
Saturday. October 26
   9 a.m. to 3 p.m.

 Oakton High School
  2900 Sutton Road
     Vienna, Va.


 Edison High School
 5801 Franconia Road
   Alexandria. Va.

EXHIBIT  1  (Continued)
                  THE PROBLEM

                                  WHAT WILL HOT aeACCXPTCD
                                                                   QUESTIONS A ANSWERS
              . Thay may Bamac.

ca*y awaTrhaynMiga tram malatnaar
f.nrnivm men aa Mad and mcury.
noujn JiamaaM ot vagua  lunaaniy
sucn aa caomunv and on c ma na»ar
                                                                                       nousanoia Hazardous wtstf on

                      • (audt « TrtcnM«oaavana1 mat
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                                                                            Fairfax County
                                                                     HOUSEHOLD HAZARDOUS
                                                                       WASTE CLEAN UP DAY
                                                                              Han or Sim
                                                                     DAY: SaMday. Oclobaf 28.1996
                                                                     TIME: 9 a.m. to 3 pm.
                                                                     LOCATIONS. OakionHlghScnoot
                                                                               EdawnHIgM School
                                                                               SBOt Ftancoma Hoad
                                                            Edaon Hgh School


      In  the  original  plan,  three collection sites were  selected, to  be  operated
 simultaneously.   These were  to be located in the southern, central  and western
 parts  of  the  County.  The  recommendation by the contractor  and   prohibitive
 costs,   led  to the selection  of  two sites, Edison High School  in   Springfield
 (southern  area) and Oakton  High School in Oakton (west-central area).   (1)


     The   collection   site  operations  were  similar   at  both  sites.     The
 participant  entered   the collection site and drove around a series  of  traffic
 cones  to  the disposal area.   No traffic direction was  evident at either  site.
 This  caused  considerable  confusion.  Moreover,  vehicles that  were  at   the
 schools  for  other   events  drove  to the disposal area.   A  diagram  of   the
 collection   site appears in Exhibit 2.  After arriving  at the collection point,
 the  participant was  greeted by a County employee for an interview.  The wastes
 were removed from the  car by a County employee (in most instances) and  moved to
 the processing area.   GSX personnel then sorted, packed, and manifested the  HHW
 for transportation and disposal.  Fairfax County Police, Virginia Department of
 Emergency  Services,   and   GSX  staff were on-site in   the  event  an   incident
 occurred.    Additionally,  refuse staff were on-site to collect and  dispose  of
 any normal refuse brought to the site.

     The  types of waste accepted at this household hazardous waste  collection
 day  included: pesticides (including chlordane, malathion, DDT, arsenic);  weed
 and  rodent  killers;  fertilizers; paint thinners  and  solvents;   degreasers;
 swimming  pool  chemicals;  wood preservatives (including  stains,   varnishes);
 photographic chemicals; spot removers; chemistry sets;  unused flammable liquids
 (gasoline, kerosene); oil-based paints; and batteries. Wastes excluded  from  the
 program  (though accepted if brought to the site) included: biologically active
 wastes,  radioactive  wastes,  normal   refuse,    asbestos,  used   motor  oil,
 explosives,  cylinders  of compressed gas, shock-sensitive materials,   dioxins,
 and  kepones.  Any unknown materials were screened by County  personnel  before
 being  accepted.  If the county did not accept the unknown material, GSX  noted
 the  incident in the daily log.  Small quantity generators and businesses  were
 also  excluded  from the HHW collection day.   Any small  quantity  generator  or
 small business that attempted to participate was rejected.


     Several  forms of liability insurance were involved.  Limited liability was
 accepted  by  the  County  of Fairfax.  This included  its  employees   and  the
 physical   collection site (land,  buildings).   As the generator, the  contractor
was  liable  for  any  incidents    occuring  during  the  sorting,   packaging,
 transportation or disposal  of the wastes.   The Department of Emergency  Services
personnel were insured against liability by the Commonwealth of Virginia.

Edison High School
                                                                                  -Packed Drums
                                                                                                 /CSX Supply

                                                                                                                     I         I
                                                           rHHW Staff  Table
                                                                                        ^"^ Sorting/Manifesting

                                                                                     t> t> (>      Tables
                                                                          Participant Drop/Off Are
                            -HHW Staff Parking
                                                                               >  0


     A  total  of 251 households particpated in the household  hazardous  waste
collection day out of approximately 223,000 total  households in the County. The
greatest  amount  of wastes collected included oil-based paint and  pesticides.
Latex  paints  brought  to the collection site, were disposed of  in  a  refuse
container  and  transported to the landfill.  The same procedure was  used  for
aerosal  cans. Waste oil was taken to Fairfax County's vehicle maintenance yard
for recycling.

     Results of the on-site survey indicate that 60 percent of the participants
would  have  continued  to store the wastes if the HHW collection day  had  not
occurred.   Likewise, a majority (55 percent) said they would participate in an
annual  household hazardous waste collection day.  A summary tabulation of  the
participant survey is shown in Exhibit 3.

     Participation  and  quantities  recovered  are shown in Exhibit  4.    The
figures  for  the  quantities  recovered and the  waste  per  participant  were
estimated  due to the lack of data available when this case study was prepared.
The  estimate for the total weight of waste collected and the resultant  weight
per  participant was based on three sources.  This consists of a report by  the
Agency  of  Environmental  Conservation  on the methods and  programs  for  HHW
collection  and  disposal(4),  the  data from the  Albuquerque  HHW  Collection
Program,  and  on-site personal- observations.  Using this information,  it  was
estimated  that  each  household  contributed approximately 31  pounds  of  HHW
(including waste oil).

     Cost  for  the one-day collection program is estimated at nearly  $70,400.
Many  of the costs are estimates due to the lack of available data.  The  costs
also  include estimated values of volunteer labor, factors for fringe  benefits
for  County  and State employees and administration costs.  A cost  summary  is
shown in Exhibit 5.  Cost per pound of HHW collected was estimated at $9.05.


     The  County  is  establishing  a one-year pilot project  consisting  of  a
transfer  and  disposal  site at the Lower Potomac Pollution Control  Plant  at
Lorton,  in  the  extreme southern portion of the County.  The wastes  will  be
collected  and  stored  on-site  and periodically transported  to  a  permitted
facility  by  a  hazardous waste transporter.(1)  The objective of  this  pilot
project is to determine the cost-effectiveness and feasibility of a permanently
operating  facility. The County will also sponsor another HHW collection day in
the  spring.  Funding  has already been appropriated for the  project,  however
details have not yet been made available.(l)


(1)   Personal Communication, Robin Byrd, Fairfax County Department of Public
           Works, Wastewater Treatment, October 26, 1985.

(2)   Fairfax County Request for Proposal, No. 6-0125-20-27, Fairfax County,
           Department of Public Works, August 19, 1985.

(3)    Memorandum to J.  Hamilton Lambert - Fairfax County Executive from Jean
           Van Devanter,  Office of Public Affairs,  October 22,  1985.

(4)    Methods and Programs for the Collection and Disposal of Household
           Quantities of Hazardous Waste, State of Vermont.  Agency of
           Environmental  Conservation,  Montpelier,  VT,  January 10, 1985.

                     EXHIBIT 3.  SUMMARY OF FAIRFAX COUNTY
                         VIRGINIA PARTICIPANT SURVEY
Edison High School:  116 Participants     Oakton High School:  135 Participants

                      Total Number of Participants:  251

Type of Waste(s) and Amount Delivered:

	Type of Waste	Number of Containers

Paint and Paint Related Products (Non-Latex Paint,
  Turpentine, Varsol, Paint Thinner)                               779

Cleaners and Solvents                                              216

Petroleum Products (Asphalt, Tar, Petroleum
  Distillate)                                                       65

Automotive and Fuel (Lighter Fluid, Kerosene,
  Oils That Were Mixed)                                             65

Chemicals and Flammables (Resins, Wood
  Preservatives, Xylol, Sealer)                                    151

Pesticides and Herbicides                                          682

Corrosives (Acids, Rust Remover)                                   228

Poisonous (Potassium Cyanate, Copper Sulfate,
  Sodium Thiosulfate, Boray)                                       194

Oxidizers (Potassium Dichromate, Strontium
  Ditrate, Nitric Acid)                                          	24

TOTAL CONTAINERS                                                 2,402*

Was this location convient?  Yes:  82.3 percent       No:  17.6 percent

What  would  you  have done with this waste if this clean-up day had  not  been

      Included it with your household garbage:  15.1 percent
      Continued to hold onto and store the wastes:  60.1 percent
      Poured it down the sink or toilet:  0.3 percent
      Poured it down the storm drain:  0.3 percent
      Buried the material:   0.7 percent
      Other:   23 percent (Most of which said they would call the County for
              disposal  information.

EXHIBIT 3 (Continued)
How often would you use this clean-up day services?

      Once a year:  55.6 percent
      Twice a year:  25.4 percent
      Four times a year:  4.0 percent
      Never again:  2.4 percent
      Other:  12.5 percent of the participants stated they would use this
              service once every other year.

How did you hear about the Household Hazardous Waste Collection Day?

      School Brochure:  21.5 percent
      Newspapers:  24.1 percent
      Cable TV:  1.4 percent
      Radio:  2.2 percent
      Weekly Agenda:  13.0 percent
      Flyers:  7.8 percent
      Posters:  20.0 percent
      Special Events ("Fairfax Day"):  1.4 percent
      Word of Mouth:  2.6 percent
      League of Women Voters:  3.3 percent
      Employer:  0.3 percent
      Homeowners Association:  1.8 percent
* Source:  Personal Communication, Robin Byrd, Department of Public Works
            Division of Waste Water Treatment, County of Fairfax, Fairfax
            Virginia, November 12, 1985.


      •  Duration:  1 day  (October 26, 1985)
      •  Locations:  2
      t  Participants:  251 households
      •  Participation Rate:  0.11% (251/223,000 households in County x  100)
      t  Weight of Waste Collected
              -- Households:  6,777 pounds*
              -- Waste Oil:   1,004 pounds**
      •  Waste per Participant
              -- Household:  Approximately 27 pounds*
              -- Waste Oil: 4 pounds**
      •  Total Costs:  $70,400 (estimated)
      t  Cost per Pound of Waste (including oil):  $9.05
* Estimate based on the Connecticut/Vermont HHW Collection Day Summary Report
        and On-Site Personal Observations.
** Estimate Based on Albuquerque, NM HHW Collection Program Data.


Salaries - County Employees (Planning)
       1 Project Manager
      11 Staff Members

Salaries - Project Staff (on-site)

       2 County Representatives
       6 Technicians
       2 Policemen
       2 Firemen
       2 Refuse Workers
       3 State Health Employees
140 hrs 0 $15/hour (est)
 80 hrs (3 $13/hour (est)
  8 hrs @ $15/hour (est)
  8 hrs 0 $13/hour (est)  •
  8 hrs (? $ll/hour (est)
  8 hrs 9 $ll/hour (est)
  8 hrs 8 $8/hour  (est)
  8 hrs @ $12/hour (est)

  Subtotal  Salaries:

  22.5 % of salaries:

  (Est. 20% of salaries):
                                     200 mi 9 $.20/mi (est)
Benefits for County Employees



      Flyer Distribution
      Travel to Collection Site


       10,360 Brochures
      187,000 Flyers
          686 Posters

Contractor Expenses (2 Crews of 3 Men and 2 Trucks)

      Per Diem ($50/person/day)
                                                                       $  2,100

$ 15,172



EXHIBIT 5 (Continued)
Donated Services (est)
      Brochure and Flyer Distribution
        League of Women Voters
        School Board (through interoffice mail to all schools)
        Libraries (through interoffice mail to all libraries)
        Fire Station (through interoffice mail to all fire stations         500
                                     Estimated Total Costs:            $ 70,390
Sources:  Robin Byrd, HHW Project Manager, Department of Public Works, Waste
               Water Treatment Division, Fairfax County, Virginia
          Fairfax County Fire Department, Fairfax County, Virginia
          Fairfax County Police Department, Fairfax County, Virginia
          Office of Personnel, Classification Division, Fairfax, County, VA

                               STATE OF FLORIDA
    In  1983, the Florida Legislature passed the Water Quality Assurance Act to
protect Florida's ground water from further contamination.   A provision of this
act  mandated  that  the  Department  of  Environmental   Regulation  conduct  a
hazardous waste collection program entitled Amnesty Days.   The program required
two  collection  periods per year for three years.   Each collection  period  is
from  one  to six weeks in length.  A collection effort is  to be  conducted  at
least  once in each county in those three years.  The goals of the project  are
to  collect  the  greatest  amount  of   waste  from  schools,  small  quantity
generators, government agencies, farmers, and households;  to educate the public
to  make  them  aware  of what is and what is not a  hazardous  waste;  and  to
determine  the  need and feasibility of facilities  for storage or  disposal  of
waste in the State.(1)

    The Amnesty Day program is funded by the Water Quality  Assurance Trust Fund
which  is part of the Coastal Protection Trust Fund.(2)  The project is  funded
on  an  annual basis.  Ceilings on administrative and publicity costs are  each
set  at  5 percent of the program funds.  The remainder is  used for the  actual
collection and disposal costs.

    The State is responsible for total program coordination and administration.
This  includes  locating  a  collection  site,  setting  up  collection  dates,
contracting a hazardous waste management firm, publicity,  and providing on-site
personnel  to  coordinate activities at the collection station.(3)   The  State
also  maintains a toll-free telephone number for citizens and businesses to use
for  any  questions reqarding hazardous waste storage and disposal  or  Amnesty


    Publicity  is  funded  by the State.  A five-fold approach has  been  taken
towards educating the public on the Amensty Day program(l):

    t  Television and radio public service announcements

    •  Pamphlets targeted at specific groups or organizations

    •  Films  shown on local cable TV stations

    t  Newspaper advertisements

    •  Electric and water bill  inserts

In  addition  civic groups and  professional organizations  include  Amnesty  Day
information   in  their  newsletters.  The State also enlists  the help  of  such
groups  as   the League of Women Voters to distribute pamphlets and  disseminate
information.(3)    A  sample  of  some of the publicity materials   is  shown   in
Exhibit 1.

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                             Amnesty  Days
                             Amnesty  Days
                             Amnesty  Days
                             Amnesty  Days

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                                                                   . Flarid* 33301
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                                                                                     Amnesty  Days
                                                                                     Amnesty  Days
                                                                                     Amnesty  Days
                                                       ...for tha promt disposal
                                                               of hazardous waste...

                                                       How you can got involved
                                                                        •W Imrjortaru-    Wriat ar» hazardous materials, and
                                                        «vr>r can't/**? f contagion •» I*****, oaefc m • larqor con
                                                                                      twivr antf u*» m «o>efO«m maiengi men 34
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                                                                                      vMfti aiMoroant matartat

   EXHIBIT  1  (Continued)
 How To Participate

 You may  register for  the
 Amnesty Days Cooperative Ser-
 vices Program by calling the
 special toll-free telephone
 number   established   for
 "Amnesty Days". (See the toll-
 free number below). The infor-
 mation operator will register
 your  name,  address  and
 telephone number, and you will
 be contacted to schedule your
 service or. you may wish to
 register at the "Amnesty Days"
 Collection Station. Remember.
 the Collection Station will pro-
 vide FREE disposal for up to 5 S
 gallons or 430 pounds of com-
 bined waste per participant, but
 if you have more than  this
 quantity, you will need to use
 the.Amnesty Days Cooperative
 Services Program.
   Additional Information
 Amnesty Days
                                Amnesty Days
                                Amnesty Days
      2600 Blor SUM AMU
           i Bond«32301
. ./or the proper disposal
    o/hazardous waste
   Information & Collection
      Station Location
What is "Amnesty Days
Cooperative Services"?
 Services Provided
        Fee Schedule
   The Amnesty Days Cooperative
   Services Program is designed in
   conjunction  with "Amnesty
   Days" to provide for the proper
   handling and disposal of haz-
   ardous materials which exceed
   the limit under  the original
   "Amnesty Days"  program.

   Under Section 403.7241 of the
   Florida Statutes. "Amnesty
   Days"  is made  available to
   dispose of small quantities of
   hazardous waste —  free of
   charge — for homeowners.
   fanners, schools, state  agen-
   cies, and small businesses.

   The Amnesty Days Cooperative
   Services Program provides not
   only active disposal  of haz-
   ardous waste,  but any  infor-
   mation regarding the "what's",
   "Where's",  and  "why's" of
   hazardous waste disposal. Our
   objective is.  that with proper
   information and guidance, you
   can gain confidence and under-
   standing in dealing effectively
   with hazardous waste manage-
   ment and disposal.
The  Florida  contractor  for
"Amnesty Days" is Triangle
Resource Industries (TRT). a
division of SCA Chemical Ser-
vices. Inc. (SCA). SCA will offer
special reduced prices for all
services to participants for the
duration of "Amnesty Days". A
schedule of dates and locations
for your area is shown on the
back of this brochure.

SCA and TRI are full-service
hazardous waste management
operations who specialize in
serving  small  generators,
schools, and research facilities.
This specialization helps us to
better  understand your needs
in hazardous waste disposal.

An SCA Program representative
will contact you with an easy-
to-use  information service
packet describing all available
services and their costs. We will
assist in evaluating any special
needs. Some areas in which you
may  need help  include lab
analysis, manifesting, training.
shipping containers, packaging
supplies and labels, licensing
support, health and safety, and
emergency-spill back-up.
   As a result of SCA's "Amnesty
   Days" involvement, we are of-
   fering a minimum 23% reduc-
   tion in normal charges for per-
   sonnel services, transportation,
   disposal, containers, and sup-
   plies. To  help forecast  your
   costs. us« the following charts:
   (A full fee schedule will be pro-
   vided hi the service packet.)
   wtut* Disposal a. Transportotton
   Wuu Tvos
Standard Fee Amnesty Fee
   MaMTiol* and Supplies
Item Standard Fee Amnesty Fee
33-gsl steel drams 128.0O
33-^al poly drams 138.0O
39-iiat non-corrosive
solidification drams 144.30
39-gsi corrosive
solidification drams 149. SO
averpacKs 1123.0O
vermiculite 17.30/eg
dram liners ll.30/es.
121. OO
   Labor and Personnel
Title Standard Fee Amnesty F
Supervisor J43.0O/hr.
Explosives Technician S4O.OO/hr.
Industrial Hygiemst MO.OO/nr.
Field Chemist 333.0O/hr.
Technician 123.0O/nr.
S27 OO/hr
S27 OOyHr
11 9. OO/hr


    A  request for a proposal was  issued by the Department of Regulation   (DER)
on January 13, 1984.(4)  The award was based on eight criteria:

    t  Safety plan

    •  Technical approach and record keeping

    •  Project organization and management

    t  Experience

    •  Personnel assigned and level of effort

    t  Schedule  implementation and estimated level of participation

    •  Ability to maintain a professional image

    •  Price

Each  of  the  selection  factors were assigned a value ranging from  0  to   15
depending  upon  the relative importance of the factor.  The State  then   rated.
each  factor  in each of the submitted proposals the contract was awarded  with
the highest numerical score.(4)


    The  Contractor  was  responsible for supplying the  personnel,  materials,
service,  and  facilities to accomplish the tasks.  This  included  collecting,
packaging,  transporting, and disposing of the hazardous waste.  The Contractor
was also responsible for handling a separate accounting of all records and fees
of  those  businesses  and government agencies that disposed of  quantities   of
hazardous waste above the designated limit.  The Contractor was to be bonded  or
insured  to  guarantee responsibility for any liability that may incur  in  the
collection, packaging, transport or disposal of the hazardous waste.(4)


    Florida  is  divided  into several  Regional Planning Councils.  Each   is  a
group  of counties with similar long-term planning interests.  The statute that
established Amnesty Days set the dates  for collection programs in each council.
State-level program personnel  then select a good location in each council.(3)

    The  location chosen for a collection site must be situated on a flat, well
drained paved area.  This facilitates easy and rapid clean-up of any spill that
might  occur.  The sight must also be centrally located, easily accessible  and
its  name  must be well-recognized.  If possible,  it should  be  publicly-owned
property.    Collection  sites   have    included  courthouses,   county  health
departments,  city warehouses,  airports  and libraries.(3)


    The  State  operates two types of mobile collection facilities.
population  and  geographic  area, the State may operate one or both
facilities  within  a  Regional  Planning  Council.    The  larger  of
facilities, the main site, consists of the following:
                                            the  two
       Two  semi-trailers
       storage space.
separated by a canopy that covers a  laboratory  and
    •  Eight chemists and/or industrial  hygienists

    t  One explosives technician

    t  One Department of Environmenatal  Regulation (DER) representative

The  satellite site is smaller and consists of one semi-trailer with a  canopy,
six chemists and one DER representive.  A general  site plan is shown in Exhibit

    The  two facilities operate simultaneously.  They may be in the same county
within  a Regional Planning Council (if substantiated by population) or in  two
different counties.  Each facility remains at a collection site for 1 to 6 days
depending  on  the geographic area to be served and the expected  participation

    At  the  collection site, the participant is directed to a receiving  area.
The  participant  is  interviewed  to  gather  general  information  concerning
disposal  habits,  type  of organization, if the participant  would  support  a
permanent  program,  and their source of water (e.g., well or  public  system).
There  is  also an industrial hygienist on-site to answer any inquiries.    The
participant  is  then routed to the collection area and transfers the waste  to
the  Contractor. The Contractor sorts, packages, manifests and tests any uknown
wastes  in the mini-lab van.  Methods to process explosives and reactives, even
though  they  are listed as unacceptable, are present.  An  on-site  explosives
technician  arranges  for  this  disposal of the material.   Other  wastes  not
accepted include those that are biologically active,.gas cylinders, and aerosol

    The  Amnesty  Days progam allows a participant to dispose of one barrel  or
450  pounds  of  hazardous waste.  If that amount is exceeded,  the  contractor
offers a discounted fee of 25 percent off the regular disposal fee.(6)

    After  sorting, the wastes are routed to a packaging area separate from the
collection  area.   There the waste are categorized according to hazard  class,
labeled,  and  manifested.  The wastes are then moved to a storage  area.    The
wastes  are transported to the Contractor's fixed transfer and storage facility
to  be  categorized  and  shipped to an  appropriate,  permitted  treatment  or
disposal facility.

 pubic, ares?
  mag. £ van
                  barrier rope

                  information tables


    The  Amnesty Days progam is funded on an annual  basis in July from a  grant
from  the Florida Legislature.  The program requires two collection periods per
year  for three years.  A collection period is from 4 to 6 weeks.  There is one
collection  period  in  the  fall  (October - November) and one  in  the  spring
(May-June.(3)    Of  the  total   funds    5  percent  has  been  mandated  for
administrative  costs  and 5 percent for publicity costs.  The remaining  funds
are  used  for  the  actual collection, transportation,   and  disposal  of  the
hazardous  waste.    The costs for each collection  period  vary  considerably.
Factors that cause this variaton include geographical locality,  population size
of  the county served, and the number of units operating.  Also, the State does
not have a policy that excludes other Regional Councils  from participating at a
collecton  site.(7)    Exhibit  3   is a cost overview  for  each  of  the  four
collection periods that the State  has operated thus far.

    Costs  are  calculated on a daily basis for each collection  center.   If  a
county  has  two  collection  sites operating  simultaneously,  the  costs  are
calculated  individually for each  site.  The Contractor's costs  are  classified
into  three categories.  These are operating expenses (salaries, lodging, food)
materials  and  transportation costs.  The cost for the  DER  representative  is
included  in  the  initial 5 percent allocation  for  administrative  costs.(7)
Included  in  Exhibit 4 are the daily costs, by category, for  three  counties:
Palm Beach County, Lee County, and Highlands" County. These counties were chosen
to  illustrate the differences in  operating costs for three different types  of
operations and populations.

    Palm  Beach County has a population of 576,863 with  234,339   households.(8)
The  State operated both the main  and satellite sites in the county.  The  main
site  operated  for 4 days in each of the two locations  and the  satellite  site
operated  at  one  location for 4  days.  The total cost  for  this  project  was
$179,184  or  $22,398  per  day.  In Lee County,  with the  population  of  over
205,266 (82,509 households), the State operated the main site for a period of 5
days.  The  total costs for this type of operation was $83,693 or  $16,739  per
day. Highlands County has a population of 47,526 (18,960 households).  A single
satellite  site  was operated at one location for 4 days.  The total costs  for
this project was $17,895 or $4,474 per day.

    No  data is currently available relating the quantities of waste  collected
in  any one county to costs.  Thus, collection costs per pound of HHW cannot be
directly  calculated.    Exhibit  5 is a tabulation of data on  28  of  the  43
counties  where collection programs have been conducted.  Total  cost for  these
43  counties  is  the  sum  of the funding amounts shown  in  Exhibit  3  ($2.4
million).  Assuming  that  the remaining 15 counties generated  a  proportional
amount of HHW, a total of 937,000  Ibs or 469 tons of waste were  collected. This
results in a cost of some $2.56 per pound.

    Exhibit  5  illustrates  the  Amnesty Day collection totals   for  May  1984
through  June  1985.  Included in  this exhibit are the participation  rates  in
percents  for  each  of  the  counties where a  collection  took  place.    The
participation  rates  range from 0.07 percent in Dade County to  1.8 percent  in
Alachua  County.    However,  the  overall participation  rate  of  0.31  percent

corresponds  with the national participation averages of less than 1 percent of
the population.


1.  The Florida Department of Governmental Regulation Presents Amnesty Days,
         Bureau of Operations, Florida Department of Evironmental Regulation.

2.  Household Hazardous Waste, Solving the Disposal Dilemma, Golden Empire
         Health Planning Center, Sacramenta, CA, 1984.

3. "Personal Communication, Jan Kleman, Amnesty Days Program Coordinator,
         Florida Department of Environmental Regulation, November 1, 1985.

4.  Request for Proposal, Solicitation No. 8047, Florida Department of
         Environmental Regulation, January 13, 1984.

5.  "Amnesty Days - How You Can Get Involved", Florida Department of
         Environmental Regulations, 1984.

6.  "Amnesty Days Cooperative Service Program, Florida Department of
         Envionmental Regulation, 1984.

7.  Donna Clark, Amnesty Days Information Specialist, Florida Department of
         Environmental Regulation, January 15, 1986.

8.  County and City Data Book, 1983, U.S. Department of the Census,
         U.S. Government Printing Office, 1983.

                                            EXHIBIT 3.  COLLECTION PERIOD  COSTS
Dates Covered
May-June 1984
October-November 1984
May-June 1985
Octob°r-November 1985
Funding Approved
July 1983
July 1984
Date Not Available
July 1985
Funding Amount
Area Collected
7 Counties
14 Counties
7 Counties
15 Counties

      Personal Communications, Jan Kleman, Florida Department of Environmental  Regulation,  November  1,  1985.

      Personal Communication, Donna Clark, Florida Department of Environmental  Regulation,  January  15,  1986.

(Salaries, Lodging, Food)
Palm Beach
(232,339 Households) Main A/Day 1
A/ Day 2
A/Day 3
A/Day 4
Main B/Day 1
B/Day 2
B/Day 3
B/Day 4
Satellite C/Day 1
C/Day 2
C/Day 3
C/Day 4
$ 4,860
$ 2,755
$ 12,172
                                                                                                       Subtotal $24,440
          Total  For  Palm Beach  County

         EXHIBIT 4.  (Continued)
Lee County Main
(82,509 Households)

Total for Lee County
Highlands County Satellite
(18,960 Households)

A/Day 1
A/ Day 2
A/ Day 3
A/ Day 4
A/ Day 5
A/ Day 1
A/Day 2
A/ Day 3
A/ Day 4
$ 4,860
$ 3,240
$ 1,668
$ 443
$ 7,464
$ 1,946
$ 14,022
$ 83,723
$ 5,629

          Total  For Highlands  County
$ 23,914

                                 EXHIBIT J,   "AMNESTY  DAY"  COLLECTION  TOTALS (MAY  1984  - JUNE 1985)

Escambia County
Okaloosa County
Santa Rosa County
Walton County
Bay County
Holmes County
Washington County
Brevard County
Orange County
Osceola County
Lake County
Seminole County
Volusia County
Putman County
St. Johns County
Flagler County
Baker County
Duval County
Clay County
Nassau County
Alachua County
Dade County
Broward County
Monroe County
Manatee County
Hillsborough County
Pinellas County
Pasco County
Number of

Amount of Waste
Collected (pounds)
91 ,640

(x 1000)

(x 1000)

Rate %

          References:   •  Amnesty Day Collection Totals,  Florida Department of Environmental Regulatipns,  Tallahasee, Florida,  1985.
                       •  County and City Data Book, 1983,  U.S. Department of  the Census, U.S.  Government Printing Office, 1983.

corresponds  with the national participation averages of less than 1 percent of
the population.


1.  The Florida Department of Governmental Regulation Presents Amnesty Days,
         Bureau of Operations, Florida Department of Evironmental Regulation.

2.  Household Hazardous Waste, Solving the Disposal Dilemma, Golden Empire
         Health Planning Center, Sacramento, CA, 1984.

3.  Personal Communication, Jan Kleman, Amnesty Days Program Coordinator,
         Florida Department of Environmental Regulation, November 1, 1985.

4.  Request for Proposal, Solicitation No. 8047, Florida Department of
         Environmental Regulation, January 13, 1984.

5.  "Amnesty Days - How You Can Get Involved", Florida Department of
         Environmental Regulations, 1984.

6.  "Amnesty Days Cooperative Service Program, Florida Department of
         Envionmental Regulation, 1984.

7.  Donna Clark, Amnesty Days Information Specialist, Florida Department of
         Environmental Regulation, January 15, 1986.

8.  City and County Data Book, 1984.


      JAN 281986
SUBJECT. CERCLA and RCRA Liability of Municipal Sponsors of Household
       Hazardous Waste Collection Programs

  FROM: John P. Lehman, Director fjJU*/A^^iLf
       Waste Management and Economics Division  (WH-565)

    T0: Basil G. Constantelos, Director
       Waste Management Division
       Region V

            I am responding to your October 29,  1985, memorandum
       requesting an Agency policy statement concerning the  liability
       under the Comprehensive Environmental Response, Compensation,
       and Liability Act  (CERCLA) of municipal sponsors of household
       hazardous waste collection programs.  In  addition, this
       memorandum clarifies the issue of potential liability under
       the Resource Conservation and Recovery Act  (RCRA).  The
       following interpretations are based on discussions of these
       issues with the Office of General Counsel (OGC) and the Office
       of Enforcement and Compliance Monitoring  (OECM).

           • In a June 7,  1984, memorandum to the Deputy Administrator,
       Lee Thomas (then Assistant Administrator  for the Office of
       Solid Waste and Emergency Response) clarified the issue of
       RCRA liability.  This memorandum, which is  attached,  stated
       that household hazardous wastes are by definition exempt from
       regulation under Subtitle C of RCRA.  Section 261.4(b)(l)
       unconditionally exempts household wastes  from being designated
       as hazardous even when accumulated in quantities that would
       otherwise be regulated or when transported, stored, treated,
       disposed, recovered, or reused.  However, when household
       wastes are mixed with hazardous wastes from small quantity
       generators, this resulting mixture is subject to the  small
       quantity generator rules (Section 261.5).   In addition,
       when household waste is mixed with other  regulated hazardous
       wastes, the entire mixture becomes subject  to full hazardous
       waste regulation (Section 261.3(a)(2)).   For this reason,
       sponsors of household hazardous waste collection programs
       should be careful  to limit the participation in their programs
       to households to avoid the possibility of receiving regulated
       hazardous wastes from commercial or industrial sources.

            With regard to CERCLA, we cannot offer relief from long-
       term liability.  CERCLA does not contain  any type of  exclusion
       for household waste or any type of exclusion based on the
       amount of waste generated.  As a general  matter, any  waste that
       qualifies as a hazardous substance under  CERCLA is subject to
       the liability provisions of Section 107.   Hazardous substances
       are both defined under Section 101(14) and designated under
       Section 102(a).  Therefore, if a household  waste contains a
       substance that is  covered under either section  (whether or not
EPA Form 1320-6 (R«v. 3-76)

it is a RCRA hazardous waste), potential CERCLA liability
would apply regardless of whether the material was picked up
as part of a community's routine trash collection service or
was gathered as part of a special collection day program.
With respect to household hazardous waste, such waste would
clearly qualify as a "hazardous substance" if it contains any
substance listed in Table 302.4 of 40 CFR Part 302.

     With regard to enforcement under CERCLA, you noted that
John Skinner, former Director of this office, recently cited
a policy statement in a May 4, 1984, letter  (attached) from
Region I Administrator, Michael DeLand, to Dana Duxbury of the
Massachusetts League of Women Voters.  This policy statement
relied on enforcement discretion in indicating that EPA had no
intention of taking enforcement action against a Massachusetts
town that sponsored a contracted collection day, if problems
arose in the transportation or disposal of the household
hazardous waste collected during the collection program.
Further clarification was offered by Courtney Price (OECM)
in a memorandum dated May 11, 1984 (attached), to Alvin Aim,
former Deputy Administrator.  For the specific case of that
Masssachusetts town, the company collecting and transporting
the wastes and the disposal facility owner or operator would
be considered the responsible parties.

     While you are correct in stating that the Agency's general
policy is to not give "no action" assurances in enforcement
matters (see attached Courtney Price memorandum of November 16,
1984), Ms. Price addressed a specific household hazardous
waste collection program in the May 11, 1984, memorandum and
explained their position in the Region I case in Massachusetts.
The decision of "no action" in the Massachusetts case was
based on the facts about that specific program.  An important
feature was limiting collections to household hazardous wastes.
No wastes from small commercial businesses were accepted.
Courtney Price indicated that OECM would have to look at the
specific facts of any situation involving wastes from small
businesses to determine whether an exercise of enforcement
discretion would be appropriate.

     In our recent discussions with OECM, we have considered
the concept of "no action" as a possible general policy for
sponsor* of household hazardous waste collection programs.
OECM ha* not yet completed their analysis of this issue.  They
expect to complete their analysis in the next several weeks
and will supply their policy statement in a separate memorandum.

     If you have any questions regarding the issues addressed
in this memorandum, please contact Michael Flynn of my staff
at 382-4489.



. I
                                               REGION V

        SUBJECT- CERCLA Liability to Municipal  Sponsors  of
              ' Household Hazardous Waste Collection  Programs
Basil G. Constantelo
Waste Management 01 vis
            TO:  John P. Lehman,  Director
                Waste Management and Economics  Division  (WH-56b)

                I am requesting  a definitive  Agency  policy  statement  concerning the
                CERCLA liability of municipal sponsors of household hazardous waste
                collection programs.

                Under Section 8001 of RCRA, Region V awarded  17 yrants,  totaling
                $466,194,  to local  communities  to support household hazardous waste
                collection programs.  Several grantees (Glen  Ellyn, Illinois, the
                Northwest  Municipal  Conference  (suburban Chicago), and Shiawassee
                County, Michigan)  have requested  relief  from  lony-tenn Superfund
                liability.  They are hesitant to  sponsor such programs without
                assurances from  the United States Environmental Protection  Agency
                that they  will not incur  lony-term liability.

                During the Headquarters-sponsored HSWA Conference  in  Washington on
                August 1-2, 1985,  Dr. John Skinner endorsed a policy  statement on this
                issue that had been issued by Region I.  I  have enclosed the  letter
           —   outlining  that policy, a  May  4, 1984 letter from Region  I Administrator
                Michael Del and to  Ms. Dana Duxbury of the Massachussetts League of
                Women Voters. Region I's policy  relied  on  Agency  enforcement discretion,

                I had solicited  a  similar policy  statement  from our Office  of Reyional
                Counsel (ORC) (see enclosed September lu, 1985, memo  to  Ms. Mary Gade).
                Regional Counsel's response,  after conferring with Mr. Steven Leifer  of
                the Office of General  Counsel (OGC)  has  been  one of "no  exceptions."
                The precedent for  this approach is a November 16,  1984 memo from
                Ms. Courtney Price (enclosed),  which advises  against  yiving "no action"
                assurances in enforcement matters.   ORC  and OGC recommended chat any
                deviation  from the Courtney Price memo would  have  to  come from
                Headquarters in  the form  of a policy statement from the  Office of
                Solid Waste and  Emergency Response.

                Because several  communities have  put their  household  hazardous waste
                collection plans on hold  while  awaiting  Agency guidance, a  prompt
                response would be  greatly appreciated.

                If you or  your staff have any further questions, please  contact Ken
                Westlake of my staff at FTS 886-7b80.
       EPA FORM 13304 (RtV. 3-79)

/sign«d/ Lee M. Thomas
                                                        Day a
                             MM ini aerator
                  '„*            •   • • -j — -• •
                   tha Mputy Ad»inUtfator
                response to your •avorandua of Nay ?* 1M4»'Z    '-'""' '
        have looked into tha issue of 1PA support for coasvinity-wida
    -   Collectlona of household hasardous waate.  Z fully agree that
    "-*  4isp«**l of household hasardoua waste IB Subtitle C facilities
     '^l«prv far able to disposing of these vateriala in aanitary
     ,:T lajsdfilia and that BPA should support these progravs to the
     ~ "^ngreateat. axtsnt practicable.                           ...  .,
                    » I aa soaowhai laaa cartaia aa to tha axtaot
              1EPA should bocoaa involvad in tha prograaa aine
                     of tha Agency's regulatory control undar BGBA*•'.-" -.-'
                  wastes «ra specifically excluded froa tha definition
               KV to 1PA involvamattt in thaaa prograaa,
                Mdftr tha circuaataocaa, tha raaponaibility
                aad ovarsiehfc appropriataly raata with th«
           ttataa.  Any aappoct which tha Agancy dacidaa to
•«t«Ml to such program afaould ba giwan on * caaa by caaa
te«i« a4tar a thorough raviaw of tha «p«cific situation and
only at tba roqvoat of individual 8tata».  Abaant any
rofiVlAtajry control ahould problaaa ariao* parhapa tha aoat
appropriata couraa for ETA to taka would ba to aiaply
provida clarification on apacific iaauaa whan aakad («»q»»
       clarification of tha liability iaaua in Haaaaclmaatta}
and to avoid actiona that night vnnacaaaarily diacouraga tha
davalopnant of auch programa*
WH-5€2BtRAxelrad 15/18/84 tS240:x382-5218

                                         ^.^-U^. -«~  ft

                                              0   5L

                                MESION I

 May "4,  1984
Dana Duxbury
Natural Resources Director
League of Wonen Voters of Massachusetts
B Winter Street
Boston, KA   02108

•Dear Dana:

Thank you for  your letter of April 17, 1984, concerning the commen-
dable efforts  of the League of Ucnen Voters to encourage residential
hazardous waste cleafn-up programs in the Commonwealth of Massachusetts.
Specifically,.your letter raises the question whether a town would
become liable  for remedial costs if there is a'release to the environ-
ment of hazardous substances collected during the clean-up either from
the ultimate disposal  facility or during transporation to the ultimate
disposal facility.

EPA has reviewed your  letter and the accompanying February 9, 1?34,
memorandum  from V?illiam F. Cass, Director, Division of Hazardous
Waste, Department of Environmental Quality Engineering (DEQE),
specifying  DFCE's policy regarding household hazardous waste collec-
tion days.   We believe the DEOE sets forth sound requirements for the
safe and proper handling of hazardous wastes during this collection
effort.  Based on our  understanding of how the program operates .and
assuming the town adheres to the requirements set forth in Mr. -'Cass's
memorandum,  EPA has  no intention of taking an enforcement action
against the  town under the circumstances described in your letter.

EPA applauds the League's involvement in this effort.  The establish-
ment of these  collection programs ensures the safe disposal of chemical
that might otherwise be handled improperly.   Further, such programs
perform a valuable public education function.  We support you in these
endeavors and  hope that household hazard waste collection days become
an annual event in every community.
Sincerely yours,

Michael R.
Regional Administrator

                    WASHINGTON. O.C. 2C460
                          MAY 11

SUBJECT:  Potential EPA InvoLveaenc in "Household Hazardous Waste
          Collection Days"   ->
                            /  I
FROM:     Courtney M. Price (	.
          Assistant Administrator far Inforcement
            and Compliance Monitoring

"•« .        « 1 «-•< •» T  1 ^ •»
*w :        A—v^n l*. A-—
          Deputy Administrator

     My office recently became aware of hazardous waste collec-
tion cays vhen ve vere" asked by Region I to consider the poten-
tial liability of cctisunities involved in --ase activities.
In gsnsrsl, I*support the ccncept of household hitarcous vasts
collection days and advocate £?A involvement in support of these-
activities.  "                                    "

-  '   In the specific situation presented to ny office by Region
I,? a .town in Massachusetts sought assurances froc IPA that the
town would not be held liable for any problems that later arose
from disposal of waste through a collection day.  My office has
advised Region I that under the specific facts presented by
Massachusetts for their household hazardous waste collection
days, the Agency would1 not intend to take an enforcement action
against the sponsoring coaounity, if a hazard arose during
transportation or later disposal (see attached letter).  In
these circumstances, the company collecting and transporting
the wasteland the disposal facility owner or 'operator would
be conti'wrtd che responsible parties.
              I should note that the Massachusetts program is
expressly limited to collection of hazardous waste which is
produced, by a household as part of normal household activity.
The Wall Street Journal article that was attached to your May 1,
1984 memorandum indicated that the program in Florida allowed
disposal of waste from small businesses.  This office's statement
concerning liability only covered collection of household waste,
an activity of which I fully approve.  I feel we would need to
look at the specific facts of a situation involving waste from

                             - 2 -
small bust

:.«o deceraine whecher an  exercise  of  enforceaent
be appropriate under che particular  circuascances

                        WASHINGTON. DC. 20460
                                                           Of tICI 0'
                                                         tNtO'CEMtmr ANC

 SUBJECT:  Policy Against  "No .Action" Assurances
 FROM:      Courtney  M.  Price
           Assistant Administrator  for  En
            and Compliance Monitoring

 TO:        Assistant Administrators
           Regional Administrators
           General Counsel
           Inspector General

     This  memorandum reaffirms EPA policy against giving
 definitive assurances  (written or oral) outside the context of
 a  formal enforcement proceeding that EPA will not proceed with
 an enforcement response for a specific individual violation of
 an environmental protection statute, regulation, or other
 legal requirement.

     "No action" promises may erode the credibility of EPA's
 enforcement program by creating real or perceived inequities
 in the Agency's treatment of the regulated community.  This
 credibility is vital as a continuing incentive for regulated
 parties to comply with environmental protection requirements.

     In addition,  any commitment not to enforce a legal
 requirement against a particular regulated party may severely
 hamper later enforcement efforts against that party/ who may.
 claim good-faith reliance on that assurance, or against other
 parties who claim  to be similarly situated.

     This policy against definitive no action promises to
parties outside the Agency applies in all contexts,  including
assurances requested:

     •   both prior to and after a violation has been committed;

   .  •   on the basis that a State or local government is
        responding to the violation;

      •  on the basis that revisions to the underlying legal
         requirement are being considered;

      0  on the basis that the Agency has determined that the
         party is not liable or has a valid defense;

      0  on the basis that the violation already has been
         corrected (or that a party has promised that it will
         correct the violation);  or

      •  on the basis that the violation is not of sufficient
         priority to merit Agency action.

      The Agency particularly must avoid no action promises
 relating either to violations of judicial  orders, for which a
 court has independent enforcement authority,  or to potential
 criminal violations, for which prosecutorial  discretion rests
 with the United States Attorney  General.

      As  a general rule,  exceptions to  this policy are warranted

      •  where expressly  provided by applicable statute or
         regulation (e.g.,  certain upset  or bypass situations)

      0  in extremely unusual  cases in  which a  no  action
         assurance is clearly  neccessary  to serve  the  public
         interest  (e.g.,  to allow action  to avoid  extreme risks
         to public health or  safety,  or  to  obtain  important
         information  for  research purposes)  and which  no other
        mechanism can  address  adequately.

 Of course,  any  exceptions  which  EPA grants  rrust be  in  an area
 in which  EPA  has  discretion not  to act under applicable law.

     This  policy  in  no way is  intended to  constrain the way in
 which EPA  discusses  and  coordinates  enforcement plans  with
 state or  local  enforcement authorities consistent with  normal
 working relationships.   To the extent  that  a statement  of EPA's
 enforcement intent is necessary  to  help support or  conclude  an
 effective  state enforcement effort,  EPA can employ  language
 such as the following:

     "EPA encourages State action  to resolve violations of
 the 	 Act and  supports  the actions which    (State)
 is taking  to address the violations at issue.   To the extent
 that the State action tfoes not satisfactorily  resolve  the
violations, EPA may pursue its own enforcement action."

     1 am requesting  that  any  definitive written or oral no
action commitment receive  the  advance concurrence of my office.
This was a difficult  decision  to  reach in light of the valid
concerns raised  in comments  on this  policy statement;•neverthe-
less, we concluded that Headquarters concurrence is important
because the precedential implications of providing no actic-n
commitments can  extend beyond  a single Region.   We will attempt
to consult with  the relevant program office and respond to any
formal request for concurrence within 10 working days from the
date we receive  the request.   Naturally, emergency situations
can be handled orally on an  expedited basis.

     All instances in which  an EPA official gives a no action
promise must be  documented in  the appropriate case file.  The
documentation must include an  explanation of the reasons
justifying the no action assurance.

     Finally, this policy  against no action assurances does not
preclude EPA from fully discussing internally the prosecutorial
merit of individual cases  or from exercising the discretion it
has under applicable  law to  decide when and how to respond or
not respond to a given violation, based on the Agency's normal
enforcement priorities.

cc;  Associate Enforcement Counsels
     OECM Office Directors
     Program Compliance Office Directors
     Regional Enforcement  Contacts
U.S. Environment?! " -'-action Agency y
Region 5,Lii.r?.ry "  •"",!)
77 West Jackson L.ou:-vard, 12th Floor
Chicago, 11 6G604-3590