United States
Environmental Protection
Agency '
Risk Reduction
Engineering Laboratory
Cincinnati, OH 45268
Research and Development
EPA/600/S2-89/064 Feb. 1990
&ERA Project Summary
Management of Household and
Small-Quantity-Generator
Hazardous Waste in the United
States
Although hazardous waste
generated by households Is exempt
from federal legislation, several
states do apply their regulations to
household hazardous waste. Small-
quantity generators of hazardous
waste, generally those generating
more than 100 but less than 1000
kg/mo, are regulated on most
governmental levels, but differently
from large-quantity generators.
The full report, which was
prepared for an international survey,
defines which wastes from these two
sizes of generators are addressed,
the policy and plans of the different
governmental levels to deal with
these wastes, which government
policies are compulsory and which
are voluntary in nature, and the
promotion of the hierarchy the U.S.
Environmental Protection Agency
(EPA) has established for waste
management: reduction, reuse,
recycling, treatment, and disposal.
This Project Summary was
developed by EPA's Risk Reduction
Engineering Laboratory, Cincinnati,
OH, to announce key findings of the
research project that is fully
documented in a separate report of
the same title (see Project Report
ordering information at back).
Introduction
The report summarized herein was
prepared in response to a survey
conducted by the International Solid
Waste and Public Cleansing Association
(ISWA), an international nongovernmental
organization made up of 27 national
organizations of waste management pro-
fessionals. The survey was designed to
generate information for an international
report of household hazardous waste
(HHW) and small quantity generators
(SWQs), which will serve as an
instrument for mutual exchange of
experience and cooperation.
In the United States, the congressional
acts governing hazardous wastes
[namely, the Resource Conservation and
Recovery Act (RCRA) and the
Comprehensive Environmental
Response, Compensation, and Liability
Act (CERCLA)] and the regulations the
EPA has promulgated under these Acts
establish what substances and consumer
products are considered hazardous. The
report also includes amendments to
these Acts, such as the Superfund
Amendments and Reauthorization Act
(SARA), that regulate hazardous
substances as they pertain to waste site
cleanup and emergency response and
provide information to communities
(community right- to-know information).
Under RCRA, individual states may be
authorized to regulate waste generators
at least as stringently as the federal law
requires. Thus, wastes and generators
addressed by a state's policy regarding
SQGs or HHW vary depending on state
definitions and priorities.
Hazardous substances in the
workplace are also regulated. The
Occupational Safety and Health Admin-
istration has set permissible exposure
limits for approximately 400 substances,
which appear on the "Z list" of the
Occupational Safety and Health Act.
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Exempted Generators
Subtitle C of RCRA excludes from
regulation those businesses that do not
generate hazardous wastes in sufficient
quantities to be regulated as large-
quantity generators (LQGs) or SQGs of
hazardous waste. These conditionally
exempt businesses must meet carefully
spelled-out criteria and may still be
subject to compliance with state
regulations, which are often more
stringent.
Wastes generated by households
(which include single and multiple
dwellings, hotels, motels, and other
residential sources) are also excluded
from regulation under Subtitle C of
RCRA. Thus, wastes generated by
households are not legally defined as
hazardous although the EPA and
individual states have defined HHW.
Household Hazardous Wastes
Federal, State, and Local Policy
At the national level, because HHW is
not regulated under RCRA Subtitle C,
EPA's policy is not aimed at regulating
but rather at promoting HHW collection
and management programs by providing
funding, information, and technical
assistance to states and local
governments.
Directed by Congress to explore how
household products and HHW relate to
the formation of leachate at landfills, EPA
completed an initial study entitled "A
Survey of Household Hazardous Waste
Collection Programs" in October 1986.
In November 1988, EPA issued a formal
policy statement regarding its support of
HHW collection management programs,
which listed all of the perceived
advantages of such programs.
With regard to the state and regional
policy, most of the 50 states do not
regulate HHW; however, California and
Rhode Island have chosen to apply
hazardous waste regulations to HHW.
Although state policies and management
plans vary since 1981, more than 1300
HHW collections have occurred in 43
states with varying levels of state support
and guidance
Local/community management plans
for HHW vary significantly, ranging from
no action to activities such as public
education only, one-time collection days,
periodic collections, collections involving
single waste streams such as paint only
or pesticides only, exchanges such as
paint exchange days, joint community
sponsored collection, permanent
collection facilities that operate
somewhere between 1 day a month and
5 days a week, and curbside collection of
HHW such as used oil.
Definitions of HHW
The exemption of HHW from federal
hazardous waste management
regulations also applies to HHW collected
in large quantities, such as during an
HHW collection program. When HHW is
mixed with any quantity of regulated
hazardous waste, however, the resulting
mixture is subject to regulation under
RCRA. The EPA also recommends that
sponsors of HHW collection programs
manage the collected HHW as hazardous
waste.
The EPA-developed list of household
wastes that would be regulated as
hazardous if they were generated in
larger quantities includes wastes listed as
hazardous in the regulations or ones that
demonstrate characteristics of hazardous
waste [i.e., ignitability, corrosivity,
reactivity, and extraction procedure (EP)
toxicity]. The categories of common
household products include household
cleaners, automotive products, home
maintenance and improvement products,
lawn and garden products, and
miscellaneous products (photo-
processing chemicals, batteries, pool
chemicals, and personal care products).
At the state and regional level, states
that apply hazardous waste regulations
or formal guidelines to HHW
management have promulgated strict
definitions of HHW, which vary by state.
At the local/community level several
organizations have attempted to define
HHW by listing items considered
hazardous. Although these lists vary
widely, they are often similar to EPA or
state definitions.
Information Activities about
HHW
At the national level, EPA sponsors
information activities. The Agency has
sponsored three national conferences on
household hazardous waste
management. In the 1988 conference,
approximately 70 experts from the United
States, Canada, and Europe delivered
presentations addressing topics
concerned with the definition, regulation,
liability, collection, management, and
disposal of HHW.
A quarterly newsletter, with a
projected 4000 circulation, is targeted to
provide communities with information on
HHW collection and management
beginning in 1989. The EPA also makes
available a 26-page bibliography of
literature to answer specific questior
Product labeling is an<
informational activity required b
federal government. For example
Federal Insecticides, Fungicides
Rodenticides Act (FIFRA) rec
informative and accurate labeli
pesticide products.
The Chemical Specialties ^
factures Association, a national in
association, established
nongovernmental Household Prc
Disposal Council. The Council set
information and referral servic
community organizers, groups, and
managers to provide informati
concerned consumers.
At the state/regional level,
information activities include pro
"hotlines" and referral services, prc
speakers for workshops and confer
distributing informational mati
promulgating shelf-labeling require
for retail stores, and responding to
inquiries. The full report gives s
examples of these activities.
At the local/community level,
cities, towns, and local institution!
sponsored educational act!
concerning HHW. Efforts in
developing curricula for schools,
tising HHW collection program;
offering telephone assistance "hotli
Compulsory and Voluntary
Management
The national policy for addi
HHW management is essentially
on voluntary activities because h
not federally regulated under
Subtitle C. Municipalities, howev
subject to liability incurred beca
HHW under CERCLA and SARA. I
roughly 165 municipal solid
landfills were included among the
the National Priorities List (NPL)
requiring cleanup under Supi
Municipalities that send waste, in
HHW, to these landfills are pot
liable for cleanups costs. This p
liability provides an incent
municipalities for voluntarily undi
HHW reduction, reuse, and mana
activities to avoid the potential lo
liability for landfill cleanup.
One regulatroy provision add
HHW is FIFRA's labeling requi
which includes informative and <
labeling of pesticide produ
provision addressing home pe
requires the label to contain infc
recommending that consumer
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/aste pesticides in newspaper and put
lem in the rubbish.
At the state level, many states rely
eavily on voluntary activities to address
1HW management. Although collection
irograms are frequently sponsored at the
ounty and local level without state
ivolvement, some states support these
ifforts by providing funding, information,
nd technical assistance.
Compulsory programs at the state
ivel include state-required labeling,
fanning, mandatory collection, and
jgulations pertaining to the operation of
ermanent and temporary collections.
Much of the local HHW activity results
•om voluntary programs. Counties, cities
nd towns, industry (including waste
management companies) ,and environ-
mental advocacy groups support or
ponsor programs that educate
onsumers about HHW, provide consu-
ters with HHW collection days, and
rovide or promote the dissemination of
(formation about substituting non-
azardous or less-hazardous sub-
tances.
Examples of voluntary and compulsary
rograms are given in the full report. No
cal programs requiring HHW manage-
ient activities were identified.
Front-End " and "End-of-the
Ipe" HHW Management
'easures
The EPA recommends that generators
f hazardous waste adhere to the
ollowing waste management hierarchy-
aste reduction, reuse, recycling,
reatment, and disposal. The federal
overnment's formal policy concerning
azardous waste is therefore based on
promoting "front-end" measures (i.e.,
waste reduction, reuse, and recycling) as
opposed to "end-of-pipe" measures such
as treatment and disposal. The EPA's
:ommitment to the waste-reduction step
was recently demonstrated by establishi-
ng its Pollution Prevention Office. In
support of these front-end solutions, EPA
las established programs such as the
J001 Grants Program and the RCRA
ntegrated Training and Technical
\ssistance (RITTA) Grants Program, both
if which have provided funds for state
lazardous waste minimization pro-grams.
"he EPA also sponsors an annual
lationat HHW conference that addresses
IHW from both front-end and end-of-
iipe perspectives.
National policy makers also recognize
ie importance of end-of-pipe measures
or the safe, environmentally
sound collection and disposal of HHW
that has accumulated in homes. Both
EPA and the U.S. Congress Office of
Technology Assessment (OTA) support
HHW collection programs.
At the state level, when the first HHW
collection days were held in the early
1980's, states focused attention on
removing and disposing of HHW that had
been accumulating for years in
consumers' homes. Because of the
success of this program, focus is shifting
somewhat from HHW collection to source
reduction and recycling. States, in
addition to supporting the front-end
measures, continue to support end-of-
pipe measures designed to ensure the
safe, environmentally sound disposal of
HHW. One reason some states support
HHW collection is to help residents
recognize that consumers share respons-
ibility with industry for ensuring proper
disposal of hazardous waste. It is hoped
that this recognition will promote the
public's cooperation in acceptance of the
siting of a hazardous waste treatment,
storage, and disposal facility in their
communities.
Local activities have included both
front-end and end-of-the pipe strategies
for addressing HHW. Front-end activities
nclude public education efforts to inform
people about product substitutes and
efforts to encourage reduced use of toxic
substances plus lobbying efforts for
labeling and source-reduction legislation.
Communities also continue to sponsor
end-of-pipe collection programs, and the
number of collections has increased
steadily since 1981.
Small-Quantity Generators
Federal, State, and Local Policy
At the national level, before the 1984
Hazardous and Solid Waste Act (HSWA)
amendments to RCRA, SQG waste was
not regulated as hazardous waste.
Currently, SQGs must comply with
national hazardous waste management
requirements. Like HHW generators,
SQGs are also addressed by CERCLA
and SARA, which pose retroactive, strict,
joint-and-several liability on the
generators of hazardous wastes.
In April 1986, EPA published an
implementation plan describing its
strategy with regard to regulations that
apply to SQGs. This strategy relies
heavily on information dissemination,
voluntary compliance, spot compliance
monitoring, and enforcement action for
major violators as the means for im-
plementing standards.
This approach is meant to encourage
SQGs to apply EPA's waste management
hierarchy-reduce, reuse, recycle, treat,
and dispose of-to the management of
hazardous waste. The Agency's newly
established Pollution Prevention Office
addresses the prevention of pollution
through programs that include grants for
state waste minimization efforts.
At the state and regional level,
individual states have adopted a policy
that includes both regulatory and
nonregulatory programs aimed at SQGs.
The regulatory policy involves
implementation of RCRA requirements of
their own equally or more stringent
requirements.
A nonregulatory hazardous waste
policy of the states is to promote the
reduction of hazardous waste. To this
end, in 1985, the National Roundtable of
State Waste Reduction Programs was
organized to promote the development of
state programs and to exchange
technical and general information on
waste reduction. The Roundtable is
composed of governmental, academic,
and public interest groups representing
42 states.
At the local/community level, efforts
have been made to promote regulatory
compliance and improved waste manage*
ment. To date, however, no national
coordinated official policy, legislative
framework, or management plan has
been applied at the local level to address
SQGs.
Definitions of SQGs
Small-quantity generators of haz-
ardous waste are regulated differently
from LQGs. An SQG is defined as one
that generates hazardous waste at a rate
of more than 100 kg/mo but less than
1000 kg/mo; generates no more than 1
kg/mo of acutely hazardous waste; ships
hazardous waste offsite within 180 days
after 1000 kg have been accumulated;
and accumulates no more than 6000 kg
at any one time.
At the state/regional level, policy
varies from state to state. For example,
waste oil is defined as a hazardous waste
in eight states and as a special waste in
six states. State-level SQG programs
address a wide variety of wastes and
generators based on the concerns of
residents, policymakers, and program
administrators in a given region.
Because no federal official policy,
legislative framework, or management
plans exist at the local/community level,
the SQG wastes and generators that
receive attention vary with local concerns
and priorities.
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SQG Informational Activities
At the national level, the EPA
sponsored a clearinghouse to assist
SQGs with technical and regulatory
questions. Approximately 400 assistance
calls were handled between April 1 and
December 1, 1988. The clearinghouse
also published a free quarterly newsletter
as an information exchange vehicle on
minimizing small-quantity-generated haz-
ardous waste; it reached regulatory and
nonregulatory federal, state, and local
agencies; technical assistance programs;
research facilities; and waste exchanges.
The EPA also has a program for
awarding grants to states for administer-
ing SQG and other waste reduction
programs.
The EPA runs two phone lines (the
Small Business Ombudsman and the
RCRA Hotline) that SQGs can use to
obtain information and assistance
regarding hazardous waste management.
Still another EPA assistance program
involves a pollution prevention infor-
mation clearinghouse; now in the plan-
ning stages, it is expected to begin
offering services by the end of 1989.
At the state and regional level, a
variety of information and assistance
programs are available to SQGs.
Between 1985 and June 1988, members
of the National Roundtable of State
Waste Reduction Programs helped
establish and expand waste reduction
programs in 35 states. Programs include
compliance assistance, general infor-
mation, clearinghouses, general and
onsite technical assistance, matching
grants, research grants, loans, tax
incentives, workshops/training, public
education, and waste exchanges.
At the local/community level, local
institutions and organizations (e.g.,
municipal governments, universities, and
research organizations) provide assis-
tance to SQGs.
Compulsory and Voluntary
Management for SQGs
At the national level, EPA relies in part
on voluntary compliance because of its
limited resources for enforcing SQG
compliance with national hazardous
waste regulations and policies through
inspections. Rising hazardous waste
disposal costs and the liability associated
with improper hazardous waste manage-
ment serve as incentives to SQGs for
voluntarily reducing, reusing, and pro-
perly managing hazardous waste.
Some components of EPA's strategy
regarding SQG's, however, focus on
compliance and enforcement activities.
The Agency intends to apply the same
compliance monitoring methods for
SQGs as those used for LQGs. Under
RCRA, EPA has the authority to inspect,
fine, and close down institutions that
violate the federal hazardous waste regu-
lations.
Resources at the state level are also
too limited to ensure compulsory
compliance with hazardous waste
requirements that apply to SQGs.
Therefore, states have responded with
voluntary outreach, education, and
assistance programs.
States that have been delegated
authority to administer their own RCRA
programs, instead of having the federal
program, can conduct inspections, levy
fines, and close down institutions that fail
to comply with hazardous waste manage-
ment requirements. State agencies often
target an SQG industry with an enforce-
ment effort combined with an
education/assistance program.
At the local/community level, counties,
cities, and towns sponsor many voluntary
programs that promote best management
practices and voluntary compliance with
hazardous waste management require-
ments.
When they have local jurisdiction,
localities can take action to enforce
federal and state laws that apply to
SQGs.
Future Perspectives for HHW
and SQGs
The national policy toward SQGs and
HHW is expected to continue to
emphasize pollution prevention and to
promote EPA's waste hierarchy of
reduction, reuse, recycling, treatment,
and disposal.
Consumer products (e.g., batteries
that contain lead or cadmium) are
expected to receive particular attention.
At the state/regional level, future
trends may include labeling laws that
focus on hazardous consumer products,
deposit systems for items such as
batteries, and tax incentives and
legislation that promote reduced use of
toxic materials.
Cities and towns are recognizing that,
although 1-day HHW collection events
are useful as a public education tool,
permanent and more cost-effective
solutions are needed. Many communities
are working to institutionalize collections
and to set up permanent HHW collection
facilities. At the same time, they are
promoting waste-reduction and recycling
initiatives designed to reduce the
for HHW collections.
With regard to SQGs, communitit
expected to continue to spc
programs to assist small local bu
ses in reducing and safely man
HHW.
Other Information Included
Report
The full report also includes the folk
• List of institutions, organization
authorities involved in HHW
governmental levels.
• Several case studies illustratir
application of policies to auto
shops, batteries, used oil, and f
• Descriptions of existing and pi
facilities/collection center
recycling, treating, or dispos
HHW.
• Descriptions of research
development activities by inc
government, and citizens' groi
alternatives to hazardous hou
products.
• Information on ecologically
products and the use of all-
ingredients.
The full report was submit
fulfillment of a task under Contn
68-02-4279 by Dana Duxbur
Associates, Andover, MA, und
sponsorship of the U.S. Environ
Protection Agency.
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This Project Summary was prepared by Staff of Dana Duxbury and Associates,
Andover, MA 01810.
James S. Bridges is the EPA Project Officer (see below).
The complete report, entitled "Management of Household and Small-Quantity-
Generator Hazardous Waste in the United States," (Order No. PB-90 148
867I AS; Cost: $17.00, subject to change) wilt be available only from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
Cincinnati, OH 45268
United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
Official Business
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