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
Penalty for Private Use $300

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