Haphazard handling forbidden

Companies collecting and hauling municipal solid waste (MSW) may not necessarily wish to handle materials classified as household hazardous wastes (HHW) by the U.S. Environmental Protection Agency (EPA).

However, as part of many municipal and solid waste district contracts, it can be difficult for such firms to completely avoid the HHW sector, even if their involvement entails seeking a qualified subcontractor.

The additional compliance responsibilities linked to HHW, as well as the potential liabilities, mean any involvement by hauling firms will require due diligence and, perhaps, the help of outside consultants.

Defining and identifying

On its website, the U.S. EPA describes HHW as consisting of certain “leftover household products that can catch fire, react, or explode under certain circumstances, or that are corrosive or toxic as household hazardous waste. Products, such as paints, cleaners, oils, batteries and pesticides can contain hazardous ingredients and require special care” when discarded.

For haulers engaged in residential collection, working with solid waste departments and districts to educate residents about HHW can be a primary and critical task.

Residents are the cliché front line in identifying and segregating HHW items, and their ability to do so can make a difference beyond the compliance aspects of proper handling. “Certain types of HHW have the potential to cause physical injury to sanitation workers [or to] contaminate septic tanks or wastewater treatment systems if poured down drains or toilets,” the U.S. EPA says.

For hauling firms that also serve commercial and industrial clients, handling special and hazardous wastes is likely to be familiar territory.

In some ways, handling HHW has been made easier by the EPA compared to larger volumes of such materials, thanks to Title 40 of the Code of Federal Regulations Part 261.4, which provides an exclusion for HHW from some of the specific guidelines found in the Resource Conservation and Recovery Act (RCRA). Specifically, the Title 40 exclusion covers waste generated by individuals on the premise of a temporary or permanent residence.

While the exemption can be interpreted as good news for waste haulers in many instances, whether it makes matters simpler or more complicated in the long run can depend on the state or states in which they do business.

“State regulatory requirements for generators may be more stringent than those in the federal program,” the U.S. EPA says. The EPA also warns residents and the haulers serving them to “be sure to check your state’s policies.”

A map on the EPA website indicates that most states adhere to the Title 40 federal code as written, but eight states and Washington have modified their HHW rules and regulations.

California is the largest of the eight states, and an eight-page document describing its HHW rules refers primarily to the handling of silver-bearing materials as a potentially hazardous material, thus applying mainly to certain types of films and electronic scrap.

Rounding it all up

Solid waste districts and departments and the waste firms that serve them can collect HHW in different ways, but the most common methods involve drop-off locations and one-day targeted events.

Although it dates back to 1993, the U.S. EPA still houses a 78-page manual on its website that offers guidelines for one-day HHW collection events.

The manual lists a roster of recommended HHW items to target for collection, including:

• refrigerants;
• pesticides and herbicides;
• drain unclogging fluids and oven cleaners;
• metal polishes and paint removers;
• automotive fuel additives and fuel injection cleaners; and
• fungicides and wood preservatives.

The role of due diligence when contracting with the firm that will handle the collected HHW is emphasized, as is working cooperatively with all relative agencies and city departments.

On the budgeting side, haulers and planners are encouraged to investigate federal or state grants that may defray the costs of an HHW collection event.

A wide-ranging list of responsibilities and planning items noted by the manual includes securing an appropriate site, obtaining insurance, communicating with the local fire department and putting into place a public outreach program that can help maximize the volume collected.

“A HHW program cannot succeed without a strong public education effort,” the manual states. The EPA goes on to state, “The media is an especially important vehicle,” adding that the local media’s “understanding of HHW issues helps ensure accurate and responsible reporting.”

A program in Raleigh, North Carolina, that dates back to the 1980s has included publicity efforts where collection event notices are sent with city water department bills. The initial 1989 event proved so popular that the most common complaint concerned long waiting times for participants. (This resulted in increased staffing, often volunteers, at follow-up events.)

The formula is far from unique to Raleigh, with HHW collection events now a routine practice throughout the U.S.

More problematic for planners of such events are shrinking budgets for government agencies at all levels. HHW drop-off centers with steady hours may be the first casualty.

In mid-January 2018, northern Illinois TV station NCTV17 reported that a HHW collection center in Naperville, Illinois, which opened in 2015, was facing a steep funding cut courtesy of a sharply whittled Illinois EPA budget for 2018.

The media report indicated the facility would likely face a reduction in hours, although city officials also were considering shutting it down entirely. Such action might be necessary after the Illinois EPA reduced funding for the facility from $516,000 in 2017 to $250,000 in 2018.

While Naperville’s city government is unhappy about the cut, an Illinois EPA official contacted by the TV station says such cuts will allow the agency to fund more one-day events around the state.

Such budget and funding struggles taking place throughout the U.S. may make HHW collection events less frequent in 2018, or they may prompt city governments to seek corporate or nongovernmental agency sponsorships—or ask their hauling firms for new, fresh ideas.

The author is an editor with the Recycling Today Media Group and can be contacted at btaylor@gie.net.