United States Solid Waste and EPA530-R-92-026

Environmental Protection Emergency Response August 1993

Agency (OS-305)

Household Hazardous
EPA

Waste Management
A Manual for One-Day
Community Collection Programs

Recycled/Recyclable Printed on pper that contains at least 50% reccled fiber.

T
his handbook is designed to help communities plan
and operate a successful household hazardous waste
(HHW) collection program. The handbook focuses on
one-day drop-off programs. Other types of HHW collection
programs—permanent, mobile, and special-are not discussed
in detail.

The handbook is intended for community leaders and HHW

collection program organizers. It provides guidance for all as-
pects of planning, organizing, and publicizing a HHW collec-
tion program. It does not provide technical information about
the treatment, disposal, or transport of HHW. These jobs are
performed by professional contractors or others with special-
ized training. The manual includes information about select-
ing a qualified hazardous waste contractor
I

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

Page
Introduction . . . . . . . . . . . . . . . . . . . . . . . ...1
Section 1 Getting Started . . . . . . . . . . . . . . . . . . . . . ...5
Section 2 Selecting Wastes and Collection Methods . . . . . . . . . .11
Section 3 Selecting Waste Management Methods . . . . . . . . . . .17
Section 4 Minimizing Liability . . . . . . . . . . . . . . . . . . ...21
Section 5 Funding the Program and Controlling Costs . . . . . . . . .25
Section 6 Publishing the Request for Proposals and
Signing the Contract . . . . . . . . . . . . . . . . . . ...31
Section 7 Selecting, Designing, and Operating the
Collection Site . . . . . . . . . . . . . . . . . . . . . ...37
Section 8 Training the Collection Day Staff . . . . . . . . . . . . . .41
Section 9 Education and publicity . . . . . . . . . . . . . . . . ...45
Section 10 Evaluating the Program . . . . . . . . . . . . . . . . ...49
Section 11 Case Studies . . . . . . . . . . . . . . . . . . . . . . ...51
Appendix A Hazardous Waste Laws and Regulations . . . . . . . . . . .58
Appendix B State and Regional Hazardous Waste Contacts . . . . . . .62
Appendix C Information Resources . . . . . . . . . . . . . . . . . ...68
Appendix D Sample Participant Questionnaire . . . . . . . . . . . . . .74
What Is Household once the consumer no longer has any use for
them. The average U.S. household generates
Hazardous Waste? more than 20 pounds of HHW per year. As
Many common household products con- much as 100 pounds can accumulate in the

1
I N T R O D U C T I O N

home, often remaining there until the resi- photographic chemicals, no “safe” substi-
dents move or do an extensive cleanout. tutes exist. So, communities will need effec-
tive HHW management programs for some
Hazardous waste is waste that can catch
time to come.
fire, react, or explode under certain circum-
stances, or that is corrosive or toxic. The
U.S. Environmental Protection Agency Communities Find
(EPA) has set stringent requirements for the
management of hazardous waste generated
Solutions
by industries. Some HHW can pose risks to
HHW programs can benefit communities
people and the environment if it is not used,
in several important ways. They can reduce
stored carfully, and disposed of properly.
However, Congress chose not to regulate it the risks to health and the environment re-
sulting from improper storage and disposal
because regulating every household is sim-
ply too impractical. of HHW. They can reduce communities’
liability for the cleanup of contamination
Government and industry are working to resulting from improper HHW disposal.
develop consumer products with fewer or Finally, HHW programs can increase com-
no hazardous constituents. However, for munity residents’ awareness of the potential
some products, such as car batteries and risks associated with HHW and promote a

ommon Household Hazardous Wast

(These items, and others not included on this list, might contain materials
that are ignitable, corrosive, reactive, or toxic.)
● Drain openers
● Oven cleaners
● W and metal cleaners and polishers
● Automotive oil and fuel additives
● Grease and rust solvents
● Carburetor and fuel injection cleaners
● Air conditioning refrigerants
● Starter fluids
• Paint thinners
• Paint strippers and removers
• Adhesives
• Herbicides
• Insecticides
• Fungicides/wood preservatives
Source: A Survey of Household Hazardous Wastes and Related Collection Programs, Office of
Solid Waste and Emergency Response, U.S. Environmental Protection Agency. EPA/530-86-038.
 I N T R O D U C T I O N

better understanding of waste issues in tions in the United States has grown dramati-
general. cally over the last decade. Since 1980, when
the first HHW collection was held, more
Many communities have established pro-
than 3,000 collection programs have been
grams to manage HHW. The impetus for
documented in all 50 states.
starting a HHW program can come from the
grassroots level, from local or state gover- Although programs vary across the coun-
nment agencies, from community groups, or try, most include both educational and col-
from industry. The number of HHW collec- lection components. Communities usually

PROGRAMS
1 ,000

859
802
800
693

600
484

1990
400
300
273
175

200

0 1980 1981 1982

2 4 8 31 94

1983 1984 1985

YEAR
1986
L
1987
1988
1989 1991

Number of HHW Collection Programs in the United States, 1980-1991.

SourceWaste Watch Center, Andover, Massachusetts, 1991.
N T R O D U C T I O N

begin a HHW program by holding a single- 16 states. In addition, communities have

day drop-off HHW collection. Organizing a initiated pilot programs for curbside pick-up
collection event is an important first step in by appointment, neighborhood curbside col-
reducing and managing risks associated lection programs, and drop-off programs for
with HHW. specific types of HHW.
The efforts of communities across the
Some communities hold annual or semia- country provide a wealth of experience for
nnual collections, while others have estab- other communities beginning HHW manage-
lished permanent HHW collection programs ment programs. As the number of these pro-
with a dedicated facility (open at least once grams continues to grow, public awareness
each month) to provide households with about HHW will also grow, and the environ-
year-round access to information and reposi- mental problems associated with improper
tories for HHW. By 1991,96 permanent storage and disposal of HHW are likely to
HHW collection programs were operating in decrease.
Getting Started

5
G E T T I N G S T A R T E D

lanning for your first HHW collection must begin very early-as long as 6 to 18
P months before a projected HHW collection date. See box for a sample timeline for
planning the HHW collection. In addition, the case studies presented in Section 11
describe how two communities successfully planned HHW collection days.
Define Roles and citizen groups; and representatives from lo-
Responsibilities cal business and industry.

Although one person can be the catalyst The HHW

for beginning a community program, the
success of the program depends on the in- Program Sponsor
volvement of a variety of individuals and
organizations. A key initial step in planning Every community HHW management
the program is identifying who should be program needs a sponsor or co-sponsors.
involved and defining their roles and Usually the sponsor is a government agency,
responsibilities. but some programs are sponsored by a civic
organization or a business. The sponsor’s
The Planning role includes:
Committee Managing and funding all aspects of the
program.
The most important step in beginning a Developing Requests for Proposals
program is enlisting a core group of people (RFPs) and contracts with a licensed
who can assemble the needed resources and hazardous waste contractor.
manage the program. The planning commit- Recruiting, managing, and delegating re-
tee can perform or oversee many different sponsibilities to supporting agencies and
functions, such as: staff.
■
Providing background information. Involving community leaders and resi-
Setting policy and goals. dents in planning and implementing the
Obtaining finding and other resources. program.
Championing the program in the
community. The Hazardous
Supervising a sponsor.
Waste Firm
The process of forming a planning com-
mittee can begin at a meeting of community Most communities contract with a quali-
officials and interested members of the pub- fied hazardous waste firm that handles the
lic where they can discuss instituting a HHW at the collection site and brings it to a
HHW management program. Telephoning hazardous waste treatment storage, and dis-
influential community members and placing posal facility (TSDF). If you hire a hazardous
announcements in the local media can help waste contractor to handle the HHW collec-
boost attendance at the meeting. tion, be sure to choose a firm or firms licensed
If sufficient support for a program exists, to store, transport and dispose of HHW ac-
the people gathered can choose a program cording to federal and state requirements. Haz-
coordinator, form a planning committee and ardous waste contractors might not need to
subcommittees, and begin planning the pro- be fully licensed (see Appendix A) to per-
gram. The planning committee usually in- form the duties your contract requires.
cludes solid waste, health, public safety, and Licensing, however, helps to ensure that the
planning officials; legislators; members of contractor is experienced. The roles of the

6
 G E T T I N G S T A R T E D

contractor are spelled out in the contract and ■ Providing necessary services on collec-
can include: tion day, such as unloading wastes from
Providing necessary materials and vehicles; screening, packaging, testing,
equipment. and labeling wastes; supervising volun-
Properly training its collection staff. teer personnel; and hauling and dispos-
■ Obtaining necessary insurance. ing of the waste.
Consulting with the program planners ■ Complying with all applicable federal,
about waste management methods to be state, and local requirements.
used. ■ Submitting post-collection reports.
■ Identifying appropriate hazardous waste Information on selecting a contractor is
TSDFs. provided in Section 6.

6 to 18 Months before Collection •Identify/order equipment

•Arrange disposal and recycling of
•Establish planning committee
nonhazardous material
•Identify program goals
•Select program sponsor and cosponsors brought in
•Contact environmental regulatory •Continue education and intensify
agencies publicity efforts
•Begin designing education program •Solicit volunteers
•Initiate community outreach •Acquire insurance
•Research laws, regulations, and guidelines •Develop collection day surveys
•Determine collection methods
0 to 6 Weeks before Collection
•Set tentative collection date(s)
•Select potential sites •Receive equipment and supplies
•Initiate public education program •Conduct worker training/safety training
• Determine targeted wastes/excluded •Complete publicity campaign
wastes/generators • Confirm police/emergency service
•Estimate costs involvement
•Secure funding
•Issue Requests for Proposals (RFPs) Collection Day
• to S Months before Collection •Set up site
•Orient community staff and volunteers
•Evaluate RFP submissions
•Complete participant questionnaires
•Interview contractors
● Receive, package, and ship HHW
•Select contractor
•Clean up site
• Identify markets for reusable and
recyclable HHW Post-Collection Day
•Involve emergency services (fire,
police, etc.) •Tabulate survey responses
•Begin publicizing collection program •Evaluate collection/public education
•Obtain permits results
•Publicize results
6 to 12 Weeks before Collection
•Thank participants and volunteers
• Design site layout and draw site plan through the media
•Develop collection day •Write summary report
procedures/written plan •Prepare for future events

7
G E T T I N G S T A R T E D

Developing a sense of community

Involve the ‘ownership”
Community People involved in planning and imple-
menting a project will feel that the program
Community involvement is critical to the
belongs to them. Community ownership
success of a HHW management program.
helps to ensure greater participation on col-
Government agencies, community groups,
lection day as well as community pride
local legislators, businesses, industries, and
about the outcome of the event.
concerned citizens should be involved from
the start. They can promote the HHW pro- Providing community assistance
gram in a number of ways: Volunteer groups and residents often can
contribute expertise or resources and can
Building acceptance for the program share the responsibilities of planning and
If key community leaders participate in implementing the program with
the planning process, they can help build the program sponsor.
community acceptance and support for the
project. In addition, local officials will know
the mood and interests of the community
and can help avoid or overcome
sensitive issues.

8
 G E T T I N G S T A R T E D

Providing leadership on HHW issues might be more stringent than federal hazard-
The more community leaders learn about ous waste management regulations. For ex-
managing and reducing HHW, the more ample, states might require HHW collection
likely they will be to support an ongoing or programs to obtain operating permits. Local
permanent program. Many community lead- governments also might have applicable re-
ers also will alter their buying and disposal quirements, such as zoning laws or building
practices, becoming examples for the com- codes. These issues are discussed in Section
munity. 4 and Appendix A. The sponsor or planning
committee should review current literature,
attend conferences or workshops about man-
Assemble the Facts aging HHW, if possible, and contact the
Members of the planning committee state hazardous waste management agency,
should conduct background research during the EPA regional office, and local agencies
the program’s early planning stages. At least (see Appendix B).
a month or two is needed to acquire the in- It is also important to anticipate the types
formation necessary to plan the program and of wastes to be collected, since different
inform the community. This research can be types of HHW present different transport
conducted by planning committee members, and handling requirements. The type of ac-
who can provide important information in cumulated HHW is strongly influenced by
their own areas of expertise: whether the community is in an urban, sub-
Health department officials can pro- urban, rural, or agricultural area. For exam-
vide technical data (such as material ple, an agricultural area might generate large
safety data sheets) about specific hazard- quantities of pesticides. Pesticides are
ous materials. among the most expensive wastes to dispose
Police and safety officials can provide of. HHW programs in rural or agricultural
procedures for handling materials and areas, therefore, might be more expensive
for preventing and managing accidents than programs in urban or suburban areas.
(such as site selection procedures and Collection programs in environmentally
traffic management). proactive communities usually will have
Legislators and public officials can higher participation and collection rates than
provide relevant regulations and programs in less environmentally active
guidelines. communities.
Public interest groups can provide site
selection considerations, media con-
tacts, informational materials, and proce- Establish Goals
dures for volunteer recruitment. Every HHW management program needs
Businesses can provide information clear, realistic goals and feasible ways of
about sources of funding and material achieving them. Typical program goals
and equipment donations. include:
Educators can provide curricula and
■ Maximizing public participation. By
audiovisual materials. maximizing participation in the HHW
It is essential that the sponsor and the program, the quantity of hazardous ma-
planning committee learn about the federal, terials will be reduced in both the solid
state, and local regulations that apply to waste stream and the wastewater
their HHW management program as well as stream. Greater participation will mean
the steps they can take to minimize liability. higher costs for the community in the
It is important to note that state regulations short run but will help avoid or reduce

9
G E T T I N G S T A R T E D

however, might result in higher labor

costs (e.g., for paint consolidation). In
addition, communities will have to lo-
cate and secure markets for the materials.
■ Removing from homes those wastes
considered most hazardous. Instead of
collecting all wastes, some communities
might want to collect specific wastes
that they consider to present an unac-
ceptable risk or to be a likely source of
environmental contamination, such as
oil-based paint and used motor oil. It
might be difficult, however, to educate
people to bring only those wastes to the
collection. In addition, environmental,
health, and safety problems could
result from uncollected wastes in the
community.
9 Educating the public about reducing
generation of HHW. Some program
sponsors might want to establish a
HHW program to provide information
to consumers about proper HHW man-
agement and alternative ways to reduce
generation of HHW. No matter how ef-
fective education is, however, collection
programs will still be needed for wastes
costs associated with potential environ-
for which there are no alternatives (such
mental cleanups. It will also help to pre-
as car batteries) and for existing HHW
vent or minimize health and safety
stored in homes.
problems associated with improper
HHW storage and handIing in homes. Identifying goals will help collection pro-
maximizing the reuse and recycling gram organizers determine the basic type of
of HHW. By maximizing reuse and re- collection program (e.g., periodic drop-off,
cycling, program sponsors will mini- curbside, or permanent), the amount of fund-
mize their hazardous waste disposal ing needed to collect and manage the wastes
costs and will conserve natural and fi- and to educate the community about the pro-
nancial resources. Collecting products gram, and the waste management practices
such as paint for reuse and recycling, that the program will use.

10
Selecting Wastes
and Collection
Methods
S E L E C T I N G C O L L E C T I O N M E T H O D S

w hen initiating a collection program, the planning committee must decide who
may bring wastes to the collection, what types and quantities of waste will be
accepted, and how the waste will be collected.

Decide W h o Decide What Types

May Bring Wastes Of HHW to Accept
to the Collection
Program The two types of waste received most
often at HHW collections are used motor oil
and paint. Pesticides usually are the third
Most collections are limited to wastes largest category. Programs also receive sig-
generated by individuals at home and ex- nificant numbers of car batteries. Over the
clude hazardous waste from commercial next few years, the types of wastes collected
and institutional generators. This is primar- might begin to change, and the volume of
ily because programs are expensive, aver- certain types of HHW will probably de-
aging $100 per participant. In addition, by crease. For example, the proportion of latex
limiting the number of participants it is paint compared to oil-based paint will prob-
possible to limit the amount of wastes (al- ably increase since sales of oil-based paint
though it also reduces effectiveness). have been decreasing. It will take a long
time, however, to remove stored materials
Some HHW collections, however, are from all the homes in a community. (In San
open to small businesses that are “condi- Bernardino County, California, for example,
tionally exempt small quantity generators” the paint brought to HHW collections is an
(CESQGs) of hazardous waste (see Appen- average of 10 years old.)
dix A). Examples of businesses and institu-
tions that might be considered CESQGs To minimize costs, some programs tar-
under certain circumstances include flo- get only specific recyclable HHW, such as
rists, home repair businesses, gas stations, used oil, car batteries, antifreeze, and latex
and schools. CESQGs often are unaware paint. In addition, HHW collections often
that they produce hazardous waste, and so exclude certain wastes that the contractor
sometimes store and dispose of wastes im- is not licensed to receive or does not have
properly. A HHW program that includes the necessary equipment to identify or han-
these generators can educate them about dle. Certain wastes also might be excluded
environmentally sound ways to manage if the TSDF will not accept them. Fre-
their hazardous waste. Requirements that quently excluded wastes include garbage,
must be followed if a HHW collection pro- asbestos, dioxin-bearing wastes, explo-
gram accepts wastes from these small busi- sives, radioactive such as smoke detec-
nesses are explained in Appendix A. These tors, and unlabeled or unknown wastes.
generators usually are charged based on Most programs also exclude medical
the cost of managing their wastes. The wastes. In New Jersey, however, some pro-
charge for CESQG waste is less than what grams have begun to collect medical waste
generators would pay if they managed the using a hauler licensed to handle such
waste themselves. wastes.

12
 S E L E C T I N G C O L L E C T I O N METHODS

Decide Whether to Limit the Amount Of HHW

Select a Collection
Method
To maximize participation, many commu-
nities are experimenting with a variety of
collection methods. Some use a combination
A few programs limit the amoubt of HHW that each participant may bring to the collectopn. For example, some collections

of collection methods. Common collection

methods include one-day, permanent facil-
ity,downmobile facility, door-to-door pickup,
impose a five-gallon or 50-pound limit per participant, while others limit the size of the containers. This practice holds

curbside, and point-of-purchase. Although

this manual focuses on one-day drop-off pro-
collection-day costs. Limits can also prevent CESQGs or small quanity generators (SQGs) (see AppendixA) from grams, bringing the next section briefly introduces
each of the major types of HHW collection
programs.
wastes to the collection, if that is a goal of the program. In some states, limits on the amount of HHW are set by law. In addition,

One-Day Drop-Off
Most communities begin HHW programs
state permits for one-day collections or program contracts may forbid overnight storage of the hazardous waste. Amounts, therefore,

with one-day, one-site events at which resi-

dents drop off their HHW. The events usu-
might need to be limited so that all wastes can be properly packaged before the end of the day.
ally are scheduled in the spring or fall;
participation during other seasons is limited
by summer vacations and winter weather in
much of the country. One-day drop-off col-
Programs accepting waste from small businesses (CESQGs only) might limit amount acepted ro charge a participation

lections typically are held on Saturday, with-

out appointments, starting in the morning
and ending in the afternoon.
fee so that the program will not be overwhelmed by disposal costs. Allowing dropoff "by appointment only" will prevent the

A potential limitation of drop-off pro-

grams is finding a date for the collection on
collection site from being overwhelmed by too many CESQGs.
which the hazardous waste contractor will

13
S E L E C T I N G C O L L E C T I O N METHODS

be available. It is important to confirm the Training local staff to perform many of

date with the contractor as early as possible the responsibilities usually assumed by
(six months in advance is recommended), es- the hazardous waste contractor atone-
pecially if HHW collections are scheduled day collections.
■
on the weekend. Weekend HHW collections An institutionalized, predictable funding
in the spring and fall are very popular, and source.
■
these dates fill up quickly. Compliance with additional state and lo-
Another potential limitation of one-day cal regulatory requirements that might
programs is that the chosen day might not apply to permanent programs.
be convenient for some residents. To ad- Permanent programs require a larger up-
dress this concern, some communities hold front investment than one-day collections,
drop-off collections on more than one day— but they probably will reduce costs per par-
for example, a Saturday and Sunday-or on ticipant for the community in the long run.
two successive weekends. The selected For example, communities generally use
HHW collection date(s) should not conflict their own employees instead of contractors,
with other major events in the community. often resulting in lower costs.
Holding collections in more than one loca-
tion within the community also can increase Drop-Off at a
participation.
Mobile Facility
Still another potential limitation is that
participants sometimes must wait an hour or Most surveys show that the average col-
more to drop off their wastes. Organizers of lection day participant travels five miles or
drop-off collection events need to plan ways less to the site. Sponsors can purchase a mo-
to avoid long waits. Strategies for reducing bile facility and equipment to provide peri-
waiting time include using express lanes for odic collections on a regular schedule at
certain wastes (see Section 7), holding the different sites within a county or large com-
collection in several different locations, munity. This is an effective method for pro-
holding the collection over several days, and viding service to geographically large and
implementing a two-phase program (for ex- diverse regions. Like permanent programs,
ample, accepting paint and oil one day and these mobile collection programs might cost
other wastes the next). more than one-day programs in the begin-
ning, but they probably will reduce costs per
Permanent Drop-Off participant over the long term.

If the limitations of one-day collections Door-to-Door Pickup

prove too great, a community might want to
consider instituting a permanent drop-off Door-to-door pickup by appointment is
program. The community must anticipate a expensive, but it is more convenient for par-
number of needs that accompany permanent ticipants than drop-off. The personnel who
drop-off programs, including: collect materials must be trained in handling
Managing the increased annual quantity hazardous waste, including how to pack and
of HHW and increased participation separate the waste in the collection vehicle.
rates. It also allows participation by housebound
■ Ongoing public education and publicity. individuals and others who cannot travel to
■ A facility for onsite storage of HHW. a collection site. Sometimes the programs

14
 S E L E C T I N G C O L L E C T I O N M E T H O D S

are offeredto certain individuals in addition because leaving highly toxic or incompat-
to the one-day event. ible wastes at the curb can be dangerous,
and because collecting and transporting
a variety of hazardous materials in residen-
Curbside Collection tial neighborhoods presents logistical
difficulties.
Curbside programs usually are limited to
a few selected wastes collected from house- The most common type of waste
holds on a regularly scheduled basis. Restric- collected at curbside is used oil. More than
tions on the types of waste are necessary 115 communities have set up programs to
S E L E C T I N G C O L L E C T I O N M E T H O D S

collect recyclable used oil at curbside. Other In addition, several states require that cer-
communities collect household batteries and tain retailers take back some types of HHW.
paint at curbside. In Massachusetts and New York, for exam-
ple, retailers must take back automobile bat-
teries and used motor oil. Regulations in
Point of Purchase Connecticut, Minnesota, and Oregon ban
In some immunities, a few types of car batteries and used oil from landfills
HHW can be returned to retail stores. and/or require deposits and retailer redemp-
community HHW program planners can tion.
publicize these point-of-purchase programs Regulations regarding proofs of pur-
as part of an overall HHW management chase, deposits, and surcharges for returns
strategy. are different in each state. Massachusetts
Retailers have implemented some point- used oil law, for example, requires proof of
of-purchase programs voluntarily. in New purchase. Auto battery regulations usually
Hampshire andVermont for example, some require retailers to post a notice informing
hardware and jewelry stores collect custom- customers that they may return their batter-
ers’ spent household batteries in buckets or ies and stating how many may be returned at
specially designed cardboard boxes. one time.

16
Se ecting Waste
anagement
Methods

17
S E L E C T I N G M A N A G E M E N T M E T H O D S

n designing a collection program, it is important to determine what will happen to the

wastes that are collected. When selecting among various waste management options,
HHW program planners should try to recycle or offer for use as much of the collected
wastes as possible. The HHW that cannot be recycled or used should be managed as a hazardo-
us waste. If the communities use contractor services to manage some or all of this HHW,
waste management priorities and procedures should be communicated clearly to the hazard-
ous waste contractor.

In addition, it is essential that the pro- schools. Experience shows that paint
gram planners investigate the soundness of exchanges can reduce the amount of paint
any facility where the waste will end up- being disposed of at HHW collections by as
1
particularly if CESQG waste is accepted much as 90 percent.
(see Appendix A). The planners should ask
potential contractors about the methods they
will use to manage the wastes, and they
should also ask for copies of the permits for
the hazardous waste facilities that are to be EPA recently prohibited mercury in indoor latex paint. Latex paint
used. Planners can also contact the state haz- exchange programs and disposal, however, still must be carefully
ardous waste agency (see Appendix B) to managed.
find out if a facility is properly permitted. Interior latex paint manufactured before August 20,1990, might
contain mercury. For this reason, all latex paint in a paint exchange or
“drop-and-swap” program should be assumed to contain mercury
Reduce through Use and labeled “FOR EXTERIOR USE ONLY.” Using interior paint
Reusing materials brought to HHW col- outside will substantially reduce the risk from exposure to mercury.
lections can reduce the amount of HHW that Interior paint used outside, however, might not hold up as well as
the contractor must manage, often signifi- paint originally manufactured for exterior use. Alternatively, interior
cantly lowering program costs. Some com- latex paint may be swapped for interior use if mercury levels of less
munities have set up waste exchanges to than 200 parts per million (ppm) can be confirmed. This can be done
make materials available for other partici- in several ways
pants’ use. These exchanges can take place A commercial laboratory can test the paint for mercury.
at a HHW drop-off site or through The National Pesticides Telecommunications Network
telephone/hotline referrals. For example, (800-858-7378) provides names of paint brands that contain less
reusable paint can be placed on “drop-and- than 200 ppm of mercury.
swap” tables for collection program partici-
The date of manufacture might appear on the label; no interior
pants to pick up, or it can be bulked and
latex paint manufactured after August 20, 1990, contains
blended for use by people or institutions
mercury. No paint manufactured after September 30, 1991, may
who request the paint. This “second-hand”
contain mercury.
paint is readily accepted by the public, com-
munity groups, religious and recreational Usable latex paint can be consolidated and then might or might
centers, graffiti removal programs, and not be reprocessed. The consolidated paint should be tested for
mercury. If it contains more than 200 ppm, it must be labeled “FOR
EXTERIOR USE ONLY.”
Duxbury, Dana and Philip Morley. 1990. Overview of
1

collection&management methods. Proc. of the Fifth

Unusable latex paint (such as paint that is frozen or solidfied) that
National Conference on Household Hazardous waste contains more than 200 ppm of mercury should be managed as
Managements, November 5-7, 1990, San Francisco,
hazardous waste.
California, pp. 251-274.

18
 S E L E C T I N G M A N A G E M E N T M E T H O D S

Other materials suitable for reuse can save money because they often are staffed
include unwanted pesticides, cleaning prod- by the sponsor. Communities that send
ucts, and automotive products. These materi- HHW off site for recycling should contact
als often can be used by the sponsoring their state environmental regulatory agen-
municipality for its buildings and vehicles. cies to identify recyclers and to verify that
Communities should offer products only if the recycler is reputable (see Appendix B
they are in the original container and the la- for a list of state regulatory agencies).
bel is intact and legible. They should not of-
fer products if the container is banned, The results of the State of Florida’s
leaking, rusting, or otherwise damaged. “Amnesty Days” show the great potential
Products should not be repackaged for reuse. for recycling HHW received at one-day

Recycling Recycling Used Oil:

A significant percentage of HHW can be ject ROSE
recycled. For example, used oil can be
rerefined for use as a lubricant. It also can
For over 14 years, a trailblazing
be reprocessed for burning as a supplemen-
program in Alabama has worked to
tal fuel (as can oil-based paint and ignitable
stimulate the collection of used
liquids). EPA has issued several publications
automobile oil for recycling. Project ROSE
to help communities safely collect and recy-
(Recycled Oil Saves Energy) has taken the
cle used oil (see Appendix C, Project
lead in helping communities across the
ROSE).
state develop used oil recycling programs
Other recyclable HHW includes: tailored to local circumstances.
Antifreeze. Project ROSE has built an extensive
Latex paint. (Up to 50 percent of latex infrastructure for recycling used
paint can be recycled by filtering, bulk- automobile oil generated by people who
ing, and blending it for reuse.) change their own oil (do-it-yourselfers)
Lead acid batteries. Lead used in dental throughout Alabama. Because much of
x-rays. Alabama is rural, collection centers, in
Mercury-oxide, mercury-silver, silver- the form of service stations, are the most
oxide, and nickel-cadmium household widely used system. In addition, several
batteries. Several firms in the United larger cities provide curbside collection of
States take these batteries for a fee; the used oil.
contractor can be required in the con-
The program uses publicity and
tract to investigate the option of ship-
education to develop the momentum to
ping used batteries to one of these firms
start local used oil recycling programs and
for recycling.
then coordinates the effort of
Fluorescent light bulbs.
established networks by matching buyers
Some communities sponsor “recyclables- of used oil with collectors. This strategy
only” days to divert the large-volume materi- relies heavily on recruiting leaders from
als (motor oil, car batteries, and latex paint) local organizations, who then work with
from HHW collections and to reduce the Project ROSE to help introduce and
amount of waste that the contractor has to re- support recycling programs in their area.
ceive, package, and process. Recycling days

19
S E L E C T I N G M A N A G E M E N T M E T H O D S

collections. Thirty-six percent of the HHW Procedures for

collected at 107 Amnesty Days (984,655
pounds out of a total of 2.7 million pounds) Excluded Wastes
was recycled over a two-year period. The re-
HHW program planners and contractors
cycled material consisted of used oil, car bat- often exclude certain wastes from collection
teries, and latex paint. programs. Frequently excluded wastes in-
clue radioactive materials, explosives,
banned pesticides, and compressed gas
Treatment cylinders. Program organizers must let par-
Treatment technologies reduce the vol- ticipants know which wastes will not be ac-
ume and/or toxicity of HHW after it is gener- cepted and must give them other options
ated. These technologies include chemical, and instructions for managing the excluded
physical, biological, and thermal treatment. wastes. For example, the police usually will
Common treatment procedures are neutrali- arrange for pickup of explosives. Smoke de-
zation of acids and bases, distillation of sol- tectors, which often contain a minute quan-
vents, and incineration. The methods are tity of radioactive material, are accepted by
dictated by the types of waste, proximity to some manufacturers (see product labeling
treatment facilities, cost, and the contrac- for instructions). If participants are not pro-
tor’s access to treatment facilities. However, vided with alternative management options,
the contract can specify the waste manage- they often discard these wastes in the near-
ment methods to be used. If the waste is sent est trash can.
off site for treatment, the contractor should
provide the sponsor with documentation
verifying the waste’s final destination.
Information is available through EPA-sponsored environmental
outreach programs
Landfill
Informational materials on recycling reuse, disposal, and
As a result of current and pending bans collection program design are available through: RCRA
on land disposal of certain hazardous wastes Hotline 800424-9346; the Waste Watch Center
and the efforts of communities to reduce the 508470-3044 and the Solid Waste Information
amount of HHW sent to municipal solid Clearinghouse 800-67SWICH.
waste landfills, more HHW is being reused, With EPA support the International City Managers
recycled or treated. As with waste destined Association (202-962-3672) and the Solid Waste Association
for offsite treatment the hazardous waste of North America (301-585-2898) provide technical
hauler should provide the sponsor with assistance to communities and other nonprofit groups
manifests, state-approved shipping docu- through a peer matching program. This program provides
ments, or similar documentation verifying direct, hands advice and assistance on a peer-to-peer
the waste’s final destination and showing
basis (e.g., mayor-to-mayor).
that the hazardous waste landfill is properly
permitted.

20
Minimizing Liability

21
M I N I M I Z I N G L I A B I L I T Y

C ommunities can be liable for an injury to a collection day worker, an accidental re-
lease of HHW to the environment at the site, or an accident during the transportation
of HHW from the collection site to the disposal site. The following recommendations
can help communities minimize potential liability.

requirements that are more stringent than

Become Familiar those set by the federal government.
With National,
State, and Local In addition, program planners should be
familiar with regulations governing manage-
Hazardous Waste ment of specific wastes. For example, con-
Regulations solidated oil-based paint must be tested for
polychlorinated biphenyls (PCBs) before it
Planners of community HHW is sent to a supplemental fuel-burning facil-
programs must know the laws that govern ity. Paint that contains more than 50 parts
their collection activities. Planners also per million of PCBs must be sent to an incin-
should be aware that their state might have erator permitted to burn PCBs under the

22
 M I N I M I Z I N G L I A B I L I T Y

Toxic Substance Control Act. Latex paint

Make Training and
usual] y is not considered a hazardous waste.
Several states recommend treating it as a Public Education a
hazardous waste, however, because of the High Priority
levels of heavy metals found in some brands Proper training of the sponsor’s in-house
and formulations. staff and volunteers is essential for minimiz-
While hazardous waste regulations might ing potential problems on collection day.
seem complex at first, program planners Section 8 discusses training requirements in
should remember that there is potential li- greater detail. Public education and public-
ability associated with taking no action at all ity also can help ensure a safe operation.
to manage HHW. By complying with the re- Publicity should inform participants about
quirements set out in federal, state, and local how to safely package their HHW and trans-
laws, communities can reduce their overall port it to the collection site. For example,
liability. Appendix A summarizes the federal participants should be instructed not to trans-
requirements that apply to HHW programs. port HHW within the passenger compartm-
ents of their vehicles.

Develop a Safety Plan Obtain the

Well in advance of collection day, the Necessary Insurance
sponsor (or contractor) should develop a The sponsor should ensure that the
safety, accident prevention, and contingency program has adequate insurance to cover
plan. Hazardous waste management firms general, employee, transportation, and envi-
experienced in servicing HHW collections ronmental liability, Some communities will
can provide a sample plan. The plan should choose to self-insure for any HHW collec-
include steps for preventing spills, a contin- tion liability, especially when a contractor
gency plan in the event of a spill or acci- has most of the responsibility. The minimum
dent and a list of the health and safety insurance required includes:
equipment available on site. The plan also
General Liability Insurance. Contrac-
should specify when an evacuation would
tors managing all collection site opera-
be necessary, the evacuation routes and
tions and activities usually provide $1
methods, and who would be in charge of an
million to $2 million of general liability
evacuation. For example, primary emer-
insurance for damage to property or for
gency authority should be designated to a
bodily harm at the collection site caused
specific police and fire department if more
by actions of the contractor’s staff. This
than one department has jurisdiction. Police
coverage does not apply to property
and fire departments should be involved in
damage or bodily harm caused by the
the planning and provided with the layout of
sponsor’s staff or volunteers.
the collection site, information about the
Motor Vehicle Insurance The contrac-
wastes that will be handled, and possible
tor needs insurance to coverall drivers
evacuation routes.
and vehicles transporting the collected
A copy of the safety plan should be avail- waste.
able at the collection program. One person In-Transit Insurance. In-transit insur-
should be designated to control any emerg- ance is required by the Department of
ency operation. Transportation for interstate movement

23
M I N I MIZI NG L I A B I L I T Y

of hazardous materials or waste. The A “bid bond” to cover the sponsor for
contractor’s coverage, up to $5 million, time and expenses for the bid period in
will vary according to the types of mate- the event that a contractor turns down
rials transported. This insurance covers the contract after it is awarded.
environmental restoration of property or A “performance bond” to ensure satis-
compensation for bodly harm. factory performance and, if necessary,
■ Indemnification Clause. The contract cover the costs of completing the pro-
with the hazardous waste firm should in- ject according to the contract.
clude an indemnification clause stating A “certificate of insurance” from
that the sponsor is blameless in the the contractor’s insurance company,
event of contractor negligence, acts of and a clause in the contract requiring
omission or wrongdoing. Similarly, the that the sponsor be given notice in the
contractor can request indemnification event of cancellation of the contractor’s
by the sponsor for any costs incurred by policy.
the sponsor’s negligence.
■ Workers’ Compensation Insurance
The sponsor should obtain coverage for In addition, the sponsor should ask to see
any staff or volunteers working at the a copy of the TSDF’s environmental impair-
collection day who are not provided by ment liability insurance. These facilities
the contractor. need this insurance to cover lialility under
the Resource Conservation and Recovery
The sponsor also can require additional Act (RCRA), the federal law covering haz-
protection from the contractor to help mini- ardous waste management. The insurance is
mize liability, including: not available to HHW collection programs.
F U N D I N G T H E P R O G R A M

nticipating and reducing costs of a HHW program, as well as locating funding

A sources, are major concerns for program planners. However, many communities
have found creative ways to finance their programs and effective ways to cut costs.

HHW program costs generally increase on recycling and reuse for waste manage-
as the amount of waste collected increases. ment will greatly reduce the cost.
It is important to keep in mind, however,
that the potential consequences of mismana- Participation
ged HHW-soil and ground-water contami-
nation, hazardous emissions at landfills, On average, each participant brings 50 to
worker injury and equipment damage, inter- 100 pounds of HHW to a collection, at a
rupted water treatment, and contaminated ef- cost to the sponsor ranging from $50 to
fluent at water treatment plants-can result slightly more than $100 per participant.
in much greater costs. Participation rates usually range from one to
three percent of eligible households and can
be as high as 10 percent. Suburban commu-
nities, especially those with a hazardous
Factors that Affect waste problem or a solid or hazardous waste
costs facility, experience high rates of participa-
tion. Extensive education or publicity pro-
A review of the data on approximately grams also can increase participation rates.
3,000 collection programs held since 1980
indicates that costs for a one-day HHW Waste Management
collection range from as little as $10,000
to more than $100,000. The final cost of a
Methods
HHW collection is difficult to predict be- Waste management costs are the largest
cause many variables cannot be estimated item in the HHW program budget. The over-
or controlled easily. These variables in- all waste management costs will depend on
clude the number of households that par- the types of waste collected and the waste
ticipate, the types and amount of waste management methods that are used. For ex-
collected, and the waste management ample, programs that accept only recyclable
methods used. Major urban multi-site materials or provide a “drop-and-swap” area
collection events, targeted farm pesticide will experience much lower waste manage-
collections, and collections in communi- ment costs and lower personnel costs as
ties located a long distance from hazard- well. Reusing or recycling HHW or burning
ous waste disposal facilities will it as a supplemental fuel is less expensive
experience higher costs. See box for devel- than incinerating the waste at a hazardous
oping a rough cost estimate for a one-day waste facility. Pesticides, especially those
HHW collection. This formula is based on containing dioxin, and solvent paints and
1991 estimates of disposal costs. These other materials containing PCBs can be very
estimates might need to be adjusted if expensive to manage ($850 per 55-gallon
waste management costs change. This drum in 1991). Burning used oil and solvent-
formula is based on much of the work be- based paint as supplemental fuel typically
ing done by a contractor. Programs that costs the sponsor $175 to $250 in manage-
use less contractor help and that rely more ment fees. In 1991, the cost of sending most

26
Funding the
Program and
Controlling Costs

25
 F U N D I N G T H E P R O G R A M

other wastes to a hazardous waste incinerator

Collection Methods
or land disposal facility ranged from $350 to
$500 per drum. These costs can vary and
might increase over time; the hazardous waste The program’s collection method also
contractor or appropriate state agency can pro- affects the overall cost. For example, col-
vide current rate schedules. lecting HHW door-to-door is more expen-
sive than holding a drop-off collection
Other factors will affect waste manage- day. Permanent programs might be more
ment costs as well. For example, contractors cost effective than one-day collections.
who own and operate their own TSDFs or The number of participants might increase
have access to facilities close to the collec- with a permanent program; however, in a
tion site might be able to charge less for a permanent program, there are often more
collection than other contractors. Communi- opportunities to arrange for recycling or
ties that are located closer to hazardous reuse of collected materials, resulting in
waste management facilities also might less waste per participant to be disposed of
benefit from lower costs. as hazardous waste.

Estimating Costs
.
There are no proven formulas for estimating cost fora one -day HHW collection.
Below is a formula for a very rough cost estimate range:

.01 H (low participation) x $350 + $5,000=$

(low estimate)
8 (consolidation)

.03H (high participation) x $350 +$5,000=$

(high estimate)
4 (no consolidation)

H is the number of households in the target area.

The formula produces a range, reflecting a participation rate from one to
three percent of the targeted households.
If oil and paint are to be consolidated, divide the number of expected
participants by eight, as shown in the equation, to calculate the number of
55-gallon drums. (It generally takes seven or eight households to fill a
55-gallon drum of waste.) If no wastes are consolidated, divide by four, as
shown in the equation.
$350 is the average cost of treatment/disposal per 55-gallon drum.
Add $5,000 for set-up and personnel costs.
Local staff time, publicity, and education are additional but are usually not a major
cost item for one-day collection programs.
Note: Dollar figures above are 19% estimates.

27
F U N D I N G T H E P R O G R A M

Ways To Minimize State and Local

Costs Governments
program sponsors continue to find ways The majority of funding for local govern-
to reduce both overall costs and the average ment programs comes form municipal solid
cost per participant. For example: waste budgets. In addition, county and local
Consolidating instead of lab-packing agencies that benefit from HHW collection
HHW reduces costs by allowing for days often contribute a portion of their budg-
much more waste per drum. (A lab-pack ets to HHW management programs. Among
consists of a large container that holds the agencies that benefit from HHW collec-
several smaller containers.) Paint used tions are water and sewer departments, since
oil, and antifreeze are frequently less HHW is poured down drains; fire and
consolidated. health departments, since less HHW is
Some programs reduce costs by using stored in homes; and public works &part-
volunteers (only for low hazard items) ments, since less HHW is discarded with
or city or county personnel to receive, municipal trash. Some state environmental
consolidate, and package the waste, agencies, such as departments of natural re-
rather than using contractor staff for sources or the environment also provide
these functions. funds for HHW management programs.
The sale of some recyclable items, such Sources of state funding have included state
as silver-oxide button and lead-acid bat- Superfund budgets, oil overcharge funds,
teries, can help defray a program’s costs. surcharges on environmental services or haz-
ardous products, and special environmental
Of course, one of the best cost-cutting
bond issues and trust funds.
measures is to educate the public about how
to reduce HHW generation and how to mana-
ge existing HHW without bringing it to a Fees and Taxes
collection center. For example, consumers
can bring used Oil and antifreeze to some Many communities increase landfill tip-
service stations. In addition, wastewater ping fees, property taxes, or water/sewer
treatment plants in some communities take fees to create a fund for managing HHW.
used oil to discourage improper disposal of Some communities also have imposed user
this waste and prevent damage to the treat- fees, but these might be a deterrent to partici-
ment plant. Generally, car batteries can be pation in the collection program, since
returned to the point of purchase. household residents in most states legally
can throw HHW in their trash.
Some states have instituted specific taxes
Obtaining Funding for HHW programs. For example, the State
HHW management program sponsors of Washington has imposed a tax on the first
have obtained funding from a wide variety use of certain chemicals by manufacturers
of sources. They have used state, county, or wholesalers. The tax will be used in part,
and local general funds; taxes, fees, and pen- to fired county HHW collections. Retailers
alties; “in-kind” contributions from industry, in Iowa selling prducts covered under the
cities, and districts; and the help of shelf labeling law pay a $25 registration fee.
volunteers. In New Hampshire, a tax on hazardous

28
 F U N D I N G T H E P R O G R A M

waste generators funds matching grants to Cities counties, civic groups, environ-
communities for HHW collection programs. mental organizations, and corpora-
In Florida, local governments receive three tions often provide seed money or
percent of the gross receipts from permitted matching grants for collections.
waste management facilities. ■ Hazardous waste contractors some-
times donate collection and transporta-
tion services.
Local industries or businesses that pro-
Contributions, duce or distribute household products
In-Kind Donations, that can become HHW sometimes con-
And Volunteers tribute money or services to HHW man-
agement programs because they
Donations of money, materials, and labor recognize the importance of product
are the lifeblood of many community HHW stewardship. In some communities, lo-
programs. These donations can come from cal printers have donated services for ad-
many different sources: vertising or education materials.

In late 1986, the Seattle Metrocenter Young Men’s Christian Association (YMCA)
(see Appendix C for address), the community development branch of the Greater
Seattle YMCA launched an impressive campaign to sponsor and fund a HHW
collection day in King County, Washington.
Metrocenter decided to seek the help of outside catalysts to develop a HHW
collection program. Ultimately 15 cities, King County, and several other public
authorities and agencies joined together to sponsor a series of major HHW
“roundups” between 1987 and 1989.
Fourteen different local and regional government agencies provided funding for the
roundups. Additional financial support was provided by:

. A cigarette tax.
. Revenue from a Department of Ecology tax on hazardous materials sold within
the state.
. A water quality fund, a county solid waste fund, and the general funds of cities.
. In-kind contributions from cities, districts, and corporations.

Metacenter also made extensive use of volunteers to stretch its resources for the
“roundups.” For example, chemistry graduate students performed some of the
actual site work.

29
F U N D I N G T H E P R O G R A M

■ Civic and environmental organizations Programs can attract direct financial

can provide volunteers to help plan, publi- contributions, in-kind donations, and vol-
cize, or staff the HHW collection. Volun- unteer services by giving donors positive
teers can be used to direct traffic, hand out recognition, such as a mention in flyers,
literature, fill out questionnaires, and han- an award, or a recognition ceremony. A
dle nonhazardous waste. publicly acknowledged donation from one
State and municipal agency staff and
group or company often encourages others
local fire and police departments often to contribute or participate in some other
provide supervision and traffic control. way.

30
 Publishing the
Request for
Proposals and
Signing the Contract

31
357-4450 -93- 3:QL3
R F P s A N D C O N T R A C T S

f a contractor is to be used to do some or all of the collection work, the HHW collection
program probably will issue a Request for Proposal (RFP). An RFP will solicit informa-
I tion on which contractors are available and qualified to manage a HHW collection pro-
gram, and the amount they will charge. Most local governments have specific procedures for
issuing RFPs. A contractor should be selected based on the proposals received in response to
the RFP, and a formal contract between the sponsor and contractor must be signed. This proc-
ess ensures that the community is provided with all the necessary services at a reasonable
cost, and that the roles of everyone involved in the collection event are clearly defined. This is
the only way to ensure proper management of the waste.
● unloading HHW from participants’
Issue the RFP vehicles (for a drop-off collection).
A good RFP provides a comprehensive ● pre-screening waste.
description of the services to be provided so
that prospective contractors can bid on the ● sorting, segregating, and packaging
cost of delivering those services. The more waste.
specific and clear the RFP, the better the ● testing unknown wastes.
chances of obtaining complete proposals ● labeling wastes.
and realistic bids.
● combining materials for reuse (e.g.,
An RFP can include the following paint consolidation).
information: ● filling out hazardous waste forms
A detailed narrative description of the (manifests).
sponsor’s goals for the program. ● obtaining a temporary EPA identifica-
The proposed collection site(s) and
tion number, if necessary (see Appen-
date(s).
dix A).
The size of the targeted population and
types of generators (e.g., households, ● controlling traffic.
farmers, and/or schools). ● hauling and disposing of the waste.
The size and relevant characteristics,
Post-collection reports to be submitted.
such as community demographics, of
The materials and equipment to be pro-
the targeted geographic area.
vided by the contractor (see box).
The percentage of the targeted popula-
The waste management preferences of
tion within five miles of the selected site.
the sponsor, including the wastes that
Copies of the completed manifests.
the sponsor wants recycled.
The extent and focus of planned educa-
The ultimate destination for each waste
tion and publicity (to help estimate par-
(when the sponsor has preferences).
ticipation rates).
Proof of insurance.
The targeted waste categories.
An “escape clause” to ensure that the
The type of collection (drop-off, curb-
sponsor reserves the right to reject all
side, etc.)
bids or to modify the plan.
Any specific waste handling require-
costs.
ments.
Use of volunteers and in-house staff and The RFP can be advertised in the local
the tasks they will perform. press (this might be required by local
Training required for HHW handlers. ordinance) and in waste management trade
All services required of the contractor, journals. It also can be sent to the contrac-
potentially including: tors on “bid lists” (lists of qualified

32
I

R F P s A N D C O N T R A C T S

contractors are available from state, local, contractor’s qualifications and experi-
and EPA regional offices). ence. It also should include a list of ref-
erences from any previous HHW
collection programs handled by the con-
Select the Contractor tractor. (The sponsor should carefully
The program sponsor should base the se- check these references.)
lection of the contractor on the following in-
formation requested in the RFP and supplied
in the proposal: Equipment
■ Contractor’s license. The contractor
must be licensed to handle hazardous The equipment needed at the
waste in the state where the HHW col- collection day is supplied by either the
lection will be held. contractor or the collection program
■ Contractor’s HHW experience and sponsor. It usually includes:
references. The proposal should include Waste management/disposal
a narrative section describing the equipment: Awning or tent (if
needed for shelter), drums,
absorbent for spills, shipping
manifests, labels, testing equipment,
and a dumpster.
Safety equipment: Plastic
ground covering, safety
coveralls/Tyvek suits, aprons,
goggles, splash shields, gloves,
respirators, traffic safety/refIector
vests, eye wash hoses, fire
extinguishers, first-aid kits, towels,
blankets, washtubs for scrubbing
contaminated clothing, and air
monitoring instruments
(recommended for monitoring
explosive vapor and organic vapor
levels).
Traffic control equipment:
Traffic cones, barriers, and signs.
Furniture: Tables, benches,
stools, and chairs.
Other equipment: Portable
bathroom (if needed), portable
water (if needed), food, dollies,
dumpster for garbage, stapler, tape,
markers, scissors, hammers,
clipboards, coolers with ice, coffee
maker, shovels, brooms, and
garbage bags.

33
R F P s A N D C O N T R A C T S

■ Compliance record. (State and environ- proposal. (If the RFP contains a model
mental regulatory agencies also can pro- contract, the contractor can accept it or
vide the regulatory compliance/violation modify it as necessary.)
records of contractors.) How recyclable materials, such as
■ Insurance/indemnification provided used oil, batteries, paint and anti-
by the contractor. A list of insurance freeze, will be managed. This should
carriers and policy numbers should be specify any offsite recycling facilities
included. that will process these materials.
■ Waste management services offered The number and level of training of
and the immediate and ultimate desti- personnel proposed for the collection.
nation of the collected waste. A con- Highly trained personnel are more ex-
tractor might own waste management pensive and are not always needed. (For
facilities or might contract inde- example, they might not be necessary at
pendently with incinerators, landfills, a recyclables-only event or a paint drop-
treatment facilities, and recycling firms. and-swap.)
The sponsor should confirm the relation- A health and safety plan. The proposal
ship of the contractor with any treat- should include a safety, accident preven-
ment and/or disposal facilities to be tion, and contingency plan. (The spon-
used. The sponsor also should receive sor also might need to be involved in
copies of manifests or other shipping ensuring the availability and coordina-
documents confirming the receipt of the tion of emergency services.)
wastes at the facilities identified by the Cost per drum, per product, or per
contractor. unit of waste. It also must be clear how
■ Contractor costs. The proposal should much waste will be placed in each drum
include itemized costs for site set-up, la- or container.
bor, equipment materials, hazardous
waste training, transportation, and Write the Contract
disposal.
■ Available collection dates. Fall and Once a contractor is selected, the sponsor
spring weekends are especially busy. and contractor sign a formal contract agree-
The contractor should have enough ing to the services the contractor will pro-
equipment and personnel to operate at vide and the compensation the contractor
the times the sponsor selects. will receive. The contract usually is based
A list of wastes not accepted by the on the contract in the original RFP or the
contractor. If a community expects one supplied in the proposal. It usually is a
large quantities of unusual wastes, this lengthy document, containing addenda with
might be a consideration in choosing the copies of insurance policies and rate and per-
contractor. sonnel schedules. It should include the fol-
■ A list of wastes that will be consoli- lowing clauses:
dated and those that will be lab- ■ The names and addresses of all the par-
packed in original containers. ties to the contract.
Consolidation of high-volume wastes The specific role and status of each
can result in significantly reduced costs party, and the terms and conditions un-
to the sponsor. der which each operates.
■ A sample Contract The contractor usu- A full description of the services to be
ally provides a sample contract with the performed.

34
 R F P s A N D C O N T R A C T S

The time, place, and duration of the ■ Any insurance and liability guarantees
work. and requirements.
The fee schedules for all thework to be ■ The procedure for amending provisions
done. of the contract.
Submission of proof (manifests) of de- The contractor’s guarantee of compli-
livery of all wastes prior to payment to ance with any applicable laws.
the contractor.
The default guarantees and assurance
and bond provisions for the quality
and completeness of the work to be
performed.

35
R F P s A N D C O N T R A C T S

■ The data the contractor will provide to have current model contracts that cover all
assist in evaluating the program. federal and state requirements. The indemni-
■ A “savings” clause that protects the re- fication and insurance clauses usually cause
mainder of the contract should any part the most difficulty. The contract should indi-
of it be deemed illegal or inappropriate. cate clearly which liabilities and hazards are
covered and to whom the indemnification
As with the RFP, the more specific, com- and insurance clauses apply (e.g., contrac-
plete, and clear a contract is, the less the con- tors, haulers, municipality and individual
tractor will have to assume and the more departments, or volunteers). The sponsor’s
satisfactory the results will be. State hazard- legal advisors should review the contract
ous waste contacts (see Appendix B) usually before it is signed.

36
Selecting, Designing,
and Operating the
Collection Site

37
 S I T E C O N S I D E R A T I O N S

roper site selection, design, and operation are crucial in promoting maximum participa-

P tion in the HHW collection and subsequent collections. An easily accessible, effi-
ciently run site will help ensure positive experiences on collection day, which can
result in favorable publicity for the next event.

Site Selection environmental risks. Onsite utilities should

include running water, fire hydrants, and
The site chosen for the collection electric hookups (or generators) in case
should be well known, centrally located, lights are needed to pack and label the
and easily accessible. It also should be HHW after dark.
well removed from residences, parks Collection sites typically are located on
where children play, and environmentally publicly owned land, such as stadium park-
sensitive areas, such as open bodies of ing lots, solid waste landfills or transfer sta-
water, wells, faults, and wetlands. Local tions, schools, fire stations, and public
zoning regulations might specify required works yards. A wastewater treatment plant
setbacks and buffer zones and might iden- is a good collection site because it also
tify acceptable or restricted areas. Using offers the opportunity to educate the public
sites with an impermeable surface (e.g., about water pollution problems caused by
pavement or concrete) helps to minimize improperly managed HHW.

Simple site plan for a one-day drop-off HHW collection program.

38
 S I T E C O N S I D E R A T I O N S

Site Design and The simple plan shown in Figure 1 might

not be adequate for all programs, however.
Operation Depending on the design and goals of the
A well-designed and well-operated HHW program, a more complex layout might be
collection site allows participants to move required, such as the layout shown in Figure
through the collection area quickly and effi- 2. Described below is a commonly used sys-
ciently. It includes areas for people who re- tem for designing the site layout. There are
quire special attention, and adequate space many other ways an effficient collection can
for waiting lines. It also has staff on hand to be achieved.
direct traffic, offer informational materials,
and answer questions.
The size of the site is critical to the effi-
Entrance
ciency of the program; sponsors should plan Collection staff or volunteers should
for traffic overflow. The site should beat stand at the entrance or check-in station to
least 10,000 square feet. greet the participants and direct them to the
Figure 1 shows one example of a site plan receiving area. Police officers or volunteer
for a one-day drop-off collection program. personnel should be stationed just outside

Shower Rest Rooms Safety Gear Check-Out Fork Lift

Break Area Kitchen Drum storage

Waste Management Company's Semi Truck

Decontamination Area Safety Station Dumpster

I Fire Truck or Aid Van

Recycling Area

Paint Receiving

Flammables Explosive Poisons Aerosols Corrosives

Unloading Zone for

"ESCAPE ROUTE Non-Hazardous
Unload Unloading Zone for Paint
EXIT Wastes
for Paint
‘
for Ineligible Vehicles Unloading Zone
I
ENTRANCE CHECK IDENTIFICATION TRAFFIC FLOW & TRAFFIC HOLDING LINE

Legend (not to scale): DRUM TABLE

PALLET Pallet

More complex site plan for a one-day drop-off HHW collection program.

39
S I T E C O N S I D E R A T I O N S

the entrance to manage traffic flow that can- sorting area. Arrangements can be made for
not be contained on the site. removing and replacing the dumpsters dur-
Several unloading lanes with signs and ing the day if necessary. A volunteer can flat-
traffic cones can help control the flow of ten boxes for recycling or to reduce the
traffic on and off the site. Separate express amount of room the boxes take up in the
lanes for the wastes received in the highest dumpster. Any unknown material needs to
volume (usually paint and used oil) can help be sorted as a hazardous material.
speed up service to participants.
Before participants drop off their HHW, Packing Area
they can be asked to document their eligibil-
ity to participate in the collection (resi-
In the packing area, trained personnel
(usually contractor staff.) lab-pack the
dency), complete questionnaires, and list the
wastes or bulk them into drums. They
wastes they have brought to the site. (A sam-
then label all containers by hazard class
ple questionnaire is provided in Appendix
and load them onto the appropriate truck(s).
D.) The staff can offer informational materi-
Consolidation of wastes (e.g., paint, motor
als, answer questions, and provide informa-
oil, or antifreeze) can be performed in this
tion about what to do with excluded wastes.
area.
To minimize traffic delays, these tasks can
be completed while participants wait to en-
ter the receiving area. Temporary Storage
Area
Receiving Area Empty drums are kept in the temporary
At the receiving areas, trained personnel storage area. Fully packed and sealed drums
(usually the contractor’s staff) screen each can be placed in the storage area until they
vehicle for unknown, unacceptable, recycla- are loaded onto a truck. To ensure that this
ble, or nonhazardous waste. Participants area stays dry and uncontaminated, it should
should not be permitted to remove any be covered, at least by an awning, and the
wastes from their own cars and should be en- floor should be covered with chemically re-
couraged to remain in their cars. The staff sistant plastic.
members unload recyclable materials and
take them to the recycling area. The recy-
clable should be handled and packaged ac-
Break Area
cording to any instructions from the Staff and volunteers should have a break
recycling firm. They then take the rest of the area, separate from the waste-receiving area,
acceptable wastes to a sorting table. After re- where they can eat, drink, rest, and use a
moving the HHW from the vehicle, the staff bathroom.
members direct the participant to the exit.

Parking Area
Sorting Area A special parking area is recommended to
In the sorting area, staff members or con- accommodate people who need extra atten-
tractor personnel sort the wastes into hazard tion, such as those who bring in unidentified
categories and deliver them to the packing wastes or have spilled a container in their ve-
area. They place empty containers and non- hicle. Parking spaces also can be designated
hazardous waste in dumpsters located in the for volunteer and staff vehicles.

40
 Training the
Collection Day Staff
T R A I N I N G T H E S T A F F

roper training of all personnel is essential to a safe and efficient collection. Training
required for the contractor’s staff, volunteers, and the sponsor’s in-house staff is
described below.
the site in the event of an emergency. The
The Contractor’s contractor’s staff also must be briefed on
Staff any limitations of the permit or the facility,
The contractor is responsible for ensuring including excluded materials and procedures
that all of its technical and professional staff to be followed.
are properly trained and certified. The con-
Reviews and drills of the emergency plan
tract should specify the qualifications of the
should be conducted for all collection day
professional personnel who will be present
personnel by qualified instructors. For regu-
at the collection.
larly scheduled collections, the training pro-
If your state requires an operating permit gram should provide for update sessions to
for HHW collection, staff training might reinforce safety procedures and provide up-
need to meet the requirements of the Occu- dated packing information.
pational Safety and Health Act, Section
1910.120. Check with your state agency to
determine training requirements. These regu-
lations specify the content and length of
training required for personnel at hazardous
waste operations. The level of training re-
quired for each employee depends on his or
her job functions and responsibilities. Topics
that must be covered include the names of
personnel responsible for site safety and
health, the hazards present at the site, the
use of personal protective equipment, work
practices that can minimize risks, the safe
use of engineering controls and equipment
on the site, and medical surveillance require-
ments. In any case, this training is recom-
mended for all personnel who will be
handling the waste, even if it is not required.
The contractor’s staff can include techni-
cians, chemists, and a manager. The
manager should receive training appropriate
for his or her involvement in the physical
operation of the program. Chemists should
have 40 hours of field chemist/technician
training to the Occupational Safety and
Health Administration’s (OSHA’S) “Site
Emergency Responder” level. Technicians
should have eight hours of training to the
“First Responder Operations” level, since
they would have to evacuate everyone from

42
 T R A I N I N G T H E S T A F F

Volunteers and ducting participant surveys, and providing

In-House Staff general assistance, such as running errands,
emptying trash, and providing refreshments.
The volunteers and in-house staff who The sponsor’s in-house staff can perform
will work at the collection site must also re- other collection day tasks, such as unloading
ceive proper training. Because of accident cars, pouring used oil into consolidation
and liability concerns, the responsibilities of drums, or opening and scraping out paint
the volunteers at a one-day collection are cans, depending on the volunteers’ training
usually limited to controlling traffic, con- and qualifications. All these tasks must

43
 n

T R A I N I N G T H E S T A F F

be performed under the contractor’s ceiving participants, controlling traffic, and

supervision. handling waste; and what their roles would
In some cases, the state or municipality be in the event of an accident or spill.
will provide professional staff to carry out Before the collection date, the sponsor
some of the more technical work. The state should hold an orientation session with the
hazardous waste contact (Appendix B) can contractor for all volunteers and in-house
provide information about appropriate staff who will be working at the collection
training for these personnel (such as OSHA’s site. This session should inform the volun-
40-hour, 20-hour, and 8-hour courses). teers about the operating procedures and
The sponsor’s project coordinator and the emergency plan. Police and other emer-
contractor should explain to volunteers and gency personnel who will be on site or on
in-house staff what they may and may not call should participate in the planning and
do on collection day; the procedures for re- orientation.

44
E D U C A T I O N A N D P U B L I C I T Y

HHW collection program cannot succeed without a strong public education effort

A that provides general information about HHW and specific instructions about how
to participate on collection day. This education also might benefit the community by
reducing the quantity of HHW collected in subsequent programs. It is still too early to know,
however, just how effective educational efforts will be in reducing the generation of HHW. At
current collection program participation rates, it will be some time before the stored waste is
cleaned out of a community. It is likely, though, that the amount of waste per participant will
decrease in communities with regular or permanent collection programs. Many examples of
well-planned education programs are available. Sources for these materials are listed in
Appendix C.

Target the Audience reduction is defined as the design, manu-

facture, purchase, or use of materials or
Residents are the most important target of products to reduce their amount or toxic-
a HHW education program. Information ity before they enter the solid waste
about HHW also should reach public offi- stream.)
cials, civic groups, solid waste personnel, What products contain fewer or no haz-
and the business community to encourage fi- ardous constituents.
nancial support, donations of in-kind serv- How to shop “smart” (e.g., buying only
ices, or other assistance. The media is an what is needed).
especially important vehicle; media under- How to reduce the amount of HHW gen-
standing of HHW issues helps ensure accu- erated (e.g., using up household prod-
rate and responsible reporting. Educators ucts or giving away what cannot be
need resources to develop and communicate used).
a strong understanding of the issue to the How to use products in a way that mini-
people they teach. Manufacturers, retail mizes harm to the environment.
stores, school chemistry departments, hospi- How to properly store and handle prod-
tals, agricultural extension services, and ucts containing hazardous constituents
farmers also can benefit from education in the home.
about HHW.
Public education before a planned collec-
tion day should not only focus on identify-
Determine the ing HHW and helping people understand the
Message and Select hazards associated with HHW, but also
should present the sponsor’s plans for ad-
Educational Methods dressing HHW management. Public educa-
Public education about HHW is a good tion efforts also should communicate the
idea even if a HHW collection event is not individual’s role in the HHW management
yet planned. The scope of this effort will program, including what to bring to a collec-
depend on the finds and personnel avail- tion and how to transport it safely. This
able. Early education can focus on: phase of the education program should be-
■ What products contain hazardous con-
gin at least six months before the collection
stituents. day. Intensified education in the final two
weeks before a collection day can have a
■ How household generation of hazardous
major impact on participation rates.
waste can contribute to pollution.
Why source reduction is a major goal of Publicity, a component of public educa-
a HHW management program. (Source tion, focuses on a single goal-bringing the

46
 E D U C A T I O N A N D P U B L I C I T Y

Public Education Methods and Techniques

Education through the media. Well-prepared media Garbage can labeling. Some communities distribute
handouts-feature articles, public service announcements, and plastic adhesive labels that residents can put on their trash
other materials for the press—m inexpensive options and cans. The labels alert people to the potential hazards of
require less staff time than many other educational methods. mixing HHW with their trash, list products containing
Information about HHW can be presented in a variety of hazadous constituents, and advertise whereto dispose of
ways. For example, a radio broadcast might feature a HHW properly.
hazardous waste expert who can answer phone-in questions Street banners. Banners announcing the place and time
on HHW. A local television station can cover a tour through of collection have worked well for some communities.
a home with an environmental expert, who can discuss the
products that can become HHW and how to manage them Displays/exhibits/audiovisual presentations. Public
safely. education staff can use slide shows, video presentations, and
hands-on exhibits at community group meetings, county fairs
Information and referral services. A publicly or other special events, public information sessions/
advertised local telephone hotline can encourage people to workshops, shopping malls, and other public forums. For
call for information about managing HHW, and also can example, the League of Women Voters of Martha’s Vineyard,
facilitate a waste exchange/referral service. These services Massachusetts, bought a video on managing HHW and
can be effective but require telephones, office space, training, offered it free to any group on the island who would show it
and personnel. at a meeting. (Slide shows available for rental or purchase are
listed in Appendix C.) The local public library also might be
Mailings and mailing inserts. Utilities, banks, billers, willing to set up a HHW resource center.
and advertisers may be willing to include HHW
announcements and informational literature in their regular Speaker bureau. Municipal departments usually have
mailings. Inserts mailed with water bills, garbage bills, or tax access to knowledgeable speakers who can make
bills not only provide information about HHW, but also can presentations to local groups at a nominal fee or free of
educate the public about the links between HHW generation, charge. Sources for community education experts include
waste management ground-water protection, and cooperative extension services, soil and water conservation
water/garbage rates. Community groups can include districts, and health and solid/hazardous waste administrators.
educational information about HHW management in their Formal education. Presentations in schools and special
mailings or newsletters. HHW program sponsors can send curricula can educate students (and their parents) about
direct mailings to people who participated in previous HHW managing HHW. A number of organizations have developed
collections. school curricula on HHW (see Appendix C).
Posters, handouts, and brochures. Flyers and Point-of-purchase information. Information about
posters often are displayed or handed out at schools, the potential hazards of household products can be
libraries, community centers, and senior citizen centers. distributed where the products are sold. For example,
Businesses can post signs and notices for shoppers and hardware stores can distribute handout on what to do with
customers on how to safely manage household products that used motor oil, paints or varnishes. An Iowa law requires
might become HHW. Real estate agents can offer their clients stores that sell products covered under the shelf labeling law
information about HHW with their other community to provide HHW content and hazard information through
resource materials. Solid waste facility personnel at drop-off shelf labeling and informational materials. A hardware store
landfills, transfer stations, and recycling centers can discuss chain in San Diego, California voluntarily initiated a similar
HHW and provide written information when residents drop program.
off waste or recyclable. Handouts can include HHW Workshops and conferences. Workshops,
“wheels” that highlight the potential hazards of household presentations, and conferences on managing HHW can bean
products and suggest less hazardous substitutes (see excellent way to bring information to citizens, HHW program
Appendix c). volunteers, local business groups, and community officials.

47
E D U C A T I O N A N D P U B L I C I T Y

desired number of participants (and HHW)

safely to a collection program. Good public-
ity explains:
Why people should participate in HHW
collection programs.
When and where the collection will be
held.
Which materials will be accepted and
which will be excluded.
What to do with excluded HHW.
How to transport HHW to the collection
center.
To maximize participation in the collec-
tion program, publicity should begin as
soon as a date for the collection is chosen.
The publicity should appear on a regular ba-
sis, highlighting progress in the planning,
presenting additional facts about HHW, and
providing contacts for more information.
Advertising in local newspapers and
newsletters is a highly effective form of
publicity. The local press usually will pub-
lish articles, photographs, and letters to the
■ Press-ready ads publicizing the collec-
editor. The planning committee should pre-
tion day. Newspapers and radio and TV
pare a press kit to facilitate newspaper pub-
stations might run these ads free of
licity. It should contain:
charge on a space-available basis, or lo-
A list of local contacts and experts who
cal firms might sponsor them.
can answer questions about HHW.
■ Press releases about the HHW manage-
ment program and the upcoming HHW Local groups, such as civic groups, pub-
collection(s). lic agencies, schools, local media, and busi-
■ Two or three short feature articles. nesses, often are willing to help with
■ Black and white photographs (with cap- publicity and outreach. A local advertising
tions) of hazardous materials (in the agency or public relations firm might agree
home, on store shelves, at collection to plan or produce the publicity campaign.
programs) that can either stand alone or Invite the firm to participate on the planning
be used with news or feature articles. committee.

48
Evaluating the
Program
E V A L U A T I N G T H E P R O G R A M

valuation is important to the continued success of any HHW collection program,

E whether it is a one-time event or an on-going, regularly scheduled program. The spon-

sor should compile data from the program, including the number of participants, the
percentage of the target population served, the quantities of the different wastes collected, the
quantities and percentages of recycled waste, the itemized total costs, the cost per participant,
and the waste management cost per pound. This information can help the sponsor determine
whether program goals have been met. The sponsor’s contract with the hazardous waste
company should specify what data the sponsor needs from the contractor for post-collection
evaluation.

In addition, sponsors can ask contractors studies can detect whether less HHW is pre-
and participants for input on flaws in the sent in the municipal solid waste and waste-
Program, such as inconvenient operating water streams after HHW collections, if
hours and locations or inefficient collection pre-collection data also are available. This
methods. This information allows programs might indicate changes in disposal practices.
to adapt to meet the needs of the public.
Finally, followup is important after a
Public satisfaction with the HHW man- HHW collection event, especially for spon-
agement program can be measured through sors who hope to maintain and institutional-
questionaires published in newspapers or ize the program. Local media should be
filled out when participants arrive at the col- provided with followup stones of the event,
lection site (see Appendix D for a sample on- such as a report about the amount of HHW
site questionnaire), and by requests for collected. A summary report should be
feedback when people call a HHW hotline. prepared to document the results of the
In addition, garbage sorts and wastewater program.

50
C A S E S T U D I E S

Raleigh

Raleigh, North Carolina

n October 1989, the Raleigh, North Carolina Public Utilities Department (the city’s water
and sewer utility) sponsored a pilot HHW program at the Department’s Operations Center.
The program had two objectives: to educate the citizens of Raleigh about HHW and
proper HHW management methods; and to collect HHW from Raleigh residents and recycle
some of the collected wastes.
The program met both of these goals, Publicity
demonstrating that a water utility can effec-
tively design and implement a HHW collec- Advertising for the October collection
tion. The first collection day in 1989 drew started at the beginning of January. A variety
an extraordinary number of participants for of publicity and public education methods
a first-time drop-off HH W collection-a to- were used:
tal of 1,149, or 1.4 percent of the targeted
80,000 households. ■ More than 40 press releases were pre-
pared for newspapers, TV, and radio.
■ Five hundred letters were mailed to
Planning the
civic organizations.
Collection 9 Presentations with videotapes were de-
The collection was planned by a HHW livered at civic group meetings.
steering committee that included repre- ■ Bright yellow inserts were placed in
sentatives from the public utilities depart- every Raleigh water bill approximately
ment the Governor’s Waste Management six weeks before the collection.
Board; the North Carolina Hazardous Waste ■ A member of the Environmental
Branch; the Institute for Environmental Quality Advisory Board sponsored an
Studies at Chapel Hill; the City of Raleigh’s entire afternoon on a classical music
Environmental Quality Advisory Board; the radio station that included repeated
city’s public works, fire, transportation, announcements about the HHW
police, and safety departments; and others. collection.
The committee began planning for the ■ Raleigh’s cable television station aired
collection day a full year before the event an informational program on HHW
was held. several times.

52
 C A S E S T U D I E S

Graduate students from a local university to the HHW collection were identified for
surveyed the collection participants to find recycling: good-quality latex paint, used
out how they heard about the collection. The oil, and automobile batteries. More than
results are shown below. (Note: The total 100 gallons of latex paint were donated to
percentage exceeds 100 because some peo- the Raleigh Housing Authority for use in
ple heard about the collection program from its projects. An oil service company in
more than one source.) Raleigh accepted 2,800 gallons of motor
oil for processing as industrial-grade fuel
oil. A battery firm in Wilson, North
Newspaper
Carolina, took 105 automotive batteries
Water bill inserts 34% for recycling. Wastes not accepted at the
Radio 16% collection included radioactive, biologi-
Television 14% cal wastes, explosives, ammunition, and
nonhazardous waste.
Other forms of advertising 8%
Civic groups 3%
Funding and Costs
Except for a one-time $10,000 matching
Among the factors credited for the re- grant from the state, Raleigh’s program was
markable turnout at the collection was the funded entirely from the city’s Department
steering committee’s ability to personalize of Public Utilities budget. HHW collection
the issue when presenting it to the commu- (waste management and public educa-
nity. The program manager focused her ad- tion/publicity) was performed under con-
vertising efforts to ensure that people tract; these direct costs totaled $141,147.
understood that HHW management is an en- Indirect costs-the cost of providing city
vironmental issue that literally “hits home.” staff on site (police and fire) and the hours
The highlight of this personalized effort spent by the HHW steering committee to
was a press conference held in a home- plan the program-totaled an additional
owner’s basement. This enabled the press to $26,017. City employees bulked used motor
actually see what HHW is, to recognize that oil, directed traffic, and were available for
it is something most people have in their emergency response.
own homes, and to take advantage of a
photo opportunity. Several major newspa-
pers ran feature articles about HHW follow-
Expanding the
ing this press conference. Television stations Program
also included the press conference in their On April 7,1990, Raleigh and Wake
news reports. County held a collection open to the entire
county. This collection drew 1,778 partici-
Types of HHW pants. The cost of the event was $175,210.
It was funded by a separate line item on the
Collected and city water and sewer bill (40¢/month), and
Waste Management the county share was funded through the
Methods Used landfill tipping fee.
The hazardous waste contractor for the An ad hoc group of Raleigh public
collection sent 355 drums of collected HHW works, utility, and transportation employees
for hazardous waste treatment and/or managed the program. The group was
disposal. Three types of materials brought responsible for expanding the program to

53
C A S E S T U D I E S

the full county and for developing a HHW The collection organizers made several
curriculum for local schools. The group also other improvements over the 1989 event.
is planning future collections. The two most frequent suggestions from
participants at the first collection were to
The most effective publicity techniques reduce waiting time and to ban smoking.
for the April 1990 collection were flyers In response to these suggestions, organiz-
sent with water bills one month before the ers staffed two sites with 100 contractor
event and a series of press releases in the fi- and local personnel, reducing the waiting
nal week before the collection. The base- time at the second event to a maximum of
ment press conference was not repeated. 15 minutes. In addition, the sites now have
permanent signs that ban smoking. In
Organizers of the April 1990 event set a 1990, Habitat for Humanity bulked the
goal of increased recycling. A local paint good-quality latex paint at the collection
company consolidated and blended 2,500 site and then used it to paint low-income
gallons of latex paint, charging only for the housing. The hazardous waste contractor
five-gallon plastic buckets used ($2 apiece). analyzed the bulked latex paint for heavy
The City Housing Authority will save an es- metals. None of the bulk paint was
timated $9,500 by using this paint. In addi- rejected.
tion, the Parks and Recreation Department
Source: Cindy Kling, City of Raleigh, Public
received 12 drums of pesticides from the
Utilities Department.
collection.

54
 New York

Monroe County, New York

onroe County in upstate New York held its first HHW collection on October 21,

M 1989, in the City of Rochester. The collection was attended by 1,400 of the 250,000
households in the county (0.56 percent participation rate) even though the day was
overcast and cold. The site was open from 9 a.m. to 2 p.m. Lines formed as early as 8:20 a.m.
Program organizers believe that hundreds of additional households did not participate because
of the long wait or because many were turned away at 2 p.m.

used oil and automotive batteries. The haz-

Planning the ardous materials team was on site all day
Collection and the bomb squad was on call. County
Initial planning meetings began 18 and municipal police and hospitals were no-
months before the collection. A 12-person tified about the day’s event.
volunteer subcommittee of the county’s En-
vironmental Management Council (EMC)
conducted background research, and the Publicity
County unanimously accepted the EMC’s
The Monroe County EMC Household
recommendations in January 1990.
Hazardous Waste Committee was responsi-
Monroe County established a committee ble for education for the event. The planning
of county professionals from the depart- committee arranged for publicity before the
ments of solid waste, planning, health, and collection day through newspapers, TV, ra-
firm, as well as legislative and legal repre- dio, flyers, and slide shows. Eastman Ko-
sentatives, to plan and implement the collec- dak, a local employer, also publicized the
tion event. The EMC coordinator was the event in its in-house newsletter and encour-
project manager for the event. The County aged all employees to participate. Kodak
Division of Solid Waste carried out the de- also purchased fill-page newspaper ads
tails of site planning and provided the site about the company’s recycling efforts and in-
coordinator. Chemists from the County cluded a quarter of a page in the ads about
Health Department sampled and handled the the HHW collection.

55
C A S E S T U D I E S

county. Thus, the total cost of the program,

Types of HHW including all monetary and in-kind contribu-
Collected and tions, exceeded $150,000.
Waste Management
Methods Used Program Evaluation
The program collected 3,000 gallons of The county considered its frost-time
used oil, 13,375 pounds of automotive bat- HHW collection a tremendous success.
teries, and 80,000 pounds of other types of Recommendations for future one-day collec-
HHW. Used oil was reprocessed into fuel oil tions include designating an individual to as-
by a local firm, and automobile batteries sist the media on site (no one was available
were sold to a local broker for recycling. for this on the collection day) and using vol-
Wastes excluded from the collection in- unteers in shifts so that they can take breaks.
cluded unlabeled waste, latex paint, radioac- The only significant problem at the event
tive and biohazardous waste, explosives, was that many potential participants had to
shock-sensitive wastes, and propane tanks. be turned away. Collection organizers do not
believe that increased staffing would have
solved this problem—the contractor pro-
Funding and Costs vided 24 staff people and worked efficiently,
To pay for the collection program, Mon- processing four households per minute. In-
roe County spent $62,000, the City of Roch- stead, the county has decided to establish a
ester contributed $5,000, and local permanent HHW collection program. The
businesses donated $57,000 (as well as in- county hired an engineering firm to design a
kind contributions such as free publicity). permanent facility and selected a site for the
Eastman Kodak saved the county an addi- program. The facility opened in the spring
tional $32,410 in waste management costs of 1992.
by accepting 384 thirty-gallon drums and Source: Alice Young, League of Women Vot-
135 five-gallon pails of paints and solvents. ers, Rochester Metro, Chair Monroe County
These wastes were burned at Kodak’s haz- Environmental Management Council,
ardous waste incinerator at no cost to the Household Hazardous Waste Committee.

56
A. Hazardous Waste Laws and
Regulations
B. State and Regional
Hazardous Waste Contacts
C. Information Resources
D. Sample Participant
Questionnaire

57
 industrial waste. Hazardous waste is regu-
lated under RCRA’s Subtitle C program.
Subtitle C establishes a system for control-
Hazardous Waste ling hazardous waste from “cradle to
grave’’-from the moment it is generated
Laws and until its ultimate disposal. These controls
include:
Regulations A tracking system that requires a
manifest document to accompany
transported hazardous waste from the
point of generation to the point of final
Federal disposal.
Requirements For An identification and permitting sys-
HHW Management tem that enables EPA and the states to
ensure the safe operation of all facilities
Programs involved in the treatment, storage, and
EPA has issued regulations governing haz- disposal of hazardous waste. Certain
ardous waste under the Resource Conserva- generators, transporters, and treatment,
tion and Recovery Act (RCRA) and the storage, and disposal facilities (TSDFs)
Comprehensive Environmental Response, must obtain an EPA identification num-
Compensation, and Liability Act (CERCLA ber. TSDFs also must obtain a permit to
or Superfund). This Appendix generally operate, which ensures that they meet
summarizes the regulations that may be ap the standards established under the
plicable to HHW collection programs man- RCRA program for proper waste
aging various types of hazardous wastes. It management.
is important for organizers to consult appro- A system of restrictions and controls
priate EPA regional and state personnel to on the placement of hazardous waste on
get abetter understanding of how these regu- or into the land.
lations apply to HHW collection programs. RCRA requirements for hazardous
In addition, state laws maybe more strin- waste management vary depending on
gent than the federal regulations described whether the waste is HHW, condition-
below. Therefore, it also is important that ally exempt small quantity generator
HHW collection organizers familiarize them- (CESQG) waste, or small quantity
selves with and follow state hazardous generator (SQG) waste. These require-
waste requirements. Consult your state solid ments are described below.
and hazardous waste agency (see Appendix
Household hazardous waste
B) for further information.
Household waste, including HHW, is
The Resource Conservation and exempt from federal hazardous waste
Recovery Act (RCRA) regulations and liability under RCRA
RCRA is the federal law requiring Subtitle C. Therefore, HHW is not regu-
safeguards and encouraging environmen- lated under RCRA as a hazardous waste
tally sound methods for disposal of (see 40 CFR 261 .4(b)(l)). Programs that
household, municipal, commercial, and collect HHW do not need a Subtitle C

58
 L A W S A N D R E G U L A T I O N S

permit or EPA identification number, and federal hazardous waste requirements. No

HHW can be transported without following Subtitle C permit or EPA identification num-
hazardous waste transportation regulations ber is needed, and CESQG waste can be
(e.g., people can bring HHW to a collection transported without following the federal
facility in their cars). No quantity of HHW hazardous waste transportation requirements.
or length of time of accumulation triggers
In general, CESQGs must comply with
the Subtitle C requirements.
two requirements. They do not store more
To be defined as “household” waste and than 1,000 kilograms (about 2,200 pounds)
thus be exempt from federal hazardous of hazardous waste at their facility at one
waste regulations, the waste must be: time, and they send their hazardous waste to
Generated by individuals on the prem- a recycling facility, a hazardous waste facil-
ises of a residence for individuals (a ity, or a facility permitted, licensed, or regis-
household). tered by the state to manage municipal or
and industrial solid waste (usually, a municipal
Composed primarily of materials found landfill). These CESQGs may send their haz-
in the wastes generated by consumers in ardous waste to HHW collection programs
their homes. that are state-permitted, licensed, or regis-
Even if waste generated by a commercial tered to manage municipal or industrial
or industrial establishment looks like house- solid waste. Because CESQG waste is condi-
hold waste, it is not exempt from federal tionally exempt throughout its management
hazardous waste regulations. cycle, collection programs managing
CESQG waste are not covered by the fed-
The household waste exemption applies eral hazardous waste regulations, but are
to HHW through its entire management cy- subject to requirements imposed by states
cle. The waste collected through a HHW col- through their municipal or industrial waste
lection program does not lose its exemption permit, license, or registration programs.
by being consolidated with other household
waste. In summary, if a program accepts EPA encourages the collection and proper
only waste from households, there are no ap- management of CESQG waste. Community
plicable federal hazardous waste regulations. collection programs can help meet this goal
by accepting CESQG waste from schools,
Conditionally exempt small quantity small businesses, farms, government agen-
generator (CESQG) waste
cies, and other commercial and institutional
Some communities decide to run pro- hazardous waste generators.
grams that collect CESQG waste as well as
HHW. Communities generally make this de- CESQGs are responsible for ensuring
cision to help small businesses keep hazard- that their waste is managed in compliance
ous waste out of the municipal waste with federal requirements. They may ask the
stream. Hazardous waste generators are con- collection program for documentation of reg-
ditionally exempt from the federal hazard- istration or licensing if required by the state.
ous waste regulations if they generate less CESQGs can refer to EPA’s Understanding
than 100 kilograms (approximately 220 the Small Quantity Generator Hazardous
pounds or about half of a 55-gallon drum) of Waste Rules: A Handbook for Small Busi-
hazardous waste per month. Like HHW, ness for more information about the require-
CESQG waste is exempt from most of the ments that apply to them. Contact your

59
L A W S A N D R E G U L A T I O N S

regional EPA office for this publication or of 10 days or less). Therefore, sponsors
for more information. should be careful to limit participation in
EPA recommendations for their programs to households and CESQGs
programs that collect HHW and to avoid the need to obtain a RCRA permit.
CESQG waste To ensure that a hazardous waste generator
Although HHW and CESQG waste are is a CESQG and not a regulated SQG, pro-
exempt from most federal hazardous waste gram sponsors should establish procedures
regulations, EPA recommends that sponsors to differentiate between the two types of
of HHW collection programs manage the generators. Some programs exclude SQG
collected waste as a Subtitle C hazardous waste by requiring pre-registration by
waste-that is, it should be managed at a re- CESQGs. At the time of pre-registration,
cycling or licensed hazardous waste facility. program personnel can inquire about the
Given the effort and expense a community types and quantities of waste that the gener-
has already put into its HHW collection pro- ator wishes to bring to the collection.
gram, it makes sense to ensure the greater
level of environmental protection that will The Comprehensive
result from the Subtitle C controls.
Environmental
EPA also recommends that HHW
Response, Compensation,
collection programs use licensed hazardous
waste transporters who will properly iden- And Liability Act
tify, label, manifest, and transport the col- (CERCLA/Superfund)
lected wastes for recycling, treatment, or
disposal. State hazardous waste agencies Congress passed CERCLA in 1980 to ad-
(see Appendix B) can provide a list of li- dress the cleanup of inactive and abandoned
censed facilities and transporters. hazardous waste sites. Under CERCLA, if
cleanup of a hazardous waste disposal site is
Small quantity generator (SQG) waste necessary, all sources of the waste, as well
SQGs are those that generate more than as the owner or operator of the site, might
100 kilograms (220 pounds) and less than be potentially responsible parties (PRPs),
1,000 kilograms (2,200) pounds) of hazard- who are liable for the entire cleanup cost for
ous waste per month. SQGs must use speci- the site.
fied packaging for their waste; use a fully CERCLA does not exclude HHW from li-
completed manifest form when shipping the ability, nor does it allow any exemption
waste off site; use only hazardous waste based on the amount of waste generated. If
transporters; and send their waste to author- HHW contains a substance defined as haz-
ized hazardous waste management facilities ardous under CERCLA, potential liability
with EPA identification numbers to trans- exists. The Agency, however, will generally
port, treat, store, or dispose of their hazard- not notify generators or transporters of mu-
ous waste. nicipal solid waste—including HHW collec-
HHW collection programs may not ac- tion programs—that they are considered
cept SQG wastes unless the program has a PRPs, unless EPA has information indicat-
RCRA Subtitle C permit (or is a transporter ing that the waste came from an industrial,
who stores manifested shipments of hazard- institutional, or commercial process or activ-
ous waste at a transfer facility for a period ity. This includes, but is not limited to, SQG

60
 L A W S A N D R E G U L A T I O N S

waste from commercial or industrial proc- 800-553-7672. Alternatively, you can contact
esses or activities, and used or spent sol- your EPA regional office (see Appendix B).
vents from private or municipally owned
maintenance shops. EPA makes decisions State and Local
about notifying PRPs on a case-by-case ba-
sis, and may, in exceptional situations, no-
Requirements
tify parties who generated or transported
only household waste to a site. PRPs may Some states have regulations or guide-
sue other parties that they believe share li- lines for HHW management programs or
ability. Citizen suits are unrestricted. permanent HHW management facilities that
are more stringent than the federal require-
While CERCLA does not exempt HHW ments. These may include requirements for
collection programs from liability, it is im- a permit, permit variances, or a plan for the
portant to realize that the potential for liabil- collection day.
ity might be greater if a community takes no
action to ensure proper disposal of HHW. Some states do not have an exemption for
The additional safeguards provided by CESQGs; others might use a lower cut-off
HHW collection and Subtitle C management than 100 kilograms per month or have differ-
can reduce the likelihood of environmental ent management requirements. States also
and human health impacts, and thereby might have CERCLA-type legislation allow-
might reduce potential CERCLA liability. ing recovery of the costs of hazardous waste
site cleanup. Organizers of HHW manage-
For more information about federal ment programs must check with their state
laws pertaining to HHW, you can call the environmental officials (see Appendix B) to
RCRA/Superfund Hotline at 800-424-9346. learn about applicable regulations. In addi-
In Washington, DC, please call 703-412- tion, local zoning, building, and fire codes
9810. The Hotline is open Monday through might apply to HHW collections; the appro-
Friday, 8:30 a.m. to 7:30 p.m. EST. For priate local agencies must be contacted to
the hearing impaired, the TDD number is ensure compliance.

61
 Arkansas
Hazardous Waste Division
Arkansas Department of Pollution
State and Regional Control and Ecology
P.O. BOX 8913
Hazardous Waste Little Rock, AR 72219-8913
Contacts 501-562-7444

California
Department of Toxic Substances Control
State Contacts Hazardous Waste Division
P.O. BOX 806
Alabama 400 P Street
Land Division Sacramento, CA 95812-0806
Alabama Department of Environmental 916-324-1826
Management
1751 Cong. William L. Dickinson Drive
Colorado
Montgomery, AL 36130 Hazardous Materials and Waste
205-271-7730 Management Division
Colorado Department of Health
Alaska 4210 E. 1 lth Avenue
Solid and Hazardous Waste Denver, CO 80220
Management Section 303-331-4830
Alaska Department of Environmental
Conservation
Commonwealth of Northern Mariana
410 Willoughby Avenue, Suite 105 Islands
Juneau, AK 99801-1795 Division of Environmental Quality
907-465-5150 Department of Public Health and
Environmental Services
American Samoa Commonwealth of the Northern
Environmental Quality Commission Mariana Islands
Government of American Samoa Saipan, Mariana Islands 96950
Pago Pago, American Samoa 96799 Overseas Operator: 670-234-6114
Overseas Operator: 684-663-2304 Cable Address: Gov. NMI Saipan

Arizona Connecticut
Office of Waste Programs Bureau of Waste Management
Arizona Department of Environmental Department of Environmental Protection
Quality State Office Building
3033 N. Central Avenue 165 Capitol Avenue
Phoenix, AZ 85012 Hartford, CT 06106
602-207-4108 203-566-8476

62
 HAZAR DOUS WASTE CONTACTS

Delaware Hawaii
Division of Air and Waste Management Solid and Hazardous Waste Branch
Department of Natural Resources and Department of Health
Environmental Control 5 Waterfront Plaza, Suite 250
P.O. Box 1401 500 Ala Moana Boulevard
89 Kings Highway P.O. BOX 3378
Dover, DE 19903 Honolulu, HI 96813
302-739-4764 808-586-4226

Idaho
District of Columbia
Hazardous Materials Bureau
Pesticides and Hazardous Materials Water Quality Bureau, Division of
Division Environmental Quality
Department of Consumer and 1410 North Hilton Street
Regulatory Affairs Boise, ID 83706
2100 Martin Luther King Avenue, SE. 208-334-5860
Suite 203
Washington, DC 20020 Illinois
202-404-1167 Division of Land Pollution Control
Illinois Environmental Protection
Florida Agency
Division of Waste Management 2200 Churchill Road
UST Springfield, IL 62794-9276
217-785-8604
Department of Environmental
Regulations
Indiana
Twin Towers Office Building
Hazardous Waste Management Branch
2600 Blair Stone Road Indiana Department of Environmental
Tallahassee, FL 32339-2400 Management
904-487-3299 105 S. Meridian Street
Indianapolis, IN 46206-6015
Georgia 317-232-3292
Land Protection Branch
Floyd Towers East/Room 1154 Iowa
205 Butler Street, SE. Air Quality and Solid Waste Section
Atlanta, GA 30334 Department of Natural Resources
900 East Grand Avenue
404-656-2833
Des Moines, IA 50319-0034
515-281-8852
Guam
Hazardous Waste Management program Kansas
Guam Environmental Protection Agency Air and Waste Management
IT& E Harmon Plaza Department of Health and Environment
130 Rojas Street, Unit D-1 Forbes Field, Building 740
Harmon, Guam 96911 Topeka, KS 66620
Overseas Operator 671-646-8863 913-296-1593

63
H A Z A R D O U S W A S T E C O N T A C T S

Kentucky Minnesota
Division of Waste Management Hazardous Waste Division
Department of Environmental Protection Minnesota Pollution Control Agency
18 Reilly Road 520 Lafayette Road, North
Frankfort, KY 40601 St. Paul, MN 55155
502-564-6716 612-297-8502

Louisiana Mississippi
Hazardous Waste Division Division of Hazardous Waste
Louisiana Department of Environmental Management
Quality Department of Natural Resources
P.O. BOX 82178 P.O. BOX 10385
7290 Bluebonnet Drive Jackson, MS 39289-0385
Baton Rouge, LA 70884-2178 601-961-5171
504-765-0355
Missouri
Maine Waste Management Program
Bureau of Hazardous Materials Control Department of Natural Resources
and Solid Waste Control Jefferson Building
Department of Environmental Protection 205 Jefferson Street
State House, Station #17 P.O. BOX 176
Augusta, ME 04333 Jefferson City, MO 65102
207-289-2651 314-751-3176
Maryland Montana
Hazardous and Solid Waste Solid and Hazardous Waste Bureau
Management Administration Department of Health and
Maryland Department of the Environmental Sciences
Environment Cogswell Building
2500 Browening Highway Helena, MT 59620
Baltimore, MD 21224 406-444-2821
410-631-3304
Nebraska
Massachusetts Department of Environmental Control
Divison of Solid and Hazardous Waste P.O. BOX 98922
Massachusetts Department of 301 Centennial Mall S.
Environmental Protection Lincoln, NE 68509-8922
One Winter Street, 7th Floor 402-471-4210
Boston, MA 02108
617-292-5853 Nevada
Waste Management program
Michigan Division of Environmental Protection
Waste Management Division Department of Conservation and
Department of Natural Resources Natural Resources
608 W. Allegan Street Capitol Complex
BOX 3338 123 West Nye Lane
Lansing, MI 48933 Carson City, NV 89710
517-373-2730 702-687-5872

64
 HAZARDOUS WASTE CONTACTS

New Hampshire Ohio

Office of Waste Management Division of Solid and Hazardous Waste
Department of Environmental Services Management
6 Hazen Drive Ohio Environmental Protection Agency
Concord, NH 03301-6509 P.O. Box 1049
603-271-2900 Columbus, OH 43266-0149
614-644-2958
New Jersey
Division of Hazardous Waste Oklahoma
Management
Hazardous Waste Management Service
Department of Environmental Protection
Oklahoma State Department of Health
401 East State Street/CN 028
1000 Northeast l0th Street
Trenton, NJ 08625
609-292-1250 Oklahoma City, OK 73117-1299
405-271-7052
New Mexico
Hazardous and Radioactive Waste Oregon
Bureau Hazardous and Solid Waste Division
Environmental Department Department of Environmental Quality
525 Camino de los Marquez 811 Southwest 6th Avenue, 8th Floor
P.O. BOX 26110 Portland, OR 97204-1390
Santa Fe, NM 87502 503-229-5913
505-827-4308

New York Pennsylvania

Division of Solid and Hazardous Waste Division of Hazardous Waste
Management
Department of Environmental
Conservation Pennsylvania Department of
50 Wolf Road Environmental Resources
Albany, NY 12233 P.O. BOX 2063
518-457-6603 Fulton Building
Harrisburg, PA 17105-2063
North Carolina 717-787-9870
Solid and Hazardous Waste
Management Branch Puerto Rico
Division of Health Services Environmental Protection Agency
Department of Human Resources 1413 Fernadez Juncos
P.O. BOX 27687 Santurce, PR 00909
Raleigh, NC 27611-7687
809-729-6920
919-733-2178

North Dakota Rhode Island

Division of Waste Management Air and Hazardous Materials Program
Department of Health Management and Department of Environmental
Special Studies Management
1200 Missouri Avenue, Room 302 291 Promenade Street
Bismarck, ND 58502-5520 Providence, RI 02908
701-221-5166 401-277-2797

65
HAZARDOUS WASTE CONTACTS
South Carolina Virgin Islands
Bureau of Solid and Hazardous Waste Department of Planning and Natural
Management Resources
Department of Health and Suite 231, Nisky Center
Environmental Control 45-A Estate Nisky
2600 Bull Street St. Thomas, VI 00802
Columbia, SC 29201 809-774-3320
803-734-5200
Virginia
South Dakota Hazardous Waste Division
Office of Air Quality and Solid Waste Virginia Department of Waste
Management
Department of Water and Natural
Resources Monroe Building, llth Floor
523 E. Capitol 101 North 14th Street
Richmond, VA 23219
Foss Building, Room 416
804-225-4761
Pierre, SD 57501
605-773-3153 Washington
Solid and Hazardous Waste
Tennessee Management Program
Division of Solid Waste Management Department of Ecology
Tennessee Department of Public Health P.O. BOX 47600
701 Broadway Olympia, WA 98504-7600
Customs House, 4th Floor 206-459-6316
Nashville, TN 37219-5403
615-741-3424 West Virginia
Waste Management Division
Texas Commerce, Labor, and Environmental
Industrial and Hazardous Waste Division Resources
Texas Water Commission 1356 Hansford Street
P.O. BOX 13087 Charleston, WV 25301
Austin, TX 78711-3087 304-348-5929
512-908-2334 Wisconsin
Bureau of Solid and Hazardous Waste
Utah Management
Bureau of Solid and Hazardous Waste
Department of Natural Resources
Management
P.O. BOX 7921 /SW-3
Department of Environmental Quality
Madison, WI 53707-7921
288 North 1460 West
608-266-2111
Salt Lake City, UT 84114-4880
801-538-6170 Wyoming
Solid Waste Management Program
Vermont State of Wyoming Department of
Hazardous Waste Management Division Environmental Quality
Agency of Environmental Conservation 122 West 25th Street
103 South Maine Street Herschler Building
Waterbury, VT 05761-0404 Cheyenne, WY 82002
802-244-8702 307-777-7752

66
 HAZARDOUS WASTE CONTACTS

EPA Regional Contacts

EPA Region 1 EPA Region 6
(Connecticut Maine, Massachusetts, New (Arkansas, Louisiana, New Mexico,
Hampshire, Rhode Island, Vermont) Oklahoma Texas)
Contact: - Contact:
Waste Managenent Division RCRA Programs Branch (6H-H)
90 Canal Street First Interstate Bank Tower
Boston, MA 02 14 1445 Ross Avenue, Suite 1200
617-573-5707 Dallas, TX 75202-2733
214-655-6700
EPA Region 2
(New Jersey, New York, Puerto Rico, EPA Region 7
Virgin Islands)
(Iowa, Kansas, Missouri, Nebraska)
Contact:
Contact:
Hazardous Waste Compliance Branch
RCRA Branch
26 Federal Plaza, 10th Floor
New York, NY 10278 726 Minnesota Avenue
212-264-2301 Kansas City, KS 66101
913-551-7051
EPA Region 3
(Delaware, District of Columbia, EPA Region 8
Maryland, Pennsylvania, Virginia, (Colorado, Montana, North Dakota,
West Virginia) South Dakota, Utah, Wyoming)
Contact: Contact
Waste Management Branch (3HW30) Hazardous Waste Management Division
841 Chestnut Street One Denver Place
Philadelphia, PA 19107 999 18th Street Suite 500
215-597-6633 Denver, CO 80202-2405
303-293-1720
EPA Region 4
(Alabama, Florida, Georgia, Kentucky, EPA Region 9
Mississippi, North Carolina, South (Arizona, California, Hawaii, Nevada,
Carolina, Tennessee) Guam, Marianas)
Contact Contact
Residuals Management Branch
Office of Waste Programs (T-2A)
345 Courtland Street, NE.
75 Hawthorne Street
Atlanta, GA 30365
San Francisco, CA 94105
404-347-7603
415-744-1500
EPA Region 5
EPA Region 10
(Illinois, Indiana, Michigan, Minnesota,
Ohio, Wisconsin) (Alaska, Idaho, Oregon, Washington)
Contact: Contact:
RCRA Program Management Branch Hazardous Waste Management
77 W. Jackson Boulevard HRE-8 1200 Sixth Avenue, 1 lth Floor
Chicago, IL 60604-3507 Seattle, WA 98101
312-886-4434 206-553-4973

67
 Environmental Health Coalition
1717 Kettner Drive #100
San Diego, CA 92101
Information 619-235-0281

Resources Household Hazardous Waste Project

1031 East Battlefield, Suite 214
Springfield, MO 65807
417-889-5000
Organizations
Metrocenter YMCA
Agency of Environmental Conservation 909 Fourth Avenue
(paint swaps) Seattle, WA 98104
103 S. Main Street, M Building 206-382-5013
Waterbury, VT 05671-0407
802-244-7831 Minnesota Office of Consumer Policy
NCL Tower, Suite 1400
445 Minnesota Street
P.O. Box 7414 St. Paul, MN 55101-2131
Berkeley, CA 94707 612-296-7575
510-524-2567
Minnesota Pollution Control Agency
California Integrated Waste Management 520 Lafayette Road, North
Board St. Paul, MN 55155
8800 Cal Center Drive 612-296-6300
Sacramento, CA 95826
916-255-2200 National Coalition Against the Misuse of
Pesticides
Center for Safety in the Arts 701 E Street, SE., Suite 200
5 Beekman Street, Suite 1030 Washington, DC 20003
New York, NY 10038 202-543-5450
212-227-6220
National Recycling Coalition
Concern, Inc. 1101 30th Street, NW.
1794 Columbia Road, NW. Suite 305
Washington, DC 20009 Washington, DC 20007
202-328-8160 202-625-6406

Ecology Center of Ann Arbor Nuclear Regulatory Commission (smoke

201 Detroit Street detectors)
Ann Arbor, MI 48104 Washington, DC 20555
313-761-3186 301-504-2240

Environmental Hazards Management

Institute (EHMI) (HHW wheels)
10 Newmarket Road, P.O. Box 932
Durham, NH 03824
603-868-1496

68
 I N F O R M A T I O N R E S O U R C E s

Office of Solid Waste Books and Pamphlets

U.S. EPA
401 M Street, SW. (0S-305) Alternatives (a series of fact sheets),
Washington, DC 20460 Washington Toxics Coalition.
EPA RCRA/Superfund Hotline: (EPA/530-SW-88-014).
800-424-9346 Bibliography on Household Hazardous
Wastes, U.S. Environmental Protection
Project ROSE (used oil) Agency. Available through the
University of Alabama RCRA/Superfund Hotline, 800-424-9346.
P.O. BOX 870203
Tuscaloosa, AL 35487-0203 Chemicals in Household Products, Bradley
205-348-4878 C. Clark, Ingham County Health
Department, 5303 S. Cedar, P.O. Box
Solid and Hazardous Waste Management 30161, Lansing, MI 48909.
Program Decision Makers Guide to Solid Waste
Washington Department of Ecology Management (1990), U.S. Environmental
P.O. BOX 47655 Protection Agency. Available through the
Olympia, WA 98504-7655 RCRA/Superfund Hotline, 800-424-9346.
206-459-6303 (EPA/530-SW-89-072).
Disposal—Do It Right, Household Products
Solid Waste Information Clearinghouse
Disposal Council, 1201 Connecticut
(SWICH)
Avenue, NW., Suite 300, Washington, DC
800-67-SWICH
20036,202-659-5535.
Toxicant/HHW Project The “Environmentally Friendly” Consumer
METRO Office of the Minnesota Attorney
821 Second Avenue, Mail Stop 81 General, Consumer Services Division,
Seattle, WA 98104 1400 North Central Life Tower, St. Paul,
206-684-1233 MN 55101,612-296-3353.
Fire Protection Guide to Hazardous
University of Wisconsin Cooperative Materials (1990), National Fire
Extension Protection Association, 1 Batterymarch
Environmental Resources Center Park, P.O. Box 9101, Quincy, MA
1450 Linden Drive 02269-9101,800-344-3555.
Madison, WI 53706
608-262-0020 Guide to Hazardous Products Around the
Home (1989), Household Hazardous
Washington Toxics Coalition Waste Project, Springfield, MO.
4516 University Way, NE Hazardous Wastes from Homes, Enterprise
Seattle, WA 98105 for Education, 1320 A Santa Monica
206-632-1545 Mall, Santa Monica CA 90401,
213-394-9864.
Waste Watch Center
16 Haverhill Street Home Safe Home, Washington Toxics
Andover, MA 01810 Coalition.
508-470-3044 Household Batteries in Minnesota, Karen
Arnold et al., Minnesota Pollution
Control Agency.

69
I

I N F O R M A T I O N R E S O U R C E S

Household Hazardous Waste: Guidelines Tufts University. Proceedings from the

for Conducting Collection Events (1989), Fourth (PB90- 163-189) and Fifth
Washington Department of Ecology. (PB91-206-607) National Conferences
are available from the National Technical
Household Hazardous Wrote: Solving the
Information Service, Springfield, VA
Disposal Dilemma, Gina Purin et al.,
800-553-6847 or Waste Watch Center
Local Government Commission, 909
508-470-3044.
12th Street, Suite 205, Sacramento, CA
95814,916-448-1198. Recycling Used Oil: What Can You Do?
(EPA/530-SW-89-039B), Recycling Used
Household Hazardous Waste Management
Oil: 10 Steps to Change Your Oil
Planning (1990), Donald Seeberger,
(EPA1530-SW-89-039C), Recycling Used
Hennepin (MN) County Environment and
Oil: For Service Stations and Other
Energy Division/Urban Consortium
Vehicle Service Facilities
Ninth Year Energy program.
(EPA/530-SW-89-039d), U.S.
Household Hazardous Waste Wheel, EHMI, Environmental Protection Agency. These
Durham, NH. pamphlets are available through the
Household Hazardous Wastes: Feasibility of RCRA/Superfund Hotline,
Operating a Collection and Disposal 800-424-9346.
Assistance Program, (1989), Illinois States’ Efforts to Promote Lead-Acid Battery
Environmental Protection Agency Recycling (PB92-119-965), U.S.
(IEPA/ENV/99-066). Environmental Protection Agency.
Household Hazards: A Guide to Available from the National Technical
Detoxifying Your Home (1991), League Information Service, 800-553-6847.
of Women Voters, 35 Maiden Lane, A Survey of Household Hazardous Wastes
Albany, NY 12207-2712,518-465-4162. and Related Collection Programs, U.S.
Household Waste: Issues and Opportunities, Environmental Protection Agency.
(1989) Andy Knaus et al., Concern, Inc.. Available through the RCRA/Superfund
Hotline, 800-424-9346
How to Organize a Community Collection (EPA/530-SW-86-038).
Day, Department of Environmental
Protection, Hartford, CT. Take Me Shopping: A Consumer Guide to
Using Specific Materials, Techniques,
How to Set Up a Local Program to Recycle
and Substitutes for HHW Santa Clara
Used Oil (1989), U.S. Environmental
County Hazardous Waste Management
protection Agency
Program, 408-441-1195.
(EPA/530-SW-89-039a).
Used Oil Recycling (newsletter), U.S.
The Merck Index: An Encyclopedia of
Environmental Protection Agency.
Chemicals and Drugs, Merck and
Available through the RCRA/Superfund
Company, Rahway, NJ.
Hotline, 800-424-9346.
Proceedings of the Sixth National
Conference on Household Hazardous
Waste Management, Dana Duxbury &
Periodicals
Associates, 1991. Summaries of the First BioCycle
(PB89-179-501), Second (PB89-179-519), 419 State Avenue, Second Floor
and Third (PB89-179-527) National Emmaus, PA 18049
Conferences also are available from the 215-967-4135
Center for Environmental Management,

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 INFORMATION RESOURCES

Garbage HHW Project

2 Maine Street Washington Department of Ecology
Gloucester, MA 01930 P.O. BOX 47655
508-283-3200 Olympia, WA 98504-7655
206-459-6303
Household Hazardous Waste Management
News Massachusetts League of Women Voters
The Waste Watch Center 133 Portland Street
16 Haverhill Street Boston, MA 02114
Andover, MA 01810 617-523-2999
508-470-3044 Prevention Program
Resource Recycling Contra Costa County Health Services
P.O. Box 10540 75 Santa Barbara Road
Portland, OR 97210 Pleasant Hill, CA 94523
800-227-1424 510-646-6511
Wanner Bulletin Refuse Industry Products, Inc.
The World Resource Foundation P.O. Box 1011
83 Mount Ephraim Grass Valley, CA 95945
Tunbridge Wells, Kent UK TN4 8BS 916-274-3092
0892-24626 San Bernardino County DHS
Waste Age HazMat Risk Assessment & Planning
1730 Rhode Island Avenue, NW. 385 N. Arrowhead Ave.
Suite 1000 San Bernardino, CA 92415-0160
Washington, DC 20036 714-387-4629
202-861-0708 The Video Project
World Wastes LMV of California
Communications Channels, Inc. 926 J Street, Suite 1000
6255 Barfield Road Sacramento, CA 95814
Atlanta, GA 30328 916-442-7215
404-256-9800
HHW Curricula for
Audiovisual Materials Schools
(compiled from information provided by
Videotapes and other audiovisual materials
the Household Hazardous Waste Project,
are available from: Springfield, MO)
Ecology Center of Ann Arbor Activities for Teaching about Hazardous
417 Detroit Street Materials in the Home (1989). Grades:
Ann Arbor, MI 48104 K-3, 4-6,7-9, 10-12. ERIC Science,
313-761-3186 Mathematics, and Environmental
Environmental Health Coalition Education Clearinghouse, The Ohio State
1717 Kettner Blvd. #100 University, 1200 Chambers Road, 3rd
San Diego, CA 92101 Floor, Columbus, OH 43212,
619-235-0281 614-292-6717.

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I N F O R M A T I O N R E S O U R C E S

Bags, Beakers, and Barrels: An Action Household Hazardous Materials: Pollution

Curriculum Toward Resolving Hazardous Solutions Start at Home ( 1989). Three
Materials Issues (1987). Six units and 35 5-day units. Grades: Middle School.
activities. Grades: Middle and High Environmental Health Coalition, 1717
School. Industrial States Policy Center, Kettner Blvd. #100, San Diego, CA
17 Brickel Street, Columbus, OH 43215, 92101,619-235-0281.
614-224-4111. Household Hazardous Waste Educational
CHEM: Chemicals, Health, Environment, Program Kit (1986). Handbook and
and Me (1990). Ten teaching units. instructional materials. Grades: K-6. San
Grades: Middle or High School. Bernardino County, Department of
Chemical Education for Public Environmental Health Services,
Understanding Program (CEPUP), Environmental Education Program, 385
Lawrence Hall of Science, University of N. Arrowhead Avenue, San Bernardino,
California, Berkeley, CA 94720, CA 92415-0160,714-387-4639.
510-642-8718. Household Hazardous Waste Learning
Garbage in America (1988). Recycling and Stations (1990). Ten learning stations and
environmental curriculum, including a video. Grades: 4-6. Minnesota
video. Grades: K-6, Junior High, Senior Pollution Control Agency, 520 Lafayette
High. Refuse Industry Productions, P.O. Road North, St. Paul, MN 55155,
Box 1011, Grass Valley, CA 95945, 612-297-8324. Will distribute only in MN.
916-274-3092. Household Toxics (1988). Grades: 4-6. Six
lesson plans with activities and games.
Hazardous Waste Education Kit. Kit with 5
Environmental Health Coalition, 1717
workbooks and a resource section.
Kettner Blvd. #100, San Diego, CA
Grades: 7-9. Federation of Ontario
92101,619-235-0281.
Naturalists, 355 Lesmill Road, Don Mills
ON, M3B 2W8 CANADA, Household Toxics (1 989). Interdisciplinary
416-444-8419. with activities and teaching materials.
Grades: 5-6. Municipality of Anchorage,
Hazardous Wrote School Curriculums. Solid Waste Services, P.O. Box 196650,
Grades: K-12. State of Alaska, Anchorage, AK 99519-6650,
Department of Environmental 907-261-5221.
Conservation, PO. Box O, Juneau, AK
99811-1800,907-465-2671. Making the Connection. A Teacher's Guide
to Household Hazardous Substances and
Healthy Environment-Healthy Me (1990). the Classroom. Video with activities and
Interdisciplinary with videos. Grades: resources. Grades: Middle and High
K-5. Resource Center for EOHSI, School Teachers. Ecology Center of Ann
Brookwood II, 45 Knightsbridge Road, Arbor, 201 Detroit Street, Ann Arbor, MI
Piscataway, NJ 08854,908-463-5353. 48104,313-761-3186.
Household Hazardous Materials and A Manual for the Household Hazardous
Labels: A Reference for Teachers (1986). Materials Audit (1987). Booklet and
Book and worksheets. Grades: Middle survey. Grades: Middle Schools through
School. East Michigan Environmental Adults. Alaska Center for the
Action Council, 21220 West Environment, 519 W 8th Avenue, Suite
Fourteen-mile Road, Birmingham, MI 201, Anchorage, AK 99501,
48010,313-258-5188. 907-274-3621.

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Project Erase Waste (1991). Ten lessons Tools for the Environmental Teacher (1992).
about solid waste management with Inventory, worksheets, and a game.
activities. Grade: 6. Kern County Waste Grades: Junior and Senior High
Management 2700 “M” Street, Suite 500, School. Household Hazardous Waste
Bakersfield, CA 93301,805-861-2159. Project, 1031 East Battlefield, Suite
214, Springfield, MO 65807,
SLEUTH: Strategies and Lessons to
417-884-5000.
Eliminate Unused Toxicants, Help!
(1982). Teaching unit that presents HHW Toxics in My Home? You Bet! (1984).
issues. Grades: 4-12. METRO, Water One-week curriculum available in
Resources Section, HHW Project, 821 English and Spanish. Grades: K-12.
Second Avenue, MS 81, Seattle, WA Local Government Commission, Inc.,
98104-1598,206-684-1233. This 909 12th Street, Suite 205, Sacramento,
document is only available on a CA 95814,916-448-1198.
check-out basis.

Too Close for Comfort: Reducing

Household Toxics. Video on health and
environmental problems associated with
common household products. Grades: 4
through Adult. Prevention Program, 75
Santa Barbara Road, Pleasant Hill, CA
94523,510-646-6511.

73
 1. Do you own or rent your home?
❑ Rent Own

Sample Participant 2. Ageunder25

❑ 26-40 ❑ 41-65 ❑ Over 65
Questionnaire 3. Sex
❑ Female ❑ Male

4. City Zip Code

5. This waste is left over from what type of operation?

❑ Household ❑ Farming/ranching ❑ Commercial/business
6. Please check the type of hazardous waste you brought:
❑ Used oil Medications
❑ paint ❑ Unlabeled Containers
Solvents ❑ Pesticides ❑ Batteries ❑ Other Wastes
7. Are the wastes you brought from more than one household?
Yes ❑ No
How many households?
8. How long have you had the wastes?

9. How far did you drive to come to today’s collection event?

❑ 1-5 miles 6-10 miles 11-15 miles
16-20 miles Over 20 miles
How far would you be willing to drive?
10. How did you hear about the collection day?
❑ Poster ❑ Billboard ❑ Radio ❑ Brochure delivered to home
❑ Television ❑ Insert with utility bill ❑ Newspaper article ❑ Word of mouth
❑ Newspaper ad ❑ School/children ❑ Grocery store flyer
Other
Il. Have you ever been to a household hazardous waste collection before?
Yes N o

l2. How much would you be willing to pay to dispose of your household hazardous waste on a regular basis?
(Household hazardous waste is very expensive to dispose of properly-over $350 per drum for waste paint.)
Nothing $5/month $ (fill in amount)
13. How often would you use a household hazardous waste collection in your area?
Monthly Twice a year Once a year Once every 2 years
14. If this collection event had not been held, what would you have done with your
household hazardous waste?

Source Dakota County Household Hazardous Waste Collection Inventory and Data Sheet; San Francisco Household Hazardous Waste Collection Facility
Participant Questionnaire; Klickitat County Household Hazardous Waste Collection Days Questionnaire; Iowa Deportment of Natural Resources Toxic Cleanup
Days Questionnaire.

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