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Retail Collection of Retail Collection of Universal Waste and Universal Waste and
Latex PaintLatex Paint
Some background...Some background...
Many unused and unwanted consumer Many unused and unwanted consumer products are classified as hazardous waste in products are classified as hazardous waste in CaliforniaCalifornia
Hazardous waste, including HHW, is banned Hazardous waste, including HHW, is banned from solid waste landfills in this statefrom solid waste landfills in this state
As of 2006, households may no longer dispose As of 2006, households may no longer dispose of batteries, lamps and electronic devices in of batteries, lamps and electronic devices in the trashthe trash
That’s good for public health and the That’s good for public health and the environment, but...environment, but...
The problemThe problem
UW and Latex paint some of the largest UW and Latex paint some of the largest volume wastes @ HHWCFsvolume wastes @ HHWCFs
Are (or are presumed be) hazardous Are (or are presumed be) hazardous wasteswastes
Costly to handle, transport, and Costly to handle, transport, and dispose/recycledispose/recycle
Some paint numbersSome paint numbers
Julia Au of SF Environment recently surveyed Julia Au of SF Environment recently surveyed 30 HHWCPs about paint30 HHWCPs about paint
During their reporting year, respondents During their reporting year, respondents collected collected 1.45 million gallons1.45 million gallons of paint at a cost of paint at a cost of nearly of nearly $9.6 million$9.6 million(Average cost per gallon = $ 7.06)(Average cost per gallon = $ 7.06)
This represents, on average, This represents, on average, 50.7 percent50.7 percent of of the respondents’ total waste volume and the respondents’ total waste volume and 38.9 38.9 percentpercent of their total cost of their total cost
Other options...Other options...
Paint, batteries, lamps, and electronics Paint, batteries, lamps, and electronics don’t don’t havehave to be collected at the HHWCF to be collected at the HHWCF
Retail take-back is very feasibleRetail take-back is very feasible Simple options for authorizationSimple options for authorization
Normally, collecting HHW Normally, collecting HHW requires a permit, but...requires a permit, but...
Universal wasteUniversal waste: exempt, pursuant to : exempt, pursuant to 66261.9 of title 22 of the California Code 66261.9 of title 22 of the California Code of Regulationsof Regulations
RecyclableRecyclable latex paint: exempt, pursuant latex paint: exempt, pursuant to section 25217.2 (a) of the California to section 25217.2 (a) of the California Health and Safety Code (“Recyclable Health and Safety Code (“Recyclable latex paint may be accepted at any latex paint may be accepted at any location if all of the following conditions location if all of the following conditions are met...”)are met...”)
Advantages of retail Advantages of retail collectioncollection
Convenient for householdsConvenient for households Frees up the resources of local HHW Frees up the resources of local HHW
collection programs for higher-hazard collection programs for higher-hazard wasteswastes
Quantity limits for CESQG don’t applyQuantity limits for CESQG don’t apply
What about mandatory What about mandatory retail take-back?retail take-back?
Currently, only a few State mandates for Currently, only a few State mandates for retail take-back in California:retail take-back in California:Rechargeable batteries Rechargeable batteries Cell phonesCell phonesMercury thermostatsMercury thermostats
How are these mandatory How are these mandatory take back laws working?take back laws working?
Rechargeable batteries:Rechargeable batteries: 2007: 4.2 million pounds2007: 4.2 million pounds 2008: 5.6 million pounds2008: 5.6 million pounds
Cell phones: estimate 25 percent Cell phones: estimate 25 percent recycling rate recycling rate
Other proposed EPR Other proposed EPR legislation...legislation...
California Product Stewardship Act California Product Stewardship Act – AB 283 (Chesboro): 2-year bill– AB 283 (Chesboro): 2-year bill
Architectural Paint Stewardship ProgramArchitectural Paint Stewardship Program – AB 1343 (Huffman): 2-year bill– AB 1343 (Huffman): 2-year bill
Residential Fluorescent Lamp Recycling Residential Fluorescent Lamp Recycling ProgramProgram – AB 1173 (Huffman): vetoed by – AB 1173 (Huffman): vetoed by the Governor the Governor
Mandatory take-back in Mandatory take-back in other jurisdictionsother jurisdictions
OregonOregon: new paint law is the nation’s first state : new paint law is the nation’s first state requirementrequirement Includes the cost of safely managing leftover paint in Includes the cost of safely managing leftover paint in
the purchase price of new paintthe purchase price of new paint Sets up an industry-led program to reduce paint Sets up an industry-led program to reduce paint
waste, increase reuse and recycling, and safely waste, increase reuse and recycling, and safely dispose of unusable paintdispose of unusable paint
San Luis Obispo CountySan Luis Obispo County: ordinances require : ordinances require paint, batteries, fluorescent lamps, and sharps paint, batteries, fluorescent lamps, and sharps be taken backbe taken back
A partial solution: voluntary A partial solution: voluntary retail collectionretail collection
Retailers voluntarily taking back Retailers voluntarily taking back waste:waste:
Electronic devicesElectronic devices
Fluorescent lightingFluorescent lighting
Paint Paint
The challenge of The challenge of voluntary retail collectionvoluntary retail collection
Marketing to retailersMarketing to retailers They will have concerns about:They will have concerns about:
FundingFunding Safety/LiabilitySafety/Liability MessesMesses SpaceSpace Illegal dumping/orphaned wasteIllegal dumping/orphaned waste
Making retail take back Making retail take back more appealing to a retailermore appealing to a retailer
Things you can say to a retailer:Things you can say to a retailer: Promotes foot trafficPromotes foot traffic Good publicityGood publicity
Things you can do:Things you can do: Provide signage to the retailerProvide signage to the retailer Have your contractor pick it up the paint, UWHave your contractor pick it up the paint, UW
More about the More about the wastes...wastes...
What is “recyclable latex What is “recyclable latex paint?”paint?”
Health and Safety Code section 25217: Health and Safety Code section 25217: “... any water-based latex paint, still in “... any water-based latex paint, still in liquid form, that is transferred for the liquid form, that is transferred for the purposes of being recycled”purposes of being recycled”
If it’s not “recyclable,” it doesn’t meet the If it’s not “recyclable,” it doesn’t meet the definition and the exemption allowing definition and the exemption allowing retail collection doesn’t applyretail collection doesn’t apply
Is latex paint a hazardous Is latex paint a hazardous waste?waste?
Latex paint is listed in Title 22 as Latex paint is listed in Title 22 as presumed to be hazardous wastepresumed to be hazardous waste
Most modern latex paints probably aren’t, Most modern latex paints probably aren’t, but...but...
The generator usually The generator usually won’t know if his/her paint won’t know if his/her paint is or isn’t HWis or isn’t HW
What is universal waste?What is universal waste?
Common, widely generatedCommon, widely generated By definition, universal wastes are hazardous By definition, universal wastes are hazardous
wastes, but exempt from the usual ruleswastes, but exempt from the usual rules BatteriesBatteries Fluorescent and other HW lampsFluorescent and other HW lamps Electronic devicesElectronic devices Mercury devices, including thermostatsMercury devices, including thermostats Aerosol cansAerosol cans
Overview of the Rules Overview of the Rules for Collecting Waste for Collecting Waste Latex PaintLatex Paint
California Health and Safety Code California Health and Safety Code Chapter 6.5, Article 10.7Chapter 6.5, Article 10.7
Collecting waste latex paintCollecting waste latex paint
No disposal to land or waterNo disposal to land or water May be accepted May be accepted and recycledand recycled at any at any
location, provided it’s managed location, provided it’s managed properly/safelyproperly/safely
If it turns out not to be recyclable, it’s If it turns out not to be recyclable, it’s considered generated as a waste at the considered generated as a waste at the retail site and must be managed retail site and must be managed accordingly (e.g., as hazardous waste)accordingly (e.g., as hazardous waste)
Collecting waste latex paint Collecting waste latex paint (2)(2)
The collection site (e.g., retailer) must The collection site (e.g., retailer) must comply with applicable requirements for a comply with applicable requirements for a Hazardous Materials Business Plan Hazardous Materials Business Plan (Health and Safety Code chapter 6.95)(Health and Safety Code chapter 6.95) Check with your local CUPACheck with your local CUPA
No DTSC notification or reporting No DTSC notification or reporting requiredrequired
Transporting waste latex Transporting waste latex paintpaint
Use of a registered transporter is not Use of a registered transporter is not requiredrequired
Manifest not required; bill of lading OKManifest not required; bill of lading OK Must include required informationMust include required information 3 year record retention requirement3 year record retention requirement
California’s latex paint California’s latex paint remanufacturing facilitiesremanufacturing facilities
We have several...We have several... Amazon – WhittierAmazon – Whittier E-Coat (division of Kelly-Moore) – E-Coat (division of Kelly-Moore) –
Sacramento Sacramento Visions – McClellanVisions – McClellan
Where are they getting it? Where are they getting it? How much do they recycle?How much do they recycle?
Amazon Paint says:Amazon Paint says: 80 percent of paint they accept comes 80 percent of paint they accept comes
from HHW facilitiesfrom HHW facilities On a weekly basis, they accept 10,000 On a weekly basis, they accept 10,000
gallons of paintgallons of paint
What do remanufacturing What do remanufacturing facilities do?facilities do?
Recycled in 2 ways:Recycled in 2 ways:
1.1. Reprocessed into new paintReprocessed into new paint FilteringFiltering Mixing with standard paintMixing with standard paint Adding pigmentsAdding pigments Adjusting pHAdjusting pH
2.2. Used as a cement additiveUsed as a cement additive
Overview of the rules Overview of the rules for Universal Wastefor Universal Waste
California Code of RegulationsCalifornia Code of RegulationsTitle 22, Chapter 23Title 22, Chapter 23
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Seven categories of Seven categories of universal wasteuniversal waste
BatteriesBatteries Mercury containing equipmentMercury containing equipment LampsLamps Aerosol cansAerosol cans Electronic DevicesElectronic Devices Cathode Ray Tubes (CRTs) Cathode Ray Tubes (CRTs) CRT glass CRT glass
A retailer that accepts universal waste A retailer that accepts universal waste (batteries, lamps, electronics, etc.) (batteries, lamps, electronics, etc.) generated off-site (e.g., from customers) generated off-site (e.g., from customers) is regulated as a is regulated as a universal waste handleruniversal waste handler
2828
Universal waste handlers Universal waste handlers
Universal waste handler Universal waste handler requirementsrequirements
ProhibitionsProhibitions NotificationNotification Waste Waste
ManagementManagement Labeling/MarkingLabeling/Marking Accumulation Time Accumulation Time
LimitsLimits
Personnel TrainingPersonnel Training Response to Response to
ReleasesReleases Offsite ShipmentsOffsite Shipments Tracking ShipmentsTracking Shipments ExportsExports
As universal waste handlers, retail As universal waste handlers, retail collectors are prohibited from:collectors are prohibited from:
Disposing of, Disposing of, Diluting, or Diluting, or ““Treating” universal waste.Treating” universal waste.
3030
Universal waste handlers: Universal waste handlers: prohibitions prohibitions
3131
Universal waste handlers: Universal waste handlers: notificationsnotifications
A handler that may accumulate more A handler that may accumulate more than 5,000 kg of universal waste at any than 5,000 kg of universal waste at any one time must obtain either a California one time must obtain either a California or a federal EPA ID# for each locationor a federal EPA ID# for each location
A retailer that plans to accept electronic A retailer that plans to accept electronic waste from the public must also notify waste from the public must also notify DTSC 30 days in advanceDTSC 30 days in advance
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Universal waste handlers: Universal waste handlers: waste managementwaste management
In general, the handler must manage In general, the handler must manage universal waste “in a way that prevents universal waste “in a way that prevents releases of any universal waste or releases of any universal waste or component of a universal waste to the component of a universal waste to the environment...”environment...”
Accumulate lamps in a closed containerAccumulate lamps in a closed container Prevent breakagePrevent breakage
3333
Universal waste Universal waste handlers: labelinghandlers: labeling
Label each item or container with one Label each item or container with one the following phrases (as appropriate):the following phrases (as appropriate): ““Universal Waste – Batteries”Universal Waste – Batteries” ““Universal Waste – Lamps”Universal Waste – Lamps” ““Universal Waste – Electronic Devices”Universal Waste – Electronic Devices” Etc.Etc.
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Universal waste handlers: Universal waste handlers: accumulation time limitsaccumulation time limits
A handler may accumulate universal waste A handler may accumulate universal waste for up to for up to one yearone year from the date it was from the date it was receivedreceived
No exceptions No exceptions Must be able to demonstrate the length of Must be able to demonstrate the length of
time accumulatedtime accumulated
3535
Universal waste handlers: Universal waste handlers: personnel trainingpersonnel training
Annual training is required for personnel Annual training is required for personnel who manage universal waste, or who manage universal waste, or supervise themsupervise them
Includes any person who consolidates, Includes any person who consolidates, sorts, treats, recycles, packages for sorts, treats, recycles, packages for transport, offers for transport, or transport, offers for transport, or physically relocates containers of physically relocates containers of universal wasteuniversal waste
3636
Universal waste handlers: Universal waste handlers: personnel training (2)personnel training (2)
Materials must be Materials must be writtenwritten (e.g., brochures, (e.g., brochures, electronic mail, company letters, electronic mail, company letters, pamphlets, posters, etc.) and dated pamphlets, posters, etc.) and dated
Must include:Must include: The types and hazards associated with the The types and hazards associated with the
particular universal wastesparticular universal wastes Proper disposition of the waste Proper disposition of the waste Procedures for responding to releases of e-Procedures for responding to releases of e-
wasteswastes
Three year record keeping requirementThree year record keeping requirement
3737
Universal waste handlers: Universal waste handlers: response to releasesresponse to releases
A handler is required to: A handler is required to: Immediately contain all releases of Immediately contain all releases of
universal wastes and of their residuesuniversal wastes and of their residues Determine whether any resulting material Determine whether any resulting material
is a hazardous waste, and if so, manage it is a hazardous waste, and if so, manage it accordinglyaccordingly
A handler may repackage leaking, A handler may repackage leaking, broken, or otherwise damaged broken, or otherwise damaged universal waste and manage it as universal waste and manage it as universal wasteuniversal waste
3838
Universal waste handlers: Universal waste handlers: offsite shipmentsoffsite shipments
AA handler may send or take universal handler may send or take universal waste only to:waste only to: Another universal waste handlerAnother universal waste handler A destination facilityA destination facility A foreign destination A foreign destination
If, for some reason, the shipment is If, for some reason, the shipment is rejected, the original handler can take it rejected, the original handler can take it back or arrange for another destinationback or arrange for another destination
3939
Universal waste handlers: Universal waste handlers: tracking shipments tracking shipments The handler is required to keep a record The handler is required to keep a record
of of each shipmenteach shipment sent or received sent or received Who it was shipped to/fromWho it was shipped to/from How much of each type of universal wasteHow much of each type of universal waste When it was shipped or receivedWhen it was shipped or received
The record can be in the form of a log, The record can be in the form of a log, invoice, manifest, bill of lading or other invoice, manifest, bill of lading or other shipping documentshipping document
4040
Yes, by DTSC and/or the local CUPAYes, by DTSC and/or the local CUPA A retail collection site is an off-site facility A retail collection site is an off-site facility
(i.e., it receives waste generated (i.e., it receives waste generated elsewhere)elsewhere)
CUPAs have jurisdiction for generators CUPAs have jurisdiction for generators and HMBPand HMBP
DTSC has jurisdiction over off-site DTSC has jurisdiction over off-site hazardous waste facilitieshazardous waste facilities
Can a retail collection site Can a retail collection site be inspected?be inspected?
Take home on compliant Take home on compliant retail collection programsretail collection programs
The retailer who wants to collect The retailer who wants to collect universal waste and latex paint needs to:universal waste and latex paint needs to:Know and understand the rulesKnow and understand the rulesDevelop policies to for complianceDevelop policies to for complianceCommit the time and resources to ensure Commit the time and resources to ensure
the polices are followedthe polices are followedKeep required recordsKeep required recordsPlan for the unexpected...Plan for the unexpected...
Help retailers have a Help retailers have a successful compliant successful compliant programprogram
Good for the retailer: foot traffic, Good for the retailer: foot traffic, community goodwillcommunity goodwill
Good for the HHW program: diverts Good for the HHW program: diverts waste and costwaste and cost
Good for California’s environment: more Good for California’s environment: more convenient collection sites => less likely convenient collection sites => less likely these wastes end up where they don’t these wastes end up where they don’t belongbelong
4343
Questions?Questions?
4444
Thank you!Thank you!