Household hazardous waste

Q&A: How do I dispose of hazardous waste generated by a household?

Q&A: How do I dispose of hazardous waste generated by a household?

Here’s a question I received from a distressed person with a problem back on August 2nd of 2017:

Hey Daniel,

Sorry for the unsolicited email but I’m not sure where to turn. I am cleaning out my dad’s house in <<City>> in Illinois and trying to figure out how to dispose of some normal household waste such as used oil, old gas, solvents, etc. No one can seem to tell me of a disposal site and the unspoken thread seems to be ‘don’t worry about it just drop it in the dumpster.’ Hmm, that’s not really responsible. Do you know of any collections events or sites?

I could sympathize with his distress having been in the same situation years before.  I was able to reply the same day:

Thank you for contacting me.  You are doing the right thing in trying to dispose of your waste properly.

Please refer to this link from the IEPA about HHW collection programs in IL.  Some highlights from the website:
  • 1 day collection programs are held throughout the state in the Spring and Fall.
  • You can request a program to be held in your city.
  • There is a permanent collection site in Rockford, IL open on the weekends.
  • Used oil can be brought to registered collection centers (e.g. oil change shops).
  • Latex paint can be solidified and disposed of in trash.
  • There are options for rechargeable batteries as well.
I hope this helps.
Please don’t hesitate to contact me with any other questions.

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I think I was able to help him where others didn’t because his reply was quick and exuberant:

Awesome! I’ll give this a shot:  Household Hazardous Waste Disposal / Permanent Site / 3333 Kishwaukee / Rockford, IL

Thanks,

Conclusion:

It is unfortunate that a private citizen had so much trouble trying to do the right thing.  Of course, the easiest thing to do would have been to dump the waste down the drain or set it out with the trash, but that is not what is best for the environment.  You may be asking yourself, “Why isn’t this person subject to the hazardous waste regulations when a business – generating the same waste – must comply?”  The answer is that at the beginning of the hazardous waste program created by RCRA the U.S. Environmental Protection Agency (USEPA) decided that its regulations would apply to businesses, government agencies, and commercial enterprises – i.e. a person – but not to a private citizen as a homeowner or other businesses similar to a residence such as a hotel.  The regulations codified this decision in the Household Hazardous Waste Exclusion found at 40 CFR 261.4(b)(1).

While the caller never became a customer, they did help me by reviewing my services and posting it for all to see.  You can do this too!  If you like this article or I have ever been of service to you, please take just one minute to tell the world about it!

Oregon DEQ Fines Citizen of Grants Pass for Violating Solid Waste Regulations

The Bullet:

A private homeowner – a person in the eyes of the regulations – was issued a civil penalty of $7,395 for the disposal of household waste on their property.

Who:

  • The Oregon Department of Environmental Quality (OR DEQ, or just DEQ if you live in Oregon).
  • Contact:  Katherine Benenati / Public Affairs Specialist / Eugene, OR / 541-686-7997 / benenati.katherine@deq.state.or.us
  • A person of Grants Pass.  I won’t name the person in this article.  I will refer to them as person.  See the DEQ news release if interested.

What:

From on or about January 2017 through December 5, 2017, person disposed of approximately 80 cubic yards of household garbage and other debris at their property by open burning and burial.  Upon discovery and subsequent investigation by DEQ the person was issued a civil penalty of $7,395 for violation of Oregon state regulations.  DEQ also ordered that the person clean up the property within 30 days.  Person didn’t appeal the penalty.

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

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Where:

The violations took place at the person’s property in Grants Pass, OR.

When:

  • Violations took place from on or about January 2017 through December 5, 2017.
  • On March 13 2017, person burned household garbage.
  • On May 5, 2017, DEQ staff observed that the debris pile had been burned and some debris was buried on the property.
  • Enforcement letter from DEQ to person dated December 5, 2017.
  • DEQ News Release dated March 27, 2018.

Why:

From the DEQ News Release:

Burning household trash can pollute the air and threaten public health, especially for the young, elderly and those with respiratory conditions. Illegal dumps can pollute ground and surface water. Such dumps can also threaten human health by attracting insects and rodents.

How:

The act of discarding a material – such as by open burning or burial or other activities – causes it to be subject to federal and state regulations as a solid waste.  This includes materials discarded from a household by a private citizen.  Don’t be misled by the term “solid waste”, a solid waste may be in the form of a solid, semi-solid, liquid, or containerized gas (e.g. aerosol can).

Also, under federal and state regulations a “person” includes an individual as well as a corporation and others.  Read:  Who or What is a “Person” in the Eyes of the USDOT/PHMSA and the USEPA?

Oregon, like most states, has an authorized hazardous waste program.  This means that it may create and enforce its own state-specific regulations for the management of hazardous waste.  Further, under subtitle D of RCRA, the cradle-to-grave management of non-hazardous waste is largely left to the states.

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Conclusion:

I believe this incident is significant due to the severity of the penalty ($7,395!) and the fact that it was levied against a private homeowner and not a business or government agency.  It’s clear to see that DEQ, like other state and federal agencies, takes its enforcement authority seriously.  While the creation of new legislation and regulations may lessen from one federal administration to another, the enforcement of existing regulations – especially at the state level – can proceed and even increase.

I think any business in Oregon that generates a waste should read this incident as it may have been intended: A warning from DEQ that existing regulations will be strictly enforced and there will be consequences for their violation.

Fortunately for this person, their solid waste is not regulated as a hazardous waste due to the Household Waste Exclusion from Definition as a Hazardous Waste per 40 CFR 261.4(b)(1).

What could this person have done differently?  Read: Proper Management of Household Hazardous Waste

 

Q&A: How do I Ship Hazardous Waste Generated by Homeowners?

Here is a question I received almost a year ago on December 17, 2015 from a person who found me while searching the internet for an answer to his questions:

sign for household hazardous waste collection siteDaniel, hope this finds you well.  Could you give me your opinion on waste disposal companies using ORM-D for Household Hazardous Waste (HHW) shipping names (e.g. flammable paint, cleaners that may have low or high pH and others that may fit into DOT respective hazard classes).  I am concerned as the material is no longer packaged according to the original  ORM-D packaging.  Are you familiar with any US DOT interpretation that would allow that those shipping names continue to be used?  My concern comes from reviewing a waste disposal company that is still using ORM-D shipping names.  Thanks for input and thoughts.  Wish you a Merry Christmas, Thanks.

Well, it took me a few days.  But just before Christmas (12.22.15), I replied:

I apologize for my delay in replying to your question.  I’ll do my best to answer it below.

  • Waste collected from households is excluded from regulation as a hazardous waste at 40 CFR 261.4(b)(1).  See this short presentation for more information:  The Household Hazardous Waste Exclusion.
  • Due to the HHW exclusion, the waste does not require a Uniform Hazardous Waste Manifest when transported or offered for transportation by the Shipper/Generator.
  • USDOT/PHMSA regulations define a hazardous waste as a waste that requires the Uniform Hazardous Waste Manifest when transported.  Therefore, excluded HHW is not a hazardous waste per USDOT/PHMSA regulations.
  • As you describe, the excluded HHW may be a USDOT/PHMSA hazardous material for other reasons, e.g. Class 3 Flammable, Class 8 Corrosive, &etc.
  • Hazardous materials that meet the requirements of the Consumer Commodity exception may be re-classified as an ORM-D and shipped accordingly.  Read more about the Consumer Commodity Exception in this short article.
  • Use of the Consumer Commodity Exception for an excluded HHW does require compliance with specified packing instructions but it does not require the original packaging.Household hazardous waste accumulated at collection site

In sum, if the Shipper/Generator is complying with the HHW exclusion and the Consumer Commodity Exception, then they should be able to ship the waste as a Consumer Commodity.

 I hope this helps.  Please don’t hesitate to contact me with any other questions.

Household Hazardous Waste Collection in St. Louis

After completing the Annual RCRA Refresher Training for a client in St. Louis, I had some time to drive around before heading to the airport to continue journey for the week.  I stumbled upon a site that all St. Louis residents should be aware of and hopefully take advantage of.  It’s the St. Louis Household Hazardous Waste Collection site, located on the grounds of the Lemay Wastewater Treatment Facility.

Lemay HHW FacilityHousehold Hazardous Waste - St. Louis, MO
291 E. Hoffmeister
St Louis MO 63125

Its hours of operation are Thurs-Sat 9am-5pm.

The young man operating the site that day was kind enough to answer my questions and let me take some pictures.

Directions for use of the HHWSTLSince I’m not eligible to bring my household hazardous waste here for disposal (the site is open to residences, not businesses, in St. Louis and Jefferson counties and the City of St. Louis), my interest was purely professional.

I do know that the waste generated by homeowners – not just homes, but some commercial and governmental site as well – is conditionally excluded from the definition of hazardous waste at 40 CFR 261.4(b)(1).  100_5534This USEPA exclusion for HHW extends beyond its collection at a state-approved collection site such as this one.  In other words, the waste collected at this program does not need to be managed as a hazardous waste, even after its collection.  Of course, the Treatment Storage and Disposal Facility that is responsible for final disposal of the HHW may prefer to manage it as a hazardous waste for the sake of its RCRA permit.  In addition, a state may require HHW to be managed as a hazardous waste once it leaves a collection site like this and goes to the TSDF for final disposal.Storage of HHW in St. Louis

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Unfortunately, the HHWSTL does not accept waste from a business.  If you generate a hazardous waste, then you must have some form of training for your Hazardous Waste Personnel.

Household hazardous waste collected for disposal in St. Louis, MO