National Survey of Household and Small Business Hazardous Waste Collections

Small businesses that generate hazardous waste can be classified as Conditionally Exempt Small Quantity Generators (CESQG) if they produce less than 100 kilograms per month of hazardous materials. The United States Environmental Protection Agency (EPA) allows collection of these materials through Household Hazardous Waste (HHW) collection programs, as many of the materials are similar or identical to materials already being collected from households. However, the EPA defers to the states on the regulation of this activity, and some states do not allow collection of CESQG material through HHW programs. To gain more information on this issue, the Lone Star Chapter of the North American Hazardous Materials Management Association (NAHMMA) conducted a survey of Household Hazardous Waste (HHW) collection programs nationwide. The purpose of the survey was to determine how many states allow the collection of Conditionally Exempt Small Quantity Generator (CESQG) waste through HHW programs, and to assess the pros and cons of CESQG collection via HHW programs.

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The survey results show that 31 of 50 states, or 62% of states, do allow collection of CESQG through HHW programs. In states allowing such activities, primary reasons given for doing so were to provide a cost-effective disposal option to small businesses, to protect the environment through prevention of illegal dumping, and to mitigate the costs of providing HHW collection to citizens. The primary drawbacks to CESQG collection through HHW programs were a reluctance to accept and handle payments, need for increased capacity and training, and potential for increased liability. Because CESQG collection is not mandatory even in states where it is allowed, the majority, if not all potential drawbacks are avoided by allowing each HHW facility to elect not to collect CESQG materials if they did not wish to do so. The North American Hazardous Materials Management Association (NAHMMA) has recognized that significant environmental, financial and programmatic benefits can be realized by collecting CESQG waste through HHW programs. NAHMMA recommends that states not currently allowing these activities consider reviewing their current policies and regulatory structure. NAHMMA members are available to speak to the benefits and to provide examples of successful collection program options.

Pros of CESQG Collection Via HHW Programs

• Cost-effective disposal option for small businesses
• Protection of the environment
• Prevention of illegal dumping
• Reduces the cost burden of HHW disposal
• Existing resources used to handle greater volume
• Ability to assist with school laboratory cleanouts

Cons of CESQG Collection Via HHW Programs

• Need for increased capacity
• Inability/lack of desire to handle financial transactions
• Need for more training
• Potential for increased liability

To read the complete report which has been endorsed by the North American Hazardous Materials Management Association and the Environmental Quality Company, Click here.