Transitioning to Full Producer Responsibility for Household Hazardous Waste

NAHMMA NW Chapter Conference6/25/2014

Today’s agenda• Introductions• Background

Why EPR for HHW?Canadian Programs

• Key elementsWhat products to cover Financing Services – role of HHW infrastructurePerformance standards

•Next steps

EPR - Extended Producer Responsibility• [a] manufacturer's responsibility for its product

extends to post-consumer management of that product…

• financial and management responsibility, with government oversight, [shifts] upstream to the manufacturer and away from the public sector

• Provid[es] incentives to producers to incorporate environmental considerations into the design of their products and packaging.

– Product Stewardship Institute; California Product Stewardship Institute; Upstream (formerly Product Policy Institute)

Why EPR for HHW?

From the HHW collection program point of view: •Helps us fully achieve our mission•Helps us financially

The HHW “Mission”• Protect human and health and the

environment by providing effective and environmentally sound management of HHW that is generated (in spite of our best efforts at source reduction)

• Many HHW programs are doing a valiant job of collecting the HHW generated in their region, but resources are limited, and we are not getting it all

• With a robust EPR program, we can finally get pretty darn near all of the HHW generated

Why EPR for HHW • It should be as easy to get rid of a product

as it is to buy it• Make it easy for people to do the right

thing• Fairness:– “polluter pays” principle– Industry is in the best position to take

responsibility

Benefits

• PaintCare has saved Metro ~ $1 million annually• We believe another $2 million savings

annually with wide-ranging EPR for HHW

But - it’s important to make sure EPR benefits urban, rural, large & small HHW programs!

Canadian programs

EPR programs for a variety of HHW products in these provinces:

•British Columbia•Manitoba•Ontario

see handout

Key EPR Elements• What’s covered?• How are things paid for?• What services provided and how

arranged for?• What’s required: – of stewards? – of government?

Key EPR Elements• What’s covered?– How designated – lists, standards?

• Who’s responsible?– Single or multiple stewards?

• How are things paid for?– Eco fees, cost internalization?

• How are services arranged?– Collection, consolidation, facilities, events?

• What’s required: of stewards? of government?– Convenience; “rates and dates”; plan review

EPR Elements

Other Key Elements• Promotion/education • Goals – rates & dates• Reporting• Enforcement• DEQ role (oversight, fees

to)• Disposal bans

Today’s focus• Coverage• Financing• Services• Performance

Today’s Product Coverage Focus

The “other stuff”• Flammables (e.g.,

solvents)• Pesticides• Corrosives• Other toxics &

hazardous materials

Works in progress• Paint (covered)• Mercury lights• Batteries

– Primary & Rechargeables

• Sharps• Pharmaceuticals

Conceptual Overview

Element Draft Legislative Concept

Coverage Similar products and criteria as BC, SK and Manitoba - Canada

Stewardship organizations Allow multiple

Financing No government approved fees

Services •Collectors authorized by DEQ•Coordination with other HHW materials collection

Performance requirements:• convenience• recycling\recovery rates and dates

Status quo plus (what’s collected now with more service in underserved areas)

Coverage – Q’s for discussionWorking assumption – Use criteria

similar to Canadian standards• What can we learn from Canadian

experience? • Covered products– What makes a good list? – What likely to be biggest problems?

• Non-covered products– How much non-covered comes in?– How critical to keep communicating to

public that we take all?

Financing – Q’s for discussionWorking assumption: no government approved

fees• Why? – Too many products; too costly for government

• How to handle “free riders”?• How can producers recover costs from

supply chain without government approved fee?

• Other methods?

Services – Q’s for discussionWorking assumptions: Stewards negotiate with existing permanent HHW

facilities; collection events historically expensive

• What costs – direct, indirect (capital, O&M) should HHW programs take to the table?

• How do costs for non-covered and orphaned products figure into this discussion?

Performance requirements – Q’s for discussion

Working assumption: At least status quo plus - what’s collected

now plus more service in underserved areas

• How can we establish what more should be? Beyond more?

• How coordinate with other HHW efforts (e.g., paint)?

Next steps

Further develop legislative concept

If you would like to be involved in further discussion, please sign clipboard