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What are Household Hazardous Materials? Many products used in the home every day contain hazardous and toxic chemicals. The typical American household uses products that may contain 100 or more different substances listed as hazardous by the U.S. Environmental Protection Agency (EPA). Examples of these products include insecticides, pesticides, and fungicides; wood preservatives; motor oil and automotive supplies; paints, thinners, stains and varnishes; adhesives and glues; heating oil; medicines, cosmetics, nail polish and removers; batteries; various cleaners and polishes; swimming pool chemicals; and smoke detectors. When discarded, these products have generally been referred to as "household hazardous waste," a term that inaccurately describes the waste. The term is being replaced by the more accurate term "household hazardous materials." Although household hazardous materials (HHM) may exhibit the same physical characteristics of ignitability, corrosivity, reactivity, and/or toxicity that are normally used to characterize hazardous wastes regulated under federal law, they are not directly regulated under Subtitle C of the Resource Conservation and Recovery Act (RCRA), the federal law governing solid and hazardous waste management and disposal practices. Title 40 Code of Federal Regulations (CFR) 261.4(b)(1), EPA regulations promulgated under RCRA, specifically declares all solid wastes generated by households (including military housing) to be non-hazardous waste under RCRA. However, despite its RCRA non-hazardous status, communities still must manage the collection and disposal of HHM in accordance with any other applicable federal, state, or local laws and ordinances. For example, municipal waste disposal facilities may be required to screen for HHM in order to avoid operating under more restrictive local laws applicable to facilities accepting wastes that exhibit hazardous characteristics (i.e., HHM). In addition, some communities may be required to establish a HHM management program in order to qualify for local permits needed to manage stormwater runoff and discharge. Even in those areas where there are no direct or indirect regulatory requirements to control HHM, it is still important to manage and dispose of HHM properly. Proper management of HHM can have many benefits including protection of surface water, soils, and groundwater from contamination; prevention of hazardous discharges from landfills; and ensuring normal biological processes at municipal wastewater treatment plants are not disrupted by toxic chemical discharges into sewers. The purpose of this fact sheet is to describe some of the potential dangers associated with HHM, as well as to provide information about how to properly manage and prevent the generation of HHM. Also included are sources of additional information, as well as examples of Air Force installations that have successfully implemented HHM management programs. Preventing the Generation of HHM The U.S. Environmental Protection Agency estimates that the average American household disposes of about 20 pounds of HHM each year, and that as much as 100 pounds of products containing hazardous ingredients accumulate in the home and remain there until the resident moves or undertakes a thorough "spring cleaning." The EPA also estimates that HHM accounts for approximately one percent, or 1.6 million pounds, of a typical community's annual solid waste output. There are several ways to prevent the generation of HHM. One is to purchase products that are free of hazardous materials. Reading the label on a product can provide a great deal of information including its ingredients, use, proper storage, and occasionally even disposal instructions. If the product contains hazardous ingredients, certain key words (amongst the list of unrecognizable chemical ingredients) can also serve as a guide to the purchaser that the contents could pose an environmental threat if not managed properly:
Finally, properly using and storing products can also avoid HHM generation by preventing spills. Avoiding spills prevents waste of unused HHM as well as the need to dispose of contaminated rags used for cleanup. Applicability of DoD's New Diversion Goals The Department of Defense (DoD) established new Pollution Prevention Measures of Merit (MoM) effective January fiscal year (FY) 1999. The MoM for non-hazardous solid waste is to achieve, where economically feasible, a 40 percent or greater diversion rate by the end of FY2005. The diversion rate is the rate at which non-hazardous solid waste is diverted from entering a disposal facility. As previously stated, when HHM is disposed of in a household's regular trash, it is classified as a non-hazardous solid waste under RCRA, and becomes part of the installation's overall solid waste stream. Therefore, establishing a HHM management program that removes these items from the solid waste stream not only provides for an environmentally preferable disposition for them, it also assists the installation with meeting its diversion goals. For copies of DoD measure of merit documents, please contact PRO-ACT. Establishing a HHM Management Program As mentioned above, many communities establish HHM management programs in response to local directives restricting the disposal of certain types of wastes in landfills. On Air Force installations, HHM programs are typically managed by a team of on-base organizations including Civil Engineering, Bioenvironmental Engineering, the Hazardous Materials Pharmacy (HAZMART), the Qualified Recycling Program (QRP) Manager, and the Housing and Legal Offices. By combining the expertise of these groups, the installation is assured of meeting all Air Force, federal, state, and local requirements that govern the management of a HHM program, as well as obtaining the necessary logistical and financial support needed to make the program a success. The Air Force does not currently have specific instructions applicable to HHM management programs. Most of these programs are established independently by installations in response to local circumstances, concerns, and level of community awareness. Technical assistance and support for establishing HHM programs is available from Headquarters Air Force Center for Environmental Excellence, Environmental Quality Directorate (HQ AFCEE/EQ), Brooks AFB, TX, DSN 240-3371. Installations should also communicate with their State and local community officials, who are generally willing to share their own HHM management experiences and provide guidance. In addition, funding for these types of programs is generally not available through normal AF environmental funding channels and is at the discretion of the installation Commander. The best place to start when planning an installation HHM management program is the State agency responsible for regulating hazardous waste. This agency should be able to provide guidance on any existing regulations applicable to HHM, and provide the names of nearby hazardous waste treatment, storage, and disposal facilities (TSDFs) that can accept items that cannot be otherwise used. It is also prudent to check with local governments (city, county, township) for any regulations or ordinances that may apply. Once this basic background material is obtained, efforts should be made to determine the scope of the HHM program and how it will be implemented at the installation. Key issues to consider will include:
Budgeting for a HHM Management Program
The cost of running a HHM management program will depend on the types and amounts of waste the facility accepts, and the manner in which materials that cannot be reused are disposed of. Recycling and reusing/exchanging as many of the turned-in products as possible is generally the least costly option. Some items that may be recycled include used batteries, oil, antifreeze, and used solvents; while good candidates for exchange include products such as unused solvents, paints, pesticides, motor oil, household cleaning products, and antifreeze.
HHM not recycled or exchanged must be disposed of in accordance with applicable regulations. Federal regulations require different treatment and disposal methods for different types of waste. For example, some pesticides may require incineration, while other pesticides may be allowed in a hazardous waste landfill. Other hazardous wastes may be destroyed or detoxified through chemical or biological processes. The appropriate methods and resulting cost will be dictated by the types of waste, any applicable land disposal restrictions, and the proximity of the community/installation to treatment facilities.
Disposal costs are, by far, the greatest expense associated with a HHM management program. According to the EPA, the proper disposal of one 55-gallon drum of the most hazardous materials such as pesticides, dioxins, or polychlorinated biphenyls (PCBs) can cost $850. Transporting used oil and solvent-based paints to a facility to be used as supplemental fuel in an approved burner typically costs $175 to $250 per drum, while the cost of sending most other wastes to a hazardous waste incinerator or hazardous waste landfill ranges from $350 to $500 per drum.
Defining Types & Quantities of HHM to be Accepted by the Program
Once it is known what types of HHMs may make their way into the program, it is important to consider any potential problems that may be associated with disposing of these items if they are not able to be reused by the base community. Certain HHMs, such as pesticides or used smoke detectors (which often contain a small amount of radioactive material) may be barred from disposal in local landfills or from the installation's TSDF. However, the HHM program may still be able to accept these items because smoke detectors can often be returned to the manufacturer for recycling, and excess pesticides can be donated to local businesses, charities, or other local non-profit organizations such as the Boy or Girl Scouts. Good sources of information for identifying alternative "disposal" methods may be found by visiting a State's household hazardous material/waste World Wide Web (WWW) site, or requesting that the TSDF provide any alternatives they may have for the wastes they exclude. Determining what materials may or may not be acceptable into the HHM program should be a continuous process. Restrictions may ease over time and alternative solutions may become available so that new materials may be brought into the program. Conversely, restrictions may become more stringent or donation sources may change, thus requiring previously accepted items to be prohibited from inclusion in the program.
The HHM management program must also determine what impacts other regulations may have on the types of material the program can accept and the disposal options that can be used for materials that ultimately cannot be reused/exchanged. For example, some hazardous materials may be subject to RCRA land disposal restrictions (LDRs), and may have to be disposed of in a hazardous waste incinerator rather than a hazardous waste landfill. In addition, disposal of radioactive materials is governed by separate radioactive waste regulations, not RCRA.
After consideration of the above recommendations and constraints, a list of acceptable HHM products and alternative disposition options for excluded materials can be developed. As an example, the HHM management program at the Air Force Academy accepts cleaners, paints, batteries, and used oil in either the original container or in some other non-leaking container. They do not accept tires, medicines, compressed gasses, explosives, or ammunition. The final list of acceptable items will depend upon different conditions and circumstances at each installation. In addition, one of the most important decisions to be made when planning a successful HHM management program includes identifying an on-site storage area for the collected materials. Also, it is typically the HHM program manager's (usually the Qualified Recycling Program (QRP) Manager) responsibility to ensure that materials that cannot be reused/exchanged are disposed of properly.
Establishing HHM Management Operating Procedures
Implementing a HHM management program requires the identification of a facility where personnel can drop off HHMs that can be redistributed to on-base housing residents. Establishing a permanent facility allows for year-round service to families and individuals moving into or out of the on-base community. Some installations have had success incorporating the permanent drop-off facility into the existing recycling center, hazardous material pharmacy (HAZMART), or Self-help Store. In addition to the permanent drop-off facility, at least one installation has had success with curbside HHM collection. Collecting HHM curbside from military housing areas is most effective if it is limited to a few types of materials collected on a regularly scheduled basis. Used oil, household batteries, and paints are good candidates for this type of collection. Although this method is very labor intensive, it can be accomplished under a contract vehicle (see the Andersen AFB Success Story below).
Successful HHM collection programs will also frequently supplement existing recycling programs or the HAZMART pharmacy. In addition, many Army Air Force Exchange Service (AAFES) service stations accept used automobile batteries in exchange for a new battery purchase, and may also accept used motor oil and tires for a nominal fee.
In addition to determining how the HHM will be collected for exchange/reuse, there are other operational procedures that must be determined before a program can be implemented. These procedures include establishing:
Publicizing the Program and Raising Community Awareness
Public announcements for "advertising" the HHM program should include the following information:
Andersen AFB Recognized as Recycling Leader
An education program was initiated for MFH residents to raise their awareness of the potential for recycling through the reduction, reuse, and separation of wastes. There are 1,756 residential units in military family housing (MFH) at Andersen AFB, a good source of recyclable materials. Curbside pickups of recyclable materials and household chemicals were established throughout MFH. However, the program had no manpower or vehicles assigned, nor was there money to let a contract at this early stage. To remedy this situation, Andersen AFB sought out and obtained permission to borrow vehicles from the War Reserve Material (WRM) stockpile, volunteers fabricated necessary support equipment, and a request was submitted and approved for Air National Guard man-days so Guard members could be utilized for curbside pickups. Through the use of these innovative solutions, the recycling and HHM management programs were able to save approximately $160,000 in FY98.
The use of Guard members was only meant as a temporary measure, and in a short time two contracts were let, one small temporary one, the other a larger one for one year with an option for four additional years. The larger contract started just in time for the beginning of FY99, and covers curbside pickup at MFH, base pickups, and the processing of materials at Andersen's new state-of-the-art Recycling Center. The contractor conducts weekly pickups throughout MFH where residents are responsible for taking the bins to the curb on their designated pick-up day. Items such as leftover paints, window cleaner, spray-on lubricants, varnishes, and furniture polish, are singled out for reuse and/or recycling. The biggest users of this program are families moving into or out of MFH; those at the end of their tours dropping off used products, and newly arriving families picking up products for use in their base-assigned homes.
Volunteers from all organizations on-base help collect and containerize household hazardous materials that cannot be reused or recycled for proper disposal. Off-base residents of the island also participate in this program. A big benefit to allowing off-base participation is the reduction in illegal dumping that could result in dangerous chemicals contaminating the island's sole underground source of drinking water. The Air Force, Navy, and Guam EPA formed a partnership to combat recurring improper disposal of HHM throughout the island. The partnership is called "Hasso Guam," which means "Think of Guam." To find out more about Andersen AFB's easily adaptable recycling programs, contact Mr. Russ Grossley, 36 CES/CEVQ, Andersen AFB, DSN 315-366-2557.
Minimization of Hazardous Lighting Waste through Recycling at the USAF Academy
The Academy provides the following background information to those interested in learning more about recycling mercury lamps:
"Fluorescent and HID lamps contain a small quantity of mercury that can be harmful to the environment and to human health if improperly disposed of. Mercury is regulated under RCRA and lamps containing more than 5 parts per million (ppm) of mercury as identified through the toxicity characteristic leaching procedure (TCLP) must be managed as hazardous waste. When lamps are tested using TCLP, the test results vary considerably, depending on the lamp manufacturer, the age of the lamp, and the laboratory procedure used. The cost to test one lamp is approximately $140. Any lamp may be recycled at permitted or licensed recycling facilities. The recycling process separates the toxic substances from the glass, aluminum, and other lamp components, and all materials may be reused in manufacturing other products. Recycling costs for fluorescent lamps are typically calculated by linear foot and average $0.10/ft. Disposal costs for fluorescent lamps at a hazardous waste landfill range from $0.25 - $0.50 per 4-foot tube. Because of the varied supply of lamps purchased for the Academy, it is more cost-effective to recycle all fluorescent and HID lamps versus sampling them for hazardous waste determination. Not only does recycling of the lamps save money over the long run, it also is better for the environment and serves as a waste minimization initiative."
For more information about recycling and hazardous waste minimization at the Air Force Academy, contact Ms. Diana Dean or Ms. Carol McKinney at DSN 333-4483 for referral.
Household Reuse Program at Bolling AFB
Bolling's Household Reuse Program accepts only household cleaning and maintenance products, automotive products, paints/thinners, and household pesticides and herbicides. Bolling requires that the products turned in be in their original non-leaking container, be in good condition, have a sealed lid or cap, and display a legible manufacturer's label. The Program does not accept chemicals in any other condition. The base currently uses three storage cabinets in the Household Reuse area of the HAZMART to store the chemicals. The on-base residents drop off their excess chemicals (only those that are accepted) at the Household Reuse area, where HAZMART personnel segregate them into the proper cabinet. Customers are allowed to browse the cabinets at any time for household chemicals they can use. Consequently, Bolling's Household Reuse Program requires very little cost and manpower.
For the customer's convenience, the Household Reuse Program accepts products during all daytime, as well as some evening and weekend hours. It has been well publicized on the base via print and television media. It is estimated that over $10,000 in savings were passed on to Household Reuse Program customers in fiscal year 1998. Any questions about Bolling AFB's Household Reuse Program should be directed to SSgt Hendrickson or Senior Airman Peterson at the HAZMART Pharmacy, (202) 767-8294 or DSN 297-8294.
The Waste Watch Center (WWC) is a non-profit organization devoted to education, consensus building, and policy development in the areas of solid and hazardous waste management. It is the national clearinghouse for information on household hazardous material (HHM) concerns. The WWC maintains a database of HHM management programs nationwide, including over 300 permanent HHM facilities and more than 2,000 HHM collection programs. Projects initiated by the WWC include Public Education Programs, Plans, and Materials Development Projects; HHM Programs Planning and Design Projects, Specialized Pilot Program Development and Implementation; and Research and Policy Analysis. The WWC's WWW site offers links to State-by-State HHM Information and National HHM Contractors, as well as a selection of Publications and Brochures. Each State site contains points of contact, applicable regulatory citations and publications, and a list of communities in the state with active HHM programs. Visit the WWC WWW site at http://www.wastewatch.org/.
EPA Regional Offices are responsible within selected states for the execution of EPA programs, considering regional needs and the implementation of federal environmental laws. Links to each of the 10 EPA Regional Offices are located at http://www.epa.gov/epahome/locate2.htm. Many of the EPA Regions can provide region-specific information on household hazardous materials programs and contractors.
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