Producer Responsibility for HHW

23 Feb 2016 1:00 PM | Nicole Plese (Administrator)

You’ve probably heard about PaintCare, the paint industry funded and operated program for collecting and managing leftover paint, now operating in 8 states plus the District of Columbia. Here in Oregon we were fortunate enough to be the first state to have PaintCare, which launched here in July of 2010. PaintCare is a great example of a producer responsibility program, also known as extended producer responsibility, or EPR. You can learn a lot more about EPR at the Product Stewardship Institute website, but in short it is the idea that the producers who make products should take responsibility for collection and proper management at the end of life. 

I oversee a large HHW collection program here in the Portland, Oregon metropolitan area. When PaintCare came into the picture our operating costs were reduced significantly, to the tune of $1 million annually. This caught the attention of our upper management, and we were asked to study the possibility of establishing EPR programs for other HHW that we collect, and what the cost savings from that might be. Based on the consultant study that we commissioned to answer this question, we could save up to another $2 million annually. I can share copies of this study, drop me a line if you are interested.

But the arguments for pursuing EPR for HHW go beyond just reducing the cost burden to local government. Since the early 1980s many local governments have recognized the risks to public health and the environment that are posed by HHW. In most places HHW is exempt from the rules and regulations that govern the management of commercial and industrial hazardous waste, but the exact same stuff if generated by a business would require cradle to grave management.  Because of this gap in the regulations, local agencies have established collection programs around the country, to provide places for their residents to bring unwanted leftover hazardous products from their homes for proper disposal.

However even the leading HHW programs - and I’d like to think my program is among them- are not able to capture anywhere near 100% of the HHW that is generated. While there is unfortunately not a lot of solid information about just much HHW is actually generated vs. how much is collected, my estimates are that the best programs are collecting somewhere in the neighborhood of 50-75% of what is generated. In many areas it is lower than that, and there are large swathes of the country with no HHW collection at all. Meanwhile here in the Portland area it looks like 100% of the paint generated is being collected, now that we have a solid stewardship program in place.  In order to truly solve the HHW problem that we set out to solve more than 30 years ago now, I argue that robust EPR programs provide the only viable answer.

My agency has launched an effort to pass legislation here in Oregon that would establish a statewide EPR program for a wide variety of products that end up as HHW.   While Oregon would be the first state in the US to implement EPR for HHW, there are three Canadian provinces that have programs in place already, from which we took inspiration, and there are plans for all of Canada to eventually implement similar programs.  In conjunction with a co-worker of mine who works on the policy side of the house here at Metro, we drafted a bill, which made it to a legislative committee hearing earlier this year. We are now moving into a stakeholder engagement process, in the hopes of improving the bill for introduction at a future legislative session. You can see an overview of the bill here, and the bill itself, as amended, here. If you are interested in being kept up to date on future developments, or would like to tune in to our stakeholder meetings, please contact me.

If you have any questions or comments about this effort, feel free to post them in the comment section (you need to be a NAHMMA member with a website login to do so).  


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