Incorporating sustainable practices into HHW collection operations and supporting vendors takes thoughtful consideration of many factors. By leveraging waste management hierarchy policies, evaluating net impacts and benefits of operating options, and examining everyday practices and vendor contracts for opportunities, any HHW program can become more sustainable.
By Larry Sweetser and David Nightingale, CHMM, S.C.

Household Hazardous Waste (HHW) programs provide an opportunity for environmentally appropriate and safe management of hazardous products from households and sometimes small businesses. In keeping with the theme of minimizing environmental impacts, HHW programs should also look at their facilities and operations through the lens of sustainability. In part 1 of this series on sustainability for HHW programs (Waste Advantage Magazine, August 2021), we examined what is in a sustainability plan and how that might be applied to HHW facilities and operations. In this final part of the series, we will examine other aspects of HHW programs and how they may become more environmentally sustainable


Preventing Waste Generation and Waste Diversion
Promoting the use of alternative products to hazardous ones can prevent generation of future hazardous wastes and reduce the demand for HHW service. Waste generation prevention can include:
• Education of product alternatives
• Reuse programs
• Administrative Program Practices

Education of Product Alternatives
Educating the public on how to avoid over purchasing and seeking out safer alternatives can reduce future hazardous waste generation and can be safer for use especially for people with chemical sensitivities. A few examples of product alternatives include:
• Baking soda and vinegar instead of harsh chemical cleaners
• Using biologic plant pest control or less toxic pesticides
• Using rechargeable batteries instead of disposable, single-use types

Promoting refillable small propane containers instead of disposable ones

Reuse Programs
Many unwanted products delivered to HHW programs are still usable as originally intended. Some delivered products are brand new. Many HHW programs already offer reusable household products and some programs have reported HHW diversion rates in the 30 to 40 percent range.1 Programs offering reuse often adopt practices to minimize potential liability such as:

• Product review to ensure that dangerous or outdated products are not set out

• Only making products available that are in good condition with intact original labels

• Requiring users to use products as intended

• Customer signed liability waivers acknowledging that product use is at their own risk

• Limit the number of items taken to prevent hoarding and excess accumulation risks

Some HHW program sponsors may hesitate to offer reusable products to the general public. In those cases, programs can target reuse to certain local agencies or organizations. Examples of this focused reuse practice include fertilizers and registered pesticides for parks departments, pool chemicals for public pool maintenance, cleaning supplies used by schools and janitorial firms, and paint and construction supplies needed by theater groups.

One sustainability metric for reuse is to track the quantity of products sent out through the reuse program and calculate the estimated costs savings if the products had instead been disposed. Hundreds of thousands of pounds per year of HHW can be diverted from disposal by aggressive suburban/urban reuse programs. Some programs have saved 10 percent or more of their disposal costs by implementing reuse programs. For larger programs this can amount to hundreds of thousands of dollars annually.2

One HHW program reported that in serving 3,899 customers from March to September, their reuse program avoided HHW disposal costs of $46,577 and estimated the value of products given to their citizens through their HHW reuse program at an additional $83,075 benefit to the community.3 In that instance, the value of good products provided back to the community through their reuse program was 1.78 times the disposal savings cost.

Administrative Practices and Procurement
Several facility practices that support the HHW operation can
reduce waste generation or increase recycling and should be
incorporated into HHW programs wherever possible. Some of these more sustainable practices are listed below.

Administrative Efforts
• Use of double-sided paper with recycled post-consumer content4
• Recycled toner and inkjet printer cartridge refills
• Compost bin for food in the lunch area and recycling of beverage containers
• Use of reusable kitchenware like cups, silverware, and plates
• Refillable water stations rather than disposal container bottledwater
• Use of extra paper as scratch paper

Procurement Practices
• Use hazardous waste containers with recycled content, e.g., recycled/refurbished steel drums, which are recertified to meet DOT shipping container requirements
• Use of launderable coveralls or lab coats instead of disposable PPE suits
• Reusable aprons can provide protection of clothing and extend the life of other PPE
• Reusable cubic yard totes, often steel or plastic, instead of fiber boxes

Sustainable Waste Management Hierarchy
If your organization does not already have a waste management hierarchy, adopting a waste hierarchy policy in order of sustainability concepts can establish the policy to be implemented. Waste management methods higher on the list are more sustainable. An example of a waste hierarchy listed in order of sustainability preference is:
• Avoid or reduce waste generation
• Reuse wastes
• Recycle wastes
• Product stewardship
• Treatment to reduce toxicity or environmental availability
• Waste as a substitute for virgin fuels, also called alternative or A-fuel
• Destructive incineration
• Landfill

An example of the current sustainable waste management practices on a statewide level is shown in Figure 1. California jurisdictions reported 107 million pounds of HHW collected in fiscal year 2019 to 2020 with HHW disposition as shown on Figure 1. Well over half, 59 percent, of all California HHW is recycled. California has nine product stewardship laws.5 Product stewardship organizations take the next largest part of the waste stream at 18 percent. Because California HHW programs include a large proportion of electronics and latex paints, this must be considered before directly comparing waste disposition percentages to other state or local programs.

Figure 1: California 2020 HHW Waste Disposition.
Images courtesy of Special Waste Associates.

The California statewide reuse level is rather low at only 3 percent. There are a number of individual HHW programs in the U.S. that have double digit reuse diversion rates, as mentioned previously. For example, Johnson County, KS’ HHW collection reuse program diverted more than 29 percent of all the collected HHW in 2020 through latex paint blending and a long-standing product reuse
program for other HHW types (See Figures 2 and 3).

Figure 2: Johnson County KS, HHW reuse shelf.


Figure 3: Johnson County, KS latex paint blending.
Figures courtesy of Special Waste Associates.

Product stewardship programs involving manufacturers can also promote recycling management for recycled-content products. PaintCare, associated with the American Coatings Association, manages paint product stewardship programs in 10 states and the District of Columbia, and recycles millions of gallons of latex paint annually.6 Other product manufacturer groups could choose to follow the paint industry’s lead.
Minimizing landfilling of HHW fits with sustainable practices and also minimizes potential long-term liability for program sponsors. A few wastes can only be managed by landfilling such as asbestos
accepted by some HHW programs. Where there are waste management options, landfilling can be less expensive in the short run, but does not match well with sustainability policy and practices, which prefer methods higher on the waste management hierarchy.

Vendor Sustainability Practices
Selection of a hazardous waste contractor and other vendors can become an essential part of a more sustainable HHW program. HHW program sponsors with adopted sustainability policies can require their selected vendors to be consistent and aligned with their commitment to those sustainable practices for products and services.

Imposing sustainability practices on vendors can be incorporated into the vendor requests for proposals (RFPs) and service contracts. HHW sponsors should be aware that imposing sustainability practices might result in increased costs for companies that do not already have internalized sustainability practices. Imposing the same requirements on all service proposers, which include sustainable practices, should offset the competitive advantage of not providing sustainable services.

Selection of sustainability practices needs to balance net environmental benefits, resource use, with labor costs. For example, vendors using significant amounts of labor and water to rinse reusable metal or plastic containers can be compared to using fiber containers that are combusted with the wastes when looking at lifecycle impacts. Each HHW sponsor will need to determine their own priorities in their own policy and how to evaluate the various vendor sustainability practices.

Vendor sustainability practices, which may be included in RFPs and contracts, generally fall into these categories:
• Operational practices
• Waste management hierarchy
• Designated facility waste practices
• Transportation methods and routing
Applications of each of these practices is discussed below.

Operational Practices
Various sustainability practices can be used by the HHW vendor in the same way as the local HHW operation, such as double-side printing, energy and water efficient buildings, refurbished or reusable containers, and use of launderable uniforms or aprons rather than using disposable plastic coveralls.

Waste Management Hierarchy
Similarly, HHW sponsors can impose a preferred waste management hierarchy on the management of HHW collected by vendors through the RFP contracting process where collection events or
facilities are staffed by contract labor. Contract provisions, which give financial incentives for vendors to set aside qualifying products for reuse, can be a key to implementing a more sustainable HHW
management system. Providing vendor incentives for diverting HHW to reuse programs can be an effective means to align the vendor profit motive with the waste management hierarchy.

Recycling options include processing of latex paint into usable paint, processing used oil into reclaimed oil, processing fluorescent lamps into recyclable materials, materials recovery of batteries and others. Treatment processes for neutralizing corrosives and oxidizers are a common technology as is the use of flammable liquids for energy recovery rather than direct incineration with no energy recovery. Landfilling of HHW is typically the last resort since the waste continues to exist without usefulness.

Designated Facility Waste Practices
Designated facilities are often identified in vendor contracts for final recycling, treatment and disposal. These are the only places allowed by contract to receiving a specific category of collected HHW. In the bidding process, sustainability and waste hierarchy practices can become part of the evaluation of proposals. Since these designated facilities are often under subcontract agreements by the main vendor, required sustainability practices will need to be incorporated into the main vendor as well as subcontractors in the Sponsor’s agreements. Sustainability practices that might be found at designated facilities receiving HHW could include7:
• Pour off drum contents from reusable containers rather than incinerating fiber container
• Using solvent or oil recycling service
• Demonstrating emission controls or operating practices that reduce greenhouse gas below historic levels as well as those required by operational permits
• Use of paper residual from paper manufacturers in the solidification treatment process of wastewater sludge, which offsets the use of manufactured solidification products
• Use of waste caustics and waste acids from various manufacturing operations as a substitute for virgin chemicals in wastewater neutralization processes
• Use of regenerated-spent carbon versus virgin carbon in air stripping and wastewater treatment processes.
• Use of by-products from mining activities, such as ferrous-sulfate dust, as treatment stabilization media for company landfills, reducing the need to purchase virgin chemicals
• Use of cement kiln dust, fly-ash and waste Portland cement as substitute treatment stabilization media offsetting the need for virgin materials
• Use of flammable and combustible waste to fire incinerators to offset the need for virgin fuel
• Use of a waste fired boilers that provides beneficial re-use for clean solvents.
• Stabilization of ash from waste combustion and incineration operations
• Chlorine Recycling Program

HHW program sponsors who have sustainability provisions in their vendor contracts should include requirements for annual reports describing and quantifying the sustainability practices implemented for the collected HHW. The lack of HHW management accountability has been a problem historically.

Transportation Methods and Routing
Sustainability methods for transportation can be incorporated into the management of HHW since most HHW travels significant distances before reaching a final destination facility. Some of these transportation sustainability practices can be incorporated into fleet management and routing efficiencies. Use new technology in fleet vehicles such as:
• Vehicles, which are hybrid, green hydrogen or all-electric powered
• Imposing proactive preventative maintenance programs
• Reclaimed oil and other lubricating products
• Installation of auto-idler systems to shut down vehicles idling for more than five minutes
• Upgrading fleet vehicles to new Clean Air standards
• Regenerative engine fume re-burn systems
• Installation of governors to prevent driving over 65 mph

Routing efficiencies can include:
•  Routing technology to create efficient collections
• Collection with larger vehicles to allow for less frequent collection if facility storage area allows for larger loads
• Coordination of collection routes from different nearby facilities to allow for fuller truck loads
• Use of transfer stations to store less commonly collected wastes until full loads can be assembled
• Incorporating backhaul transportation services including delivery of supplies at the time of HHW collection

Incorporating sustainable practices into HHW collection operations and supporting vendors takes thoughtful consideration of many factors. Nonetheless, by leveraging waste management hierarchy policies, evaluating net impacts and benefits of operating options, and examining everyday practices and vendor contracts for opportunities, any HHW program can become more sustainable. | WA

David Nightingale is the Principal at Special Waste Associates in Olympia, WA. He can be reached at (360) 491-2190 or e-mail at [email protected]
Larry Sweetser is President of Sweetser Associates, Inc. in Richmond, CA. He can be reached at (510) 703-0898 or e-mail [email protected]

HHW Corner,, May 2020. Ibid.
“Johnson County Environmental Department’s Household Hazardous Waste Site 2003”, presented at the annual conference of the North American Hazardous Materials Management Association, Kansas City, MO, October 6, 2003.
See recycled content guidance in Title 16, Code of Federal Regulations, Section 260.12
Based in part on Proposal to Provide HHW Facility Operations and Disposal Services for the City of Thousand Oaks, Clean Harbors Environmental Services, Inc., April 20, 2016.


Read Part One:

First of Two Parts: Should our Community have a Permanent HHW Collection Facility?