HHW reuse is not only popular with the public, but can also dramatically reduce operating costs.
By David Nightingale, CHMM, S.C.

Reuse is a traditional waste management hierarchy method just behind Reduce. Because the cost of HHW programs is expensive on a dollars per ton basis, even modest reuse programs save a lot of operating costs as well as provide good products back to members of the community. Where there are well organized and convenient HHW reuse programs, the waste diversion from disposal is typically in the double-digit percentage range.

Figure 1:
Product reuse shelves with household cleaners at Johnson County, KS HHW facility.

History of HHW Reuse Programs
Following the emergence and adoption of integrated waste management hierarchies in the 1980s, early professionals in the HHW arena looked to the possibility of pushing the management of HHW up the waste management hierarchy. The waste management hierarchy has various looks but the City of Lincoln, NE is representative. In order of preference, Lincoln calls for waste to be managed by:
1. Waste Reduction
2. Waste Reuse
3. Recycling and Composting
4. Energy Recovery
5. Residual Disposal¹

The focus on reuse of HHW dates back to at least 1990 where some of the formative HHW leaders recognized the value of HHW reuse programs.² In 1993, the U.S. EPA published HHW collection event guidelines that suggested that HHW reuse would be viable for paints, pesticides, cleaners and automotive products. EPA cited common program restrictions such as any HHW provided for reuse be only offered in the original containers with intact labels, prohibit the reuse of banned pesticides, and exclude any containers that are leading, rusted or otherwise damaged.³ Many local HHW programs now provide some level of HHW reuse, but many programs seem to underperform the leading reuse programs. Some possible reasons for underperformance are as follows.

Figure 2: Pinellas County, FL Household Electronics and Chemical Collection Center.

Contractor Disincentives
Many HHW programs are operated by regional or national contractors who provide HHW day-to-day operating staff as well as transportation and disposal services. The national HHW contractors are vertically integrated; the same organization provides collection operating staff, transportation of the wastes, waste consolidation and processing services, and the ultimate offsite recycling and disposal facilities for HHW. If HHW is diverted from requiring transportation and offsite disposal, some of the potential revenue stream for that contractor is removed. In that way, a successful HHW reuse program represents a financial disincentive for vertically integrated contractors unless the contract is structured to remove that financial disincentive. Consequently, it is not reasonable to expect HHW contractor staff to embrace or champion reuse. In cases where operating staff are employees of the local sponsoring agencies, this inherent conflict of interest with a robust HHW reuse program disappears.

Liability Concerns
Risk managers and legal counsel staff are paid to imagine and play out worst-case scenarios and possible legal theories which may be applied to program activities to the financial detriment of program sponsors. There is nothing wrong with this, as it helps to inform decision-makers about the outer edges of possible negative consequences. In some cases, the fear of these possible negative outcomes has restricted the ability of HHW programs to aggressively implement reuse programs. However, in the decades of working in this niche area of solid waste, I am not aware of any case where a person taking HHW from a reuse program threatened legal action against the program sponsor. In order to avoid the specter of potential legal action, many HHW reuse programs provide a statement to be signed by participants waiving any future claims of liability for the use products that they take. Whether these waiver forms have been effective in avoiding any potential legal suites is unknown.

Collection Event versus Permanent HHW Collection Facility Operating Costs
At collection events run by contractors, the cost for the contractor services often run between 70 and 90 percent of operating costs. At permanent HHW collection facilities the proportion of costs devoted to contractor services are often closer to 50 percent. This is typically due to:

• The significant collection event cost to mobilize the equipment and staff to manage a temporary collection activity
• Preference for collection events on weekends, which can require higher wages
• The ability to more efficiently pack HHW into containers at a permanent facility without the press of dozens if not hundreds of cars waiting to drop off their HHW at a collection event.
The more organized and efficient waste management workflow at permanent facilities also allows for more deliberate waste diversion to reuse. A key question is “How much can I drive down operating costs if my program pursued aggressive HHW reuse?”

HHW Reuse Program Results
Let’s examine three HHW collection programs with permanent facilities that have aggressively pursued the benefits of HHW reuse.


chart-2This level of HHW diversion is impressive and represents significant operating savings. In addition, reuse programs require less transportation of waste, which reduces the program carbon footprint, as well as benefiting local community members who reuse good materials. Figure 1, page 19 shows product reuse shelves with household cleaners at Johnson County, KS HHW facility. The most successful HHW reuse programs provide an attractive experience for the customer, not unlike a retail store environment. An example of an attractive HHW facility is shown in Figure 2, page 19, from Pinellas County’s Household Electronics and Chemical Collection Center in Florida.

Significant waste diversion percentages and financial benefits of HHW reuse have been clearly demonstrated across the U.S. Barriers to HHW reuse may originate from inside or outside your organization. There is an inherent financial disincentive to promote local HHW reuse from vertically integrated waste management firms. To maintain revenues they have motivation to maximize the amounts of HHW waste transported offsite and disposed of at their facilities. There may also be resistance from in-house risk managers who raise the specter of customer liability suits. However, such suits are unheard of at HHW reuse programs and standard practices help ensure that HHW products set out for reuse are appropriate. Finally, the direct benefits to the community for reusing good products is locally appreciated and the reduction of offsite transportation of HHW helps reduce the overall carbon footprint of the HHW program. | WA

The next issue’s column will focus on Natural Lighting.

David Nightingale, CHMM, S.C., is Principal at Special Waste Associates (Olympia, WA), a company that assists communities in developing or improving HHW and VSQG collection infrastructure and operations. They have visited more than 140 operating HHW collection facilities in North America. As a specialty consulting firm, Special Waste Associates works directly for program sponsors providing independent design review for new or upgrading facilities—from concept through final drawings to create safer, more efficient and cost-effective collection infrastructures. Special Waste Associates also published the book, HHW Collection Facility Design Guide. David can be contacted at (360) 491-2190, e-mail contact@specialwasteassoc.com or visit www.specialwasteassoc.com.


Handbook on Household Hazardous Waste, Second Edition, Adapted from Figure 3.1 Integrated Waste Management Hierarchy, Shelly Fuller, Dan King, Sue Bruning, and Mike O’Donnell, Ed. Amy D. Cabaniss, Bernan Press, 2018.
Duxbury, Dana and Morley, Philip, Overview of collection and management methods. Proceedings of the Fifth National Conference on Household Hazardous Waste Management, November 5-7, 1990, San Francisco, as cited in US EPA publication EPA530-R-92-026, p. 18, August 1993.
Household Hazardous Waste Management: A Manual for One-Day Community Collection Programs, US EPA ID EPA530-R-92-026, pp. 18-19, August 1993.