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Managing Your HHW Program: Additional Program Guidance

This section provides additional information on topics related to Household Hazardous Waste (HHW). The resources provided are only intended to refer operators to other programs within or outside of the TCEQ.

HHW-Related Programs

Household Hazardous Waste (HHW) requirements are specifically outlined in 30 TAC Subchapter N. However, while managing an HHW program, operators may need to be aware of other program requirements by the TCEQ and other local, state, and federal agencies.

Below, you will find compliance assistance resources for programs related to HHW. This list is not necessarily exhaustive.

General inquiries can be coordinated through the HHW program manager:
Phone: 512-239-3143
E-mail: recycle@tceq.texas.gov

Guidance Topics

To navigate through the various topics on this page, select any of the items below. 

Other TCEQ Program AreasOther State or Federal AgenciesOutlined in HHW Rules
Used Automotive Oil Pharmaceutical Take Back Exemptions from HHW
Electronics Collections Rendering (Yellow Oil) Collections of BOPA
Used Tires

Exempt Radioactive Waste (Smoke Detectors)

Items for Reuse

Stormwater Permits

 

DOT Requirements

Storage & Accumulation

Promotional Materials

  General Shipping of HHW
  Final Disposal

Used Automotive Oil

Operators of HHW events collecting used oil should be aware of the TCEQ Used Oil Recycling Program. Collection and transportation of used oil is regulated under 30 TAC 324 Subchapter A. Considerations for maintaining compliance with that program include the following. 

Registration requirements:

  • If you collect or transport used oil and oil filters, you may be required to register separately with the TCEQ Used Oil Program as a used oil collection center or used oil handler
  • Collection centers must register biannually, in odd-numbered years, while transporters and transfer facilities have a single one-time registration. 
  • You must utilize a registered Used Oil Transporter to manage the transportation of ANY amount of used oil collected if you: 
    • host a mobile collection event, 
    • operate a point-of-generation collection program, or 
    • coordinate a BOPA collection event.

Reporting requirements: 

  • If you have a used oil registration through the TCEQ, you may be required to report annually to the Used Oil Program using Form TCEQ-00567. That reporting deadline is January 25.
Additional Guidance:

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Electronics Collections

Operators of HHW events where computers and televisions are collected should be aware of the Texas Recycles Computers and Texas Recycles TVs programs.

Collections of used electronics receive an exclusion from the HHW Program rules as long as:

  • materials collected are not determined to be a waste at the time of collection, and 
  • materials collected are not handled in a way that renders them unusable. 

Because of this exclusion, programs and managers are advised against using terms such as "E-waste" or "electronic waste" when referring to recyclable electronics. 

If you choose to include a collection of used electronics in conjunction an HHW event, you should be familiar with the requirements outlined in the computer and television program rules (such as registration requirements through the TCEQ). This is especially important if you are working directly with a recycler as your vendor.

Additional Guidance: 

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Used and Scrap Tires

Used or scrap tires are sometimes accepted by HHW collection programs. The management of these tires is regulated by the TCEQ Scrap Tire Program to prevent fires and control disease vectors (mosquitoes, rats, and snakes).

Requirements for managing tires include registration, manifesting and disposal regulations. These requirements apply to those involved in the generation, storage, transportation, recycling and disposal of the tires. 

Additional Guidance:

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Stormwater Permits

If you operate a Household Hazardous Waste permanent facility, you may need to comply with stormwater permitting requirements, based off of your facility's Standard Industrial Code (SIC)

For more information or questions about stormwater permitting, e-mail wqap@tceq.texas.gov.

Additional Guidance:

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Promotional Materials

Consider using the following information for your announcements and promotional materials:

  • Types and quantities of waste that will or will not be accepted
  • Instructions for safely packaging and transporting waste to a collection
  • Location of a collection site or facility and hours of operation or collection
  • Eligibility criteria for who can bring waste

The TCEQ has no restrictions on linking to our site as long as a fee is not charged to access our material.

TCEQ Logo

The use of the logo is typically reserved for entities that have a relationship with the TCEQ, such as co-hosting an event. In some cases, certain Councils of Governments have been pre-authorized to use the logo for purposes of acknowledgment as Solid Waste Grant recipients.

The TCEQ agency logo should not be used:

  • For any promotional material, or in any situation, without prior approval by the TCEQ.
  • For the sole purpose of providing a graphic for linking to the agency from your website. The TCEQ Logo Public Use Style Guide Adobe Acrobat PDF Document provides more information on this subject.

E-mail the HHW Program Coordinator at recycle@tceq.texas.gov or Agency Communications at ac@tceq.texas.gov for more information.

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Pharmaceutical Handling & Take Back

Recovery and disposal of prescription and over-the-counter medications has increased in popularity in recent years. The Drug Enforcement Agency (DEA) Exit the TCEQ  is the primary regulating entity for the handling of controlled substances defined and regulated under the Controlled Substances Act. At a minimum, an the operator of an HHW event in conjunction with a drug take back event must coordinate with law enforcement.

A drug take back program could fall under HHW program requirements if both of the following conditions are met:

  • A collection is held and items that qualify as household hazardous waste (listed or characteristically hazardous identification) are collected.
  • The total weight of materials designated as household hazardous waste is more than 100 pounds for a collection entity in a given year.

Additional Guidance: 

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Rendering (Yellow Oil)

Waste cooking oil and recyclable cooking oil fall under rendering requirements  of the Texas Renderers' Licensing Act Adobe Acrobat PDF Document, regulated through the Texas Department of State Health Services (DSHS) Meat Safety Assurance Unit Exit the TCEQ.

Certain considerations must be made when collecting yellow oil, including container specifications and transportation standards. As with used oil, HHW operators can always consider contracting with a group that has already obtained the required permits for these operations.

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Exempt Radioactive Waste (Smoke Detectors)

Certain household items containing minute amounts of radioactive materials are exempt from licensing in the Texas Radiation Control rules (25 TAC Chapter 289). The Texas Department of State Health Services (DSHS) Radiation Control Program Exit the TCEQ administers these rules.

Exempt items include, but are not limited to, certain:

  • Smoke detectors
  • Watches & Clocks
  • Thermostat dials and sensors

To find out if a particular radioactive material is exempt from regulation under Chapter 289, see the TCEQ regulatory guide, "Disposal of Exempt Waste That Contains Radioactive Material." You can also review the requirements in 25 TAC Section 289.251For questions about use, processing, treatment, or storage of exempt radioactive materials, call the DSHS Radiation Control Program at 512-834-6688.

Additional Guidance:

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Exemptions from HHW Requirements

The following collections are exempt from the HHW program requirements per 30 TAC 335.401(c) and 30 TAC 335.417(b):

  • Household collections organized for the purpose of reuse or recycling any combination of Batteries, used Oil and oil filters, Paint, or Antifreeze (BOPA)
  • A collection of less than 100 pounds of HHW in a given year.
  • Retailers accepting waste of the same type they sell.
  • Agricultural pesticide collections where incidental amounts of HHW may also be received, as long as no fees are charged for the collection and a registered hazardous waste transporter and hazardous waste treatment, storage and disposal facility (TSDF) are used.
  • A collection of used electronic equipment from the public, provided a waste determination is not made, the electronics are not handled in a way that renders them useless, and no HHW is collected. This is why managers are typically advised against using terms such as "E-waste" or "Electronic waste."
  • A TSDF may receive HHW directly from households and is excluded from the HHW program requirements, except that they meet the reporting requirement.

Regardless of exemption from HHW requirements, collection or aggregation, transportation, and disposal must still comply with state and federal laws. See additional guidance provided here for specifics.

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Collections of BOPA (batteries, oil, paint, antifreeze)

For local governments and organizations wishing to host a collection, a hosted BOPA-only event can be a lower-cost option. These items are consistently the highest surrendered materials during an HHW event.

The BOPA collection receives an exemption from the HHW rules (30 TAC 335.401(c)). However, other rules apply for proper transportation and disposal of some of these items. For example, in Texas, it is illegal to dispose of used automotive oil, oil filters, and lead-acid batteries in the landfill. BOPA collectors must still manage the aggregated material appropriately. Be aware of the following requirements:

  • Collection and transportation of used oil is regulated (30 TAC 324 Subchapter A). Transportation of used oil aggregated at a BOPA or other HHW event must be by a registered Used Oil Transporter.
  • Batteries that are collected at an event must be appropriately packaged, labeled, and transported to their final destination according to Department of Transportation Exit the TCEQ requirements.
Additional Guidance: 

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Items for Reuse

The expectation of HHW program managers is for management of received waste to be prioritized in the following order (30 TAC 335.405(a)(4)):

  1. Reuse for the product's intended purpose
  2. Recycling
  3. Recycling for energy recovery
  4. Treatment to destroy hazardous characteristics (neutralization)
  5. Treatment to reduce hazardous characteristics
  6. Underground injection
  7. Land disposal

There are multiple benefits associated with segregating and offering useable material for reuse, including:

  • Reduced disposal cost.
  • The materials within your permanent facility that are appropriately set aside for reuse are exempt from HHW storage requirements, potentially keeping some programs under the 3,000 kg limit that triggers a 10-day disposal timeline.
  • Reuse resources and opportunities for community members.

Reuse of collected materials does fall under some regulation. Most importantly, if the reuse material is at any point shipped for processing or disposal without having been transferred to another person (i.e. if it is taken home by an individual), then it must be handled appropriately under Subchapter N rules if it is HHW.

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Storage and Accumulation Times

The HHW rules specify lengths of time that HHW may be retained or accumulated at a site based on the amounts and the program type (30 TAC 335.409(e) and 30 TAC 335.411(c)(4)). Below is a simplified chart of those requirements:

Program TypeAggregated HHW AmountTransfer or Disposal Timeline
Point-of-generation >100 pounds 72 hours
Mobile or 1-Day >100 pounds 72 hours
Permanent Facility <3,000 kg (~6,600 pounds) 6 months
Permanent Facility >3,000 kg (~6,600 pounds) 10 days*

*If good management practices do not allow materials to be shipped from a permanent facility within 10 days, a Storage Extension Request Form may be submitted to the TCEQ for review and approval to allow for a longer period of accumulation. The intent of storage extension is to allow moderate flexibility, especially for high-volume permanent facilities. It is not intended to be used or requested as an alternative to good management practices.

Facilities should calculate the material on-site that is considered household hazardous waste to determine their aggregated amounts. It is not necessary to include non-HHW materials collected at the facility in the aggregated pounds when determining the maximum accumulation period allowed.

Under no circumstances is HHW allowed to be stored for greater than 180 days, regardless of accumulated amounts or whether or not an extension has been granted for a facility (30 TAC 335.409(e)(1)(C)).

Depending on the site construction of certain collection facilities, the fire code may increase the need to ship more often, and may not allow accumulation amounts that would necessitate a storage extension. Check with your local government and fire marshal for these standards.

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General Shipping of HHW

The HHW rules allow for shipping aggregated HHW in the following ways (30 TAC 335.413):

OriginDestinationManifest?Shipping Considerations
Point-of-generation Mobile or 1-Day No DOT requirements still apply
Mobile collection Mobile or 1-Day No DOT requirements still apply
Any program type Permanent Facility No DOT requirements still apply
Any program type Hazardous Waste TSDF Yes If applicable, can ship as UW*

*When applicable, there is allowance for shipping as Universal Waste under a Bill of Lading, following Texas Universal Waste requirements.

If HHW is transferred to a facility other than another HHW program, it is required to follow the same shipping requirements as hazardous waste. Regulations that apply in this case include manifesting requirements and use of an EPA-registered hazardous waste transporter.

The process for obtaining an EPA hazardous waste transporter ID can be found on the TCEQ website. Necessary forms include:

All transportation of HHW regardless of destination is required to comply with Department of Transportation standards and rules (see below).

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Department of Transportation (DOT) Requirements

HHW programs are required to abide by current DOT standards when transporting HHW. The USDOT has established packaging and transportation requirements to include: 

  • Proper waste packaging instructions
  • Proper marking and labeling instructions
  • Proper shipping name, identification number, and hazardous class for manifest preparation
  • Placarding for transportation of waste

For USDOT regulatory information, call the DOT Pipeline and Hazardous Materials Safety Administration Exit the TCEQ at 1-800-467-4922.

HHW rules require that copies of shipping paperwork are retained for at least one year from the date of shipment (30 TAC 335.413(a)(4)).

Additional Guidance

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Final Disposal

While HHW may be transported for purposes of aggregation among HHW programs, the ultimate destination of the waste must be a hazardous waste treatment, storage, or disposal facility (TSDF) that is authorized to receive HHW and has agreed to accept that waste.

The TCEQ Office of Waste, Waste Permits Division, maintains a list of Texas landfills— Commercial Management Facilities for Hazardous and Industrial Solid Waste (GI-225) Adobe Acrobat PDF Document—that are permitted to manage industrial hazardous waste and/or industrial nonhazardous waste. The listing is for Texas facilities only and you must ensure that the facility you choose identifies "hazardous waste" as a waste accepted.

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Are you a program manager or interested in starting a collection program? Receive free updates by e-mail and text when this page is updated! Select "Program Assistance for Household Hazardous Waste Managers" in the Waste Management Category.

Household Hazardous Waste: Program Assitance

Planning Your HHW Collection Event