Planning your HHW Collection Event: Step 2 - Vendors
Please note: These pages are provided as guidance and are not intended to be used as a substitute for reading and ultimately complying with the HHW Rule (30 TAC 335 Subchapter N).
Individuals who handle household hazardous waste after it is unloaded from vehicles and before it is segregated for transport or storage must be trained as if the waste were hazardous waste.
Hazardous Waste Management Firms
Programs can choose to have staff trained according to the standards outlined in the rule (30 TAC 335.407) or can contract with a licensed hazardous waste management firm to provide staff that will handle and segregate incoming HHW appropriately and even provide for the necessary transportation and disposal of that material. When choosing a vendor, there are several factors to consider:
- Compliance with TCEQ regulations and other agency regulations
- Qualifications of personnel
- Experience with similar projects
- Current disposal and transportation licenses
- Available disposal facilities
- Safety record
- Price and service
The firm must be able to clearly identify the types of waste collected, including identifying unknown wastes (30 TAC 335.405(a)). If the vendor cannot accept certain types of materials or unidentified waste, this should be detailed in the contract.
A contract should clearly state how the material will be packaged (loose packed, bulked, consolidated), how the price will be determined (flat rate or per drum), and the disposal methods.
If contracting with a hazardous waste management firm, determine which entity will be designated as the operator. Outline these responsibilities so that no confusion exists about who is the responsible party, particularly for requirements like annual reporting, which must be completed for all events or programs. Specific things to consider include responsibility for:
- the development of an operational plan as stated in 30 TAC 335.405
- the submission of the 45-Day Notification
- the submission of the Annual Report Form
- the methods that will be used to spread awareness and educate the community about the upcoming event. This also includes how to notify the public of the items that can and cannot be accepted
Whether additional training will be required by the contract:
- certain training is required by 30 TAC 335.407
Other HHW Collection Programs
HHW permanent facilities must have staff that are appropriately trained for HHW segregation and packaging for transport (30 TAC 335.409(b)). Some collections therefore work through a local permanent facility to host a one-time collection event. This may be an option for you as an alternative to contracting directly with a hazardous waste management firm.
Special Considerations for Point of Generation Pick-Up Services
In addition to the factors mentioned under Hazardous Waste Management Firms, one should also consider the following:
How the households will utilize these services? How will they arrange for the pick-up services?
What type of vehicle will be used in the collection, how it will meet the requirements in 30 TAC 335.411 (a)(4), and how to properly segregate the materials collected?
How the vendor will meet DOT requirements (49 CFR Parts 173, 177 and 178)?
The steps that need to be taken after collecting the household hazardous waste. Within 72 hours of the collection, all waste must be:
- delivered to a permanent collection center, collection event, or registered hazardous waste transporter facility to be aggregated
- transported by a transporter (that meets the requirements as stated in 30 TAC 335.415) to a TSDF that is authorized to accept HHW
- or shipped as universal waste if allowed under 30 TAC Chapter 335 Subchapter H, Division 5
Management of Other Items
Some communities choose to collect other items on the same day and time they collect HHW. Some of these items have additional requirements or considerations, and the operator should be familiar with those, since following HHW program rules does not exclude one from appropriate management as outlined by other TCEQ divisions or other state and federal regulatory agencies. Many of these are addressed in Additional Guidance and might include:
- Used electronics
- Used oil
- Collection of "yellow oil" (rendering)
Also consider alternative methods for managing material collected. Remember that some material collected during an HHW event can be offered for reuse to residents or city and county departments (such as paint) or can be recycled instead of going directly for disposal (30 TAC 335.419).