Transitioning to Full Producer Responsibility for Household Hazardous Waste NAHMMA NW Chapter Conference 6/25/2014
Transitioning to Full Producer Responsibility for Household Hazardous Waste
NAHMMA NW Chapter Conference6/25/2014
Today’s agenda• Introductions• Background
Why EPR for HHW?Canadian Programs
• Key elementsWhat products to cover Financing Services – role of HHW infrastructurePerformance standards
•Next steps
EPR - Extended Producer Responsibility• [a] manufacturer's responsibility for its product
extends to post-consumer management of that product…
• financial and management responsibility, with government oversight, [shifts] upstream to the manufacturer and away from the public sector
• Provid[es] incentives to producers to incorporate environmental considerations into the design of their products and packaging.
– Product Stewardship Institute; California Product Stewardship Institute; Upstream (formerly Product Policy Institute)
Why EPR for HHW?
From the HHW collection program point of view: •Helps us fully achieve our mission•Helps us financially
The HHW “Mission”• Protect human and health and the
environment by providing effective and environmentally sound management of HHW that is generated (in spite of our best efforts at source reduction)
• Many HHW programs are doing a valiant job of collecting the HHW generated in their region, but resources are limited, and we are not getting it all
• With a robust EPR program, we can finally get pretty darn near all of the HHW generated
Why EPR for HHW • It should be as easy to get rid of a product
as it is to buy it• Make it easy for people to do the right
thing• Fairness:– “polluter pays” principle– Industry is in the best position to take
responsibility
Benefits
• PaintCare has saved Metro ~ $1 million annually• We believe another $2 million savings
annually with wide-ranging EPR for HHW
But - it’s important to make sure EPR benefits urban, rural, large & small HHW programs!
Canadian programs
EPR programs for a variety of HHW products in these provinces:
•British Columbia•Manitoba•Ontario
see handout
Key EPR Elements• What’s covered?• How are things paid for?• What services provided and how
arranged for?• What’s required: – of stewards? – of government?
Key EPR Elements• What’s covered?– How designated – lists, standards?
• Who’s responsible?– Single or multiple stewards?
• How are things paid for?– Eco fees, cost internalization?
• How are services arranged?– Collection, consolidation, facilities, events?
• What’s required: of stewards? of government?– Convenience; “rates and dates”; plan review
EPR Elements
Other Key Elements• Promotion/education • Goals – rates & dates• Reporting• Enforcement• DEQ role (oversight, fees
to)• Disposal bans
Today’s focus• Coverage• Financing• Services• Performance
Today’s Product Coverage Focus
The “other stuff”• Flammables (e.g.,
solvents)• Pesticides• Corrosives• Other toxics &
hazardous materials
Works in progress• Paint (covered)• Mercury lights• Batteries
– Primary & Rechargeables
• Sharps• Pharmaceuticals
Conceptual Overview
Element Draft Legislative Concept
Coverage Similar products and criteria as BC, SK and Manitoba - Canada
Stewardship organizations Allow multiple
Financing No government approved fees
Services •Collectors authorized by DEQ•Coordination with other HHW materials collection
Performance requirements:• convenience• recycling\recovery rates and dates
Status quo plus (what’s collected now with more service in underserved areas)
Coverage – Q’s for discussionWorking assumption – Use criteria
similar to Canadian standards• What can we learn from Canadian
experience? • Covered products– What makes a good list? – What likely to be biggest problems?
• Non-covered products– How much non-covered comes in?– How critical to keep communicating to
public that we take all?
Financing – Q’s for discussionWorking assumption: no government approved
fees• Why? – Too many products; too costly for government
• How to handle “free riders”?• How can producers recover costs from
supply chain without government approved fee?
• Other methods?
Services – Q’s for discussionWorking assumptions: Stewards negotiate with existing permanent HHW
facilities; collection events historically expensive
• What costs – direct, indirect (capital, O&M) should HHW programs take to the table?
• How do costs for non-covered and orphaned products figure into this discussion?
Performance requirements – Q’s for discussion
Working assumption: At least status quo plus - what’s collected
now plus more service in underserved areas
• How can we establish what more should be? Beyond more?
• How coordinate with other HHW efforts (e.g., paint)?
Next steps
Further develop legislative concept
If you would like to be involved in further discussion, please sign clipboard