Guidance for Siting Household Hazardous Waste Facilities - PUB2807

Ordinary products such as cleaning products, batteries, light bulbs, paint, pesticides and motor oil can be harmful and potentially dangerous if disposed of incorrectly. Some products may cause fires, health problems or contaminate our soil, groundwater, lakes and streams. When these products are unwanted by consumers and need to be thrown away, they are classified as household hazardous waste (HHW) according to 40 C.F.R 261.4(b)(1).

HHW facilities can only accept waste from households and farmers unless the facility is permitted to accept hazardous waste (HW). Waste generated from businesses must undergo a hazardous waste determination by the generator of the waste at the point of generation.

Regulations

The North American Hazardous Materials Association (NAHMMA), the association for professionals responsible for HHW activities, identifies some federal regulations that should serve as guidance for siting HHW facilities. The list below is not inclusive, so it is important to verify and consult local planning authorities early in the planning process:

United States Department of Transportation (DOT) Code of Federal Regulations guides HHW facilities. The DOT requirement and other important guidance for handling, sorting, packing and shipping HHW are covered in 49 C.F.R Parts 100-185. The specific training requirement is 49 C.F.R 172.700 Subpart H – Training. Other applicable sections, 49 C.F.R 172.704(a) and 172.704(c) (2), satisfy the general awareness, function specific and security awareness components.

Managing HHW and staff who handle hazardous materials is guided by the requirements established in the Occupational Safety and Health Administration (OSHA) 29
C.F.R 1910, such as Subpart I – Personal Protective Equipment, 1910.120, 1910.141(a - d and g), 1910.147, 1910.151, 1910.157, 1910.1000 and the HHW program guidance. Other state guidance documents, municipal laws, county ordinances, local building codes and Missouri uniform fire codes may apply.

General HHW Awareness Training

General awareness: Intended to raise staff awareness of hazardous materials guidelines and best practices relative to HHW identification, use, storage, packing and transportation.
 
All low-level technical staff at a minimum should have:

• Scope of Work training: Intended to detail the Scope of Work relative to handling HHW and necessary work performance standards. A good example of this training is the 40-hour Hazardous Waste Operations and Emergency Response (HAZWOPER) training.
• Function-specific training: Intended to teach the necessary knowledge, skills and abilities for supporting HHW operations and related work parameters. The HHW-specific 24-hour HAZWOPER training is a good example of this type of training.
• Safety training: Provides necessary information on hazards posed by materials and ideal personal protection measures for involved staff. The 40-hour HAZWOPER training is recommended with an eight-hour annual refresher.

Staff competency should be evaluated on an annual and continual basis.

Facility Design Considerations

• A securable facility
• Adequate vehicle queuing space
• Building size estimates in relation to service area population
• Synergy of location with, or near, compatible operations such as transfer stations
• Consideration of supporting functions such as office area, storage areas for supplies of personal protection equipment, drums, boxes, mechanical and electrical spaces and reuse areas
• Impermeable secondary containment
• Solid surfaces for customer access via paved roads
• Consideration of future expansion
• Access and turning radii for supply and shipping trucks that is separate from customer queuing space
• Utilities already on, or very near, building site (construction cost containment)
• Local requirements for land use zoning restrictions
• Safe distance from more susceptible persons such as day care facilities, schools and nursing homes
• Proximity to emergency services such as fire departments
• Possible reuse of existing buildings
• Consult local planning authorities early
• Building, fire, mechanical, plumbing and electrical codes
• Consider local “spot’ ventilation (especially where vapors or dust originate)
• Explosion-proof wiring and fixtures in high hazard (H-occupancy) areas
• Ventilation systems
• Water and energy efficiency systems
• Applicable stormwater and water permits
• Fire suppression, dust suppression, noise suppression systems
• Site map showing footprint of proposed location
• Description and photographs of site or mobile unit (if applicable)
• Proof of ownership
• Site-specific layout and facility operation plan
• Emergency response plan/contingency plan (can be incorporated into the facility operation plan)
• Site closure plan and cost estimate

For facilities to be sited on solid waste facilities, permit modifications will be needed to show the area designated for storage and an updated operations manual.

****Please note that this is not an all-inclusive list. It is important to do your due diligence.