1998-10-29 – “Trick or Treat?” HHW Days From The Contractor’s Point of View

Presented at the October 29, 1998 ANJHHWC Meeting by
Brett D. Robinson, CHMM
Vice President and General Manager of REMTECH Group.
© 1998, Brett Robinson/ REMTECH Group

It’s very fitting, I think, that we should be getting together at this time of season–some of us in costume, it appears–to discuss HHW Days because every collection carries with it some “Tricks” and some “Treats.”

You open that homeowner’s trunk and you may get just about anything–and you’d better come dressed for the occasion, just in case your safety might be at stake!

We’ve seen…

  • Cars full of kids and pets carrying open containers of flammable liquids.
  • One homeowner I remember even filled both sides of the back seat, leaving his infant strapped into its car seat “for safety.”

We’ve seen…

  • Empty whipped cream aerosol cans treated as if they were the cause of rain forest destruction while deadly poisons weren’t given a second glance.
  • Two weekends ago two older gentlemen delivered a carload of fertilizers and pesticides including a trash can full of cyanide. They wanted us to dump out the 60 pounds of cyanide so they could have their trash can back. They didn’t get it back.

We’ve seen…

  • A lady from an urban area in North Jersey deliver a box full of old knives. When we questioned her about it. She said she felt they were too dangerous to put out in the trash, fearing that neighborhood kids might find them and prove how hazardous they could be.

We’ve seen…

  • Tear gas grenades, explosive flares, 40-year-old poison gases from some exterminator’s ancient bag of tricks, leaking open bags of asbestos, explosive flash powder from a turn-of-the-century photography studio, 50 pound bags of DDT, unstable compounds from the local high school chemistry lab, broken kerosene heaters, prehistoric veterinary medicines, and just about every kind of home product imaginable, hazardous or not.

As I’m sure everyone here can confirm, there are actually two “Trick or Treat” seasons when it comes to HHWs: every spring and every fall.

So what would you like to discuss today?

Rather than talk at you, I’d rather talk with you about how to make the HHW events we all face more predictable, more safe, and more responsive to the needs of the homeowners.

How about predictability?

Just like the investment advertising warnings that “past performance is no guarantee of future gains,” every waste collection seems to be a crap shoot these days. Our Spring collection days were phenomenal. Our Fall days have been very disappointing overall.

I’m sure we’d all like to get a better handle on just how long these things should run, how much waste is coming in, and how much this could cost the local taxpayers.

 We’ve seen the following hits and misses, or rather, “Treats” and “Tricks”…

TREAT: Pre-register as many people as possible and give the homeowner a time slot to deliver his waste.

Though far from guaranteed, this approach helps the contractor to better plan his supplies and manpower. It also reduces lines.

 TRICK: Don’t limit drop-offs to only those who have pre-registered.

Once the contractor is there, he wants to get the most from his efforts. And, of course, turning away unregistered cars upsets the homeowners.

TREAT: Try to separate the small businesses from the homeowners.

Every HHW Day we do in Orange County New York is a two-day affair. Saturday is restricted to homeowners. But Friday the Small Quantity Generators (SQGs) bring in their waste (mostly pre-registered for planning purposes and to advise them of the charges). Each SQG’s waste load is tallied up and the SQG receives a bill from the county for the service. And even though they pay, the SQGs are happy to get proper disposal services for much less than the could get on their own.

I believe that this approach recognizes the hardship that waste disposal requirements place on smaller businesses and fosters a more honest response than general open collection days. “You’re driving a painting contractor van. Are you sure this waste paint isn’t from your business?”

 TRICK: Limiting homeowners to a certain gallonage or weight.

If you’re trying to keep small businesses out, try a more positive approach, like an SQG day. Homeowners really do have four car batteries under the porch, bags of old pesticides in the shed (likely bought on sale just before they were outlawed!), and 55 gallon drums in their garages.

After I told him not to pour his waste oil down the dry well in his back yard, my late father-in-law decided to make it easy on himself and put it all in a 55-gallon drum, knowing full well he would never live to have to empty it! I filled every gallon milk and detergent jug I could get my hands on so that I could empty the thing for delivery to the local waste day.

TREAT: Locate the collection near the source of the waste with good traffic access.

Our most successful days are those, such as in Sussex County, located near the local landfill where everyone is going on Saturday anyway or near a major highway, such as in Passaic County, where a drop off is convenient. Our worst day occurred 20 minutes from the closest town in a state park.

 TRICK: Don’t plan the waste day in a vacuum. Check area event calendars before setting the waste day.

We recently had a terrible turnout at a mid-Pennsylvania due in no small part to the fact that the day of our event also happened to be the day of a huge local air show and Ladies PGA golf tournament. Since it was well known that many local roadways between our site and the largest nearby city became impassable owing to the traffic associated with these events, I’m sure that many potential “customers” just stayed home.

How about promoting safety and environmental protection?

TREAT: Caution homeowners that an HHW collection is not a good choice for a family outing.

Even if there are no problems with their waste, what about the general frenzy of activity and traffic associated with this work?

 TRICK: Homeowners are not directed to stay in their cars unless needed to identify something or open the trunk.

Thus, homeowners risk injury from traffic, workers with cartloads of waste, and back strains.

I, the contractor, need to control the delivery of wastes to my workers. Homeowners carrying their spilling containers of gasoline and dripping pesticides over to the sorting tables compromise everyone’s safety.

TREAT: Caution homeowners to, if possible, carry the wastes in the truck rather than on the floor or seats in the passenger section.

Many times wastes spill on the way to the event. This can ruin upholstery and carpets. Worse, the fumes could impair the driver or create a fire hazard if someone is smoking in the car.

 TRICK: Homeowners are not told to extinguish cigarettes in the work area.

Again, if someone gets out of their car and walks to a sorting table while smoking, we’re all at risk.

TREAT: Hold the collection in an open paved parking lot away from storm sewers.

If it’s raining, you don’t want drippage–and there is bound to be some–getting off the site. I don’t know why gravel sites are chosen for some of these collections.

 TRICK: Not holding the contractor to a basic level of personal protective equipment.

I’ve observed waste days–not that we have held, of course–where workers unloaded cars and sorted wastes in shorts, short sleeves, and no safety glasses. Requiring OSHA 40 hour training for contractor workers is a good approach but the county rep, then, must enforce at least minimum standard of protection. If the workers don’t care about themselves, what makes you think they care about anyone else’s safety? By the same token, if the county reps want to wander about the work area–which I don’t think is really necessary–they need safety equipment, too.

How about keeping costs in line?

Which is the best approach? Per car pricing? Per pound pricing? Per container pricing? Per waste/container pricing? Something else?

Each approach has its pluses and minuses.

Per car pricing works well until a local business tries to pawn off its waste–by the van load typically–as household waste. In such circumstances or when a legitimate homeowner just has a huge amount of waste, usually compromises are worked out “on the fly,” counting a van as so many cars. Some clients require a running total of money spent to make sure that funding isn’t exceeded. If this is a concern, per car tallies are the quickest way to stay on top this.

Per pound pricing, where every single container is weighed, takes a lot of time. On the other hand, if the disposal truck is weighed empty and then weighed loaded and the average container weights deducted, the per pound system is more manageable for everyone.

Per container pricing is tricky. Prior to handling the collection days ourselves, REMTECH received HHW materials from other contractors. We could always tell those events where the contractor was paid by the container: Many drums must have slipped by the coordinator because they were woefully under-filled.

Segregating chemicals into their proper US DOT shipping categories and charging according to the waste/container combination is how it’s done everyday for routine lab pack work at industrial sites and school chemistry labs. It’s probably the most fair way overall to calculate disposal costs but its also the least predictable.

Bottom line…we can bid any way the event is to be held but the simpler the method (such as net pounds or per car) the easier the process of invoicing is and the easier the process of tracking costs that day may be.

Other Good Ideas

Here are some ideas for keeping costs–and headaches–in line:

  • Hire a contractor who has their own facility to (1) reduce “middleman” charges and (2) ensure a permit-enforceable paper trail to confirm that proper disposal/recycling occurs.
  • If possible, observe the contractor’s work at another waste day and/or audit the contractor’s facility to confirm that the low bidder is actually the lowest qualified bidder.
  • Separate uncontaminated boxes/cardboard from other event waste and send it to a recycler to boost the local recycling tonnage report and reduce disposal costs.

We’ve had some HHW Days where volunteers break up all the boxes to ensure the best fit and to free us up to concentrate on moving HHW wastes.

  • Alert local emergency response personnel about the event ahead of time to allow them to prepare for contingencies, rather than hiring a haz mat team to sit and watch the proceedings.

If the county would feel safer having some safety oversight during the day, then arrange to have the local publicly-funded haz mat team there. They could always use the exposure. However, paying another subcontractor to sit and wait for a haz mat emergency when you’ve hired an experienced contractor to do the work is unnecessary–not to mention the fact that it makes our hardworking guys jealous of the other contractor who sits around eating donuts and collecting the same pay for seemingly doing nothing. Did I mention that we’d love to be your standby safety team?

Seek grants and assistance from every conceivable source to offset costs and effort.

Aside from state grants, funding can come from local businesses who get some advertising as well as the opportunity to get rid of their SQG wastes at a reduced rate compared to individual service. Some bid proposals we’ve participated in require the contractor to place ads or prepare flyers. We get resumes all the time from recent college graduates who lack waste management/environmental protection/safety experience. Perhaps there is a local college who would love to have the county sponsor internships to help set up and/or run the programs.

Allow unopened consumer goods to be “recycled” on site to event participants.

This allows the truest form of recycling to occur. However, room for traffic from homeowners stopping to “take a look” must be planned for. Also, someone must manage this table to make sure that no spillage occurs.

We also invariably have several homeowners bring in something non-chemical in nature (e.g., small appliances) that they would like to see used again. These people should be directed to take such items to the local Goodwill or Purple Heart collection centers.

Arrange with a local community service organization to collect good latex paints for use in housing renewal programs or public area restorations.

Many events seek to exclude latex paints raising the ire of homeowners who don’t know what else to do with them.

Demand that hazardous waste manifests or other shipping papers document all wastes removed and that original Certificates of Disposal tied to those shipping papers document delivery to a licensed facility before paying the final bill.

REMTECH was not paid for several loads of HHW wastes brought to it by an outside contractor. After a considerable period of seeking payment we contacted the counties directly. We discovered that the unscrupulous contractor had used photocopies of the same check to us to prove to several counties that the disposal bill had been paid. Each copy presented to the county had different manifest numbers typed in according to the county it was trying to convince. The counties paid the fraudulent contractor and refused to assist REMTECH. We are suing over the incident.

Educate the homeowner better about what is potentially dangerous to avoid paying for obviously “safe” trash.

The example I gave at the start of my talk of people dropping off empty whipped cream cans happens regularly. We’ve gotten empty shampoo bottles, dry/empty paint cans, asphalt roofing shingles, electrical devices such as house fans and hair dryers, you name it. I’d say we’ve seen everything but the kitchen sink–but one of those came during a Hudson County waste day.

It’s clear to me that ANJHHWC members are sincerely interested in making HHW Days run without headaches, without safety problems, and with a great turnout. So are we.

Thanks for the opportunity to work with you in this endeavor.

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