Auditing Household Hazardous Waste Collection Sites Jennifer Volkman HHW Program Coordinator North American Hazardous Materials Management Association Conference September, 2012

MPCA’s role in HHW State Statutes, 115A.96, require MPCA to operate a HHW collection and disposal program The MPCA can contract with public or private entities to provide collection services in “Greater MN” “Metro” counties have a separate statutory requirement to operate a program

MPCA Contracts 7 Metro Counties 14 Regional Programs in GM MPCA provides to counties: technical assistance training educational materials protection for potential downstream liability

Facility/Program Auditing Completed to ensure compliance with: Contract terms Jointly developed SOPs OSHA, DOT, HHW regulations To Preclude: Inspections from MPCA regulatory programs Safety issues

Level of Regulation for HHW Equivalent to LQG regulations Notify the MPCA before operating Relaxed transportation requirements between HHW facilities and between events and facilities.

Inspection frequency 70 permanent collection sites Many close Nov-March Metro county inspections by request only Audit provided upon request or Rotational basis of one audit every 2-3 years

Audit Process Select one or several sites Pre-notify—this is technical assistance, we want the operator(s) to be there Complete checklist Provide follow up letter—requirements are enforceable via contract Follow up visit if site is having problems

HHW Facility Audit Covers: Management Facility Design Facility Operations Manifests & Waste Disposal State Contract Requirements Training Reporting & Recordkeeping HHW Mobile Collections Reuse or Product Exchange Health & Safety CESQG Programs DOT Requirements Stormwater requirements CESQG Consolidation site requirements—if program collects

Compliance Audit Checklist (8 pages)

Audit Length Entire process typically takes 2 -3 hours Additional time needed for CESQG Programs Leave plenty of discussion time for hot topics and problem items Invite regional HHW and Solid Waste staff as this is their opportunity for program questions

Facility walk through Container Labeling/Storage Accumulation/Generation limits Universal/waste management Fire & Spill response equipment

Records Review Staff training records Facility Inspections Emergency Preparedness (Contingency and DOT Security Plans) Standard Operating Procedures CESQG Shipping Papers/Manifests

Follow up Summarize audit deficiencies and send a letter to each HHW site Inspection history used during audits Note improvements from previous audit Follow up visits typically not done until next scheduled audit (generally, every two years)

Top 2 Deficiencies Container Labeling Updating Contingency Plans on a regular basis

Issues Program staff are hesitant to have an inspection from a regulatory agency Program staff are sure “everything is under control” (dead giveaway that they aren’t :) Answer shopping from other Agency staff if they don’t like the results

Exposure Studies Conducted in 1996 and 2006 at MN HHW facilities Mercury “hit” due to broken lamp No need for respirators when bulking paint inside or out Ergonomics and heat stress are the two major issues

Minnesota Study: Effectiveness of Hazardous Waste Site Visits: “Audit” vs. “Inspection” Study by Lake Superior Initiative Managed by Jenny Jensen/ MPCA in Duluth EPA funded

Audits vs. Inspections Long term effectiveness: Both types of site visits significantly decrease number of violations Postulated that site visits of any type would not be successful if enforcement “threat” did not exist. Conclusion: Neither compliance tool is mutually exclusive of the other.

Audits vs. inspections YES Do one-on-one technical assistance visits increase compliance with MN HW Rules as effectively as traditional inspections? Are behaviors changed to remain compliant? YES

Thanks for listening! For more information, contact: Teresa Gilbertson, MPCA 507-476-4254 Teresa.gilbertson@state.mn.us