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

2. 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

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

5. 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

6. 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.

7. 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

8. 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

9. 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

10. Compliance Audit Checklist (8 pages)

11. 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

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

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

14. 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)

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

16. 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

17. 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

18. 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

19. 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.

20. 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

21. Thanks for listening! For more information, contact:
Teresa Gilbertson, MPCA