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Toxic products,
whether used in the home or business, are severely regulated materials.
From precise labeling requirements, material safety data sheets, transportation
specifications and disposal provisions, toxic products have a myriad of
safeguards to minimize the risks to human health and safety. If it were
only that simple. The reason the regulations are so complex is because the
effect of toxic products in the environment is so complex. The system of
regulations fails, however, at the critical stage of disposal.
By definition, toxic products used in the home (which includes paints, stains,
drain cleaners, motor oil, etc.), are exempt from disposal regulations.
Because there is no practical way to regulate these products at the household
level, a large majority of these products end up in the municipal waste
stream where they represent a threat to groundwater supplies among other
problems.
Business, commercial and industrial generators of hazardous waste are classified
as either Small Quantity Generators or Full Quantity Generators.
A Small Quantity Generator generates less than
220 pounds of hazardous waste or 2.2 pounds of acutely hazardous waste per
month. Full Quantity Generators are subject to a "cradle to grave"
manifest system that ensures proper disposal, but Small Quantity Generators
tend to fall through the cracks. My guess is that the majority of Small
Quantity Generators are not even aware that they generate hazardous materials
and if they aware the number of hoops they are required to jump through
discourage them from being responsible stewards. Most small business owners
will dispose of hazardous material properly if it is convenient and cost
effective.
Somehow the zeal to create regulations to protect human health and safety
conflict with our efforts to create convenient and cost effective disposal
options. The City of Keene is constructing a permanent hazardous waste facility
scheduled for completion this Fall, primarily for household toxics, but
also capable of accommodating Small Quantity Generator Waste. Unfortunately,
we need a separate permit to collect this waste despite the fact that there
often little to distinguish household hazardous waste from small business
waste. Aside from a lengthy permit process including hydro-geological testing,
and setback requirements, any Small Quantity Generator Waste received must
be removed on the day of receipt. One of the hallmarks of a permanent hazardous
waste facility is the ability to store material until an efficient load
can be transported off-site. Our inability to store Small Quantity Generator
Waste due to permit restrictions is a flaw in the regulations.
As a result, the City of Keene is not pursuing a permit to collect Small
Quantity Generator Waste at this time. To get a permit to collect Small
Quantity Generator Waste given the current state of the regulations will
serve no useful purpose because unless we can offer convenient, cost effective
disposal solutions, Small Quantity Generators will not participate. The
State of New Hampshire is finally recognizing the flaws in the regulations
and are forming a review team to recommend changes. In creating cumbersome
regulations we lose sight of what we are really trying to accomplish. The
bottom line is that we are trying to prevent improper disposal of hazardous
materials. Aside from preventing the waste from being generated in the first
place, providing outlets, such as permanent collection facilities, for responsible
disposal without too much of a hassle will do more to protect the environment
and human health and safety than regulations that offer no solutions to
real problems.
Note: Charlie says- "The paper recycling program in Keene does not, I repeat, does not accept wet strength fiber such as milk, juice, or ice cream cartons."
Duncan Watson is the solid waste coordinator
for the Keene Public Works Department.