Bringing Small Business Hazardous Waste to Household Hazardous Waste Collections

Small businesses are frequently unaware of the responsibilities for managing their hazardous wastes. Many dispose of paints, fluorescent lights, pesticides and other harmful chemicals in the garbage or by pouring them down the drain. By law, these businesses must make a determination if their wastes are hazardous and are prohibited from disposing of any hazardous wastes in the regular garbage. Contracting with a licensed hazardous waste disposal facility can be expensive for a small business. Recent changes in the state’s solid waste regulations allow many small businesses, known as conditionally exempt small quantity generators, (CESQGs) to bring their hazardous waste to household hazardous waste (HHW) collections. HHW collections typically take place on Saturdays in the Spring and Fall. These programs take in hazardous wastes such as oil-based paints, pesticides, fertilizers, thinners, acids, mercury, gasoline and other household chemicals. CESQGs frequently generate similar hazardous wastes. This fact sheet is designed to answer some questions and outline the responsibilities of a CESQG interested in safely disposing of its hazardous waste through a household hazardous waste collection.

What is a CESQG?

A CESQG is any business, governmental entity or non-profit that generates less than 100 kilograms (220 pounds) in a calendar month and does not store more than 1000 kilograms of total hazardous waste (2200 pounds) at any one time. CESQGs may be small print shops that regularly generate small amounts of inks and solvents in a month, or a law office with hazardous cleaning supplies, a can of oil-based paint or some fluorescent lights.

Where can a CESQG dispose of its hazardous waste?

There are three options for CESQGs to legally manage their hazardous wastes:

1. A CESQG may deliver its hazardous waste to an off-site treatment, storage or disposal facility. This can be accomplished by offering the waste to a transporter permitted to accept hazardous waste under Section 22a-454 of the Connecticut General Statutes or by self-transporting the wastes.
2. A CESQG may deliver its hazardous waste to an out-of state facility permitted by that state to accept it.
3. A CESQG may take its hazardous waste to a participating HHW collection. The towns or other regional entities serving the towns administer HHW programs. These towns or regional entities are not required to offer collection to a CESQG but they may choose to offer collections. Household Hazardous Waste Collection Schedule

Where do the HHW collections take place?

Contact the program administrator for the exact dates and locations of the collections. The program administrators can be found at the DEEP website or by contacting the town Department of Public Works. Collections for CESQG will be by appointment only.

What types of waste can the CESQG bring in?

The programs will accept typical hazardous wastes such as paints, solvents, acids, pesticides, and gasoline. There are some wastes that will be prohibited from the collections. The CESQG should contact the HHW program administrator with a complete list of wastes to determine if they can accept them.

How does a CESQG participate?

By contacting the HHW program administrator to find out if they will be conducting CESQG hazardous waste collections. The program administrator or hazardous waste vendor will provide information. Here are some important steps the CESQG will need to take to participate.

1. Determine which of the wastes are hazardous. This can be accomplished by reading the label, consulting with the manufacturer or by obtaining a Material Safety Data Sheet.
2. Contact the HHW program administrator or hazardous waste vendor to determine what wastes are acceptable and to schedule a time to bring in the wastes.
3. At least five days prior to the date of collection, submit a signed CESQG Approval Form (DEP-Approval-001: PDF Format, Word Fillable Format) to the HHW program administrator certifying that the business is a Conditionally Exempt Small Quantity Generator.  The CESQG can also consult with the hazardous waste vendor as to the generator status.
4. Prepare a list of all the hazardous wastes to be disposed.
5. Prepare the wastes for transportation.

What are the transportation requirements? (What are the CESQG’s responsibilities?)

As the generator of the waste, the CESQG is responsible for ensuring that the hazardous wastes are properly packaged and transported safely to the collection site. The US Department of Transportation has established regulations for the transportation of hazardous waste. These regulations apply to CESQGs transporting their hazardous wastes to the collection. The program administrator or hazardous waste vendor will provide specific information based on the type of wastes to help ensure that the wastes are transported safely.

Here are some of the DOT requirements for packing and transporting hazardous wastes:

• Shipping papers - The program administrator or hazardous waste vendor will provide the CESQG with shipping papers based on the list of hazardous wastes. Shipping papers are simply a list of the hazardous wastes that are being transported to the collection site. The shipping papers may also contain information on the quantity of the wastes, a description of the wastes, the number and type of packages, emergency response information and the destination. The shipping papers will be kept in the vehicle while transporting. The CESQG should consider holding onto a copy of the shipping papers for three years as proof of proper management of the hazardous wastes.
• Packaging – The CESQG is responsible for ensuring that hazardous wastes are properly packaged for transportation and the packaging meets regulatory standards. The hazardous waste vendor or program administrator can assist with any questions concerning proper packaging. Packages used for transporting the hazardous waste need to be structurally sound, not cracked or leaking, and compatible with the contents. For example, a plastic container would be suitable for oil-based paint, but not a strong acid. CESQGs should consider using the original containers instead of repackaging the wastes. This will decrease the risk of spills and exposures. Original containers are usually acceptable for transporting wastes as long as they are in good condition. Avoid mixing of wastes.
• Labeling – The CESQG is responsible for ensuring that all packages meet DOT labeling requirements. The hazardous waste vendor or program administrator should be able to assist with any questions pertaining to labeling. There are exemptions for labeling requirements for wastes up to a certain quantity limit. Generally speaking, containers purchased at retail outlets are exempt from labeling requirements. However the CESQG should be sure that the labels on the original containers are legible.
• Transportation – The CESQG is responsible for following all DOT transportation requirements. CESQGs are not required to placard vehicles because they are below the 1000-pound threshold. Make sure that the wastes are secured before transporting. Keep incompatible wastes separate. Keep the shipping papers in the vehicle within arms reach. Once the CESQG arrives at the collection site, the program administrator and hazardous waste vendor will provide the CESQG with directions.

What will it cost to participate in the program?

The HHW program administrators will determine what to charge for disposal. The cost is dependent on the type of waste. However the cost will most likely be less expensive for a small business to take its hazardous waste to a household hazardous waste collection than to have a licensed hazardous waste transporter come to the generation site.

Prepared by the Connecticut DEEP Pollution Prevention Program.  For more information, contact Tom Metzner at DEEP 860-424-3242.

Household Hazardous Waste

Content Last Updated February 5, 2020