California Expands Haz Waste Law for Milk Runs

Posted on 11/2/2020 by Roger Marks

The California legislature recently passed a bill that amends the state Health and Safety Code to authorize the use of consolidated manifests for transporters who pick up certain hazardous wastes from retailers who do business in the Golden State.

The law also amends the manifest submission requirements for transporters. Last, it requires that incompatible retail hazardous wastes be segregated properly when transported on the same vehicle, as all incompatible hazardous wastes and materials must be. 

The bill—A.B. 2920—was signed into law on September 28, 2020.

Definition of "Retail Hazardous Waste" in California

The revised hazardous waste law defines “retail hazardous waste” as follows: Unsold consumer products in their original retail sales packaging that are determined to be hazardous waste by the retailer.

The law explicitly states that the definition of “retail hazardous waste” includes, but is not limited to:
  • bleach and other cleaning products,
  • pool chemicals,
  • laundry detergent,
  • cosmetics,
  • personal hygiene products,
  • nail polish,
  • aerosol products,
  • herbicides, and
  • fertilizers. 

What is a Consolidated Manifest?

A consolidated manifest is used when a transporter receives certain hazardous wastes from multiple stops along a route. Consolidated manifests may be used only to transport non-RCRA (i.e., California-only) hazardous wastes and Federal wastes that do not require the use of the Manifest (e.g., used oil).

Instead of receiving a separate manifest from each customer along the route, the transporter carries a single consolidated manifest that describes the waste collected at each stop. At each pick-up, the transporter issues the generator. The generator must keep this receipt for three years (at minimum).

The transporter then completes a manifest for each pick-up and submits the manifests to California Department of Toxic Substances Control (DTSC) on the generators’ behalf.
Consolidated manifests are commonly used when transporters pick up used oil from multiple generator sites.

Consolidated Manifests and Small Quantity Generators 

For generators in California who generate 1,000 kg or less of hazardous waste per month (i.e. Small Quantity Generators), consolidated manifests are also authorized for antifreeze, paint-related wastes, asbestos, printing inks, fuel filters, lab pack chemicals collected from K-12 schools, and more when certain legal conditions are met (see Cal HSC, Section 25160.2(c)).

What’s a Milk Run?

A “milk run” or “milk run logistics” describes a method of picking up deliveries from multiple customers in a single trip. This reduces the distance traveled and maximizes the capacity of the vehicle.

The name is borrowed from the method milk delivery trucks used to deliver milk and retrieve empty bottles from each customer’s home.

A transporter could pick up Client A’s waste, drive to a TSDF, unload the waste, and then driving to Client B’s facility for the next pick up—not very efficient. In a milk run, the transporter picks up Client A’s waste, then Client B’s, then Client C’s, etc.—and brings it all to the TSDF at the end of the run.

Last California Hazardous Waste Webinar of 2020! 

Join an expert Lion instructor for the California Hazardous Waste Management Refresher webinar on December 8. This live webinar will refresh your knowledge of the unique California regulations and law that impact hazardous waste generators.

Plus, we'll help you prepare for major changes that California must adopt from EPA's Generator Improvements Rule.

Cal DTSC requires annual training for hazardous waste personnel  (22 CCR 66262.34 and 66265.16). 

Tags: california hazardous waste, California health and safety code, hazardous waste manifests, new rules

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