Jennifer Volkman, Statewide HHW Program Coordinator Proud NAHMMA Member since 1995. Paint Product stewardship rollout in Minnesota. MN’s HHW Program 2014. oops. 67 Permanent HHW Sites 33 Seasonal 34 Year-round 19 VSQG/HHW sites ( 15 Advertise) 300 Mobile Events Days
Proud NAHMMA Member since 1995
60% Metro; 40 % Greater MN
Alternative Daily Cover (10-15 smaller counties)
Statutorily mandated (MPCA contracts with counties and regions)
Consistency in programs
Share ideas and resources
Safety and Health
We like each other!WHY we work together
Contracts with CountiesBreakdown of work to implement a PS Program
Subd. 2.Product stewardship program.
For architectural paint sold in the state, producers must, individually or through a stewardship organization, implement and finance a statewide product stewardship program that manages the architectural paint by reducing the paint's waste generation, promoting its reuse and recycling, and providing for negotiation and execution of agreements to collect, transport, and process the architectural paint for end-of-life recycling and reuse.
Subd. 3.Requirement for sale.
(a) On and after July 1, 2014, or three months after program plan approval, whichever is sooner, no producer, wholesaler, or retailer may sell or offer for sale in the state architectural paint unless the paint's producer participates in an approved stewardship plan, either individually or through a stewardship organization.
Included: “evidence major changes before final passage in 2013of adequate insurance and financial assurance that may be required for collection, handling, and disposal operations”
Plan is posted at: http://www.pca.state.mn.us/8kqwdryPaint stewardship plan
Coordinate with your regulators before you finalize legislation!
MN regulates businesses down to the drop; no one is conditionally exempt (CESQG vs. VSQG)
Rules revised under “housekeeping” to regulate paint only collectors at the SQG level.
Adjustments to Metro County Ordinances also required.
Impact to county and state fees collected to run HW programs in MNRegulation
Level of regulation for collectors: all HHW is fully regulated once collected; same for VSQG waste
ID numbers: must have one to drop off waste
Receipts: to demonstrate proper disposal
Reporting: discussing nationally
Changes to rules is difficult in MNPerceived Regulatory barriers
Guidance developed for Collectors and Generators located at: http://www.pca.state.mn.us/veiz8a8; scroll down to “Specific Wastes” look for paint
May 29th: Mailed guidance to ~3,200 businesses with the word “paint, wall coverings… etc. in the business name with a July 1 start.
Will be re-mailing to the 3,200 businesses with the revised start date of Nov 1.Regulatory assistance
HHW Programs went through contract and provided comments to SWMCB and SWAA, which are the groups that develop policy for Metro and Greater MN solid waste programs
Association of Minnesota Counties and Minnesota Counties Insurance Trust also weighed in.
Template “for doing business in Minnesota” developedContract process
Recitals revise the relationship SWMCB and SWAA, which are the groups that develop policy for Metro and Greater MN solid waste programs
Allows counties to continue to use established State Contract vendors.
Reduced liability and insurance provisions.
On-site services may require a different level of liability protection: bulking, transport, processing, reuseMN contract for HHW/county programs
Template was drafted and reviewed by 10+ county attorneys. SWMCB and SWAA, which are the groups that develop policy for Metro and Greater MN solid waste programs
HHW Programs commented on draft
Draft submitted to PaintCare on June 3.
Initial response from PC is that the insurance and indemnification provisions are lacking
MN counties that PC provide specific examples of potential liability issues that they will have in Minnesota for merely reimbursing for services provided under the State contract.MN contract for HHW/county programs
HHW/VSQG Programs had businesses showing up with paint and demanding free disposal in May—word is getting out!
Not many questions have come in to MPCA
Removed HHW/VSQG sites from paint locator until closer to Nov 1 or when contracts are signed.meanwhile
Those demanding free disposal in May—word is getting out!who draft legislation need to have a deep understanding of existing regulatory framework
More regular communications sooner
Future PS efforts; precedence and sustainabilityThoughts on the process
[email protected] demanding free disposal in May—word is getting out!