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Establishing EPR goals is a complex process, however, developing metrics other than the usual convenience factors for performance holds promise for truly effective EPR collection program goals.
By David Nightingale, CHMM, S.C.

In the past two decades, Extended Producer Responsibility (EPR) in the U.S. has made great strides moving towards a more circular economy for the management of hazardous and other materials, those which used to be inappropriately disposed of in the garbage. Nonetheless, to more effectively implement these EPR programs, more scrutiny needs to be applied the metrics used to establish levels of effectiveness. This requires looking beyond the common convenience goals contained in many EPR laws.

The Convenience Standard
A common criterion for which state EPR programs are required to meet is a certain level of statewide convenience. A recent example of this is from Illinois鈥� recent Paint Stewardship Act (SB 836). That law includes the goal to provide that: 鈥�(A) at least 90 percent of State residents shall have a collection site, collection service, or collection event within a 15-mile radius, and (B) at least one collection site, collection service, or collection event for every 50,000 residents of the State.鈥�

This type of convenience standard is a derivative from the early days of recycling where it was common for local jurisdictions to implement requirements for neighborhood drop-off stations for common recyclables, prior to the more common curbside collection trucks which dominate recycling today. Recycling effectiveness metrics have since evolved and so too should EPR effectiveness metrics.

Convenience Does Not Equal Effectiveness
To meet the letter of this recent Illinois paint stewardship law, a thrifty stewardship program manager looking to limit their costs could provide one collection event per year in strategic locations around the state and be done. Based on the long history of household hazardous waste (HHW) collection events across North America, where leftover paint is the largest single waste type collected, you will at best reach some low level of percentages of households per year. Individual collection events for HHW often attract only a fraction of a percent to a few percent of households in the jurisdiction on an annual basis. In a similar vein, a collection point that is only open once per month for a few hours may also be expected to be relatively ineffective in serving a local community. To be truly effective in collection of HHW, including leftover paints, a program needs to serve around 13 to 14 percent of all households per year.1

Establishing and Evolving Effectiveness Goals
Vermont has long been a leading state in adoption of EPR laws under the long-standing leadership of Jennifer Holliday of the Vermont Product Stewardship Council since 2008 and the Director of Public Policy and Communications at the Chittenden Solid Waste District. Vermont passed new EPR legislation in 2023 (Act 58); this time encompassing the larger universe of HHW not already covered by paint, battery, and other prior adopted Vermont EPR laws.

This 2023 Vermont law included a beginning collection performance goal of 5 percent of household participation per year. Future participation goals will be proposed by the stewardship organization. Future percent participation goals will be designed by examining data from waste sorting analysis and other relevant factors through a review process every five years by the stewardship organization and the Secretary of Natural Resources. This law allows the flexibility of adopting future levels of participation at regular intervals and actual evaluation of effectiveness based on the EPR program collection results, what is continuing to be disposed of in the MSW stream, and other credible information sources.

Depending on where you live in Vermont, local HHW collection programs experience different levels of participation. In some jurisdictions, such as Addison County Solid Waste Management District and Chittenden Solid Waste District, annual HHW participation levels of 12 percent and more are routinely reached. These jurisdictions have long-standing permanent collection facilities open many hours all year round. In some other parts of the state the annual level of participation are only a few percent. The 5 percent participation goal should help lower performing areas to catch up to those who have already achieved effective levels of service.

Vermont has been working with local jurisdictions to provide a more complete statewide HHW collection infrastructure to achieve higher levels of annual participation. A 2019 VT Department of Environmental Conservation study suggested that this might be accomplished by expanding the number permanent HHW collection facilities.2 The state is now encouraging the development of additional regional permanent HHW collection facilities in strategic locations through a grant program.

Waste Management and Effectiveness
Looking back to the leftover paint issue for a moment. It is laudable that some PaintCare product stewardship state programs are recycling 80 to 90 percent or more of latex paint into new paints. However, this addresses only a success regarding the proportion of collected latex paint managed at the higher levels of the normal waste management hierarchy. This does not address the overall effectiveness of collecting the total amount of paint that is leftover.

There is a commonly used estimate that approximately 10 percent of paint sales become leftover paint that needs to be appropriately managed.3 Data on overall aggregate paint sales by state is available. Using the 10 percent leftover estimate of total annual paint sales could be an even more direct path to establishing ERP goals for paint stewardship programs. A 10 percent paint collection metric would be a more direct way to effectively measure the effectiveness of that EPR program at the state and national level. Of course, leftover paints are often stored for touchups. During the national paint product stewardship initiative that led to the formation of PaintCare, an estimated average age of leftover paint was found to be 7.4 years. So, the 10 percent of leftover paint per year would need to be timed for collection with a delay of about 7.4 years.

Unlike paint, many other problematic wastes that are difficult to handle, such as electronics and batteries, are not consumed during use. In those cases, sales estimates and the expected average useful life estimates can inform establishment of meaningful goals for collection effectiveness and indexing sales to collection timing goals. For example, if a million pounds of lithium-ion batteries are sold during 2024 in a state with a useful life expectancy of four years, then a collection goal based on those batteries becoming waste in 2028 would be established. Such goals would need to account for 鈥渓eakage鈥� due to inappropriate disposal practices which might be quantifiable through periodic waste sort analysis. One hundred percent recovery of all problematic wastes is not feasible. However, considering 100 percent of sales as the baseline value of total volumes of the future problem waste stream is a good place to start development of realistic collection effectiveness goalsetting.

Difficult Problems Are Worth Solving
In reality, establishing effectiveness goals is a complex process, as there are many assumptions that must be made to design the method and metrics that are rational and achievable for EPR program collection. However, solving difficult problems is very often a worthy pursuit and, in the EPR/circular economy context, holds the promise of a cleaner future for us and those who must live with our leftovers. | WA

David Nightingale is the Principal at Special Waste Associates. Special Waste Associates assists communities developing or upgrading HHW collection infrastructure and operations. He currently serves on the North American Hazardous Materials Management Association () Board of Directors. You can reach David at (360) 259-6497 or e-mail [email protected].

Notes
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Product Stewardship Institute, Inc., Report for Vermont Department of Environmental Conservation: Research on EPR Programs for HHW, Final Report, Boston, Feb. 7, 2019.
The 2023 Illinois Paint Stewardship Act citing this 10 percent leftover paint estimate, which originated during the Paint Product Stewardship Initiative facilitated by the Product Stewardship Initiative in the early 2000s.