SOP 4.25: Non-Commercial Declaration

Contents

1.Introduction...... 1

2.Regulatory and contractual requirements...... 1

3.Health and safety precautions...... 1

4.Managing Product Reuse Materials...... 2

Attachment A: Draft example of a Non-Commercial Declaration....3

Attachment B: Inventory Sheet...... 4

1.Introduction

Although optional, this Household Hazardous Waste (HHW) Program may accept Product Reuse Material (PRM) from non-profits, retail, government or other institutions (“Donators”). This Program is not required to be licensed as a Very Small Quantity Generator (VSQG) Collection site to accept PRM from these types of generators if the organization will attest to or sign a “Non-Commercial Declaration” (see Attachment A) declaring the products are intended for household use and are still usable for their intended purpose. Verify with County Solid Waste Office protocol if a declaration is used in lieu of a variance.

2.Regulatory and contractual requirements

Acceptance of PRM is allowed in accordance with TSCA, Minn. Rules pt. 7045.0310, Subpart 2, items E through J and Subpart 3, items B & C, 7045.1400, and 7045.0381 and the Operational Contract between this HHW Program and the State.

3.Health and safety precautions

3.1Requirements

3.1.1Train staff involved in PRM management in the proper techniques and applicable rules. Please note that this provision does not provide relief of OSHA, or any other rule, regulation, or law. Staff shall be trained on proper:

  • Personal Protective Equipment (PPE) use; see SOP 2.4 PPE.
  • Ergonomic techniques to avoid injury: see SOP 2.11 Ergonomics.

4.Managing product reuse materials

4.1Review and acceptance of PRM

The designated staff responsible for ensuring proper PRM management and compliance is the Program Manager. No PRM shall be accepted at the facility without prior review and approval of the Program Manager. Prior to transport into this Program, the Program Manager shall perform the following procedures with all Donators:

  • Discuss and/or ask Donators to submit detailed information including the estimated PRM types and volumes. A manifest or shipping paper is not required during transport into the Facility because the products are not waste.
  • Confirm that all materials are in original containers, are intended for use by households and are still effective if used for their intended purpose.
  • Schedule the PRM delivery.
  • Review the following transportation guidelines with the Donator prior to transporting the PRM, including the use or availability of:

1) non-leaking outer containers

2) sufficient absorbents to contain potential spills

3) outer containers that are properly secured and are tightly sealed during transport

4) either a personal or business vehicle for waste transport

4.3Recordkeeping

  • The Program may provide Donators with a receipt as proof of proper disposal;
    see Attachment B.
  • Keep any documentation for at least 3 years from the date of issuance (preferably indefinitely).
  • Any hazardous waste received concurrently with products shall be accurately documented.

4.4Processing incoming RPM

4.4.1 Staff shall carefully examine PRM to determine that the items delivered are those that were agreed to prior to transport. Any waste or products that don’t meet the criteria in 4.1 above may be immediately rejected. Sites that have a full VSQG license may accept the material as waste if the Donator is a VSQG and store and process it in accordance with all applicable SOPs.

4.4.2 PRM facility storage areas shall exhibit Product Reuse or Exchange Signage.

4.4.3This Program is prohibited from treating or disassembling PRM.

Attachment A

Acceptance of Household Hazardous Products
Non-Commercial Declaration

Name of responsible organization/Donator:______

Contact Person: ______

Address: ______

Phone: ______

Name of Transporter: ______

Address if different from above: ______

Phone Number, if different from above: ______

Vehicle License Plate Number: ______

I hereby declare under penalty of perjury that the material listed on this form or attached inventory sheet is not waste and is usable for its intended purpose as a household product and is not a commercial waste.

"Household" means a single detached dwelling unit or a single unit of a multiple dwelling unit and appurtenant structures.

SIGNATURE: ______

DATE: ______

Does this organization generate hazardous waste? YES NO

If yes, list generator classification ______and

HW Generator ID No (if required): ______

w-hhwsop4-25 - Household Hazardous Waste Standard Operating Procedure Non-Commercial DeclarationAugust 2014

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Attachment B

Product Inventory Sheet

This form must be verified and attached to a completed acceptance of Household Products
Non- commercial Declaration Form.

Material Type/Product Name / Size of Containers / Number of
Containers

w-hhwsop4-25 - Household Hazardous Waste Standard Operating Procedure Non-Commercial DeclarationAugust 2014

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