Source Reduction Waste Minimization

There are five states in the U.S. that have taken the lead in the U.S. Government’s philosophy and concept of Source Reduction & Waste Minimization. The foundation for such a philosophy lies in the effort to prevent pollution prior to its occurrence, in other words, reducing pollution at the source. This mandate is not to be confused with the Source Reduction Documentation required under EPA’s Pollution Prevention Act of 1990 pursuant to the Toxic Release Inventory (TRI) Reporting program.

State of Arizona

  • The Arizona Department of Environmental Quality’s (ADEQs) Pollution Prevention (P2) Program requires facilities that meet the State filing thresholds to prepare and implement a P2 Plan. The annual filing deadline is December 31 for the previous calendar year in which thresholds were exceeded. Also, a Toxic Data Report is required to be filed each July 1, which includes a P2 Plan Annual Progress Report and Toxic Chemical Release Inventory Report (as required by U.S. EPA and ADEQ).

State of California

  •   Sponsored by California’s Department of Toxic Substances Control (DTSC), AB 1089 (aka Senate Bill 14 (SB-14)) streamlines the reporting requirements of the Hazardous Waste Source Reduction and Management Review Act of 1989 and makes other necessary improvements to provide consistency and clarification for hazardous waste generators and the DTSC. SB-14 requires generators to examine their current hazardous waste generating processes for hazardous waste minimization opportunities and to develop plans for the implementation of workable alternatives. The goal of this law is to promote reduction of hazardous waste generated at the source by California manufacturers. Facilities generating more than 12,000 kilograms of hazardous waste annually or more than 12 kilograms of extremely hazardous waste annually are required to prepare four documents. The documents are the Source Reduction Evaluation Review and Plan (Plan), the Hazardous Waste Management Performance Report (Report) and their respective summaries. A progress report is also required. DTSC audits specific industries and evaluates their source reduction documents. DTSC compiles the most effective concepts for source reduction techniques and then publishes and distributes these studies.

State of Georgia

  • Georgia’s Hazardous Waste Management Act (1990) is applicable to Large Quantity Generators only. The initial report was to be submitted by March 1, 2004, followed by Biennial Progress Reports to be submitted by March 1 of every even year thereafter. Facility changes shall dictate changes to the plan accordingly.

State of Texas 

  • The Waste Reduction Policy Act of 1991 (WRPA) and 30 TAC 335.471-480 has required the Texas Commission of Environmental Quality (TCEQ) to develop the Source Reduction & Waste Minimization Annual Progress Report to assess the pollution prevention progress of facilities required to develop Source Reduction & Waste Minimization Plans. This allows facilities to track their own pollution prevention progress and provide data to the TCEQ, which, in turn, assesses pollution prevention progress for the entire State of Texas. WRPA requires that designated facilities prepare a Pollution Prevention Plan, an Executive Summary of the Plan and an Annual Progress Report. These facilities are generally known to be Small and Large Quantity Generators (SQGs & LQGs) and/or reporters under Toxic Release Inventory (TRI). Original deadlines were required for March 1 annually beginning in 1995, but TCEQ changed the deadline to July 1 annually (relative to the previous calendar year) so as to align its due date with the same deadline each year for TRI Reporting under SARA Title III, Sec. 313.

State of Washington. Under Washington’s Pollution Prevention (P2) Rule

A P2 plan is required if a business or facility…

  • Generates more than 2,640 pounds of dangerous waste annually (SQGs and LQGs); or
  • Reports toxic releases under Section 313 of the Emergency Planning and Community Right to Know Act.

What does the P2 plan identify? It provides opportunities to:
    • Decrease the amount of hazardous substances you use.
    • Reduce the dangerous waste you generate.
    • Conserve water, energy, and other natural resources.
    • Reduce air emissions.
    • Recycle waste into usable materials.
    • Identify the cost savings from taking advantage of pollution prevention opportunities.
    • Regular planning helps measure these efforts over time. Washington’s Toxics Reduction Specialists also use the data to help businesses turn these opportunities into results.
What are the benefits for submitting a P2 plan?
    • A safer workplace
    • Less money spent on hazardous products and disposal
    • Helps businesses stay in compliance
    • When is the P2 plan due?
    • The P2 Plan is due September 1 each year.
Washington’s Hazardous Waste Planning Fee
    • Businesses and facilities that are required to complete a plan may also be charged the standard Hazardous Waste Planning Fee, which is due by July 1 each year.