About
Brett D. Robinson

Brett D. Robinson, CHMM, is Vice President and General Manager of REMTECH Group.

Mr. Robinson is extremely knowledgeable in waste classification with particular emphasis on US DOT rules and hazardous waste coding. In addition to creating a number of training manuals, policy/position papers, computerized compliance systems, and a monthly regulations review, Mr. Robinson is author of The Quick Classification System (© 1987, Compliance Systems, Inc.), a 1,000-page manual for building waste classifications which meet EPA RCRA, TSCA, and CERCLA regs, US DOT Haz Mat regs, and most states' rules. The manual also tied in packaging, placarding/ labeling, and paperwork rules.

We’ve seen…

• Cars full of kids and pets carrying open containers of flammable liquids.
• One homeowner I remember even filled both sides of the back seat, leaving his infant strapped into its car seat "for safety."

Rather than talk at you, I’d rather talk with you about how to make the HHW events we all face more predictable, more safe, and more responsive to the needs of the homeowners.

How about predictability?

TREAT: Pre-register as many people as possible and give the homeowner a time slot to deliver his waste.

Though far from guaranteed, this approach helps the contractor to better plan his supplies and manpower. It also reduces lines.

 TRICK: Don’t limit drop-offs to only those who have pre-registered.

Once the contractor is there, he wants to get the most from his efforts. And, of course, turning away unregistered cars upsets the homeowners.

Every HHW Day we do in Orange County New York is a two-day affair. Saturday is restricted to homeowners. But Friday the Small Quantity Generators (SQGs) bring in their waste (mostly pre-registered for planning purposes and to advise them of the charges). Each SQG’s waste load is tallied up and the SQG receives a bill from the county for the service. And even though they pay, the SQGs are happy to get proper disposal services for much less than the could get on their own.

I believe that this approach recognizes the hardship that waste disposal requirements place on smaller businesses and fosters a more honest response than general open collection days. "You’re driving a painting contractor van. Are you sure this waste paint isn’t from your business?"

 TRICK: Limiting homeowners to a certain gallonage or weight.

If you’re trying to keep small businesses out, try a more positive approach, like an SQG day. Homeowners really do have four car batteries under the porch, bags of old pesticides in the shed (likely bought on sale just before they were outlawed!), and 55 gallon drums in their garages.

After I told him not to pour his waste oil down the dry well in his back yard, my late father-in-law decided to make it easy on himself and put it all in a 55-gallon drum, knowing full well he would never live to have to empty it! I filled every gallon milk and detergent jug I could get my hands on so that I could empty the thing for delivery to the local waste day.

TREAT: Locate the collection near the source of the waste with good traffic access.

Our most successful days are those, such as in Sussex County, located near the local landfill where everyone is going on Saturday anyway or near a major highway, such as in Passaic County, where a drop off is convenient. Our worst day occurred 20 minutes from the closest town in a state park.

 TRICK: Don’t plan the waste day in a vacuum. Check area event calendars before setting the waste day.

We recently had a terrible turnout at a mid-Pennsylvania due in no small part to the fact that the day of our event also happened to be the day of a huge local air show and Ladies PGA golf tournament. Since it was well known that many local roadways between our site and the largest nearby city became impassable owing to the traffic associated with these events, I’m sure that many potential "customers" just stayed home.

How about promoting safety and environmental protection?

TREAT: Caution homeowners that an HHW collection is not a good choice for a family outing.

Even if there are no problems with their waste, what about the general frenzy of activity and traffic associated with this work?

 TRICK: Homeowners are not directed to stay in their cars unless needed to identify something or open the trunk.

Thus, homeowners risk injury from traffic, workers with cartloads of waste, and back strains.

I, the contractor, need to control the delivery of wastes to my workers. Homeowners carrying their spilling containers of gasoline and dripping pesticides over to the sorting tables compromise everyone’s safety.

TREAT: Caution homeowners to, if possible, carry the wastes in the truck rather than on the floor or seats in the passenger section.

Many times wastes spill on the way to the event. This can ruin upholstery and carpets. Worse, the fumes could impair the driver or create a fire hazard if someone is smoking in the car.

 TRICK: Homeowners are not told to extinguish cigarettes in the work area.

Again, if someone gets out of their car and walks to a sorting table while smoking, we’re all at risk.

TREAT: Hold the collection in an open paved parking lot away from storm sewers.

If it’s raining, you don’t want drippage--and there is bound to be some--getting off the site. I don’t know why gravel sites are chosen for some of these collections.

 TRICK: Not holding the contractor to a basic level of personal protective equipment.

I’ve observed waste days--not that we have held, of course--where workers unloaded cars and sorted wastes in shorts, short sleeves, and no safety glasses. Requiring OSHA 40 hour training for contractor workers is a good approach but the county rep, then, must enforce at least minimum standard of protection. If the workers don’t care about themselves, what makes you think they care about anyone else’s safety? By the same token, if the county reps want to wander about the work area--which I don’t think is really necessary--they need safety equipment, too.

Other Good Ideas

Here are some ideas for keeping costs--and headaches--in line:

If possible, observe the contractor’s work at another waste day and/or audit the contractor’s facility to confirm that the low bidder is actually the lowest qualified bidder.

Separate uncontaminated boxes/cardboard from other event waste and send it to a recycler to boost the local recycling tonnage report and reduce disposal costs.

We’ve had some HHW Days where volunteers break up all the boxes to ensure the best fit and to free us up to concentrate on moving HHW wastes.

Alert local emergency response personnel about the event ahead of time to allow them to prepare for contingencies, rather than hiring a haz mat team to sit and watch the proceedings.

If the county would feel safer having some safety oversight during the day, then arrange to have the local publicly-funded haz mat team there. They could always use the exposure. However, paying another subcontractor to sit and wait for a haz mat emergency when you’ve hired an experienced contractor to do the work is unnecessary--not to mention the fact that it makes our hardworking guys jealous of the other contractor who sits around eating donuts and collecting the same pay for seemingly doing nothing. Did I mention that we’d love to be your standby safety team?

Thanks for the opportunity to work with you in this endeavor.