Month: August 2019

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California Organic Waste Recycling Regulations

THE REGULATION: In October 2014, Governor Brown signed AB 1826 Chesbro (Chapter 727, Statutes of 2014) requiring that businesses to recycle their organic waste on and after April 1, 2016 based on the amount of weekly waste they generate. This law also requires that on and after January 1, 2016, local jurisdictions across the state implement an organic waste recycling program to divert organic waste generated by businesses. Organic waste, also referred to as ‘organics’, means food waste, green waste, landscape and pruning waste, nonhazardous wood waste, and food-soiled paper waste that is mixed in with food waste. This law phases in the mandatory recycling of commercial organics over time, while also offering an exemption process for rural counties. In particular, the minimum threshold of organic waste generation by businesses decreases over time. This means larger segments of the commercial sector will increasingly be required to comply. Legislation was enacted as China has stopped taking waste from the US, and landfills in the US are reaching critical capacity. California is making this legislative decision to take the load off landfills by requiring recycling at all levels in the state. 

(Source:https://www.calrecycle.ca.gov/recycle/commercial/organics).

IMPLEMENTATION: Effective January 1, 2019, California law AB 1826 also requires that businesses that have organic waste of 30 gallons (4 cubic yards) or more per week, must separate organic waste from other wastes. If your organic waste at the business is 30 gallons or more per week, you must set up separate containers for organics in the office and break rooms. Looking ahead, per AB 1826, if the State of California determines that the statewide recycling of organics in the year 2020 has not been reduced to 50% of the organic waste generated in 2014, then the organic recycling requirements on business will expand to cover businesses generating 15 gallons of organic waste per week. Even though the law was effective January 1, the counties and cities are now putting pressure on businesses to reduce the waste to landfills and are slowly ratcheting up the enforcement. 

ACTION NEEDED: Actions needed by management include clear labeling of containers for organic waste and directing employees to use them correctly. Janitorial services will then be required to collect the waste from the facility, keep them separated in organic and non-organic categories, and transfer the waste to the commercial hauler-provided specific containers for organic and non-organic waste. Essentially, management must provide separate containers for organic waste and non-organic waste (paper, plastic and glass) in the break room(s) and other locations where employees eat food and may dispose food and food-soiled paper. Commercial waste haulers for the facility must be contacted to provide separate bins for haul away, so that the janitorial staff can dispose the waste into proper containers as required by law.https://www.calrecycle.ca.gov/recycle/commercial/organics/faq

NOTE: Mandatory recycling of organic waste is the next step toward achieving California’s aggressive recycling and greenhouse gas (GHG) emission goals. California disposes approximately 30 million tons of waste in landfills each year, of which more than 30 percent could be used for compost or mulch (Waste Characterization Study 2014). Organic waste such as green materials and food materials are recyclable through composting, mulching, and anaerobic digestion to produce renewable energy and fuel. GHG emissions resulting from the decomposition of organic wastes in land-fills have been identified as a significant source of emissions contributing to global climate change. Reducing the amount of organic material sent to landfills and increasing the production of compost and mulch are part of the AB 32 Scoping Plan (California Global Warming Solutions Act of 2006).  

DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.  Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Our newsletters can be accessed at www.epaoshablog.com. Your comments/questions are always welcome. Please send them to sam@cellyservices.com.

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Best Can Since Canned Beer

Do it for the love of money or the benefit of the environment, or both! What can be economical, good for the environment, and less labor? It’s the refillable can of brake cleaner. Basically, the dealership gets 55 gallons of brake cleaner with refillable cans and the rest is easy. Many dealerships are doing this and find this to be very attractive, especially when taking into account all the costs related to purchase, use, and disposal of aerosol cans. We discuss the pros and cons here:

Dollars & Cents: The dealership buys the drum of brake cleaner with the refillable equipment and aerosol cans. The supplier charges for the drum only. The refillable machine and the refillable cans are free (with the purchase of the drum). A 55-gallon drum retails for about $550. Cost savings:

The refillable can is half the price of retail. Go for it!

Note: If you have to dispose aerosol cans as Universal Waste, add on another $400 for 200 not fully empty aerosol cans. Your savings just tripled. This is a no-brainer

Environmentally Sound Brake Cleaner: Acetone does not have the headaches of chlorinated solvents. Chlorinated solvents, even traces of it, can wreak havoc with used oil disposal. Disposal of used oil laced with halogenated solvents can cost a few dollars per gallon as it heads to an incinerator rather than recycling. Hexane base brake cleaners have been banned, as hexane has been shown to cause peripheral neuropathy in technicians using this solvent over a period of time. Acetone also flies below the radar of many Air Quality Management Districts that have limited the aerosol cleaners with VOC above 25 grams/liter. Acetone based brake cleaner have no AQMD limitations since it is virtually VOC free.

Fire Department Considerations: Fire Department and OSHA regulations limit the storage to 110 gallons of acetone at the facility, See the Newsletter on ourhttps://epaoshablog.com/2017/07/21/news-views-july-2017/. Some Fire Departments may require the storage in a NFPA approved cabinet. Do not over stock the drums as you will exceed storage regulations, expand on the fire hazards, and bear the wrath of the Fire Inspector. Limit your purchases to the minimum needed logistically and operationally. All drums must be properly grounded to protect from static electricity hazards. Grounding must be done with a water pipe or a steel rod 8 feet into the ground. Connection to a conduit or air-line is insufficient.

OSHA Considerations: Acetone is flammable and a toxic substance. Train employees to wear Personal Protective Equipment, such as gloves and eye protection. Use acetone in well ventilated areas, and minimize exposures. Employees spraying acetone close to a 750°F catalytic converter, or close to any other fire source, will experience a flash that will burn their eyebrows, eye lashes and other facial hair! Provide SDS to employees and train them on the Hazard Communication Program. Acetone is a serious fire hazard and can ignite, even if there is only a 2.6% concentration in the air. Fire extinguishers to control fires include foam, carbon dioxide, and dry chemical (Type B or C).

Other Winners: There are additional advantages other than cost savings and reduced waste. A few them are listed here:

  • Minimal Foot Print – A 55G drum has storage of about 500 cans. It will definitely use less storage space.
  • Longer Order Points – No need to order brake cleaner weekly. The system has a monitoring device that allows you to determine the volume remaining and order accordingly.
  • Easy Fill – The system has an easy filling mechanism that is automated and takes the guess work out of the air liquid mixture to be loaded. If the can or filling mechanism goes bad, it is replaced for free!
  • Delivery – Vendors deliver drums within 4 business days of order, as manufacturing plants are located all over the US.

DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as professional advice. Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety prior to purchase of bulk brake cleaner. Bulk storage of flammable materials have safety ramifications so employers and employees must fully understand the safety considerations involved with bulk storage and usage of flammable brake cleaner. This article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Assistance in preparing this article was provided by Tom Baker of Basics. Our newsletters can be accessed at http://www.epaoshablog.com. Your comments/questions are always welcome. Please send them to sam@cellyservices.com.

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Verification Questionnaire CALIFORNIA ONLY

What is the purpose of the California Annual EPA ID Number Verification Questionnaire?

Anyone who generates, transports, offers for transport, treats, stores, or disposes of hazardous waste must have a hazardous waste identification (ID) number, which is used to identify the hazardous waste handler and track the hazardous waste from the point of origin to its final disposal (“cradle to grave”). The purpose of this verification is to ensure that the information on record for the EPA ID Number is correct and current.


The annual Verification Questionnaire and fees assessment for hazardous waste ID numbers and hazardous waste manifests is required by California Health & Safety Code section 25205.15 and 25205.16. Any generator, transporter, or facility operator who fails to provide information required by the department to verify the accuracy of hazardous waste activity data shall be subject to suspension of any and all identification numbers assigned and to any other enforcement action (Health & Safety Code section 25205.16(c)).

What to do?

Hazardous waste generators register on the state web site. All one has to do is log-in and complete the questionnaire to determine if any fees are due. Fees must be paid promptly with the system generated invoice. Fees can range from $150-600 per EPA ID number, depending upon the number of employees at the dealership and the hazardous waste manifests completed for the year.

Options available now:

  1. Complete your EVQ Questionnaire: Dealerships must complete the EVQ questionnaire and pay the relevant fees ASAP. 
  2. Clients of Celly Services contact us to complete your EVQ: Please email us the log-in information for EVQ as follows:

A. Log In for EVQ: 

Username: _____________________

Password: _____________________

B. Number of Employees at dealership: ____________

NOTE 1: We may have stored your EVQ Log in details number from last year. In that case, send us the total number of the employees paid at the corporation.

NOTE 2: If you don’t know the user name and password just send an email to evq@dtsc.ca.govand they will email you a username and password registered to that email address. The user from last year will have the email registered under their name. The system allows you to register as a new entity as well. If you wish for Celly Services to set up log in credentials, please send us a letter on your letterhead. “Permission to obtain login credentials” (Example letter is shown below)

What happens if you do not file EVQ: 

The dealership’s EPA ID number will be made inactive. There is no real warning to the dealership. The hauler stops picking up the hazardous waste as the EPA number has become inactive. Your hazardous waste oil tanks, drums and buckets can continue to overflow! Only after completion of a new EPA ID application, completion of the EVQ and upon the payment of fees, the EPA ID number gets reactivated. This whole process can take over 2 weeks and can be demanding. In summary, consider this matter as critical and get it done ASAP. We are here to help.  

Reach us at 562-704-4000 or sam@cellyservcies.com

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DISCLAIMER: There is no warranty implied or direct or whatsoever as to the completeness or applicability of these signs presented here. The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.  Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Our newsletterscan be accessed atwww.epaoshablog.com. Your comments/questions are always welcome. Please send them tosam@cellyservices.com.