Toxic Use and Hazardous Waste Reduction
The intent of toxic use and hazardous waste reduction planning is to encourage reduction of toxic substances and reduce the generation of hazardous waste whenever technically and economically practicable, without shifting risks from one part of a process, environmental medium or product to another. The specific goals of planning are to (1) eliminate, or reduce the use of hazardous, particularly toxic, materials wherever feasible; (2) reduce the generation of hazardous waste; (3) reduce the release into the environment of chemical contaminants which have adverse and serious health or environmental effects; and (4) document hazardous waste reduction and toxics use reduction information and make that information available to State and local government and the public.
To achieve the stated goals, the Vermont Statute:10 V.S.A. Sections 6623-6632, requires certain facilities to develop a plan for toxics use reduction and/or hazardous waste reduction or generation of hazardous waste. Implementation of reduction plans is not required by the law, however the act of going through the planning process alone is an important exercise that provides the facility with a picture of their own toxics use and waste generation and ways to reduce these materials, and often leads to changes by implementing the plan.
The Planning Process
The purpose of toxic use and hazardous waste reduction planning is to identify opportunities to reduce or eliminate the use of toxic chemicals and the generation of hazardous waste at the source rather than treating or controlling these materials after they have been created or used.
A series of worksheets with instructions to assist businesses have been created to assist with developing a plan. Businesses that are subject to planning must also file an Annual Progress Report. Copies of both the Toxic Use and Hazardous Waste Planning Guidance, which includes the worksheets that make up a plan, and Annual Progress Reporting forms can be downloaded below.
Who Needs to Plan?
The law requires businesses that generate greater than 2,640 pounds per year of hazardous waste, or manufacturers (SIC Codes 20-39) that use 1,000 pounds or more per year of certain chemicals (EPA Toxic Release Inventory listed chemicals, see SARA Title III, Section 313 ), to prepare plans to reduce the generation and/or use of these materials.
Toxic Use and Hazardous Waste Reduction Annual Progress Reports and fees are due annually by March 31st.
Annual Progress Report Forms:
- Download Annual Progress Report Form - PDF format, to print and fill out
- Download Annual Progress Report Form - MS Word format, to fill out electronically
- Download EPA Toxics Release Inventory List of Chemicals for Reporting - MS Excel format
- Download EPA Toxics Release Inventory List of Chemicals for Reporting - PDF format
- P2 Annual Fee Calculator Tool- Download MS Excel spreadsheet to help calculate annual pollution prevention fee
- $400.00 per toxic chemical.
- $400.00 per hazardous waste stream.
- Up to a maximum amount of:
- $2,000.00 per plan for Class A generators.
- $400.00 per plan for Class B generators.
- $2,000.00 per plan for large users.
- $4,000.00 per plan for Class A generators that are large users.
- $1,200.00 per plan for Class B generators that are large users.
Toxic Use and Hazardous Waste Reduction Plans are due every 3 years by July 1st.
Updated plans will be due July 1, 2023.
Toxic Use and Hazardous Waste Reduction Plan Guidance and Worksheets:
- Download Guidance and Worksheets - Whole document as one PDF - to print and fill out
- Individual Worksheets in MS Word format to fill out electronically.
- Certification of Plan Completion
- Worksheet 1 - Facility Information
- Worksheet 2 - Management Policies
- Worksheet 3 - Ongoing Pollution Prevention Activities
- Worksheet 4 Toxic Substances - Worksheets 4A and 4B
- Worksheet 5 - Hazardous Waste Generation
- Worksheet 6 - Process Description
- Worksheet 7 - Identifying Opportunities
- Worksheet 8 - Technical Feasibility Analysis
- Worksheet 9 - Financial Analysis
- Worksheet 10 - Performance Goals
- EMS Alternative Application
Toxic Use and Hazardous Waste Reduction Resources on the Web:
- Zero Waste Network Pollution Prevention Options - search for P2 and waste reduction case studies by industry type, process type or type of waste reduced
- Healthcare Environmental Resource Center - pollution prevention and compliance assistance information for the healthcare industry
- Toxics Use Reduction Institute at UMASS Lowell
- OSHA Transitioning to Safer Chemicals Toolkit
- Subsport - chemical substitution support portal with ingredient and case study database
- Chemhat - chemical hazards and alternatives toolbox showing health effects, hazards, environmental impacts and safer alternatives
Environmentally Preferable Purchasing (EPP) Resources:
- EPA's Safer Choice labeling program
- Green Seal Certified Products
- Electronic Product Environmental Assessment Tool
- Energy Star, Energy Efficient Products
- UMass Lowell Toxics Use Reduction Institute (TURI) Green Cleaning Lab
- EPA Sustainable Marketplace for greener products and services
Michael Nucci at (802) 522-0287 firstname.lastname@example.org,