The HHW exclusion extends to household wastes accumulated in quantities that would otherwise be regulated or when transported, stored, treated, disposed, recovered, or reused at collection centers or during collection programs. However, if household wastes are mixed with regulated hazardous waste from commercial or industrial sources, the resulting mixture could be subject to RCRA regulation and the collection center could be a hazardous waste generator (Memo, Porter to Directors, Regions 1-10; November 1, 1988 RCRA Online #11377). If a collection center does not wish to segregate HHW from other hazardous waste, or if they wish to adopt the most environmentally conservative approach, they may handle all of the waste as hazardous waste and count it all towards their generator status (Memo, Helms to Toro; July 12, 1996 RCRA Online #11958).
Additional guidance regarding HHW collection is available in the following documents:
Memo, Horinko to Niebur; January 21, 2003 (RCRA Online #14647)
Memo, Lehman to Constantelos; January 28, 1986 (RCRA Online #12547)
These documents are available at the following URL:
Additional information regarding HHW is available at the following URL: