Hi all.  Here’s another angle you might want to consider.  Part 89, Littering, of the Natural Resource and Environmental Protection Act allows local law enforcement officers to issue a citation to people for littering (Section 8905a).  The definition of “litter” includes “waste material” (i.e. household hazardous waste, among other waste materials) (Section 8901).  Part 89 also advocates having signage warning of the enforcement that could occur (section 8906).  If a local ordinance is not available, this may be something to consider using in working with local officials and law enforcement, since Part 89 does not affect or in any way limit the powers of municipalities to enact and enforce ordinances for the control and elimination of litter (Section 8907).  I’ve not read through all of the details on this topic, but if it wasn’t already suggested, it’d also be good to use surveillance video so that you can prevail when taking action, and to work with local press to increase awareness on the ramifications associated with dumping materials. 

 

I’d think that signage could first implore people to “protect our children” and others by not leaving harmful materials where they can get into them. Then the signage could also indicate it is also unlawful and identify the enforcement ramifications that could occur.  I hope the ideas and citations help! 

 

Regards,

 

Christine Grossman, Compliance Assistance Specialist

Training and Outreach Unit, Office of Environmental Assistance, Michigan Department of Environmental Quality

Direct Phone: 517-284-6860

Environmental Assistance Center: 1-800-662-9278 or deq-assist@michigan.gov

 

 

     

 

 

 

 

This is Mike Allen from Ingham County Health Department.

 

There are 2 separate issues here, enforcement of illegal dumping and preventing off-hours drop-offs at an HHW facility. The Ingham County Health Department does enforce state rules on illegal dumping. Rene Franco is our solid waste coordinator and the enforcer of illegal dumping. We can and have used both cease and desist orders as well as clean up orders. However, we have never used this for an off-hours drop-off. Illegal dumping ordinances and rules are really not the issue for off-hour drop-offs. The issue is reducing off-hour drop-offs.   

 

We do have off-hour drop-offs. We have not, however, recorded them. I have been considering starting a log of this starting in the new fiscal year. This would help determine if there are patterns not immediately obvious.

 

The two most common times for off-hour drop-offs are:

1)      Winter months when we do not have regular open hours.

2)      Any regularly scheduled open hour that is cancelled for any reason. E.G. 2 weeks ago we closed due to lightning. The next morning we had “stuff” left by the gate. I do not believe we have ever canceled an event without some drop-offs. This is not much of a problem since we very seldom have to cancel regular hours.

 

The winter month drop-offs are more problematic. We do not inspect the site daily during off season. Not only may the waste stay there for a day or more but the waste is sometimes discovered by the snow plow. Not a good thing.

 

We do not have regularly scheduled events Oct thru April but we do take in waste by appointment. However, our experience is that when we have advertised (website or newspaper) that we do winter appointments we get considerably more drop-offs. We believe what happens is that people assume that since we offer appointments some staff will be by sometime during the next day. They feel it is safe to just leave stuff at the gate. So unfortunately we do not currently advertise that we make appointments during winter months. I would like to change this and find a way to advertise, but I am having trouble coming up with a solution.

 

We did not install cameras but we did install an “area under surveillance” sign. This appears to have reduced drop-offs but since I have not kept a log I cannot state this definitively.

 

 

Thanks Cindy.

 

 

Hello,

 

Here is a question for the group from Jon Tulman in Washtenaw County. Please reply to the group or to Jon at tulmanj@ewashtenaw.org Thank you in advance for your responses.

Cindy Foster

Household Hazardous Waste Specialist

HHW Center

269-383-8742

~~~~~~~~~~~~

 

I am evaluating security at our permanent collection facility as it pertains to persons dropping off materials when we are closed for business.

 

I am interested in learning from others around Michigan how they address this issue, specifically as to:

 

1)      Do other programs have ordinance language specific to dropping off HHW materials when the site is closed, or more general language that deals with the illegal dumping of solid waste? 

 

2)      What steps have programs taken (video surveillance, fake video surveillance, signage) to help keep off-hour drops at bay, and what is the success of these methods?

 

Jon Tulman

Solid Waste Specialist

Washtenaw County

734-222-3810

 

 

 

 

 

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