How to stem the tide of new products from coming to market without planning for end-of-life.
By Kenneth Miller
Welcome tO NAHMMA Corner! NAHMMA, SWANA, and NSAC partnered on a three-part webinar series in March, April, and May that focused on EPR, EPR for specific HHW products including batteries, propane tanks and pyrotechnic flares, and upstream solutions to prevent hazardous product sales without End of Life (EOL) management plans. When no EOL plan exists, many consumers are left with little or no options, putting refuse, recyclable, and household hazardous materials collectors and collections infrastructure at risk.
The third and final webinar in this series, which is on May 29, 2025, at Noon MT, will cover how to stem the tide of new products from coming to the market without an EOL Plan. The speakers will include Amy Lestition Burke, SWANA Executive Director and CEO, and Heidi Sanborn, NSAC Executive Director. As a preview for this final webinar, I reached out to Amy and Heidi to gather some insights on what you can expect to hear when you attend the webinar and offer some insights from NAHMMA as well.
When a hazardous product has no EOL plan who becomes responsible for the management?聽 What happens to the products?
Amy, SWANA: 鈥淭his is a huge challenge for SWANA members. I often hear stories from our members about how residents will bring hazardous products to public dropoff sites and then that site has to figure out what to do. When the consumer does not receive any direction on how to handle hazardous products at end of life, it becomes a danger to the public and to workers that come in contact with the materials. Marine flares and compressed gas cylinders have been difficult to handle. We鈥檝e even heard stories about residents bringing explosives and bombs into sites to be disposed of because they think they are doing the right thing. There is so much uncertainty and lack of options about proper disposal. We are lacking clear end of life plans and accompanying communications.鈥�
Heidi, NSAC: 鈥淲hen hazardous products lack an EOL plan that is thoughtfully communicated to the consumer via labeling and marketing, the responsibility for their management falls fully on local governments, wastewater agencies, and taxpayers. These entities must allocate limited resources (taxes and rates, which are very hard to increase) to manage the collection, storage, and disposal of hazardous materials. This system is default, thoughtless, full of cracks and holes, and has led to the mis-mashed and underfunded system we have today. Without producer responsibility, these products frequently enter recycling and trash systems and create health and fire risks. Expired or unused hazardous items, such as marine flares, pesticides, gas cylinders, and pool chemicals, are stockpiled in homes, illegally dumped in landfills or waterways, or mistakenly placed in recycling bins. This mismanagement leads to environmental contamination, increased fire risks in waste facilities, and direct health threats to workers in the waste and recycling sectors.鈥�
NAHMMA: I would echo the comments from both Amy and Heidi. A majority of or members work and operate Household Hazardous Materials collection facilities or host collection events, and in some cases also take business hazardous materials from Very Small Quantity Generators. The operations rely on customer and public funding subsidies to collect, package, and arrange for proper disposal of many products where the manufacturer had no EOL plan. Unfortunately, not every community has access to the types of facilities operated by our members or has frequent enough collection events. When access is limited, these products often end up in the waste stream, increasing the danger to those workers, the infrastructure, and the environment.
How would you like to see end of life product management change?
Heidi, NSAC: 鈥淭he most effective solution is comprehensive Extended Producer Responsibility (EPR) legislation, which requires producers to take responsibility for EOL management for their products. EPR policies should mandate manufacturers design, fund, and implement convenient and safe collection systems for their products, ensuring proper disposal or recycling. EPR incentivizes innovation in product design to reduce toxicity and cost to manage, enhance recyclability, and minimize waste. For instance, non-pyrotechnic alternatives to marine flares are approved by the U.S. Coast Guard and should be prioritized. Additionally, standardized statewide or national programs can reduce costs and improve accessibility, particularly for rural and underserved communities. Successful models, such as California鈥檚 Medication collection program, demonstrate how producer-funded systems can achieve high recovery rates while relieving local governments of financial and logistical burdens.鈥�
Amy, SWANA: 鈥淎s stated in our recent Product Safety Statement and the accompanying op-ed, we would like all stakeholders to come together to improve design, labeling, communications, and end of life options to improve safety. We encourage producers to consider the EOL management in their design. The ideal improvements to design would mean that products do not catch fire or explode, and that products are made of materials constructed in a way to be easily recycled or reused. We also encourage producers to work with us to expand options for safe end of life management, and to support the marketing to consumers about how to safely handle the items.鈥�
NAHMMA: We are committed to pollution prevention, product stewardship, and the safe, efficient, and effective handling of hazardous materials. This can be accomplished by product reformulation, development and use of less or non-hazardous products, constituents, processes, and methods, and EOL plans that include access to the proper collection of products and materials that contain hazardous components for reuse, recycling, or hazardous materials management.
How can the reader help to advance solutions in their community/state/province, etc.?聽
Amy, SWANA: 鈥淓veryone has a role to play and every action matters. We encourage you to have your employer or your association sign onto our product safety op-ed. Voice your opinion to producers and policy makers on how this topic is important to you. In addition, we are all consumers, and we all have a responsibility to practice safe management of these products and to bring them to where they can be safely handled for EOL management. You can also spend some time talking to your neighbors about this, as well as your homeowner鈥檚 association and your community associations to support widespread responsibility for proper and safe disposal.鈥�
Heidi, NSAC: 鈥淎s experts in hazardous materials management, NAHMMA members are uniquely positioned to drive systemic change by sharing what they know with the public and the media. Most of the public never think about this, or the safety issues it poses when hazardous products are illegally disposed of. Education and documenting the problem is critical鈥攖ake pictures and video, and tell stories of what arrives at your facilities and the problems people have in proper disposal, what it costs you to manage, and name by brand if possible. Invite your elected officials to your facility and explain to them the process, costs, and problems you face. Engage with policymakers to support EPR legislation and counter industry resistance with facts. Educate stakeholders鈥攊ncluding local governments, businesses, and the public鈥攐n the importance of producer accountability and the risks of improper hazardous waste disposal.
Collaborate with manufacturers and retailers to develop and promote safer alternatives to hazardous products. Encourage participation in existing stewardship programs and push for expanded producer responsibility frameworks. At the community level, organize or support take-back initiatives for hazardous items and report illegal dumping to authorities.
Finally, align with organizations like the National Stewardship Action Council to share your stories and amplify your impact. By leveraging your expertise and networks, you can transition the U.S. toward a circular economy where hazardous materials are managed responsibly at their source. Remember, pictures speak 1,000 words and help you tell your story. We will use them to increase their impact another 1,000X.鈥�
On behalf of NAHMMA, I would like to thank Amy and Heidi for taking the time to share their expertise for both this article and the final webinar in the series. | WA
Kenneth Miller is Solid Waste Agency Administrator at the Dubuque Metropolitan Area Solid Waste Agency, North American Hazardous Materials Management Association Board of Directors President, and member of the Solid Waste Association of North America.
The webinar series is free for all NSAC, NAHMMA, and SWANA members. Non-members Register for individual webinars at $75 each or get full access to all three webinars for just $200. For more information and to register, visit .
About NAHMMA
North American Hazardous Materials Management Association (NAHMMA) is a non-profit, membership-based association of individuals, businesses, government officials, academia, and non-profit organizations dedicated to pollution prevention, product stewardship, the safe and cost-effective handling of household hazardous waste. NAHMMA is a diverse network of professionals working together to promote education, guide good policy, protect our environment, and advance hazardous waste management practices throughout North America. Follow NAHMMA on social media via LinkedIn or visit .
About NSAC
National Stewardship Action Council (NSAC) is a 501(c)(4) nonprofit organization that advocates and provides consulting services to advance a responsible, circular economy, anywhere in the U.S., and at any level of government. NSAC has been instrumental in the passage of several first-in-the-nation laws such as the EPR for medicines and needles.聽 Follow NSAC on social media via Facebook, LinkedIn, Instagram, and You Tube. To join, visit .
About SWANA
The Solid Waste Association of North America (SWANA) is a member-based association of professionals from across the waste and resource management industry. Committed to advancing from waste management to resource management, SWANA empowers their members to deliver essential services to communities today and anticipate their needs for tomorrow. SWANA serves industry professionals through technical education, publications and research, and a large offering of technical training courses and credentialing to create a highly skilled workforce. Follow SWANA on social media via Facebook, LinkedIn, Instagram, and You Tube. To join, visit .