SMALL GAS CYLINDERS ISSUES AND POTENTIAL STRATEGIES
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1 SMALL GAS CYLINDERS ISSUES AND POTENTIAL STRATEGIES Prepared for Sarasota County, FL Small Gas Cylinder Meetings Tampa, Florida - May 14 & June 18, 2003 The has developed the following issues and potential strategies related to the management of small, used gas cylinders through telephone interviews with over 40 key stakeholders. These cylinders are used to contain propane (e.g., used in camping stoves), helium (e.g., for party balloons), MAP gas (for blow torches or for welding), and freon. These issues and strategies are not intended to be an exhaustive list. They are presented to provide those involved in the meetings ideas to consider prior to the meeting. The primary goals of this project are: (1) to reduce safety and environmental risks associated with cylinders in the waste stream; (2) to increase the recovery and recycling of used cylinders; and (3) to reduce financial burdens in managing the cylinders. These goals are linked. For example, if residual gas can be safely removed from the cylinders, recycling is likely to increase. Listed below are seven issues that were raised by those who PSI interviewed, followed by potential strategies that emerged from those discussions. As with the goals, the issues are also linked. For example, one issue may be an obstacle for reaching more than one of the goals. In the same manner, each of the five potential strategies recommended may address more than one issue. ISSUES Lack of Consumer Education Consumers are presented with inadequate information regarding safe disposal of the product. There are currently no messages from manufacturers or retailers about the desirability of using the tanks until empty. Messages regarding safe disposal are vague (e.g. contact local waste management authority ) and may not be helpful if the consumer s municipality does not have a cylinder management program. In many instances, consumers are also not instructed to recycle the containers. This recognizes the fact that recycling programs for pressurized cylinders are not 1
2 universal. However, when consumers throw away cylinders without any attempt at recycling, it is difficult to gage the number of cylinders that are entering the waste stream, and such behavior hinders the development of appropriate management systems. The cylinders that are thrown away because of consumer ignorance contribute to safety hazards, as they can explode during waste handling procedures. Difficulty in Retrieval Small gas cylinders are easy to dispose of in household waste and are difficult to spot on a tipping floor at a trash transfer station. This makes it difficult for workers to separate cylinders before compaction or mechanical waste processing, such as shredding or incineration, even if cylinders can be safely processed for recycling in that area. Increased Liability Waste processors are concerned about liability, and may find it easier to refuse a risky product than to develop safe systems for handling it. For that reason, it can be difficult to find local outlets for cylinder processing. Low Value of Used Material/High Management Costs Steel from cylinders is recyclable, but has a low secondary market value. Cylinders are inexpensive to produce, but costs for handling used cylinders can reach double or triple the cylinder s original sale price. This dynamic creates disincentives for governments to institute cylinder management programs, and disincentives for waste handlers to accept cylinders governments know that a collection program will translate into high costs, and waste processing companies cannot hope to profit from anything but their labor. It also poses obstacles to solutions that would pass some of the costs of disposal on to consumers, as a dramatic increase in cost would severely impact sales of cylinders and their accompanying appliances. Lack of Automated Handling Systems Interviews uncovered only one instance of a fully automated system for processing cylinders. This system (currently the option used by Sarasota County) is not patented, and not available for purchase and installation in other areas. Other systems required significant amounts of labor, which is much more expensive. While automation frequently results in cost savings, it is especially important for this product given the small amounts of hazardous materials that are found in the cylinders, and the small size of the cylinders themselves. High labor costs are more difficult to justify when the result of the labor is a relatively small amount of gas and metal. Lack of Coordination Markets develop when there is a product that needs treatment on a regular basis in regular quantities. Currently, those areas having difficulty with cylinder management have not coordinated with each other and, as a result, it is not clear to potential processors or to municipalities what quantities of cylinders could be generated regularly and what market options exist. Regulatory Concerns Existing state regulations often leave municipalities and/or waste handlers without clear instructions on preferred management. For example, in Vermont, state regulations do not advocate for either venting or flaring any remaining gas in the cylinder, and automated gas 2
3 recovery is often not available. The lack of explicit direction means individual operators are more likely to handle the tanks dangerously. Small cylinders are a household product and, therefore, escape restrictions when they enter the waste stream, since household waste is exempt from most state hazardous waste regulations. The size of the cylinder also exempts it from state laws adopting National Fire Protection Association codes and standards that exist for 4 to 40 pound tanks. Municipalities who want to reference legislative guidance to manage cylinders have few resources. Some of the interviewees acknowledged the lack of ideal management for cylinders, and yet felt that the problem was small enough to get away with it without much concern. A coordinated cylinder management program would mean collecting an amount of cylinders that was difficult to ignore, which might trigger additional regulatory restrictions or management costs. Waste hauling companies or municipalities may find this an incentive to deal with cylinders in an undercover or non-coordinated fashion. POTENTIAL STRATEGIES The following are potential strategies that were identified by PSI through the stakeholder interviews. For each strategy, we list how that strategy addresses the three main project goals. Other strategies may surface through additional interviewing and/or research. The meetings will provide the opportunity for participants to build on, and add to, these solutions, and the expanded list will serve as a basis for decisions and action. EDUCATION: An appropriate message encouraging consumers to use up the gas and look for recycling programs could be supplied through a variety of routes, including information on the product label, information attached to the appliance that uses the cylinder, information distributed at the point of sale (e.g. a flyer handed out at the cash register), or information distributed by municipal waste collection programs. Any of these messages could also point consumers to another source of information, such as a website or toll-free telephone hotline. Educational solutions could address project goals as follows: Resource Recovery: Education can alert consumers to the fact that the cylinders are recyclable, diverting them from the waste stream. Safety: Tanks with residual gas in the waste stream pose a much greater hazard than empty tanks. Consumer education could cut down on the number of partially filled tanks being thrown away, and reduce associated risks. Consumer education could also eliminate cylinders from the waste stream altogether. Economics: Empty cylinders can be less expensive to process than partially filled cylinders. REUSE PROGRAMS FOR PARTIALLY FILLED CYLINDERS: While reuse programs delay, rather than eliminate, the need for disposal, they are worth considering as part of a suite of strategies. Many areas have implemented programs where partially filled cylinders are either stored on-site for other individuals to use or are donated to non-profits such as the Boy Scouts or 3
4 Girl Scouts. Many of these groups have participants sign liability waivers. Reuse addresses project goals as follows: Resource Recovery: Reuse provides one more point for potential consumer education on recycling or proper handling of used cylinders. Safety: Reuse programs cut down on the number of partially filled cylinders in the waste stream, which decreases the likelihood of dangerous explosions. If organizations or individuals are not purchasing new cylinders, it could cut down on the number of tanks in the waste stream. Economics: Reuse eliminates financial burdens from treating partially filled cylinders. INCREASED CONSUMER TANK PREPARATION/ALTERNATIVE PREPARATION: Scrap dealers will not take cylinders that are not obviously depressurized and empty of gas. It is currently very difficult and risky for consumers to de-valve their own empty cylinders. However, if empty cylinders were received at municipalities de-valved and ready to be scrapped, it would greatly cut down on costs. Consumers could de-valve their empty tanks if they had access to the proper tool, which could potentially be included with appliances that use cylinders, or with the cylinders themselves. One rural area uses empty tanks (ones not supporting a flame) as targets at a local gun club, which leaves them with clear holes. Afterwards they are accepted by scrap dealers. Increased consumer preparation addresses project goals as follows: Resource Recovery: Consumers are able to manage their own waste, and have less incentive to hide the product in their regular household trash. Municipalities are better equipped to efficiently handle tanks that come in partially filled. Safety: Proper do-it-yourself cylinder preparation reduces cylinders in the waste stream, which cuts down on risks of explosion. Economics: Labor costs of cylinder preparation are spread to consumers, and are not a burden for municipal collection programs. MANUFACTURER TAKE-BACK: Those interviewed cited existing programs for rechargeable batteries and beverage containers as possible models for a gas cylinder management program. Manufacturers could pass some of the costs of treatment on to the consumer, and develop a collection and management program both internally and in conjunction with retail. Funds could be raised through a visible fee, an invisible fee, a deposit, or another similar mechanism. This solution addresses project goals as follows: Resource Recovery: Convenient and/or centralized drop-off in obvious locations, such as retail outlets or municipal depots, would give many incentives for consumers to recycle their product. Safety: Centralized processing would guarantee standard, consistent safety procedures. Fewer cylinders in the waste stream would cut down on risks from explosion. Economics: Costs would be shifted from municipalities to the consumer. MUNICIPAL/SCRAP METAL PARTNERSHIPS: Municipalities vary greatly in their access to cylinder processors and in the number of cylinders that are generated in their communities. Local scrap metal dealers have different standards when it comes to accepting cylinders. Municipalities could work closely with local scrap metal dealers to create management programs that respond to specific concerns. For example, scrap dealers could agree to accept cylinders that had a spray paint marking indicating they had been checked and were empty, instead of requiring 4
5 that cylinders be crushed or cut in half. Municipalities could guarantee certain inspection standards, which might relieve liability or safety concerns for scrap dealers. This solution addresses project goals as follows: Resource Recovery: With guaranteed outlets for the cylinders, municipalities could work on creating and publicizing cylinder management programs. Safety: Many parties would agree to follow specific safety standards, which would be developed with consideration for local concerns. Economics: The amount of necessary processing could be reduced, resulting in cost savings to municipalities. 5
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