Questions and Answers: Household Hazardous Waste Grants (FY 2008/09)

Questions about the FY 2008/09 (17th cycle) Household Hazardous Waste (HHW) Grants application were due in writing by July 31, 2008. Similar or related questions may be grouped together or reworded for clarity and responded to as one question.

All questions and answers will be posted during the application period and are subject to updates. It is the applicant’s responsibility to check this website for the latest information regarding this grant cycle.

• 17th cycle HHW Grant--General
• Grant Application Package Details
• Multiple Proposals, Multiple Projects, and Regional Applications
• Facility Construction
• Facility Upgrade
• Program Priority Criteria
• Sharps Materials Related Questions
• Universal Waste (U-waste) and Electronic Waste (E-waste) Materials Related Questions
• Pharmaceutical Materials Related Questions

17th Cycle HHW Grant--General

The County applied for and received a grant award for the HD 10 Grant Cycle to build a permanent household hazardous waste collection facility. Due to unanticipated circumstances the project was never completed. The County received only limited funds from the grant to cover some of the expenses incurred during the planning phase.

The County is again interested in providing a permanent Household Hazardous Waste (HHW) facility for the County’s residents. Can the County apply for the HD 17 grant to provide funds for the planning and design of a Permanent HHW Collection Facility?

Yes. The County may apply for another HHW grant, either independently or as a regional/multijurisdictional applicant to cover different phases of the development of an HHW program.

Can grant funds support local government and small business source reduction and "green" procurement outreach/education, or can funds only support education components geared at residents and qualifying Conditionally Exempt Small Quantity Generators (CESQGs)?

Yes. Grant funds may be used to support local government and small business recycling programs (such as take-back and Extended Producer Responsibility (EPR) programs) or support educational programs targeted at residents and CESQGs.

If, in the past, a jurisdiction received HHW grant funds for a project that is a similar component of the current proposed grant project, can it qualify for the funding? Will this hurt its chances of getting funded? If the current application is a regional/multijurisdictional application and it was not the lead jurisdiction that did the past project that was similar to a component of the current proposed grant project, will this affect their chances of being awarded the grant?

A jurisdiction that received an HHW grant in the past may apply for another HHW grant to support different phases of the program. However, HHW grants are not intended to represent an ongoing funding source for operations. Applications are evaluated using the General Scoring Criteria. Applicants are advised that proposed projects should not represent duplication of past grants.

What is a sustainable HHW collection facility? Is it a facility that generates enough revenue to cover HHW disposal expenses?

A sustainable HHW collection facility is one that has sufficient funding to continue operations beyond the grant term and has been certified to be using green building practices in its construction. Please refer to the Application Instructions--Program Criteria (Adobe PDF, 1.1 MB | Word, 351 KB). Visit CIWMB's Green Building home page for additional information on green building practices.

Are agency matching funds required? If so, what is the percentage of the required agency matching funds?

No. Agency matching funds are not required.

Is the 17th cycle HHW Grant offering two different types of grants?

No. The 17th cycle HHW Grant is offering one type of grant--an Infrastructure Grant. The Infrastructure Grant is similar to previous cycle HHW competitive grants for individual or multi-jurisdiction projects.

How is the 17th cycle HHW Grant different from last year’s HHW 16th Cycle grant program?

A Coordination grant will not be offered this cycle.

The 17th cycle HHW Grant offers up to six preference points for either:

• Construction of sustainable HHW collection facility (ies); or
• Implementation of retail take-back and EPR programs and initiatives.

A sustainable HHW collection facility is one that has sufficient funding to continue operations beyond the grant term and has been certified to be using green building practices in its construction. (Please refer to the Application Guidelines and Instructions--Program Criteria. MS Word, 351 KB | Adobe PDF, 1.1 MB) See CIWMB's Green Building home page for additional information on green building practices.

Bonus points will be given to applicants who did not receive an HHW Infrastructure Grant during the 16th HHW Grant Cycle (2 points) or 15th and 16th HHW Grant Cycles (4 points).

The CIWMB anticipates that up to $5,000,000 will be available to be awarded in competitive grants.

All funding is contingent on the passage of the California State Budget Act for Fiscal Year 2008/09 and appropriation of funds for this program.

May Used Oil Block Grant money be used to pay for the preparation of the CIWMB 17th cycle HHW Grant application?

No. Since the Used Oil Block Grant is, in effect, a continuously appropriated grant and is an entitlement grant, it is allowable to use Used Oil Block Grant funds to pay for preparation of Used Oil Block Grant applications. However, that does not extend to the preparation of CIWMB grants, such as the Opportunity grants, HHW grants, Tire grants, Cleanup grants or for another agency’s grants such as the Department of Conservation. HHW grant application preparation must be supported by the local jurisdiction.

Who may apply for the 17th cycle HHW Grant?

All California cities, counties, and local agencies, including Indian reservations and Rancherias with direct responsibility for HHW management, may apply individually or as a regional group. Businesses and not-for-profit groups may partner with a local government, but are not eligible to apply on their own.

Will applicants score fewer points if they were awarded an HHW 16th Cycle Grant or other CIWMB grant in the past?

No. If an applicant was previously awarded any other CIWMB grant, there would be no reduction in the points scored for the 17th cycle HHW Grant.

However, applicants who did not receive an HHW 16th Cycle Grant will receive two additional bonus points. Applicants who did not receive an HHW 15th and HHW 16th Cycle Grant will receive four additional bonus points.

An applicant with unspent grant funds in an open or ongoing grant must clearly demonstrate the reasons for having unused grant funds and justify the need for 17th cycle HHW Grant funding.

Are we allowed to maintain our resolution for more than 1 fiscal year as the UOBG program lets us maintain a resolution for 5 years?

Yes. Please see section “Resolution and Letters of Authorization” of the 17th cycle HHW Grant Guidelines and Instructions.

The Resolution may be specific to this Fiscal Year (FY) 2008/09, or it may be for up to a maximum of five (5) years (i.e., fiscal years 2008/09 through 2012/2013). Likewise, it may be specific to the HHW Grant Program or it may cover all CIWMB grants.

Grant Application Package Details

Regarding Attachment 1, if applying for grant funds to establish a new HHW collection facility, should the current practices and statistics column reflect information for existing facilities, or should the form be completed to only include information regarding the new HHW collection facility in the proposed changes column?

The "current practices and statistics" column should reflect existing collection services/facilities.

If an applicant is barely entering the design phase of a permanent HHW facility and won’t have budget information for construction/expansion, equipment, and service until after the deadline, how would you recommend the applicant proceed with completing the application?

In this case, the applicant may want to consider separating the phases in development of the HHW facility and focus on those costs related to design and permitting. The application will be evaluated on the completeness and accuracy of the materials and information submitted.

For a project that entails planning, design and permitting of a new HHW collection facility, should the General Checklist of Business Permits, Licenses and Filings form be completed to reflect the business permits, licenses and filings required to do the planning, design and permitting work, or should the checklist also reflect the permits and approvals necessary to construct and operate the facility?

Per Board policy, the General Checklist of Business Permits, Licenses and Filings is no longer required for public entities. The Application instructions for this requirement may be disregarded.

On the budget form, should the planning, design and permitting costs for a new permanent collection facility be included under the Permanent Collection Facility category? The instructions for the Budget form seem to differ slightly from what is shown on the form under the category "Other"(Design, Etc.).

Yes, the planning, design, and permitting costs should be included under the Permanent Collection Facility category. The category "Other" should be used for any items not directly attributed to those categories listed on the Budget form. The term "Design" may be disregarded in the "Other" category on the Budget form.

There are elements in the Environmentally Preferable Purchases and Practices Policy (EPPP) and Recycled Content Products Procurement Policy (RCP) that are the same. There are certain elements that are in the EPPP policy that are not in the RCP policy. What are the REQUIRED elements of the EPPP, not suggested but actually required, in order to state you have an EPPP? In terms of the grant, is a RCP policy sufficient to represent the EPPP policy?

There are no specifically required elements of the EPPP policy. The EPPP policy is a broad description of a jurisdiction's intent to support the Integrated Waste Management Act (AB 939) and foster market development for recycled products by purchasing products or services that have a lesser or reduced effect on human health and the environment when compared with competing products or services that serve the same purpose. The applicant "self-certifies" that a policy exists in the jurisdiction and is followed whenever possible.

An EPPP policy is not required to be submitted with the application. However, notification of adoption of the EPPP policy must be received by October 6, 2008  (Rev. 8/08). The EPPP Evaluation form contained in the application must also be received by October 6, 2008  (Rev. 8/08). As an EPPP policy is directed at agency purchasing practices, it is not the same as the RCP, which is directed at product content reporting.

Applicants are advised to check with other agency departments. In some instances, local government departments have adopted an EPPP policy, which has been a requirement for other programs such as Rubberized Asphalt Concrete (RAC) and Used Oil Opportunity grants for several grant cycles.

The Recycled-Content Product Certification form(s) are due with the Final Report in 2011.

Does the EPPP Policy require a resolution by the City Council or Board of Supervisors, or can it be Procurement Policies and Practices that meet the same criteria described in the example shown in the instructions?

No, the EPPP policy does not require a resolution by the local jurisdiction's governing body. The applicant may use the format shown in the EPPP Policy Example in the Application or any existing format in use by the applicant.

Is an EPPP Policy required of all participants in a regional application?

No, an EPPP policy is only required of the lead jurisdiction. Note--This is a change from the question and answers previously posted on the CIWMB website.

The Notice of Funds Available (NOFA) and Application package state that 17th cycle HHW Grant applications must be postmarked no later than September 22, 2008 (Rev. 8/08). In addition to the U.S. Postal Service postmark, will a postmark from Federal Express or UPS also be accepted?

Yes. Those two companies fall into the category of “commercial delivery service” and their postmark tracking system will be accepted. However, please note that the time and date the application is taken to a commercial delivery service may not be the same as when the application is actually mailed or postmarked. To ensure the application is mailed by the deadline, proof must be obtained from the carrier, specifically, a dated receipt that shows that the package was mailed to the CIWMB’s address. A receipt that merely shows the date and cost of mailing will not be sufficient evidence of date of mailing of an application for this grant. The burden is on the applicant to demonstrate timely mailing or delivery of the application. Late postmarked applications will not be accepted and will be disqualified from the application process.

My local government does not hold a Council Meeting until after the September 22, 2008 (Rev. 8/08) application deadline. Therefore, I am unable to obtain a resolution before submitting the application. May resolutions for the grant be turned in after the application package is submitted? What is the final deadline?

Yes. The approved Resolution for either a single or a regional jurisdiction and all supporting documents for a regional program should be submitted with the application by September 22, 2008 (Rev. 8/08). If the resolution is not submitted with the application, the resolution must be received no later than October 6, 2008 (Rev. 8/08). Submitting an incomplete application will affect the application’s “Completeness” score. Applications that are still incomplete after October 6, 2008 (Rev. 8/08), will be disqualified.

My Board currently has an approved Resolution that authorizes the submittal of grant applications for up to a maximum of five years. Is that Resolution still valid for this application?

The five-year Resolution is acceptable if it is in effect when the 17th cycle HHW Grant application is submitted and includes authorization to apply for the CIWMB’s HHW Grant.

Please clarify what an overhead or indirect cost is. Are we restricted to a maximum percentage?

Overhead/Indirect costs are expenditures that cannot be assigned or readily itemized to a particular project or activity, but are considered necessary for the operation of the organization and the performance of the program. Examples include, but are not limited to, costs of operating and maintaining facilities, accounting services, etc.

Overhead/Indirect costs for the 17th cycle HHW Grant must not exceed 10% of the grant funds reimbursed. The same restrictions apply to contractors and subcontractors for the grant, including any entities that may be partnering with the local jurisdiction.

Where can we find the Procedures and Requirements (Ps&Rs) and the Terms and Conditions (Ts&Cs) for this grant cycle?

If your application is awarded, you will receive a final copy of the Ps&Rs and Ts&Cs with your Grant Agreement. A copy will also be posted on the HHW 17th cycle page.

Will points be taken away from our final score if we do a pilot project before launching our program?

No. Pilot programs and surveys provide valuable insight for program design and are encouraged, particularly in those projects with regional/statewide applicability or using community-based social marketing public education campaigns.

Is the EPPP Policy now a requirement of the grant? How would you handle a regional grant where some participating jurisdictions do not have EPPP Policies?

Yes, the EPPP Policy is a condition of grant eligibility. Applicants must acknowledge that their organization has an EPPP Policy. Applicants who do not have an EPPP Policy in place when they submit their applications may certify in their application that they will adopt one and will send notification of the date of adoption to the CIWMB by 10/06/2008 (Rev. 8/08) or be disqualified.

No, an EPPP Policy is only required of the lead jurisdiction. Note: This is a change from the question and answer previously posted on the CIWMB website.

Multiple Proposals, Multiple Projects, and Regional Applications

If a county intends to set up a regional program with several incorporated cities, may the county apply as a regional applicant? Are Letters of Authorization required or Letters of Partnership?

Yes, your county may apply as a regional applicant. A Letter of Partnership is to be used by a private entity partner. A Letter of Authorization is for use by a participating jurisdiction in a regional/multijurisdictional grant.

For regional/multijurisdictional applications, if the applicant-jurisdiction has already developed a Letter of Partnership as discussed in the Application Instructions (page 2), the applicant-jurisdiction may submit that Letter of Partnership rather than a Letter of Authorization.

Please note that both the Letter of Partnership and the Letter of Authorization must include the Audit/Records Access provision as stated on the Required Documents for a Regional/Multijurisdictional Application web page, or the submitting partner, whether private or public, will be disqualified.

Can you have a regional HHW program without entering into a partnership?

Would a partnership with one city preclude the county from applying for any other HHW funds under this cycle or partnering with another of its cities to expand HHW service?

An applicant may submit a regional/multijurisdictional application on behalf of itself and other eligible jurisdictions; however, for this cycle only one application per jurisdiction is allowed.

Can non-contiguous counties qualify as partners for a regional/multijurisdictional application?

Yes. While there is no specific requirement that participating jurisdictions must be contiguous, the purpose of a regional award is to achieve economies of scale among communities to obtain the best value for money spent by combining resources and staffing. Those jurisdictions with similar demographics, waste streams and collection networks offer the best opportunities to achieve these results, and, are most likely to share geographic boundaries.

For a regional application submitted by a Joint Powers Authority (JPA), what type of authorization is required, if any, from the member jurisdictions (e.g., Letters of Authorization)? If required, can the authorizations be submitted by 10-06-08 (Rev. 8/08)?

For a regional application, if the JPA includes solid and/or hazardous waste management responsibilities, an eligible applicant may apply on its behalf and on behalf of participating jurisdictions. The applicant-jurisdiction must submit an authorizing resolution and the participating jurisdiction(s) must submit one of three documents to evidence its participation, see above for additional information. All authorizing documentation may be submitted after the application is filed but in no event after October 6, 2008 (Rev. 8/08).

What are the definitions of an “individual jurisdiction” and a “regional group”?

An "individual jurisdiction" is a single city government or county government applying by itself. The jurisdiction may have project partners or subcontractors but is the only applicant and is individually responsible for the grant.

A multi-jurisdictional or "regional group" is comprised of two or more eligible applicants, i.e., cities or counties, with a lead jurisdiction designated to act on behalf of all participating jurisdictions. The lead jurisdiction will be the Grantee and will be responsible for the performance of the grant, recordkeeping and for submission of all required documentation. Jurisdictions participating in a Joint Powers Authority (JPA) may designate the JPA as their regional lead jurisdiction if the JPA agreement includes solid and/or hazardous waste management.

If a jurisdiction is a participant in a multi-jurisdictional or regional application, it may not also apply as an individual jurisdiction.

Under the grant proposal, may funding be granted for multiple related endeavors, such as establishing a permanent HHW collection facility and also establishing a u-waste program, or must only one task be chosen for the grant?

A grant proposal may include as many endeavors as the applicant deems necessary to meet the needs of the community, as long as all goals and objectives are in line with the currently adopted Household Hazardous Waste Element (HHWE) for the applicant's jurisdiction.

However, in order to qualify for priority points, the applicant must select one of the program criteria listed below that best characterizes the proposed program. The applicant must designate or declare this criterion on the application Cover Sheet.

• Construction of sustainable HHW collection facility(ies); or
• Implementation of retail take-back and EPR programs and initiatives.

May the facilities or programs included in one application be initiated in two separate geographic areas?

If the separate geographical areas are in different jurisdictions, there must be a regional partnership between the jurisdictions in the form of a multi-jurisdictional application for the grant. If the separate geographical areas are within the legal boundaries of the same jurisdiction, they may be included in the application of an individual applicant.

The Venus Waste Authority representing Moon City and Saturn County wants to apply for a 17th cycle HHW Grant. Other Counties want to submit letters of participation and support for the Authority's application and, simultaneously, apply for a Grant on their own. Will the letters of support and participation from the outside Counties deem them ineligible to apply for their own Grant?

Letters of Support from eligible agencies and/or jurisdictions for competing applications will not result in disqualification of the supporting entity. However, any jurisdiction that is a participant in a regional Grant may not also apply as an individual jurisdiction for a Grant.

Facility Construction

We received an HHW 2006/07 grant for Infrastructure. Funds were not included for operating the facility or disposing of the waste collected. In order to apply for this (2008/09) grant the Statutory Priorities say:

• Establish new HHW programs for:
  • Rural areas (county having a population of 200,000 or less).
  • Small cities (population less than 35,000).
• Plan expansion of permanent HHW collection facility(ies) to accommodate increased universal waste and/or sharps collection.
• Establish a regional HHW program.

Does building the infrastructure of an HHW facility count as establishing a new HHW/Regional HHW program?

Costs to maintain existing programs are ineligible. Along with related publicity and education costs, the intent of the HHW Grant is to facilitate the design, construction, and expansion of permanent HHW facilities, not to support ongoing operational expenses. However, if, by "building the infrastructure," you are referring to the purchase of new equipment to expand services, those costs would be eligible. For clarification, the bulleted items listed above are program priorities set by Statute. They are not the eligibility requirements that must be met in order to apply for the HHW Grant.

We have governmental commitment and direction to move forward on a Permanent Household Hazardous Waste Collection Facility (PHHWCF). We have one Environmental Impact Report (EIR) in process for two different parcels of land and one EIR in process for one parcel of land which the City has already purchased (corp yard location). We anticipate that we will have clear instruction to proceed with the design of a PHHWCF on one of these parcels once the City Council decides which parcel the PHHWCF will be built on. The design of the PHHWCF will not change based on the location. Under the instructions on page 15 it reads, “You must have identified the site for the facility and have government commitment or direction to build before submitting the application”. Does this language prohibit us from applying? We believe we do have government commitment but the actual location is one of three places. During the three years of this grant cycle the location will be selected and the design would be started, we expect to start the design work prior to the next grant cycle.

The language does not prohibit you from applying as long as you can demonstrate in your application, with sufficient documentary evidence, that you are well engaged in the permitting process and have government commitment and/or direction to proceed.

Is it acceptable to apply for the planning, design and permitting of a permanent HHW collection facility, plus the costs to begin the construction of the facility (e.g., grading and paving), but not for completion of construction of the facility?

Yes. The applicant should clearly establish in the application those phases that the applicant intends to fund.

If we are proposing to build a HHW facility that will be open to all residents of the county and its cities, would we be eligible to apply for $400,000?

Yes, if two or more jurisdictions (i.e., the county and one or more cities, or two or more cities in the county) participate in the grant project, the lead applicant representing the regional group may request up to $400,000. A lead agency would need to be designated within a Resolution and a Letter of Authorization is required from each participating jurisdiction. Multi-jurisdictional projects/programs that meet regional needs also qualify for priority points.

It is assumed there will be reasonable profit and mark-up by subcontractors providing equipment and service for facility development. Will these profit and mark-up costs need to be identified separately, and is the intent of this restriction really intended for additional mark-ups over standard pricing practices?

Please reference the “Ineligible Costs” in the 17th cycle HHW Grant Guidelines and Instructions. “Profit or mark-up by the Grantee or subcontractors” is an ineligible cost. Mark-up is not addressed separately - it is contained in the original cost estimate.

The development costs needed to complete our multijurisdictional Permanent HHW Facility is estimated at $700,000. Our regional group application may request up to $400,000. To what extent should the grant application focus on activities and component details that comprise the $400,000 not covered by the grant? To what extent will matching or exceeding funds provided by the CIWMB HHW Grant increase eligibility?

Applicants are encouraged to discuss the costs (dollar figures) associated with activities necessary to complete the project. In addition, please reference the Budget Scoring Criteria of the 17th cycle HHW Grant Guidelines and Instructions as matching funds are described in more detail. The applicant should focus on needs to be addressed and funded by the grant. The grant's competitiveness will be affected by the viability of alternative funding sources to support those components of the project that are not funded by the grant. The applicant should clearly address the prospect or likelihood for additional funding of specific activities during and after the grant term.

Should the application focus on more easily verifiable costs, such as equipment and supplies, rather than construction items such as concrete, electrical or ventilation work?

Applicants are encouraged to discuss the entire cost of the project. One of the main objectives of the grant process is for the CIWMB to gain a better understanding of the full project cost. The more complete the cost data, the clearer the project is to the review panel scoring the application. The application’s budget must be comprehensive and as accurate as possible for all components funded. Activities or equipment supported by matching funds or other ongoing revenue should also be clearly supported in order to demonstrate that the facility will actually be built.

Facility Upgrade

Our County’s unincorporated government contracts with a private waste management business to collect HHW materials at its privately owned landfill site located inside our jurisdictional boundaries. May we use 17th cycle HHW Grant funds to buy more equipment for storing our u-waste at their site?

Jurisdictions that want to expand permanent HHW facilities located on private property must prove a legally binding long-term commitment between the company/private landowner and the jurisdiction that will require the facility to continue to be operated as an HHW facility. This commitment must emphasize promotion of the public interest in a manner similar to the activity described in the grant application throughout the life of the facility and/or purchased equipment.

Program Priority Criteria

Must proposed projects focus on the program priority criteria?

Other project topics may be proposed; however, projects not related to the program priority criteria will not receive the priority points.

May we use the 17th cycle HHW Grant funds to fund one of our HHW collection events if it also includes sharps and/or u-waste collection?

Yes, the 17th cycle HHW Grant is the appropriate place to propose funding for a sharps and/or u-waste collection program. The program encourages innovative initiatives or models, especially those that promote retail take-back and EPR programs and initiatives.

What procedure would a local jurisdiction follow if it were to partner with a local business for delivery of program services under the 17th cycle HHW Grant?

A local jurisdiction that seeks to enter into a partnership with a local business must obtain a Letter of Partnership from the local business (refer to the Application Guidelines and Instructions--Applicants and Partnerships). A local business may also deliver program services and receive HHW grant funds as a subcontractor.

Would a project that seeks funds for a public agency applicant to purchase a vehicle (truck) to aid in the door-to-door collection of HHW be considered for funding if the public agency applicant were to lease the vehicle to a private contractor (we use contracted service provides to accomplish our community's HHW services).

Purchasing or leasing of vehicles is an ineligible cost.

Sharps Materials Related Questions

We share in the County collection; does this mean that we cannot request an individual program for items such as Sharps or U-waste (batteries) for routine pick up and ordering containers?

Costs to maintain existing programs and ongoing operational expenses are ineligible costs. If this is a new activity in the County collection program, or a new activity for the City program, the applicant must demonstrate the ability of the program to be economically supportable beyond the HHW Grant term.

We are looking at establishing a program that would distribute two kinds of containers -- mail back containers for sharps and regular biohazard sharps containers. Can the County apply for an additional $40,000 for mail back containers or do ALL containers purchased need to fall within that $40,000 listed?
Yes, the County may apply for additional funding for mail-back containers. Mail-back containers do not fall within the $40,000 limit.

As a method of tracking the success of the sharps mail back containers we are looking at creating a postage paid reply card for participants to mail in to us when they mail in their container for disposal. Are postage expenses eligible? Are the expenses associated with the design and printing of the postage paid reply cards eligible?

Yes, postage, design, and printing of postage-paid reply cards are eligible expenses.

As a method of tracking the success of the sharps containers coming back through our HHW program we plan to label each container. These labels will be used to provide disposal instructions, recognize the funding provided by the CIWMB and to insert a tracking code. Are labels an eligible expense?

Yes, labels for sharps containers are an eligible expense.

We are looking to expand our program to include fluorescent lights and sharps. We would potentially partner with Longs Drugs for the sharps drop-off/collection and Ace Hardware for the lights. Our grant would pay for 1) sharps collection containers for the public in our service area; 2) collection and proper disposal of the sharps/containers; and 3) collection and processing of the lights.

Does this proposed dual-stream program have merit for obtaining a HHW grant?

Yes, this proposed project falls within the eligibility requirements. In addition, the Program Criteria allow for additional points for those projects that focus on implementation of retail take-back and Environmental Producer Responsibility (EPR) programs and initiatives.

Sharps containers that provide disposal instructions must be collected at an established HHW collection facility in order for the grant funds to cover transportation and disposal costs. The cost of this portion of a program is not to exceed $40,000. It is not clear whether or not additional funds for other sharps collection programs are available.

HHW grant funds beyond $40,000 may be used for other sharps collection programs such as retail take-back, EPR, etc.

Most sharps containers used by residents are sealed, rigid containers, e.g., soda bottles, etc. Most residents do not have access to containers with disposal instructions Will the grant pay for the purchase and distribution of new sharps containers to be given to residents?

Yes, the HHW grant will pay for the purchase and distribution of new sharps containers. The use of any containers must meet the requirements of the Health and Safety Code, Sections 118275-118320.

Labels can be printed for placement on the containers for distribution to residents.

The concept of dropping off sharps at kiosks is becoming popular. These would be permanent drop-off sites more numerous and convenient than a permanent HHW facility. Can the purchase and/or rental of these sharps kiosk units and the disposal of the sharps be covered by the grant? And, if so, will the program cost be limited to $40,000 for a multi-jurisdiction application?

Yes, the HHW Grant will cover purchase and/or rental of sharps kiosks and sharps disposal. Sharps kiosk units are not subject to the $40,000 limit. Any post-grant rental costs must be borne by the jurisdiction.

Will the grant cover the costs for a mail back sharps program?

Yes, the HHW Grant will cover the costs for a mail-back sharps program.

Can a city request only the $40,000 funding to just implement a sharps collection program?

Yes, a city may request funding that is limited to a sharps collection program.

Regarding sharps containers and collection, if the application is primarily for the planning, design and permitting to establish an additional permanent regional HHW collection facility, is it acceptable to apply for funds for the distribution of sharps containers and collection at existing facilities?

Yes. The applicant may have multiple objectives for the HHW program.

What materials are covered under sharps?

Disposable hypodermic needles, syringes, lancets, and other medical devices used for self-injection or blood test, which may have a sharp tip or end.

What are eligible collection methods for sharps?

(1) A household hazardous waste facility
(2) A "home-generated sharps consolidation point"
(3) A medical waste generator's facility
(4) A facility through the use of medical waste mail-back containers approved by the State Department of Health Services

Please verify that sharps are not included in the definition of medical wastes and are defined as universal wastes for the purpose of this grant.

Senate Bill (SB) 1305 (Figueroa, Statutes of 2006, Chapter 6) updated the Medical Waste Management Act by excluding home-generated sharps waste, as defined, from the definition of medical waste. Sharps are not considered universal waste, but rather a “special waste” in California.

For a complete list of universal waste, please see the list from Department of Toxic Substances Control (DTSC).

Please verify that public education expenses associated with development of take-back or EPR programs are eligible costs.

Public education costs associated with the development of take-back or EPR programs and initiatives that are directly related to HHW reuse, reduction or recycling/collection opportunities are deemed eligible costs. However, the development or redevelopment of a school’s curriculum is an ineligible cost/activity.

Please provide clarification as to whether the development of education materials focusing on u-waste/sharps that are included in school presentations are eligible costs under the grant.

The development or redevelopment of school curricula is an ineligible expense. However, the development of education materials focusing on u-waste/sharps for school presentations are eligible costs as presentations are considered an element of public outreach.

U-waste and E-waste Materials Related Questions

What materials are covered under u-waste?

See the CalRecycle u-waste page and the links to the Department of Toxic Substance Control (DTSC) Web pages for more information about these materials.

My city is interested in developing an e-waste collection program. Does the 17th cycle HHW Grant cover e-waste collection?

HD17 grant funds could cover some forms of e-waste, but only those materials not listed as covered electronic waste (CEW) under the Electronic Waste Recycling Act of 2003 (SB 20 [Sher/Romano, Statutes of 2003, Chapter 526]). Non-CEW materials include, but are not limited to:

• Computer peripherals (including, keyboards, scanners, and printers, etc.)
• Small electronics (including cell phones, calculators, VCRs, DVD players, etc.)

SB 20 CEW materials such as computer CRT monitors, television CRT monitors, and laptop LCD screens are eligible for reimbursement from the SB 20 advance disposal fees. See CIWMB's page on the Electronic Waste Recycling Act of 2003 for more details.

The Guidelines and Instructions include out-of-state travel as an ineligible activity/cost. In our project, we have consultants from other parts of the U.S. and experts from around the world speak about how they have successfully managed u-wastes in their locations. While we hope to have the parties provide in-kind donations to help defray costs, there are some government persons who may not be able to attend without travel and hotel costs being paid for and/or an honorarium or stipend provided.

With this background, we have the following questions:

• Can project consultants and international speakers coming from other locations in the U.S. to assist CA local governments be reimbursed for their travel costs?
• Can project consultants and international speakers from out-of-state be reimbursed for meals while staying in California?
• Can meals for project consultants or international speakers be reimbursed by per diem rates as is done with state employees or with receipts?
• Can hotel stays for project consultants or international speakers be reimbursed by per diem rates as is done with state employees or with receipts?
• Are honorariums/stipends (or any other similar term) for speakers eligible costs under the grant?
• Are there any cost limits for honorariums?

The Ps&Rs state that out-of-state and international travel are ineligible for reimbursement. In addition, honoraria are not an eligible expense. However, grant funds may be used to purchase reports from these experts. Grant funds may also be used to pay for conference calls and mobile conferences.

Pharmaceutical Materials Related Questions

Will a pharmaceutical collection program be an eligible element for the 17th cycle grant?

No. Please see the response posted previously under the heading, "Pharmaceutical Materials Related Questions."

Are pharmaceutical waste collection programs eligible in the 17th cycle HHW Grant?

No. Pharmaceutical wastes are a component of medical waste and are excluded from the definition of HHW. SB 966 (Simitian, Statutes of 2007, Chapter 542) requires the Board to develop, in consultation with appropriate state, local, and federal agencies model programs for the collection and proper disposal of pharmaceutical drug waste. Due to time constraints specified in SB 966 and, since no funds are allocated for this purpose, CIWMB staff must present implementation options to the Board. This is not expected to occur until after the 17th cycle HHW Grant has been awarded.

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