California Department of Resources Recycling and Recovery (CalRecycle) 

LEA Advisory #34—Attachment

Department of Toxic Substances Control Memo

To All Local Enforcement Agencies:

November 21, 1996 

To:  County Environmental Health Directors and Certified Unified Program Agencies

Subject:  Management of Recalled Mini-Blinds

Vinyl mini-blinds were recently recalled due to the presence of lead that can be hazardous to children. Children are vulnerable to lead exposure from mini-blinds if they touch the blinds and then put their hands in their mouths, or if they put the mini-blinds in their mouths directly.

In a fact sheet following the recall action, the California Department of Health Services (DHS) advised consumers to dispose of their vinyl mini-blinds with their household trash. On July 16, 1996 the Department of Toxic Substances Control (DTSC) issued a letter to all County Environmental Health Directors requesting them to advise the public not to dispose of mini-blinds in the household trash until DTSC completed and analysis of the mini-blinds' lead concentration and evaluated the risk they might pose to public health and the environment if disposed of in an ordinary landfill.

DTSC has completed its analysis of the mini-blinds. The results show that the mini-blinds that were tested contain lead in concentrations that would categorize them as hazardous waste. After evaluating the hazardous characteristics of the recalled mini-blinds, DTSC concludes that the public is more at risk if mini-blinds are left in the homes than if they are disposed of in a non-hazardous landfill. Handling the recalled mini-blinds as hazardous waste would only hinder their rapid removal from homes. Thus, given the physical state of lead in the mini-blinds, it would pose a minimal risk to the environment if they are placed in plastic bags and disposed of in household trash to non-hazardous solid waste landfills.

Anyone contacting your office for guidance regarding disposal of lead containing mini-blinds should be advised that although DTSC encourages these mini-blinds to be disposed of at local household hazardous waste collection events, they may be placed in plastic bags and disposed of with household trash.

The process described in this letter does not apply to waste mini-blinds from sources other than households or residential buildings. The mini-blinds tested are characteristic hazardous waste under the federal Resource Conservation and Recovery Act (RCRA). Therefore, mini-blinds from businesses must be disposed as hazardous waste unless exempt under federal law. If the business generates less than 100 kg. of hazardous waste (mini-blinds plus any other hazardous waste generated on site) in a single calendar month, then by federal law the business would be classified as a Conditionally Exempt Small Quantity Generator. DTSC will allow only businesses that qualify as Conditionally Exempt Small Quantity Generators to dispose of their waste blinds at a non-hazardous landfill.

Both the Chief of the Division of Clean Water Programs of the State Water Resources Control Board and the Deputy Director of the Permitting and Enforcement Division of the California Integrated Waste Management Board have concurred with DTSC's approach. For more information about the proper disposal of these mini-blinds, please contact Dr. Sangat Kals of DTSC at (916) 324-8293.

Sincerely,

Original signed by

Ted N. Rauh
Deputy Director
Hazardous Waste Management Director

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