PROPANE TANK PRODUCT STEWARDSHIP PROJECT Analysis and Actions for Minimizing 20-Pound Propane Tanks in the Waste Stream Prepared for SEMASS Partnership by Product Stewardship Institute July 14, 2003 ACKNOWLEDGEMENTS This guide was prepared under the direction of Scott Cassel, Director of the Product Stewardship Institute. Principal authors are Susan Loucks and Scott Cassel, with additional assistance from Alan Phipps. The Project Manager for SEMASS was Derek Grasso. We would like to thank all those interviewed for contributing both their time and insight. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 ii TABLE OF CONTENTS Acknowledgements Page i Introduction 1 Identifying the Project Area 3 ISSUES AND POTENTIAL SOLUTIONS 6 SECTION I: Education Problems Potential actions for SEMASS Other Potential solutions 6 6 6 11 SECTION II: Regulation Problems Potential actions for SEMASS Other Potential solutions 12 13 13 17 SECTION III: Economics Problems Other Potential solutions 18 18 19 SECTION IV: Infrastructure Problems Potential actions for SEMASS Other Potential solutions 21 21 22 24 SECTION V: Background information on stakeholder groups and propane regulatory structures. Characteristics/Interests of Selected Stakeholder groups Propane Life Cycle Flow Chart 25 25 28 APPENDIX A: Project Summary APPENDIX B: Contact/Stakeholder List APPENDIX C: Interview Notes APPENDIX D: Sample Educational Materials APPENDIX E: Explosions or Accidents involving Propane Cylinders Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 iii INTRODUCTION Used 20-pound propane tanks (typically used for barbecue grills) are a safety concern because the tanks often contain residual propane gas, which has the potential to cause fires or explosions. As a result, many municipalities hold special collections to divert the used tanks from disposal. Additional collection services are provided by companies that sell new tanks in exchange for old ones, or by companies that refill tanks with gas. The SEMASS Resource Recovery Facility, an approximately 3,000-ton per day combustion facility in southeastern Massachusetts owned by SEMASS Partnership, has also sponsored free tank drop-offs in some areas. Despite these efforts, large numbers of tanks are discarded in the household waste stream, which is a serious problem for waste-to-energy facilities like SEMASS that shred waste prior to combustion. Shredding propane tanks can result in explosions that are often powerful enough to damage equipment and buildings, and place plant workers at risk of serious injury. SEMASS staff reported that the Massachusetts facility had 62 explosions from the shredding of propane tanks from January through November, 2002, and the average cost of repairs after an explosion was in excess of $12,500. Risks of exploding propane tanks also extend to operators of garbage trucks, transfer stations, landfills, and other waste-to-energy plants. SEMASS has removed more than 2,300 20-pound propane tanks from the waste stream in 2001. That number increased significantly in 2002 due to Massachusetts’ adoption of the National Fire Protection Association (NFPA) codes that require all valves to have an Overfill Protection Device (OPD). The NFPA code, once adopted by state law, makes it illegal to fill non-OPD tanks and renders them obsolete. The first state laws (including in Massachusetts) went into effect on April 1 of 2002, after which many old tanks were improperly discarded by consumers. For the first seven months of 2002, the number of tanks removed from the waste stream was 74% higher than the first seven months of 2001. The Product Stewardship Institute (PSI) designed this project as Phase I of a fourphase Action Plan to investigate questions regarding management of used propane tanks, associated risks, existing regulations, potential solutions, and stakeholder interest in a dialogue (see Appendix A). One primary goal of this overall project is to reduce the risk from explosion of propane tanks for waste handlers by reducing the number of tanks in the waste stream. Another significant and complementary goal is to recover a useful resource by increasing the number of tanks collected – either for refurbishing or for scrapping (recycling). Phase I – the Outreach and Assessment Phase – consisted of identifying stakeholders, conducting 44 interviews, identifying issues, recommending potential solutions, and attempting to reach basic agreements (see Appendix B for a list of stakeholders). Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 1 The interviews that PSI conducted have served to educate stakeholders. Many expressed surprise at learning of SEMASS’ difficulties, and expressed an interest in taking action to alleviate plant explosions. Some of the potential solutions derived from the interviews are ones that can be implemented immediately by SEMASS in the short term, while others will require the cooperation of other stakeholders over a longer time period. The Phase I budget did not include funds for face-to-face meetings, which is the essence of the Phase II dialogue. Nearly all stakeholders we interviewed expressed an interest in participating in the dialogue. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 2 IDENTIFYING THE PROJECT AREA The SEMASS partnership serves nearly 100 municipalities at its Rochester, Massachusetts, combustion facility. As SEMASS determines further actions it wants to take to reduce propane tanks in the waste stream based on this report, it may find it necessary to work closely with a limited number of communities. Clearly, it is most important to work with communities whose residents are likely to be improperly disposing of their propane tanks. PSI conducted interviews with municipal officials or waste handlers in nine communities within the SEMASS service area. To learn about successful programs within that area, PSI targeted communities from the 2000 SEMASS propane tank survey that were reportedly collecting a large number of tanks. Based on information raised in those interviews (see #2 below), PSI categorized the nine communities into those likely to properly handle their tanks and those less likely to do so: Likely to properly handle their tanks: Less likely to properly handle tanks: Yarmouth Martha’s Vineyard Plymouth New Bedford Mashpee Duxbury Truro Harwich Bourne Kingston (not interviewed but discussed in another interview) PSI recommends that SEMASS take the following steps to prioritize the remaining municipalities within its service area for targeted action: (1) Contact Municipality: SEMASS’ 2000 propane tank survey provided useful contact information for municipal public works staff. An updated recycling contact list can be obtained from John Crisley of the MA Department of Environmental Protection, at (617) 556-1021, or John.Crisley@state.ma.us. (2) Evaluate Municipal Conditions: Through the interviews, PSI has determined that certain municipal conditions lead to proper management of used propane tanks. SEMASS should ask questions of each municipal contact to determine if the following conditions exist: Multiple tank disposal options: Some municipalities hold semi-annual one-day household hazardous waste (HHW) drop-off events or staff a permanent HHW drop-off center. Other towns have tank exchange cages run by national businesses that accept outdated or extra tanks. Dispenser/Refill operations are not consistently a way to recycle or dispose of extra tanks. Different consumers prefer different ways to fill Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 3 their propane tanks. If residents can dispose of their tanks in a way that mimics how they fill their tanks, whether that includes municipal drop-off locations or private exchange operations, they are less likely to dump tanks or hide them in the regular trash. Sample Questions: How many options for safe management exist in this area? What are those options? Where are they located? Readily accessible information on tank management options: Even if exchange and recycling options exist in a municipality, consumers need to be informed about where to take their extra or outdated tanks. The absence of readily available educational information pertaining to end-oflife management options will lead to improper disposal. Sample Questions: What type of information do you provide to residents about collection options? What additional information is available to them? Free or inexpensive tank drop-off: Many municipalities reported running successful collection programs that were either free to the consumer or had a $1-3 surcharge per returned tank. However, when prices climb towards $10, residents are likely to look for alternative and improper disposal methods. Those interviewed suggested that, at some fee level, typically over $3, at least some residents would stick their tank in a black plastic bag and put it deep into their trash can, or toss it in a commercial dumpster. Refill stations often have high trade-in prices, as they are strapped for space and may not have efficient systems to manage tanks they collect. Sample Question: How much do the different management options cost? Convenience of options: Some municipalities in the SEMASS service area have residents buy a sticker that allows them to drop off all their waste at a central facility. These people regularly make trips to dispose of their garbage, and would probably be less likely to discard their tanks improperly than residents with curbside trash service who need to travel solely to drop-off their tanks. In other areas, particularly in rural communities, facilities may be far away or open only by appointment. While residents may be accustomed to driving to dispose of regular trash, if special wastes (like propane tanks) are not collected at that same facility, residents might have incentive to dispose of the tanks improperly. Sample Questions: How convenient are the existing options? How many days and hours are the options available each week/month, etc.? Do residents find these options convenient? Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 4 Municipal involvement: Municipalities with at least one involved employee, who is aware of problems from used propane tanks, are more likely to communicate and coordinate with other departments in that same municipality (e.g., public works and fire officials) in an attempt to find safe and convenient local collection solutions. They are also more likely to educate their residents. Sample Question: Do you have an employee in your municipality who works on propane tank collection and recycling issues? Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 5 ISSUES AND POTENTIAL SOLUTIONS PSI identified the following issues and potential solutions pertaining to 20-pound propane tanks in the waste stream through 44 interviews conducted between December 9, 2002, and March 5, 2003 (see Appendix C). The issues and potential solutions have been grouped into four categories – Education, Regulation, Economics, and Infrastructure. For each category, we identify several key problems, and then follow with short-term and targeted actions that SEMASS could take. Each section concludes with additional solutions that would require additional time and resources. SECTION I: Education This category covers strategies to educate consumers, propane gas handlers, and municipal officials. PROBLEMS Consumers are often unaware of local municipal and commercial collection and recycling options for propane tanks. If retailers or municipal officials have recycling information available, it is often inconsistent or confusing to residents. There is a lack of communication regarding safety standards and tank recycling practices between retailers, municipal safety and public works officials, and state and local regulatory officials. As a result, propane tanks are, at times, inefficiently handled or not managed in a safe manner (see appendix E). For example, municipal officials often improperly vent the propane gas prior to having the tanks collected for recycling, or they store them improperly. Communication gaps can contribute to an overall sense of confusion about dealing with the product and a fear that they will be improperly handled, resulting in a lack of interest in collecting tanks. This fear contributes to a lack of disposal options. POTENTIAL ACTIONS FOR SEMASS PSI recommends that SEMASS take two basic approaches to educating consumers within its service area: (1) Use Existing Nationwide Website and Hotline (2) Conduct Targeted Education Campaign Nationwide Website and Hotline Earth’s 911 is a national website and hotline that provides local information on recycling and HHW management. PSI recommends partnering with Earth’s 911 to provide information to consumers on propane tank management. Website (http://www.earth911.org): Website users can enter their zip code and retrieve a range of environmental information, including nearby municipal and commercial (e.g., Product Stewardship Institute 6 Propane Tank Product Stewardship Project July 15, 2003 exchange) collection points for propane tanks, and whether there is a drop-off charge. More detailed information about propane tank recycling is found through the “Recycling Centers,” link although some information is also available through the “Household Hazardous Waste” link. Municipalities have the ability to update the information remotely and are responsible for any changes, so the amount of detail varies. Telephone Hotline (1-800-CLEANUP): Callers can enter their zip code for recorded area-specific information on places to drop off their propane tanks, recyclables, and HHW. While the hotline is less user-friendly than the website, it is an important option for those without web access. The State of Massachusetts, through the Department of Environmental Protection, currently contracts with Earth’s 911 to provide environmental information to residents in the state. PSI recommends that SEMASS take a multi-faceted approach to maximize the potential of this information source: (1) Enhance the functions of the existing website and toll-free number; (2) Encourage municipal officials to input information; and (3) Encourage consumers to use the website and hotline. Enhance System Function: Individual users of Earth’s 911 website may have a hard time locating propane tank recycling information. PSI recommends that SEMASS discuss with Earth’s 911 a process for developing a general propane tank Home Page, question and answer section, and more obvious references and links to that information, including making propane tank disposal information more accessible from the “Household Hazardous Waste” page as well as the “Recycling Centers” page. More specifically, PSI recommends that Earth’s 911 have a separate listing on the HHW section and that the Propane Tanks link in that section provide the same access to general information as is available in the Recycling Centers section. PSI has interviewed and met personally with Earth’s 911 staff to determine the type of additional information that might be made available for propane tank recycling. PSI will create, in conjunction with Earth’s 911, a special content section on propane tanks that will be cross-referenced throughout the website. PSI will also discuss potential website improvements with Earth’s 911. Earth’s 911 currently does not have website content where municipalities can compare costs of different tank recycling services within the SEMASS service area. PSI will provide this information on its own website(www.ProductStewardship.US), as well as provide links to Earth’s 911 and other tank recycling resources (such as commercial exchange companies). PSI will also provide and link to information about safe handling of tanks. SEMASS can publicize this web resource to its customers. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 7 Encourage Data Input by Municipal Officials: After the website format is adjusted, the next step is to ensure that the information on the site is as accurate and complete as possible. After all, the website is only as good as the information that municipal officials supply. While this process is time-consuming, it is the only way for the site to be accurate. Earth’s 911 makes available a template on its website into which municipal officials must enter specific data on the type of propane tank information available in the community. Currently, municipal contacts arrange for a user name and password with an Earth’s 911 staff member, which allows them to log on whenever they want to make a change. A box on the left-hand side of the web Home Page provides municipalities with detailed instructions and connects them directly to a contact who can help first-time users. (Contact: Ann Reichman, Earth’s 911 Director of State Coordination, 602-2245444, areichman@cleanup.org). PSI suggests that SEMASS review the template that Earth’s 911 uses to receive information from municipal officials to ensure that it is user friendly. Any changes to the format should be made prior to contacting officials to encourage them to use the template. PSI suggests that SEMASS take two approaches to reach the municipal officials – one which will be statewide and another that will target specific communities. For the statewide approach, SEMASS can write a letter for the MA DEP to send to municipal officials across the state requesting that they take advantage of the Earth’s 911 service for their residents by inputting environmental data to the system, but particularly for propane tanks as Memorial Day looms. The upgraded features of the website pertaining to propane tanks provides justification for sending a letter. DEP may have alternative suggestions. Alternatively, the National Propane Gas Association/New England could send a letter directly to municipal officials urging them to use the service. Another statewide organization that should be contacted to provide information to its members is MassRecycle. On a regional basis, the South Shore Recycling Cooperative (SSRC) can put an article in its quarterly newsletter urging its 15 southeastern Massachusetts municipalities to input data to the Earth’s 911 system. The SSRC’s newsletter is an excellent opportunity to educate at least some of the municipal officials in the region about the concerns with propane tanks. (Contact Claire Sullivan, SSRC Planner, 508-785-8318, ssrcclaire@comcast.net.) Another regional contact is the Barnstable County Cooperative Extension, which works with municipalities on Cape Cod. (Contact: Marilyn Lopes, Extension Educator, 508-375-6699, mlopes@umext.umass.edu). Lastly, the Solid Waste Association of North America (SWANA) also has direct ties to municipal officials and can publicize the need for data entry in its newsletter and website. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 8 SEMASS can also target specific municipalities whose local conditions make it ripe for their residents to improperly dispose of the tanks and/or ones whose data is particularly spotty on the Earth’s 911 website and hotline. SEMASS can use the website to check zip codes for municipalities within its service area, noting municipalities that provide outdated or sparse information. Once these municipalities are targeted, SEMASS could target a separate letter to local officials and/or make individual phone calls expressing the need to provide updated information on propane tanks. Encourage consumers to use the website and hotline: DEP promotes Earth’s 911 in a variety of ways, including putting information about the service on recycling education brochures and developing public service announcements for radio and television. More outreach can be attempted, and a variety of communication strategies can be employed. Each of the communication strategies below could advertise Earth’s 911 website and hotline number, once improvements are made to the system and information has been input. Other Communication Strategies Use Existing Educational Materials: Most of the municipalities that PSI interviewed did not have an educational campaign associated with their propane tank recycling program, or felt their campaign did not reach the target audience. Exchange and/or refill operations sometimes, but not always, posted signs on propane tank cages or equipment that had recycling information. In Appendix D, PSI provides examples of educational materials used by public agencies and private companies to convey propane safety and disposal messages. One from the Indiana Propane Gas Association is an excellent question and answer fact sheet that could be revised, with permission, to include the Earth’s 911 website and toll-free hotline. Another piece from the New Hampshire Department of Environmental Services contains disposal information and could also be adapted easily. Three other notable pieces that appear in Appendix D are from Blue Rhino (the tank exchange business), Waste Management, and the National Propane Gas Association. SEMASS could target priority municipalities in the service area with one or more of the specific communication strategies listed below. Placards: SEMASS can ensure that tank exchanges in its service area have metal placards on their collection cages. Brochures and posters: These would be effective at refilling stations, gas distribution outlets, retail outlets, municipal depots, libraries, and other prominent locations. SEMASS should first determine if existing materials are available to suit their need. PSI assembled a variety of existing materials in Appendix D. SEMASS might want to contact NPGA/New England for assistance in providing large quantities for distribution in the service area. Bill Inserts: SEMASS could place a one-page fact sheet in utility bills with cooperation from municipal administrative offices and public works departments. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 9 Cable Spots: Although it would take longer, local cable spots would be highly effective if played on local cable TV networks. Newspaper Articles: SEMASS can develop articles for placement in local papers. Identify priority distribution points: Through its interviews, PSI has determined that Refill/Distribution outlets and tank exchange cages are excellent places for recycling information such as placards and posters. However, other methods of information dispersal (e.g., newspaper ads, brochures handed out at municipal DPW yards, and bill inserts) have also been used successfully. One medium was not overwhelmingly more successful than another in conveying the message to the public, although repeated or intense coverage was an important part of any successful campaign. Develop Custom Educational Materials: Although much more costly, SEMASS can create its own messages that will be tailored for its unique circumstances. Through the interviews, PSI has gleaned that the following information is the most important to include in any communication: Where to take your unusable or empty tank – or a telephone number or website to find out that information. Why OPD valve legislation was enacted. How to distinguish OPD from non-OPD tanks. Safety information on handling and storing propane (including keeping valves closed, storing tanks upright and outside, and not de-valving, crushing, or purging tanks unless it is done professionally). A local phone number to call for more information (a live person). Solidify partnerships: PSI has determined that Worthington Cylinder and Manchester Tank, the two primary tank manufacturers in the United States, are willing to entertain proposals to develop point-of-purchase informational materials, such as signs on propane cages, and/or other public outreach materials. SEMASS can talk with municipal officials in selected areas and develop cost estimates for an educational campaign. These estimates could be developed into a proposal for consideration by these two manufacturers that would include the cost of graphic design (if existing materials are not available), printing, distribution, and program coordination. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 10 OTHER POTENTIAL SOLUTIONS The following strategies would require additional time, resources, and the cooperation of multiple stakeholders. Tank Labeling One direct and simple way to communicate with the public is by clearly labeling propane tanks with proper disposal information. The information could potentially be engraved and fixed on the tank metal, incorporated into a shrink-wrapped label, or stuck on a tank with adhesive. Manufacturers could potentially affix a metal label, or a more temporary label could be attached at distribution or refurbishing plants. Since tanks travel far from distribution and retail locations, it would not be feasible to list local tank recycling options. However, information on the label could direct consumers to their municipal public works agency or to a national hotline or website, such as Earth’s 911. In order to move ahead with this option, SEMASS needs to: (1) Establish communication with Manufacturers, Distributors, and Exchange Businesses: Worthington Cylinder and Manchester Tank expressed a willingness to consider labeling their tanks with appropriate information. SEMASS will need to have conversations with these two contacts and determine: What information do they believe is necessary to put on the tank? How would they assure that the information stays on the tank when the tank is ready for refilling or exchange? (For example, the tanks are often pressure washed and painted between uses.) What options exist for label durability? What other stakeholders are needed to reach consensus on the label language (e.g., refurbishers, tank exchange businesses, refillers, etc.)? What steps need to take place to change the label? How soon would new tanks appear at the retailer after the decision to change the label is made? How to address the concern expressed by manufacturers that they can be held liable for any problems resulting from the instructions on the label? (2) Prepare Draft Label Language: PSI assisted in developing language for use on pesticide labels for a Pesticide Registration Notice developed by the U.S. EPA. Based on this experience, PSI suggests that SEMASS start with draft language that reads: TO DISPOSE: Call your local solid waste agency, 1-800-CLEANUP, or www.Earth911.org for disposal instructions. Do not put in regular trash. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 11 (3) Reach Consensus on Label Language: Before finalizing the label language, SEMASS should attempt to reach consensus with key stakeholders in addition to the two tank manufacturers. For example, if the label will be included on shrink-wrapped sleeves for tanks in exchange programs, exchange businesses will need to participate in developing the language as well. Ongoing Communication PSI recommends that SEMASS establish an ongoing communication link with existing organizations to monitor the success of its efforts and to jointly solve problems related to tanks still in the waste stream. This group should be in contact on a periodic basis to communicate the results of efforts and plan future strategies. The key organizations in the SEMASS service area were listed above and include: South Shore Recycling Cooperative Barnstable County Cooperative Extension National Propane Gas Association/New England Solid Waste Association of North America/Massachusetts Chapter Massachusetts Department of Environmental Protection/Southeast Region MassRecycle SECTION II: Regulations This section covers problems and potential solutions that are regulatory in nature. Propane training, handling, and storage are regulated under Massachusetts code 527 CMR, section 6, which references the National Fire Protection Association (NFPA) code 58. Individual states adopt particular versions of NFPA 58 (Massachusetts has adopted the 1998 version) and reference them in their own codes. The code is then considered the minimum level of enforcement throughout the State. Municipalities are able to create more stringent ordinances or bylaws on their own, but are not allowed to drop below the statewide standard. The State Fire Marshall’s office promulgates the propane tank code, and local fire departments are responsible for enforcing the code at a site. The U.S. Department of Transportation regulates propane transport. According to the Massachusetts State Fire Marshall’s office, if refillers/distributors or tank exchange operators are found to be out of compliance in their handling of propane, they could lose their permit. PROBLEMS Lack of Enforcement of Training and Handling Procedures: The LPG code requires that all businesses that exchange or refill propane tanks train their employees in proper handling procedures. Municipal fire officials, who have the authority and responsibility to enforce LPG codes, do not consistently enforce them, particularly with regard to training and handling requirements. Recent tight municipal budget and staff limitations have exacerbated the Product Stewardship Institute 12 Propane Tank Product Stewardship Project July 15, 2003 problem. Lack of enforcement poses safety risks, especially in the case of small refillers who might overfill tanks or allow the filling operation to be unattended if staff also must pump gas. While exchange cages are safer than refill stations, mishandling (such as dropping tanks or failing to secure or protect them properly) is still possible. Several local fire marshals cited these types of scenarios as reasons why they do not want refilling or exchange operations in their municipality. Lack of proper handling by station attendants can also lead to customers being unaware of how to safely handle and dispose of their gas cylinders. Lack of Dumpster Disposal Policy, and Lack of Publicity for Existing Waste Disposal Policies: Some consumers hide propane tanks in dumpsters, in construction roll-off containers, or in opaque plastic bags they put in garbage cans. Because disposal of propane tanks in dumpsters is not explicitly against any state law or code, some waste management companies have instituted their own system of disincentives for their customers. For example, some companies pass on costs imposed on them by the disposal facility for bringing in used tanks in the regular trash. Waste management customers and the broader public may not be aware of policies prohibiting dumping, including imposition of fines, or the reasons behind the policies. Restrictive Local Rules: Local Fire Departments, out of a concern for residents’ safety, may limit local refilling or tank exchange options through zoning or permitting. These limitations can actually create added risks in the community and at other locations by causing residents to dispose of their used tanks improperly out of frustration from not having viable disposal locations. Lack of Education of Sanitation Workers: Garbage collectors often lack information on tank recycling. As a result, they may not be able to educate the public, and are not motivated to remove tanks that they see in the trash. POTENTIAL ACTIONS FOR SEMASS Increase Enforcement of: (a) Training and Handling Procedures and (b) Waste Disposal Policies: If training and handling procedures are followed, propane will be handled more safely and, as a result, local fire marshals will be more likely to allow refillers and exchange businesses in their communities. In addition, if waste disposal policies and disincentives are created and publicized, fewer tanks will enter dumpsters and get sent to the SEMASS plant. PSI suggests that SEMASS advocate for increased local enforcement of training and handling procedures and waste disposal policies through the following steps. PSI recommends that SEMASS seek greater action from waste hauling companies, which have authority to create systems of disincentives for the dumpsters they service. This approach should be tempered with educational and incentive-based approaches. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 13 Gain Support of Refillers and Exchange Businesses: Although enforcement of training and handling procedures will penalize the non-compliant companies of those that refill or exchange tanks, those companies that are in compliance have much to gain if they can do business in communities that now prohibit their services. These companies will also gain by keeping tanks out of the waste stream, increasing the potential for them to be refurbished. Gaining the support of these businesses will be key in increasing the likelihood that this approach will be successful. Target Problem Municipalities: Since municipalities have the authority to enforce training and handling procedures, as well as waste disposal laws and policies, SEMASS should target those municipalities likely to be problematic. Municipalities can be targeted using the method and questions introduced in the “Identifying the Project Area” section, with the addition of a question or series of questions, such as: Have consumers or other municipal officials expressed concerns about safety and handling of propane in this area? Have waste hauling contractors expressed a concern with propane tank disposal in trash bins or dumpsters? Send letter to Problem Municipalities: A low-resource strategy would be for SEMASS to send a letter to each of the targeted municipalities to outline legal requirements regarding training and handling of propane tanks and tank disposal. The letter could outline the increased risk due to lack of enforcement, request increased enforcement, outline the fines that could be levied against the municipality, and outline proper management options (e.g., exchanges, collection locations). Such a letter would put the municipality on notice about risks resulting from current municipal practices, which will increase their liability if they do nothing. SEMASS should explore the potential for getting the State Fire Marshal’s Office to send the letter on its behalf. However, a more comprehensive and effective strategy would involve a meeting with all key stakeholders, although this approach would be more resource intensive. OPTION: Convene Municipal Forum: If SEMASS was willing to make this resource commitment, it should convene selected municipalities and invite the State Fire Marshal, local fire chiefs, operators of refill and exchange businesses in the targeted municipalities, key representatives (mentioned above) from refillers and exchange businesses, and local waste haulers. The Agenda could include the following: Overview of the rules and regulations related to training and handling. Overview of the rules and regulations related to waste disposal. Overview of enforcement issues, fines, and proper handling procedures. Options for proper local collection. Discussion of issues and solutions related to tank recycling. Prepare for Municipal Forum: Appendix D contains training materials that SEMASS could use to prepare for a forum. SEMASS would want to request that staff from the state fire marshal’s office be in attendance to outline legal responsibilities of municipal officials, refillers, and exchange businesses. PSI provided the materials in Appendix D as background for SEMASS staff. Product Stewardship Institute 14 Propane Tank Product Stewardship Project July 15, 2003 Complementary Strategies: Either in conjunction with, or separate from, the above efforts, SEMASS could initiate the following actions: Tank Stickers: SEMASS could develop materials for waste haulers to carry with them on their routes (e.g., printed on stickers or tags). Waste haulers could tag tanks that are improperly placed on the curb or in dumpsters for disposal. The stickers would alert the consumers or business owner to the dangers of improper disposal of propane tanks, inform them about current regulations, and offer local options for proper collection and recycling. These tank stickers could also direct consumers to the Earth 911 website (www.Earth911.org) and hotline (1-800CLEANUP) for this information. Create incentives for waste haulers and trash transfer station operators: Operators of refuse-derived fuel (RDF) plants in other parts of the country have had success keeping tanks out of the waste stream through increased employee inspections. A representative from the Covanta plant in Connecticut encouraged experimentation with employee motivation systems. They have noticed improved performance when they reward inspectors with a financial bonus for every tank they retrieve. SEMASS could introduce similar incentives for local trash transfer station workers in priority areas, as well as incentives for its own workers. SEMASS did operate an incentive system in Plymouth, where a small sum was paid to the worker’s selected charity for every tank retrieved. This system was discontinued due to concerns with the type of charities that were chosen. However, the system could be reintroduced with direct payments to workers, in order to avoid similar complications. Dumpster Placards: Similar to a recommendation made in the Education section, SEMASS could work with municipalities and tank exchange businesses to create placards for dumpsters with information about waste disposal regulations, fines, and safety risks from improper disposal of propane tanks. Currently, some waste hauling contractors pass charges imposed by SEMASS or other transfer stations on to their customers (those who own the dumpsters). Charges to the customer have been reported at $20-30 for each contaminated load. This disincentive could help motivate generators to lock dumpsters or take other precautions that would limit the improper disposal of tanks. Educate Trash Truck Driver: SEMASS can compile a fact sheet that includes recycling options and locations for targeted municipalities, an explanation of safety concerns caused by propane tanks in the waste stream, and a breakdown of fines and regulations about propane tanks for that location. This information can be distributed to waste collectors, and possibly reinforced with short presentations given to waste hauling company managers. Education could focus on why tanks are a concern in the garbage and what they can do if they find them. Trash collectors can reduce the need for municipal involvement by reducing the number of tanks that are placed or left in dumpsters and garbage cans. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 15 Develop List of Improved Handling and Training Procedures: PSI’s interviews have indicated that training propane gas refillers and tank exchange businesses about proper handling procedures could be effective in diverting tanks from the waste stream. When employees handle the tanks safely, it decreases on-site risks, and when employees model good tank handling behavior, consumers can learn and follow suit. This would help eliminate consumer confusion and inconvenience – two of the main factors in improper tank disposal. If municipalities felt that propane was handled safely and well, it would also encourage them to increase options for safe recycling. SEMASS could provide municipalities with a list of training resources to supplement their existing programs. PSI has identified the following organizations that provide training and training materials. The National Propane Gas Association (NPGA) offers a free 220 page textbook to fire departments and propane dealers on training trainers which can be found at: http://www.npga.org/public/articles/?Cat=114 TEXTBOOK. NPGA also runs the Certified Employees Training Program, which has accompanying materials. The Propane Education and Research Council (PERC) offers a propane regulatory compliance program, which can be found at: http://www.propanecouncil.org/about/compliance.htm. Additional training materials can be found in Appendix D. Convene Meeting to Address Restrictive Local Rules: Another idea is for SEMASS to either hold a separate small meeting with the handful of local fire marshals that prohibit refillers and exchanges to address their restrictive local policies or expand the meeting agenda above to include a focus on those municipalities restricting access. OTHER POTENTIAL SOLUTIONS The following two strategies are more comprehensive in nature and will take longer to implement. However, they have been successfully employed in two other states. Both use similar systems - one creates a code through established regulatory frameworks, and one mimics a regulatory type solution voluntarily, using respected nongovernment associations and government/association partnerships. These solutions address the wider problem of a lack of collection options, and might also be a successful strategy for dealing with local fire officials who prohibit exchanges and refillers from operating in their communities, although their concerns will only be addressed through increased enforcement of training and handling procedures. Develop a State Rule Requiring Collection: Louisiana has successfully implemented a rule (effective January 2002) that mandates that all companies that have a permit to fill or exchange propane tanks must take them back from the customer. Propane distributors, in turn, are required under this rule to pick up tanks from the refillers without charge. Noncompliance is punishable with a fine. As a result of this rule, distributors in Louisiana Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 16 have entered into arrangements with tank brokers, who will collect the tanks at their facilities or, in some cases, at the retailer. Foster Industry Cooperation to Collect Tanks: SEMASS could also work with PGA/New England and the Propane Education and Research Council to encourage propane retailers to voluntarily collect tanks, based on a model used during the summer of 2002 in Indiana. Indiana’s Propane Gas Association encouraged its members early in 2002 to accept tanks from consumers free of charge for a 90-day period during the grilling season. Those who signed on to the program were highlighted on the state PGA website. The program generated much positive publicity, including an opening press conference featuring speakers such as the Indiana State Fire Marshal, the Assistant Superintendent of the Indiana State Police, and the Commissioner of the Indiana Department of Environmental Management. The publicity generated by this initiative encouraged large retailers and tank recycling companies to promote their tank recycling services. As a result, consumers were well informed about recycling options and had many convenient drop-off points from which to choose. A tank refurbisher, Tri-State, arranged to pick up tanks at participating retailers during that period, and Indiana expects that many of those tank broker/retail relationships will continue in 2003. This strategy worked because the state PGA rallied the industry around an issue that the association said was important. According to our contacts at the PGA, those who participated in the program did so more out of an interest in being a good corporate citizen rather than the publicity and extra business that might result. SECTION III: Economics The OPD valve change has resulted in a glut of tanks flooding municipal recycling depots. This valve change has reduced safety risks in the use of propane tanks but has increased handling costs for municipalities. Many municipalities around the country want to be compensated for their increased costs. If local government costs are not covered, they have less incentive to collect tanks, since many will not have the funds to manage a collection program. While tank exchanges and other collection options exist for consumers, any amount of disposal cost can be a powerful deterrent to managing the tanks in a safe manner. On the other hand, several large companies, as well as smaller ones, exist that collect and refurbish or recycle the tanks. These companies have incentive to seek out tanks for collection. One major key to successfully removing tanks from the waste stream will be to align market forces so that economic incentives and disincentives work together to encourage tank collection and recycling. PROBLEMS When the cost to collect and recycle a propane tank is either too costly or inconvenient, the consumer has an incentive to dispose of the tank improperly. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 17 Tanks last longer than the equipment they are sold with. Manufacturers sell a new tank along with the equipment (e.g., a barbecue grill) that uses propane as a fuel source. Selling the tank and equipment as a complete set increases the interest in and/or retail value of their product. However, this practice creates a glut of tanks. POTENTIAL SOLUTIONS Innovative economic incentive systems have been developed for other problematic wastes, such as beverage containers, tires, automobile batteries, and motor oil. For these products, as well as for propane tanks, the cost to collect and recycle is greater than the market value of the material. In other words, someone has to pay to remove these products from the waste stream. Traditionally, state and local government agencies have been the backbone of our nation’s waste management system. While manufacturers make products and retailers sell them, taxpayer-funded government programs have paid for disposal. As the toxicity of the waste stream has increased and the need to remove products has grown, so have management costs. PSI’s research has shown that the cost charged to consumers to dispose of one propane tank varies from about $3-10 in Massachusetts. PSI’s experience with other special wastes has shown that the higher the fee charged to a consumer, the greater their incentive to improperly dispose of their waste. Even a $3 disposal fee will be too much for some people. This cost barrier is a major reason for the glut of tanks heading to the SEMASS facility. PSI explored various economic solutions during this project. Implementing economic solutions requires that stakeholders be educated about the alternatives so they can eventually rally around a particular solution. This process will require a variety of stakeholders and would not be able to be implemented by SEMASS alone. Such an agreement would best be developed through an extended dialogue such as the one started at the Summit. SEMASS could advocate for a particular model or contribute to discussions as a part of a longer-term process. PSI has identified many stakeholders who are interested in exploring financial options for propane tanks, although almost all of them were unfamiliar with the concepts and wanted additional information to help them evaluate their potential. Some of these options include: Taxes – Most programs are government run and paid for by taxpayers. To increase the collection of most special wastes, new collection systems must be developed or the product must be added to an existing system. In either case, costs are increased. These costs can be covered by an agency reallocating funds to address the problem, reallocating funds within the agency’s overall administration, or increasing taxes. Owing to the concerns over continuing with taxpayer funds, especially in the current economic climate, this option does not have support among government agencies. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 18 End-of-Life (EOL) Fees – These fees are paid by consumers at the end of a product’s life to whichever entity operates the collection (e.g., retailer, municipality). While EOL fees can offset a government’s cost to manage products, most agencies view them as ineffective since consumers are encouraged to dump the product illegally to avoid payment. In addition, many agencies don’t want the responsibility to collect the payments. Deposits – Deposits can operate like the bottle bill, in which consumers can receive the full deposit value back if they return the used item. Alternatively, consumers can receive a portion of their deposit back, as is the case in many areas in Canada. Visible fees – Some states have laws that require consumers to pay an additional fee on certain products, such as motor oil. These fees are communicated visibly to the consumer and are paid by the consumer at retail to cover the extra cost to collect and recycle the product. Bounties – Consumers could also be provided with a “bounty” paid at the collection location for return of the used tanks, or with coupons to redeem at retail outlets sponsoring collections. (Voluntary) Retail fees: Another consumer incentive could involve the retailer charging a small fee only if the consumer does not bring back an empty tank when they purchase a new tank. This fee is charged by retailers in many states for automobile batteries and can be initiated without legislation requiring the retailer to take action. However, in the case of auto batteries, the product’s positive market value provides the incentive for retailers to set up such a system. Producer Responsibility/Invisible Fees: Manufacturers could factor the end-oflife management costs for used tanks (e.g., collection, transportation, refurbishing, and recycling) into the purchase price of new propane tanks. This could be done voluntarily, as in the case of the Rechargeable Battery Recycling Corporation, or legislatively, as is being implemented in many countries in Europe and Asia. The added cost to the consumer, in this case, is invisible to the consumer and paid at retail. The consumer pays more for the product, which includes the collection and recycling service, but isn’t aware of the separate cost. The funds generated by this initiative could be managed by a third party organization (e.g., the Propane Education & Research Council), which could disburse funds for educational programs, develop contracts for the transportation of tanks to designated processors, and ensure effective infrastructure and recycling programs. The fund would effectively develop a collection system so that consumers were guaranteed the ability to drop the used tank off for no extra charge at designated locations. Product Purchase Agreements – Manufacturers and retailers could also work in conjunction to create economic incentives to buy propane-powered equipment (e.g., a grill or a recreational vehicle) without having to purchase a new tank. Through its interviews, PSI has also identified existing opportunities and obstacles to implementing an alternative financing system, including: Opportunities Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 19 Existing Fee Mechanism: A law already exists that levies a .04/cent fee on every gallon of propane sold, so there is an existing mechanism that raises a significant amount of funding to be used to reduce the impacts within the propane gas industry. SEMASS and others would have to convince the Propane Gas Association and the Propane Education and Research Council that these funds should be used to help collect used tanks. The law allows PERC to raise the fee to.05/cent. In lieu of adding a deposit or another front-end fee, SEMASS and other interested parties could propose that PERC use some of the existing funds to reduce the risks posed by improper disposal of propane tanks. PERC funds are available for projects on a state basis through state PGAs. Interest to Explore Options: Key stakeholders indicated that they could consider some type of legislation that allows for a “level playing field” so that, if the price of their product was higher to reflect the cost of safe tank management, the price of all products would be higher. Those interviewed expressed a concern that a system would have to ensure that there were no “free riders.” Obstacles The industry may be resistant to additional fees or deposits, as they are already being charged a per gallon fee. The growing international market in 20-pound propane tanks may make it difficult to involve overseas companies meaningfully in a process to develop an economic solution. Creating a level playing field is more difficult with companies that are not domestic. SECTION IV: Infrastructure Infrastructure issues arise when transportation, equipment, or storage systems are not adequate to handle tank recycling needs. PROBLEMS Many municipalities and retailers lack space to appropriately store used propane tanks prior to having them collected to be refurbished or recycled. This limitation reduces their options for tank recycling, as recyclers often require a minimum number of tanks in one location for pickup. Municipalities are often served in their region by only one tank recycling operation. Because of the lack of competition, they may be forced to accept a limited range of service options. Municipalities do not have access to equipment they could use to safely prepare the tanks for scrapping, which reduces their options for managing the tanks. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 20 POTENTIAL SEMASS ACTIONS Bolster Tank Exchange/Retrieval Systems Tanks are less likely to enter the waste stream in areas where tank exchange businesses are active and/or tank brokers work with businesses to haul away empty tanks. These companies, in contrast to refillers, often accept tanks for no fee, a small fee ($1-2), or as a small charge added to the price of a new full tank of gas. However, individual exchange businesses have their own policies, so one cannot assume that they will take used tanks outside of a one-for-one exchange. It is always best to contact the company in advance. SEMASS could work with these companies to improve municipal access to these services. This may include increasing the frequency of tank pickups or increasing the geographical density of pickups within the SEMASS service area. SEMASS could take the following steps to implement this action: Identify current consumer-oriented tank exchanges in priority areas: The two largest U.S. tank exchange operations (Blue Rhino and AmeriGas) service the same municipalities as SEMASS. Each has a website with the ability to locate the nearest exchange location by entering a zip code (http://www.bluerhino.com, http://www.amerigas.com). These sites can serve as a tool to find areas that are underserved by exchanges. By plugging in zip codes of the municipalities in the SEMASS region, SEMASS will be able to determine the extent of coverage in any one area. If gaps are found, SEMASS could alert tank exchange companies of business opportunities. Tank exchange businesses will require a municipal permit. SEMASS should, therefore, involve municipal authorities in any conversations, to ensure that local authorities do not prohibit permitting tank exchanges. Identify tank brokers and coordinate with municipalities: SEMASS representatives can also talk with public works officials in selected municipalities as described in “Identifying the Project Area” (Section I) to identify any existing relationships with tank brokers, as well as to determine the numbers and locations of tank drop-off points and tank preparation requirements. Municipalities may not be aware of tank pick-up options, and tank brokers may not be aware that areas are in need of service. PSI has spoken with three businesses that pick up tanks in the SEMASS service area. Their restrictions are as follows: Tank Recyclers makes regular trips to locations that can supply 2,000 tanks/month, but also arranges more sporadic pickups for places with more than 100 tanks. Their prices, as of April, were: 20 lb. grill tanks - $1 each (100 minimum) Tanks under 20 lb. - $1 each Tanks over 20 lb - $20 each Fewer than (100) 20 lb. tanks - $5 each Helium Tanks - $5 each Fire Extinguishers - $5 each Refrigerant Canisters - $10 each Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 21 (more information is available on http://www.tankrecyclers.com/pickup.htm). McKnight Cylinder will make regular pickups for free when the amount reaches a half truckload (approximately 500-600 tanks). Tanks should be palletized and shrink-wrapped in preparation for pickup. AmeriGas will make pickups for all tanks, even those not under its own exchange program. Our initial AmeriGas contact suggested that the company does not currently impose limits on the number of tanks or geographical area (within reason) for pickups, and would consider picking up for free. (After the AmeriGas interview was conducted but prior to the Propane Tank Summit, the contact changed. Therefore, the current contact may have a different understanding of the company policy.) Once SEMASS has determined the extent of the need for service and identified an appropriate tank broker, they might go one step further and suggest that the broker collect from municipalities at identified consolidation points or operate “milk runs” through a number of smaller adjacent communities to reduce collection costs and develop an efficient return system. Publicize efforts: SEMASS can help publicize new services with bill stuffers or public service announcements. One Day Collections As mentioned earlier, PSI’s interviews indicated that brokers were more likely to take tanks for free if a larger number are consolidated. For this reason, special tank collection days, either alone or in conjunction with other household hazardous wastes, are an easy and low-cost method of keeping tanks out of the waste stream. While the trend in HHW collections is to have permanent collection opportunities, propane tanks offer a different scenario. If collected on a one-day basis, there are no capital expenses and, if collected with other hazardous materials, any set up costs can be shared. In addition, since collection would be on a one-time basis, and would not be permanent, permits are not required. Therefore, these collection days can operate in municipalities even where propane refilling and exchange services are banned. SEMASS can organize collection days by: 1. Collecting background information: Potential sources of background information include local refurbishers or municipalities who have experimented with take-back events, either for propane tanks or for other products (such as electronics). 2. Contacting Municipalities and Tank Brokers: After SEMASS determines priority municipalities to contact (see Section I), it can contact public works officials to determine if the municipality already holds an HHW collection and if it would be interested in holding a separate collection for tanks or including tanks with their HHW collection day. SEMASS will also need to determine if there is an existing Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 22 relationship with a tank broker, or if one will need to be recruited to haul away the empty tanks at the end of the event. 3. Publicizing event: SEMASS can work with local news media, such as radio stations and newspapers, to publicize the event. SEMASS can also use printed materials such as bill stuffers. OTHER SOLUTIONS Municipal/Facility Coordination – SEMASS could coordinate between tank collection businesses and municipal and/or private facilities in targeted municipalities that have space to provide a convenient local or regional drop-off consolidation and storage point for empty tanks. SEMASS could assist in arranging for periodic bulk drop-off, and could help contact companies to collect tanks when an appropriate number had accumulated. Otherwise, SEMASS should encourage municipal officials to make the calls and arrange for pickup. Equipment Purchase – SEMASS could purchase equipment to safely decommission tanks (e.g., remove valves, purge, and crush) and make it available to municipalities or groups of municipalities. This could be an important solution for towns that have continuing problems with damaged, rusty, or otherwise non-recyclable tanks and cannot afford the equipment individually. Regional/Model Contract – On behalf of the communities in its service area, SEMASS could develop a regional tank collection and recycling contract that municipalities can use to collectively contract with a vendor. Alternatively, SEMASS could develop and share model municipal contracts with municipal officials. Screen out Damaged Tanks – SEMASS could develop a screening procedure at its facility that effectively separates damaged tanks from reusable tanks. This, in turn, will reduce the need to transport non-reusable tanks back to the vendor’s facility. Instead, the damaged tanks can be sent directly to a scrap metal dealer from the SEMASS facility. This procedure will likely improve SEMASS’ relationship with these tank collection businesses, which may increase the company’s willingness to work with SEMASS on municipal tank pickups. SECTION V: Background information on stakeholder groups and Propane Tank Life Cycle Chart Characteristics/Interests of Selected Stakeholder Groups: The following are profiles of stakeholder perspectives on propane tank issues. Any proposed solution will need to recognize these perspectives and concerns and build value for those involved. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 23 Refillers Propane refillers often run small operations in remote locations and face stiff competition from larger retailers with tank exchanges. At times, these conditions may encourage them to operate in unsafe ways (for example, by refilling non-OPD tanks to keep a customer). Since they are remote, refillers may be under less regulatory scrutiny. They can make more money on filling tanks with gas than by operating a tank exchange. Furthermore, they often lack the space and incentive to take out-of-date tanks back from the consumer. While there are many excellent refillers, the above reasons make some propane refillers one of the more problematic links in the tank management chain. Tank Exchange/Refurbishing operations Exchange operations and refurbishers depend on the ability to collect a reliable and large number of good quality tanks for testing and retrofitting . The largest tank exchange companies extend their services over most of the United States, although they often limit their pick-up services based on the number of tanks in a particular location. Refuse-Derived Fuel (RDF) plants Of all combustion facilities, RDF plants present the greatest risk relative to propane tanks because they shred waste prior to combustion. In some parts of the country, RDF plants are already considered financially or technologically problematic. Therefore, the association representing these facilities does not want to focus attention on an issue that could be interpreted as another RDF problem that results in additional costs to counties or municipalities. Some RDF plants are not reporting problems with explosions from tanks, and credit their facility technology and community outreach with keeping tanks out of the waste stream. Local government Local governments are limited by available space and financial resources. They don’t want to provide collection services to their residents because they will then have to pay for the collections. Most municipalities do not like to charge extra fees just for tanks. However, towns that charge residents for each bag or barrel of garbage often have systems to pay extra for tanks. These communities may have more institutional structure and capacity for tank handling. In these limited cases, residents may be more accustomed to paying for each item disposed, and might be more likely to agree to a small end-of-life fee for tank recycling. Rural areas have a different set of challenges for propane tank recycling than urban areas. While urban areas have more tanks and a corresponding higher financial burden, rural areas may have weaker tank recycling infrastructure and no municipal household hazardous waste drop-off centers. As a result, while urban consumers may slip tanks into commercial dumpsters, rural consumers may bury tanks in their backyards. Each disposal method poses unique risks. Consumers Tanks are a recreational commodity, which means consumers are more likely to be concerned with a large price increase as compared to the purchase of a product considered a necessity. Consumers, therefore, are less likely to pay for additional tank features, such as a gage indicating whether a tank is full or empty. Consumers also like Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 24 convenience and are often willing to pay a little more for having easy access to propane gas. For example, customers will often choose tank exchanges instead of refillers because of the exchange’s extended hours. They are also likely to store extra tanks to ensure that they don’t run out of gas, and often see no problem with storing multiple containers because they are uneducated about the safety concerns. Manufacturers Propane tank manufacturers are motivated to reduce the risks from their products so that consumers will not have a negative perception of their industry. Scrap Dealers Scrap dealers will make greater profit on large pieces of heavy steel or more expensive metals. Therefore, they have less incentive to collect propane tanks, which contain less metal. To enhance the interest of scrap dealers in taking tanks, consider combining tanks with other metal products in a contract or prepare the tanks in a way that is most beneficial to them (e.g., cut in half or crushed). Propane Industry Associations The following is a brief overview of two key organizations that currently assist and educate the propane industry. The National Propane Gas Association (NPGA) The NPGA is an organization designed to promote industry safety, lobby the federal government, provide communication between members, and to be proactive in responding to industry challenges. It has an operating budget of approximately $5.4 million and reported 3,636 members at the end of February 2002. More than 75% of its members are propane marketers, with the remainder being manufacturers, international members, and distributors and service providers. Member services include access to educational programs and information (through meetings, newsletters, and bulletins) as well as an increased industry presence in Washington, D.C. The NPGA is organized under 10 districts, each made up of 3-7 states. Each district has a director, as does each state . Districts hold quarterly meetings, although the main NPGA agenda is set by a 24-member Executive Committee. Most projects are referred to and handled in the following committees: Education, Marketing, and Research and Development. Several interviewees stressed that the propane industry is comprised of many small companies, with few large players controlling the bulk of the propane market. As a result, members are accustomed to cooperating to advance common goals. This dynamic should be an advantage in proposing solutions regarding the 20-pound tank problem. Proposals should be first introduced at the state director level and then taken to a regional level if applicable. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 25 The Propane Education And Research Council (PERC) PERC works in conjunction with the NPGA. However, it is more narrowly focused on promotion and education. This organization was formed in 1996 after passage of the Propane Education and Research Act, and is funded by an assessment levied on each gallon of odorized propane (currently at 4/10 of one cent, although it can be increased to 5/10 of a cent). PERC anticipated that this assessment would provide them with an operating budget of $31 million in 2002. The Propane Education and Research Act also determines the distribution of funds within the Council. For example, not less than 5% of the money is designated for agricultural research. Other areas include safety and efficiency. PERC is governed by a board of 21 members representing retail marketers, producers, and the public in determined proportions. The board is not compensated for its services, although it meets to review proposals and designate projects. Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 26 PROPANE TANK LIFE CYCLE Tank Manufacturers Gas Equipment Distributors Equipment Manufacturers (e.g. grills, trailers) sale Big Box Retail Tank Exchanges /Brokers Sale, refill, exchange exchange Propane retail/ dispenser operators Consumers Sale, refill Waste haulers Landfills /WTE plants Product Stewardship Institute Propane Tank Product Stewardship Project July 15, 2003 Municipal Collection Facilities Scrap dealers 27