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Contamination Reduction Education Plan

New rules

Expanded education and promotion is one of 13 program elements local governments can choose to implement. Cities and counties of a certain size are responsible for implementing a range of program elements within their city or county's urban growth boundary or metro service district. The number of program elements varies by size and distance from population centers and is described under Oregon Department of Environmental Quality Administrative Rule 340-090-040

Local governments electing to implement this element will be required under new state rules to determine the level of contamination in recycling set out for collection and take action to reduce it. The new rule requires local governments to develop and implement a contamination reduction education plan (CREP) under 340-090-0041, with the authority of ORS Chapter 459A. 

This new rule is meant to be an education requirement to reduce recycling contamination and not to track contaminants or report them. 

Programs can be focused on reducing contamination in recycling set out by single-family, multifamily, commercial, public recycling depot customers or a combination of audiences. Local governments should choose at least one type of generator for focus of their plan. Local governments may want to do an initial assessment to determine which type of generator has the largest volume of contaminants when determining the focus audience. Sample implementation plans below are developed with single-family recycling collection service customers as the focus audience.

​​Local governments electing to implement this program element must submit a program plan for DEQ approval following details laid out in DEQ rule 340-090-0041. Local governments can use this optional fillable Recycling Contamination Reduction Education Plan Form to submit their program plans or use an alternate format. Local governments, garbage and recycling collection companies and materials recovery facilities are encouraged to work together to develop a plan to assess and reduce contamination before submitting this plan to DEQ including discussing problem contaminants, impact on the collection system, costs associated and potential impacts on rate-payers. Regional DEQ staff are available to help local governments develop plans. Sample Implementation Plans (SIPs) are provided below as guidance for how to fill out contamination reduction education plans. The plans cover a variety of potential methods as well as attached example materials.

  • 2017 — local governments work with stakeholders and regional DEQ staff to develop, submit and get a plan approved
  • Jan. 1, 2018 — local governments and stakeholders begin taking steps to implement plans 
  • Feb. 28, 2019 — counties, on behalf of the cities and the wasteshed, will submit a copy of the plan, that was initially approved, with the Opportunity to Recycle Reports including summary and documentation of expanded education and promotion activities to regional DEQ staff 

​​Local governments will need to choose a method to determine contamination in recycling set out for collection. Contamination refers to anything the local government’s recycling program does not accept through collection service. Having information about at least the top three contaminants is helpful to develop education materials. It is recommended that assessment is conducted at least every five years or when the program changes such as when new recycling materials are added to the stream.
Assessment options include but are not limited to:
  1. Surveying transfer station or material recovery facility operators for their observed contaminants
  2. Using results of a recycling composition and contamination study of a program that collects the same materials for recycling — no more than five years old
  3. Spotting contamination using onboard recycling truck cameras and inspecting at least 15 percent of customers’ receptacles each year within the local government’s jurisdiction
  4. Inspecting for contamination at the top of at least 15 percent of customers’ receptacles each year within the local government’s jurisdiction

Once contaminants are determined, local governments will need to take steps each year to reduce contamination, including educating residents about how to properly recycle or dispose of contaminants. Education should include how to properly manage the top contaminants. For local governments who don’t have recycling collection, they can choose to implement a program at recycling depots required by ORS 459A.

Contamination reduction education methods include but are not limited to:

  1. Sharing community-wide messaging using at least two channels that reach a majority of the audience such as newsletters, media articles, postcard mailers, social media or tabling at community events
  2. Contacting customers with contaminated recycling through a direct mailer or invoice
  3. Marking contaminated recycling with tags or hangers
  4. Informing recycling depot customers about contamination and improving signage

Cities and counties are required to report about activities implemented for the contamination reduction education plan along with expanded education and promotion activities. This is reported as part of the Opportunity to Recycle Report submitted by the county wasteshed representative. Regional DEQ staff typically ask for a summary of activities within the county and city as well as documentation each year by Nov. 1. Regional DEQ staff send reporting forms after that date. Reports are due to DEQ by Feb. 28 when requested. Representatives should also submit a copy of their approved Contamination Reduction Education Plan as described in DEQ rule 340-090-0041.

For more information, contact regional DEQ staff:

Cathie Rhoades, 503-378-5089

Serving: Baker, Benton, Crook, Deschutes, Gilliam, Grant, Harney, Hood River, Jefferson, Klamath, Lake, Lincoln, Linn, Malheur, Marion, Morrow, Sherman, Umatilla, Union, Wallowa, Wasco, and Yamhill counties 

Cathy Brown, 541-687-7325

Serving: Coos, Curry, Douglas, Jackson, Josephine, and Lane counties  

Lexi Meek, 503-229-5790

Serving: Clackamas, Clatsop and Multnomah counties 

Tom Lang, 503-229-5478

Serving Columbia, Multnomah, Tillamook and Washington counties