Form 303 Regulations and General Form 303 Issues
CalRecycle has revised the Form 303 regulations to streamline the reporting process. The key changes from previous years are:
- Forms 303a and 303b have been combined into a single Form 303
- If one jurisdiction reports data on behalf of another jurisdiction (e.g. a county reporting data that includes materials collected on behalf of participating cities), the other jurisdiction does not need to file a separate Form 303 unless they have collected/managed other HHW materials separately from the first jurisdiction.
- Materials sent to stewardship organizations for management must be reported on the Form 303 under the disposition section.
- Allow for the creation of the new Form 303 online report and database.
Is Form 303b a sub-report of Form 303?
We used to have to file form 303b. Is this system meant for both 303a and 303b filers?
The Forms 303a and 303b no longer exist; new regulations approved on July 22, 2013 have consolidated them into a single Form 303. Now we ask that you coordinate with any jurisdiction that may be reporting on your behalf and ensure that you report any data that they do not report on your behalf.
The 303bs had to report updates in contact information. If a city does not have any data to report (the regional data is reported by someone else), just a change in contact info, do they file a blank report, no report?
Under the new regulations, if a jurisdiction has no data to report (i.e., any HHW management data is reported by another jurisdiction on their behalf) then that jurisdiction does not have to file a report.
Will historic participants (individual cities) receive a notification to submit a 303 form if a regional program has submitted a regional 303 form in the past?
All jurisdictions that submitted Form 303a reports last year have been contacted in order to receive a WebPass to access the new Form 303 online system. In addition, all jurisdictions that submitted non-zero data on a Form 303b have been contacted for the same purpose. This means that if a jurisdiction did not report any Form 303 collection data in the past, they are not automatically on our mailing list and should contact Form303@calrecycle.ca.gov to be added to the list.
Is Form 303b calendar year or Fiscal Year?
The Form 303 is for Fiscal Year data. This year’s form covers materials collected and managed from July 1, 2012 – June 30, 2013.
Is reuse in disposition?
Yes it is.
A city in our JPA that uses our permanent HHW also has a recycle-only center so they report info so they will fill this out as well right?
Yes, one of the program type options is Recycle-Only Facility and collections at those facilities should be reported. If that city is operating the recycle-only center themselves, independently of your JPA, they may choose to report the HHW management at that site on their own separate Form 303.
Is CESQG pounds collected at a temp event entered as a separate column to the right I can’t see or does it go somewhere else?
CESQG pounds collected should be added to, and included with, other HHW in the appropriate program type column(s).
I am on the CalRecycle Annual Reporting: Household Hazardous Waste Collection Information page and many of the forms are dated for FY 11/12 – will these forms be updated prior to Aug 1 or am I on the wrong site?
CalRecycle’s Form 303 website will be updated on August 1st to include a link to the new online Form 303 system. The excel spreadsheets currently on the webpage are last year’s forms.
We regularly conduct multiple mobile collection events throughout Los Angeles County. In the past, we have submitted one report for all events and include an attachment that provides the date of the event, City name and EPA ID#. With the new system, will we need to submit a separate report for each collection event or can we continue submitting one report for all collection events?
Please enter each event or “Temporary (periodic) Facility” and associated EPA ID#. Materials collected at these events do not need to be reported on a separate Form 303; they can be reported in total in the “Temporary (periodic) Facility” column in the collection section of the Form 303.
If we have a sharps program in which we provide our residents with prepaid mail in boxes, do we need to report those numbers as well?
Sharps Compliance is a common mail-back provider that also sells pharmaceutical mail-back envelopes and provides data to jurisdictions on the total pounds collected. If your mail-back provider provides this data to you, you should report it in the Form 303 system (a new column may be added for “mailback”).
Where does the “household batteries” fall under in the form?
Household batteries would be reported under the category “other batteries”
If I have a WebPass for another CalRecycle application, will it work for this application?
Yes; however, if you are not already listed in the Form 303 system, the currently listed program manager and/or primary contact will need to add you as a contact in the Form 303 system. Once this is done, please e-mail Form303@calrecycle.ca.gov to request that CalRecycle staff link your existing WebPass access to the Form 303 system. CalRecycle staff will assign that WebPass ID the proper access authorities. Please make sure that the contact information and e-mail address you are providing for the Form 303 is the same as that you are using for your WebPass.
Who do I contact to get my WebPass the permission to access form 303 reporting? I also need a WebPass ID.
I already have a WebPass for the EAR, can you please send me an invite? I will be handling Form 303 b.
To get a WebPass and assigned permission to access the database, please e-mail Form303@calrecycle.ca.gov.
Did you say that one can only log in unless we’ve been e-mailed a WebPass? Does it mean that if not e-mailed a WebPass, one is no longer required to fill out the Form 303?
WebPass invitations were based on the previous year’s submissions, and do not necessarily indicate whether or not a jurisdiction is required to submit a Form 303. Per CCR Title 14, Section 18751.2.2(a), “Each public agency that is responsible for HHW management must complete and submit a ‘Form 303 Household Hazardous Waste Collection Report’”, unless, as stated in 18751.2.2(e), “all of that agency’s material collection amounts have been reported on another agency’s Form 303.”
Do you have to specify your “other” waste or can you leave it as “other”?
An “other” waste row does not need to be specified; you are allowed to create a row and label it as “Other”
Can we view the online form today?
Yes, you can view and print all sections of past year reports and print a blank form at any time. However, you will not be able to add data for your FY 2012/13 report until August 1, 2013.
Do you add the name of each city you collect and report for as a “participant”?
Yes, each city should be reported as a participant. You can also add unincorporated county regions as participants.
Do we need to enter old information or is it already there?
The contacts, participants, and programs sections of the form will be pre-filled out for you based on the prior year’s submittal. You simply need to update and/or verify your information prior to submitting the Form 303.
I see that we can print a blank form from this page. Can we print a blank form for the entire 303 form?
Clicking the “print blank form” button will print all fields shown in the Form 303 Collection and Disposition tabs.
As agencies add me to the secondary contact, will these automatically show up in the drop down menu and on my web pass, or do I have to request separate access?
As agencies add you as a secondary contact, CalRecycle staff will set the permissions to ensure the system has linked you with those agencies. If your agency has already added you but you do not see them in the drop down menu on your WebPass, please e-mail Form303@calrecycle.ca.gov and we will make sure you are granted the appropriate security access.
If we know we need our hauler/subs to be added, should the jurisdictions contact CalRecycle or can they?
Jurisdictions can add haulers and subcontractors directly in the contacts section of the database. CalRecycle staff will periodically scan through the contact lists and send invitations to any new additions.
So if your contractor fills out the report, he does so as a secondary contact, sends the info to the primary contact (me) for submittal?
Can the primary contact be a subcontractor?
According to the regulations, jurisdictions are the primary entity responsible for the submittal of a Form 303. As the primary contact is granted the ability to submit the forms to CalRecycle, we do not believe it is appropriate for a subcontractor to be assigned as a primary contact.
Can I enter data as a primary contact if I am not the Program Manager? Or does the PM need to be the primary as well?
The Primary Contact and Program Manager are assigned the same authorities and can both enter the same types of data.
If we need assistance with filling out the Form 303, where can we get assistance?
I currently have an LAMD for the EAR, would I direct my Form 303 b questions to the same person?
The help file/instructions for the Form 303 can be found in the “help” link in the upper right corner of the database. If you need additional assistance, questions should be directed to Form303@calrecycle.ca.gov.
What types of documents would need to be uploaded?
There are no documents that are currently required; CalRecycle has simply created a section in case a jurisdiction would like to send CalRecycle some documents to accompany a report. For example, a spreadsheet detailing costs could be uploaded as a supporting item for the cost survey.
What do you mean by “steward”?
We are referring to stewardship organizations such as PaintCare and the Thermostat Recycling Corporation (TRC).
Does the new online format include product stewardship programs such as TRC or PaintCare?
Yes. Stewardship programs are listed as another disposition method that can be added using the drop down menu in the top right of the disposition tab.
PaintCare – will they report to the State, to the jurisdiction or both?
To verify, we add the numbers for PaintCare, they will not be submitting anything?
PaintCare submits an annual report to the State on October 1st each year (the same deadline as the Form 303 deadline) but they are not required to report data by jurisdiction (additionally, their local boundaries may not correspond to government boundaries). Therefore, we ask that you either track the paint that you send to PaintCare by your bills of lading or weigh the paint beforehand, then report on that amount in the PaintCare column that you can add. If you are sending co-mingled oil and latex bins to PaintCare and do not have specific oil/latex volume breakouts, the relative oil/latex volumes may be estimated by using the proportions reported in your previous year’s Form 303.
Are jurisdictions required to separately report waste managed through a product stewardship program, such as PaintCare?
To clarify, jurisdictions do not report on any material collected at the PaintCare retail sites?
Jurisdictions are required to report any waste managed through a product stewardship program that comes through the jurisdiction’s program as well. For example, if a city’s PHHW facility acts as a collection site under PaintCare, then that city should report all paint sent to PaintCare under the disposition section on their Form 303 (they would add a column for PaintCare). However, the city is not required to report the volumes of paint that PaintCare collects at its retail sites.
Hazardous Waste Regulations
We collect e-waste at our county landfills and are also looking [at] collecting other HHW waste. Would we report this under Load Check or do we have an option for “Other”? It wouldn’t fall under a permanent, temporary or mobile HHW?
Staff recommends that you consult with DTSC’s Regulatory Assistance Office (1-800-728-6942 or RAO@dtsc.ca.gov) to determine under what program types (ABOP, etc.) the wastes are being collected.
What is the definition of a mobile program as opposed to a THHWCF?
You will always be able to access these kinds of definitions in the Help file available in a link at the top-right of the Form 303 interface. These are the two definitions:
Temporary household hazardous waste collection facility (THHWCF) means a HHW collection facility that meets both of the following conditions:
- The facility is operated not more than once for a period of not more than two days in any one month at the same location.
- Upon termination of operations, all equipment, materials, and waste are removed from the site within 144 hours.
Mobile household hazardous waste collection facility means a portable structure within which a HHW collection facility is operated and that meets all of the following conditions:
- The facility is operated not more than four times in any one calendar year at the same location.
- The facility is operated not more than three consecutive weeks within a two-month period at the same location.
- Upon the termination of operations, all equipment, materials, and waste are removed from the site within 144 hours.
Do E-Waste only events require an EPA ID #?
EPA Numbers are issued by DTSC, and detailed information on their issuance can be found on their website.
For temporary events, are we issued a new EPA number each time or is it the same?
EPA Numbers are issued by DTSC, and detailed information on their issuance can be found on their website. Each event or “Temporary (periodic) Facility” is usually issued a new EPA number.
Are we required to report on ewaste/uwaste collections from private companies that host in our jurisdiction that are not part of our program?
If the e-waste/u-waste collections are not part of your program, you are not required to report them on your Form 303.
Will there be a regulator portal for inspectors?
DTSC staff will have viewer rights to this data.
I am referring to CUPA inspectors.
CalRecycle is aware that CUPAs may annually request to see a jurisdiction’s Form 303 report, per Health and Safety Code section 25218.9. CalRecycle staff can provide CUPAs with viewer rights to the data in the Form 303 database and provide links to any public information posted on the CalRecycle website.
Do you have to take the survey to submit the 303?
No, the survey is not mandatory but strongly encouraged.
Can our hauler complete the survey too?