Official Department Communication from March 26, 2020 - 12:15 pm

The Materials Management Division (MMD) of EGLE is aware that sites may be experiencing an impact due to reduced workforce, which may make it difficult to maintain normal operations. We are encouraging waste and materials management businesses to proactively plan for the possibility that normal waste and materials management practices may be interrupted.

All regulated businesses are encouraged to take actions necessary to ensure compliance with environmental regulations and requirements to protect public health, safety, and the environment. Sites that collect, store, handle, process, recycle, or dispose of solid waste, E-waste, organic materials, or scrap tires need to plan and be prepared for management of these materials during the State of Emergency, to minimize the risks associated with extended storage times, excess volumes, and proper containment of the materials, to prevent contamination risks to employees and the public.

However, the in the instance that noncompliance is unavoidable directly due to impact from the COVID-19, please contact the staff listed below to talk with MMD staff about requests for potential regulatory relief. You will be asked to provide an email with specific information related to request(s) including:

• Facility name, address, and contact information.
• A concise statement supporting any request for regulatory relief.
• A description of the regulatory relief that is being requested (i.e., collection/storage practices, treatment modifications, increased storage time, etc.).
• The business must maintain records adequate to document activities related to the regulatory relief, including details of the business's best efforts to comply with the existing requirements.

Additional information, such as photo documentation, may also be requested.

Decisions on specific alternatives will be made as the response evolves, to maintain effective and efficient use of infrastructure to move material and protect public health.

Personal protective equipment and practices to prevent COVID-19 transmission should continue to be employed. Workers should:

• Use personal protective equipment.
• Maintain social distancing.
• Regularly wash hands and disinfect surfaces and equipment.

If you have any questions or need to request regulatory relief, please contact:

Solid Waste: Ms. Rhonda Oyer, Manager, Solid Waste Section (SWS), MMD, at 517-897-1395 or oyerr@michigan.gov; Ms. Margie Ring, Statewide Solid Waste Engineering Specialist, SWS, MMD, EGLE, at 517-290-6125 or ringm@michigan.gov; or Mr. Jim Arduin, Statewide Solid Waste Geological Specialist, SWS, MMD, EGLE, at 517-614-7434 or arduinj@michigan.gov.

Recycling: Mr. Matthew Flechter, Recycling Market Development Specialist, Sustainability Section, MMD, EGLE, at 517-614-7353 or flechterm@michigan.gov; or Mr. Robert Jackson, Assistant Division Director, MMD, EGLE, at 517-930-6163 or jacksonr20@michigan.gov

Organic Materials Composting: Mr. Aaron Hiday, Compost Program Coordinator, Sustainable Materials Management Unit (SMMU), SWS, MMD, EGLE, at 517-282-7546 or hidaya@michigan.gov; or Mr. Duane Roskoskey, Waste Characterization Specialist, SWS, MMD, EGLE, at 517-582-3445 or roskoskeyd@michigan.gov

Electronic Waste: Mr. Steve Noble, Electronics Program Coordinator, SWS, MMD, EGLE, at 517-449-6153 or nobles4@michigan.gov; or Mr. Jeff Spencer, Supervisor, SMMU, SWS, MMD, EGLE, at 517-281-4411 or spencerj3@michigan.gov

For additional information regarding COVID-19 and the Emergency Order, please see:

• Governor Whitmer's "Stay Home, Stay Safe" Executive Order 2020-21,
• The federal Cybersecurity and Infrastructure Security Agency (CISA) guidance on identification of critical infrastructure workers,
• The Governor's Frequently Asked Questions that accompany EO 2020-21, and
• michigan.gov/coronavirus.

Official MRC Communication from March 25, 2020 - 4:45 pm

For many states on the leading edge of COVID-19 response, recycling and organics management service providers have asked the question and gotten affirmation that these services are indeed essential. Affirmations are generally based on the "Public Works" section of the U.S. Department of Homeland Security's CISA Guidance on Essential Critical Workforce. It is clear that removing materials from the curb is important to public health and safety. And, that recyclables are important feedstock for manufacturers, especially those producing toilet paper and packaging for the medical supplies and cleaning products that are in such high demand at the moment.

Assuring the safety of workers is of utmost importance at this time. OSHA provides longstanding guidelines for the protection of Solid Waste and Wastewater Management Workers and Employers which should apply across the board. It is important that these protections be in place. What's less clear are the implications of managing a potentially impacted and diminished work force on the provision of curbside and drop-off services. The demands of home life are taking precedence for many of us. Employees are managing kids at home and as COVID-19 sweeps through the country, we are or will be caring for ourselves and loved ones - as it should be. Now, we must explore contingency plans.

Of course, we encourage you to share as much information about your program and temporary changes to services as possible with your customers and residents. However, in those communications, please take the time to reaffirm for your audience the value of recycling organic and inorganic materials as critical components of lessening our collective demand for natural resources. Putting the materials already circulating in our economy back into productive use, for the benefit of the economy and environment is essential to reducing the impact of waste, and yes, mitigating climate change.

Most importantly, if services are temporarily disrupted,m ask your clients and residents to hold on to their recovered materials until services resume. This includes bottles and cans covered under the Bottle Bill. These materials and your programs are part of a larger supply chain that provide feedstock for a significant number of businesses and organizations, large and small, across the state, and their livelihoods depend on it. 

For those of you who are leading businesses and organizations that depend upon and manage recovered materials, the Small Business Association has some good resources as you go about creating contingency plans of your own. The Michigan Economic Development Corporation is making loans of $50,000 or more, capped at $200,000, for organizations with fewer than 100 employees that can demonstrate income loss and are unable to access credit through alternative sources. The State of Michigan is making grants of up to $10,000 available for organizations with 50 or fewer employees with demonstrated income loss as a result of the COVID-19 outbreak. The City of Detroit is providing $5,000 grants for small businesses in the city with fewer than 10 employees who can demonstrate hardship due to COVID-19.

These are certainly extraordinary times. As we go about adjusting to life under "stay at home" orders, we are finding that policies and practices haven't necessarily kept up with the times. However, we are more interconnected and dependent upon public services than ever. We are doing the best we can and can help others do their best, too.