New materials entering waste streams has caused contamination to skyrocket in recent years. This has led to unforeseen challenges and costs for recycling facilities and, thereby, jurisdictions and taxpayers across the country.

Thanks to California's Short-Lived Climate Pollutant Reduction Strategy (SB 1383), there are now statewide requirements for residential organics recycling collection & container contamination minimization.

If your team is conducting route reviews, lid flips, and/or cart tagging to monitor contamination in your community, here are some following steps to consider:

STEP 1: Gather Your Account Data

This is the hardest part! Obtain a list of all your customer accounts by route from your jurisdiction’s database or talk to your hauler(s) or consultant to obtain them. Information every account must have:

• Full address (number, street, city, state, zip code)
• Waste stream (landfill, compost, recycle), container-types (carts, bins, or compactors) and sizes (32g, 64g, 2 cu. Yards, etc.)
• Associated route numbers and type (single-family, multi-family, and commercial customers), plus day of the week
• Any additional information such as bin colors, lids or container ids
• Prior notes 

Organizing the data in the right format using a spreadsheet or database is going to be very helpful in planning and executing the route reviews efficiently. 

STEP 2: Plan Your Routes

Time to get planning! Create designated day-of-the-week itineraries by route, generator, or customer type. 

There are no minimum container inspection requirements to satisfy the SB1383’s container minimization legislation. 

The number of accounts inspected on each route can be decided strategically or randomly, using sampling methodologies.

Sampling starts at 2% of the accounts per route, but we have seen some jurisdictions go all the way to 50%, staffing permitted.

Factors to consider include: 

• Types of generators - There are fewer commercial accounts than residential. 
• Route coverage (are the accounts concentrated or spread-out?)
• Budgetary constraints
• Field staff capacity
• Site locations
• Facility operating hours
• Route efficiencies, etc.
• Contamination Levels

Zabble recommends documenting inspection data and noting down observations at the bin-level using the following flat tabular format:

Pro Tip 1! For residential routes, picking a landfill route can help cover all the other routes containing recycling and organics containers thereby reducing the need to revisit accounts for those other routes. 

Pro Tip 2! For commercial routes, it's best to plan ahead of time by contacting the property manager and schedule visits in case the containers are locked or housed in enclosures that are inaccessible.

STEP 3: Schedule Route Reviews

Jurisdictions are expected to review every hauler route annually, but the number of inspections for each container type is not specified.

Once you have determined the number of accounts to sample in each route, it is time to schedule these routes in either:

1). short bursts if the staffing is limited and available only for a short period of time

2). spread throughout the year if there is access to a dedicated team of field auditors. 

‍Pro Tip! April - October is the best time to conduct route reviews. The additional daylight makes the reviews safer and more pleasant for field teams. 

STEP 4: Notify Customers

Informing residents and businesses ahead of time regarding the inspections is a critical step towards establishing trust with the community and ensuring transparency in the jurisdiction’s efforts.

Notifying customers in advance allows them time to process information and ask relevant questions, which in return helps the jurisdiction engage with community members. 

Zabble recommends notifying residents and businesses via typical outreach methods:

1. Individual fliers
2. Website announcement
3. Newsletter/Email marketing campaign 
4. Tabling at community events
5. Social media promotion 
6. Presentations 

STEP 5: Pre-inspection Planning 

It’s almost here!

Prior to beginning inspections, assign a route and day-of-the-week to each team of auditors (Example: Monday Landfill Residential Route 1). 

There are generally at least 2 auditors per team for safety reasons. 

Try it out by walking around a single-family neighborhood to see how long it typically takes to inspect 3 carts. 

Pro Tip 1! Make sure you have a map of the accounts on each of the routes on your phone so you can easily navigate from one neighborhood to the next.

Pro Tip 2! Notify the hauler(s) to let them know that field auditors will be out inspecting their routes 

STEP 6: Conduct Bin Inspections

It’s finally happening!

Locate the address of the account using a map on your mobile device. 

At the bin, lift the lid open to observe the disposed of material. 

Observe how full the bin is, note down any contaminants you see including any other observations. 

Do it for all the containers that are available to inspect whether they belong to that route or not. 

On the day of the inspection, don’t forget:

1. Gloves
2. City- or hauler-sponsored vests  
3. City vehicles to ride in, if possible
4. Mobile devices, for maps, data-collection and communication 
5. Battery bank to recharge the mobile device
6. Hotspot from your phone for internet connection, if using a tablet
7. Letter from the jurisdiction 
8. OOPs Tags and Good Job Tags
9. Additional outreach material such as door tags or fliers

Pro Tip! Determine if your team is going to inspect inside bagged material prior to the inspection day to avoid confusion

STEP 7: Notify & Educate the Generator of Violations 

If prohibited contamination is detected, you must notify the generator how to properly separate the material by leaving a notice on their container, gate, or door. You can also notify them by mail, email, or other electronic message. 

Notify the corresponding team member who is going to conduct further outreach with this generator. 

Pro Tip! If you are coordinating with the hauler, let dispatch know you are tagging a bin and take appropriate action to notify the hauler (in case of rejecting the container or picking it up as trash). 

STEP 8: Keep Records of Compliance + Contamination Minimization Requirements 

Required documentation of route reviews performed include:

• The name or account name of each person or entity
• A description of the hauler route and the addresses where prohibited container contaminants found
• Dates route reviews were conducted
• Person(s) conducting the reviews
• Findings regarding compliance, including educational materials
• Relevant evidence supporting the findings, including photos
• Copies of notices issued to generators

Pro Tip! Itemize all the records (in CSV or XL) needed for annual compliance reviews. For the Electronic Annual Reports (EAR), you also need the total number of routes inspected and the total number of notices of violation or targeted education materials issued to generators for prohibited container contaminants. 

Hurray!

Congratulations! By now you’ve successfully planned, prepared for, and executed your route reviews to help the state of California reach its SB 1383 goals. 

Climate legislation is only as effective as the teams that work to implement it. So thank you for doing your part! 

Reach out to us  to learn more about how Mobile Tagging™ for Jurisdictions can help you save time and resources while helping you stay compliant on contamination monitoring with SB 1383.