What’s Changing For Cos. In New Calif. Hazardous Waste Plan – Frost Brown Todd

Report on California’s 2025 Hazardous Waste Management Plan and Alignment with Sustainable Development Goals

Introduction

California’s Department of Toxic Substances Control (DTSC) has advanced its 2025 hazardous waste management plan for final approval. This strategic document establishes a triennial framework for the state’s hazardous waste management, directly contributing to the achievement of several United Nations Sustainable Development Goals (SDGs). The plan outlines priorities for permitting, rulemaking, and investment, focusing on four key areas designed to promote environmental sustainability, public health, and social equity.

Overarching Goals and Contribution to Global Sustainability

The plan establishes a high-level road map guided by three overarching goals. Each goal is intrinsically linked to the 2030 Agenda for Sustainable Development, particularly focusing on responsible production, health, and sustainable communities.

• Goal 1: Waste Reduction and Diversion: To reduce the generation of hazardous waste and divert materials from land disposal and incineration. This directly supports SDG 12 (Responsible Consumption and Production) by promoting source reduction, recycling, and the principles of a circular economy.
• Goal 2: Health and Environmental Protection: To ensure that waste identification and management standards are scientifically sound and protective of human health and the environment. This objective is critical for SDG 3 (Good Health and Well-being) and SDG 6 (Clean Water and Sanitation) by minimizing the release of hazardous substances.
• Goal 3: Sustainable Lifecycle Management: To utilize data and resources to support the sustainable cradle-to-grave management of hazardous materials. This aligns with SDG 11 (Sustainable Cities and Communities) by ensuring waste is managed in an environmentally sound manner.

Core Planning Focus Areas: A Framework for SDG Implementation

The 2025 plan operationalizes its goals through four distinct workstreams, each designed to produce measurable outcomes that advance specific SDGs.

Environmental Justice and SDG 10 (Reduced Inequalities)

The plan places significant emphasis on environmental justice, a cornerstone of SDG 10 (Reduced Inequalities) and SDG 16 (Peace, Justice and Strong Institutions). It mandates that permit applications and corrective action decisions include receptor-level evidence to protect vulnerable communities.

1. Evidentiary Requirements: Applicants must document routing decisions, technology selections, and mitigation measures to demonstrate reduced localized impacts.
2. Data-Driven Screening: The plan identifies CalEnviroScreen as the standard tool for assessing community-level environmental, health, and socioeconomic stressors, ensuring that decisions are aligned with the needs of overburdened populations.
3. Enforceable Protections: This approach allows the DTSC to impose enforceable permit conditions that enhance health protections and improve data for managing cumulative impacts.

Waste and Disposal Reduction and SDG 12 (Responsible Consumption and Production)

This workstream directly targets SDG 12.4 and SDG 12.5, which call for the environmentally sound management of chemicals and wastes and the substantial reduction of waste generation.

• Source Reduction Modernization: The plan proposes updating source reduction programs and targeting waste streams destined for incineration.
• Scaling Up Recycling: Emphasis is placed on expanding legitimate recycling to reduce landfill and incineration volumes.
• Accountability and Measurement: Standardized reporting and verification of diversion outcomes will be required to turn waste reduction claims into accountable performance metrics, ensuring measurable progress toward SDG 12.

Waste Criteria and SDG 3 (Good Health and Well-being)

To better protect public health and the environment, the plan initiates a methodical review of waste identification criteria, aligning with the objectives of SDG 3.

1. Scientific Alignment: The review will cover methods for ignitability, corrosivity, reactivity, and toxicity to ensure classification decisions are based on current science.
2. Improved Transparency: Clearer criteria are expected to reduce misclassification disputes, improve treatment decisions, and limit unnecessary handling that increases risk without environmental benefit.
3. Phased Implementation: The DTSC will phase in its review, starting with ignitability, corrosivity, and reactivity, followed by toxicity assessments.

Capacity Planning and SDG 11 (Sustainable Cities and Communities)

This focus area addresses the need for sustainable infrastructure and services, a key component of SDG 11. The plan evaluates statewide needs to promote safer, more innovative treatment technologies and reduce reliance on out-of-state facilities.

• Infrastructure Assessment: The plan assesses capacity across the waste management hierarchy to identify gaps and opportunities.
• Promoting In-State Solutions: The goal is to reduce haul distances and support in-state options that aid diversion and recovery, thereby lessening the carbon footprint of waste transport.
• Community-Centric Design: New infrastructure projects will be prioritized based on their ability to demonstrate measurable community protections and public health benefits, linking capacity development directly to sustainable and equitable outcomes.

Strategic Implications for Regulated Businesses

To align with the plan’s objectives and contribute to California’s sustainability goals, regulated businesses should proactively adopt strategies that reflect the four core workstreams.

Recommended Actions

1. Develop an Environmental Justice Record: Map facilities and haul routes to identify and mitigate localized risks in overburdened communities, demonstrating a commitment to SDG 10.
2. Document Waste Reduction Efforts: Implement and document source reduction programs and diversion outcomes to provide verifiable data in support of SDG 12.
3. Audit Waste Identification Protocols: Review and update waste classification procedures in anticipation of revised criteria to ensure compliance and protect public health (SDG 3).
4. Align with Capacity Planning: Businesses involved in waste treatment or recovery should align projects with the state’s capacity needs and the plan’s emphasis on community protection and public health (SDG 11).

Conclusion

The 2025 Hazardous Waste Management Plan represents a significant step toward integrating the principles of the UN Sustainable Development Goals into California’s regulatory framework. By focusing on environmental justice, waste reduction, scientific integrity, and sustainable infrastructure, the plan provides a clear road map for achieving a more equitable, healthy, and environmentally responsible waste management system. Businesses that align their operations with these four strategic pillars will be better positioned for regulatory success and will play a crucial role in advancing a sustainable future for the state.

Analysis of SDGs in California’s Hazardous Waste Management Plan

1. Which SDGs are addressed or connected to the issues highlighted in the article?

1. SDG 3: Good Health and Well-being
   • The article directly addresses public health by focusing on a plan to manage hazardous waste. One of the plan’s overarching goals is to “ensure that identification and management standards are scientifically sound and protective of human health.” It also aims to link infrastructure capacity to “public health outcomes” and reduce “localized risks” in communities.
2. SDG 9: Industry, Innovation, and Infrastructure
   • The plan’s focus on “capacity planning” is central to this goal. The article discusses evaluating statewide needs, promoting “safer, more innovative treatment technologies,” and developing “well-sited infrastructure” to manage hazardous waste within the state, thereby reducing dependence on out-of-state facilities.
3. SDG 10: Reduced Inequalities
   • The theme of “environmental justice” is a primary focus area of the plan. The article highlights the use of tools like CalEnviroScreen to identify and protect “overburdened communities” from disproportionate environmental impacts. The plan requires applicants to provide evidence on how their actions “reduce localized impacts” and address “community-level stressors,” directly tackling inequality in environmental risk exposure.
4. SDG 11: Sustainable Cities and Communities
   • The article discusses managing waste to protect communities, which is a key aspect of sustainable urban living. The plan aims to reduce the adverse environmental impact on communities by managing hazardous waste effectively, reducing haul distances, and ensuring permit decisions consider “community protections” and localized impacts near generation sites and along transport routes.
5. SDG 12: Responsible Consumption and Production
   • This is the most prominent SDG in the article. The entire plan is centered on the sustainable management of hazardous waste. Key goals include to “reduce generation and divert material from land disposal and incineration,” modernize “source reduction programs,” scale up “legitimate recycling,” and support “sustainable cradle-to-grave management.”
6. SDG 16: Peace, Justice, and Strong Institutions
   • The article describes a process of developing an effective and transparent institutional framework for waste management. The plan was developed through “10 public workshops and four Board of Environmental Safety hearings,” emphasizing community engagement and participatory decision-making. It aims to establish “clearer, more transparent criteria” for waste classification and use “enforceable conditions” to ensure compliance, reflecting the development of accountable institutions.

2. What specific targets under those SDGs can be identified based on the article’s content?

1. Under SDG 3 (Good Health and Well-being):
   • Target 3.9: By 2030, substantially reduce the number of deaths and illnesses from hazardous chemicals and air, water and soil pollution and contamination. The plan’s core mission to ensure waste management standards are “protective of human health” and to reduce risks in “affected communities” directly aligns with this target.
2. Under SDG 9 (Industry, Innovation, and Infrastructure):
   • Target 9.4: By 2030, upgrade infrastructure and retrofit industries to make them sustainable, with increased resource-use efficiency and greater adoption of clean and environmentally sound technologies and industrial processes. The plan’s goal to promote “safer, more innovative treatment technologies” and build “well-sited infrastructure” for in-state waste management supports this target.
3. Under SDG 10 (Reduced Inequalities):
   • Target 10.2: By 2030, empower and promote the social, economic and political inclusion of all, irrespective of age, sex, disability, race, ethnicity, origin, religion or economic or other status. The “environmental justice” focus, which uses CalEnviroScreen to identify and protect overburdened communities and ensures permit conditions align with “community-level stressors,” is a direct application of this principle to environmental policy.
4. Under SDG 11 (Sustainable Cities and Communities):
   • Target 11.6: By 2030, reduce the adverse per capita environmental impact of cities, including by paying special attention to air quality and municipal and other waste management. The plan’s emphasis on reducing waste generation, improving local management capacity to “reduce haul distances,” and mitigating “localized impacts near generation sites and along haul routes” contributes directly to this target.
5. Under SDG 12 (Responsible Consumption and Production):
   • Target 12.4: By 2020, achieve the environmentally sound management of chemicals and all wastes throughout their life cycle… and significantly reduce their release to air, water and soil to minimize their adverse impacts on human health and the environment. The plan’s goal of “sustainable cradle-to-grave management” and its methodical review of waste criteria to ensure proper classification and treatment are central to this target.
   • Target 12.5: By 2030, substantially reduce waste generation through prevention, reduction, recycling and reuse. This is a primary goal of the plan, which explicitly aims to “reduce generation and divert material from land disposal,” modernize “source reduction programs,” and scale up “legitimate recycling.”
6. Under SDG 16 (Peace, Justice, and Strong Institutions):
   • Target 16.6: Develop effective, accountable and transparent institutions at all levels. The plan’s creation of “clearer, more transparent criteria” for waste identification and its use of “public performance measures” to track goals are efforts to build a more accountable and transparent system.
   • Target 16.7: Ensure responsive, inclusive, participatory and representative decision-making at all levels. The development process, involving “10 public workshops and four Board of Environmental Safety hearings” to “deepen community engagement,” exemplifies this target.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

1. For Waste Reduction and Management (Targets 12.4, 12.5):
   • Volume of waste generated and disposed: The article mentions tracking the “volume sent to landfills or burners” as a key metric.
   • Diversion and recycling rates: The plan calls for “standardized reporting and verification of diversion outcomes” to turn reduction claims into “accountable performance metrics.”
   • Manifest and routing data: The article states that standardized reporting will “reconcile manifest data with routing and receiving-facility information, including shipment distances,” which can be used as indicators of management efficiency.
2. For Environmental Justice and Health (Targets 3.9, 10.2, 11.6):
   • CalEnviroScreen scores: The plan identifies this tool as the “standard tool for screening” community vulnerability. The percentile rankings assigned to census tracts based on “environmental, health, and socioeconomic indicators” serve as a direct indicator for focusing protective actions.
   • Receptor-level evidence: The plan requires permit applications to include this evidence, making health impacts more “concrete and comparable” and allowing for the verification of results from mitigation measures.
   • Measurable community protections: The plan aims to tie infrastructure projects to “measurable public health benefits,” implying the development of specific health and safety indicators at the community level.
3. For Infrastructure and Capacity (Target 9.4):
   • In-state vs. out-of-state waste management: The article notes that “roughly half [of hazardous waste] is managed out of state.” A reduction in this percentage would be a key indicator of increased in-state capacity.
   • Haul distances: A stated goal is to “reduce haul distances,” which can be measured and tracked as an indicator of logistical efficiency and reduced environmental impact from transportation.
4. For Institutional Accountability (Targets 16.6, 16.7):
   • Public performance measures: The article explicitly states that the DTSC “intends to track these goals through public performance measures,” which could include metrics on permit processing times, backlog reduction, and public dashboard data.
   • Number of public engagement activities: The mention of “10 public workshops” and multiple board hearings serves as an indicator of participatory governance.

4. Table of SDGs, Targets, and Indicators

Source: frostbrowntodd.com