NON-REFILLABLE GAS CYLINDER PRODUCT STEWARDSHIP PROJECT

Transcription

1 NON-REFILLABLE GAS CYLINDER PRODUCT STEWARDSHIP PROJECT An Action Plan to Reduce Safety Risks, Environmental Impacts, and Costs Associated with Non-Refillable Gas Cylinders in the Waste Stream Prepared for Sarasota County, Florida and the Florida Department of Environmental Protection by the June 2003

2 TABLE OF CONTENTS INTRODUCTION. 3 SECTION I: Guidance for Municipal and County Cylinder Collection Programs 5 Problems 5 Evaluation for Action 5 Short Term Management Solutions... 6 Product Stewardship Opportunities... 7 SECTION II: Increasing Acceptance by Scrap Metal Recyclers. 8 Problems 8 Evaluation for Action 8 Short Term Management Solutions.. 8 Product Stewardship Opportunities.. 10 SECTION III: Increasing Consumer Education. 11 Problems. 11 Evaluation for Action. 11 Short Term Management Solutions 11 Product Stewardship Opportunities 12 SECTION IV: Additional Strategies 13 Contract language 13 Economic strategies.13 Next Steps APPENDIX A: Project Summary APPENDIX B: Non-refillable Cylinder Life Cycle Chart APPENDIX C: Management Guidance APPENDIX D: Sample Liability Language APPENDIX E: Proposed Label Language APPENDIX F: Proposed Contract Language APPENDIX G: Economic Strategies Page 2

3 INTRODUCTION The (PSI) was contracted by Sarasota County, Florida, in conjunction with the Florida Department of Environmental Protection, to investigate the proper management of non-refillable, pressurized gas cylinders. Non-refillable gas cylinders and canisters (containing anywhere from a few ounces to 2 pounds of liquid propane, propane/butane mix, helium, or other compressed gases) have been used for many years as portable sources of fuel for camping equipment, welding torches, inflation for balloons and novelties, refrigerants, and other purposes. The increasing number of singleuse gas cylinders in the waste stream presents safety and environmental concerns, and the metal containers are a wasted resource if not recovered and recycled. Handling these through special collections adds significantly to the cost of municipal solid waste management programs. Due to the limited scope and funding for this project, PSI did not enter into the contract with the purpose of negotiating full product stewardship agreements for non-refillable cylinders. Instead, PSI s approach was to bring key parties together for two meetings to jointly identify problems related to the improper disposal of non-refillable gas cylinders and to develop both short-term and long-term strategies for Sarasota County and other Florida counties. PSI believes these strategies are applicable to other communities seeking assistance in managing non-refillable gas cylinders. To build on this initial research and dialogue, PSI has identified key strategies to pursue within the context of a national product stewardship dialogue. Project Goals The three main goals of the Florida project were to: 1. Investigate ways to reduce environmental and safety risks from cylinder management (including safely evacuating and collecting remaining gas) 2. Return a recyclable product to the recycling stream 3. Lower management costs for government and other stakeholders. Supporting goals included enhancing the existing recycling infrastructure and increasing awareness of safe, economical, and environmentally responsible, end-of-life management options among consumers, municipal officials, and other stakeholders (see Appendix A: Project Summary). Manufacturer Participation In the first part of the project, PSI identified and invited five national manufacturers of non-refillable gas cylinders to participate in interviews and a dialogue with other stakeholders. 3

4 Manufacturers included: Worthington Cylinder ( Balloon Time non-refillable helium cylinders) Columbus, OH Amtrol (refrigerant cylinders) West Warwick, RI Coleman (non-refillable propane cylinders) Wichita, KS Bernzomatic (Medina, NY), which works along with Chilton (Chilton, WI) and Gerret (Menomonee Falls, WI) to produce cylinders with propane, butane, and other gas mixtures. Worthington, Bernzomatic, and Coleman provided PSI with in-depth interviews. Worthington and Bernzomatic were full participants in discussions that identified the strategies presented in this document. In addition, Worthington assumed a leadership role and indicated an interest in contributing financial and other resources towards the development of broader cylinder management solutions that would involve all cylinder manufacturers. Amtrol indicated that it would participate in discussions, but was unable to attend due to scheduling conflicts. Coleman declined to participate in the discussions, and Gerret and Chilton were unreachable after many attempts. Stakeholder Interviews Altogether, PSI conducted 43 telephone interviews with the manufacturers and other stakeholders, including state and local government agencies, cylinder recycling/disposal services, and educational organizations. Through the interviews, PSI identified a broad range of issues and general solutions targeting various points in the cylinder life cycle (see Appendix B: Non-refillable Cylinder Life Cycle Chart). During the interviews, PSI introduced stakeholders to product stewardship principles and started to explore potential solutions such as manufacturer take-back and the need to develop a financing system that internalized the end-of-life management costs in the product purchase price. Stakeholder Meetings Following the interviews, PSI convened and facilitated two stakeholder meetings. During the first meeting (May 2003), participants further developed the key issues, suggested potential cylinder management strategies, and identified criteria to prioritize those strategies. PSI used the criteria developed at the first meeting, as well as follow up calls to participants, to produce an agenda for the second meeting (June 2003). At that meeting, participants agreed to act on three priority strategies: Providing effective cylinder collection and handling guidance for municipal and county cylinder collection programs. Increasing acceptance of cylinders by scrap metal recyclers by reducing or eliminating obstacles (e.g., safety concerns, needed equipment). Increasing consumer education on proper handling and management of cylinders. 4

5 Also identified were two other areas for action: Developing sample language to include in municipal waste management contracts for cylinder management, and Researching economic incentives and sustainable financing options as an effective means to reduce the number of cylinders in the waste stream. Owing to the short timeline for the project, participants preferred to focus on short-term strategies, while keeping open the option to work at a future time on longer-term strategies, many of which related more closely to product stewardship concepts. PSI found that, in order to have a more in-depth discussion of product stewardship, more time will be needed to educate participants on product stewardship principles, product stewardship examples in the United States and other countries, and how product stewardship could be applied to gas cylinders. Agreements Reached The following stakeholder agreements and outcomes were reached as a result of the two meetings. Each of these agreements is discussed in more detail under the section in which they pertain. Local Management Hierarchy: Participants reached consensus on a management plan to assist local governments collecting, or interested in collecting, cylinders. Demonstrating Safe Cylinder Management: The Institute of Scrap Recycling Industries (ISRI) offered to produce a video demonstrating the safe processing of cylinders. Several participants agreed to be demonstration sites. Product Label Changes: Manufacturers agreed to bring back to their management label language developed by the group that directed consumers to their local solid waste authorities, as well as the Earth 911 website and toll-free hotline, for proper recycling locations. Single Educational Source: Participants agreed on the need to develop additional cylinder collection options for inclusion on the national Earth 911 website and hotline. Continued Dialogue: Stakeholders agreed to continue meeting and attempt to gain the participation of all those who are needed to develop a comprehensive solution. Challenge Grant: The Florida Department of Environmental Protection offered a $50,000 challenge grant to its county governments for continued work on this project. This report is organized around the key strategies, with each section listing the problems, ways to evaluate whether to take action, and strategies for alleviating problems with nonrefillable cylinders. These strategies primarily highlight the potential benefits from developing local partnerships among government, recyclers, and other businesses, and feature case studies of successful programs. Listed at the end of each section are product stewardship opportunities that have been identified as a basis for future discussions involving broader stakeholder representation over a longer time period. PSI intends to pursue these more sustainable solutions through future national dialogue and action. 5

6 SECTION I: GUIDANCE FOR MUNICIPAL AND COUNTY COLLECTION PROGRAMS PROBLEMS PSI interviews with stakeholders revealed that most local governments do not have programs to collect and recycle non-refillable gas cylinders. The primary reasons were identified as: (1) The additional cost to local governments to develop and maintain a special collection program. Sarasota County, Florida does not currently advertise that it collects non-refillable cylinders, but they remove and handle cylinders received at its household hazardous waste collection program. County officials determine which cylinders contain residual gas and ship those to a facility in New York, where gas is extracted and the cylinders are prepared for scrap. This service costs the County $0.75 per cylinder, in addition to transportation costs of $150 per drum of cylinders. County workers landfill cylinders without gas at a low cost to the County. (2) The perception that there are only a small number of cylinders in the waste stream and that non-refillable cylinders do not pose a significant safety risk. It is difficult to spot small cylinders in the waste stream, which makes it hard to estimate the quantity passing through. While non-refillable cylinders can pose less of a risk during collection and disposal than larger tanks (depending on the gas content of the cylinder) they still pose a risk to those responsible for their end-of-life management. (3) The lack of understanding about safe management options for cylinders. Municipal and county programs are often concerned about worker safety in handling cylinders. Without training, it can be difficult to identify the gas content of cylinders and whether residual gas is dangerous. There are inconsistent and undocumented mechanical processes on how to prepare cylinders for recycling. (4) The lack, or vagueness, of regulatory guidance on how to manage cylinders. Nonrefillable cylinders are exempt from many kinds of hazardous waste regulations as well as National Fire Protection Association codes and standards for 4-40-pound gas tanks. State regulatory agencies often do not provide preferred management strategies for cylinders and residual gas. Without clear direction, municipalities and counties often decide to avoid the liability by not collecting cylinders at all. 6

7 EVALUATION FOR ACTION In order to determine whether your municipality or county should implement a collection and handling program for non-refillable gas cylinders, decision-makers should consider a number of questions: SAFETY: Have there been incidents with pressurized gas cylinders at the landfill, waste-to-energy plant, scrap metal processing facility, in trash compacting trucks, or elsewhere? Is garbage handled in a way that may increase the likelihood of explosions (e.g., shredding, multiple compaction)? Do you want to recycle the cylinders but are concerned about the liability of collecting and are unclear how to safely remove gas from the cylinders? What is the historic gas content of the majority of the collected tanks, and what additional safety precautions may be necessary if the gas is flammable or explosive? ECONOMICS: Is cylinder management economically feasible? VOLUME: Are a significant number of cylinders generated in your jurisdiction? CONTEXT: Do neighboring areas handle non-refillable gas cylinders? If a program exists nearby, you may be able to take advantage of existing facilities and contracts. If no program exists in neighboring counties, an opportunity may exist for the establishment of a regional gas cylinder recycling program. If the answer to all, or most, of the above questions is yes, there is a good likelihood that a non-refillable cylinder collection and handling program could be supported in your area. SHORT-TERM MANAGEMENT SOLUTIONS After identifying the main obstacles facing municipal and county cylinder collection programs, stakeholders agreed to act on the following short-term management solutions: Work with PSI to develop and finalize a guidance document listing existing management options (see Appendix C: Management Guidance). Distribute management information, as appropriate, through available information networks. For Sarasota County and other communities wishing to immediately move forward with a cylinder collection program, PSI and stakeholders have identified the following strategies derived from the Management Guidance document to further reduce program costs: Hire Expertise: Consider a contractual agreement with a business with the capability to safely collect and process cylinders. Cylinders need to be vacated of any remaining gas, and then are often punched or cut to indicate that they are empty. Cylinder management could be written into solid waste services contracts, or partnerships could be established with businesses that collect and refurbish 20-pound tanks. These businesses usually have 7

8 equipment that can safely handle small cylinders as well as the larger ones. By writing a vendor bid specification that requests collection and processing services for the desirable 20-pound propane tanks along with the less desirable non-refillable cylinders, you will increase your chances of receiving cost-effective contractor bids. Your bids could be even more competitive if white goods and other scrap metal were rolled into the contract as well. Reduce the Number of Cylinders Containing Gas: Municipal costs and safety concerns are reduced when cylinders contain no residual gas. Standards and measurements for empty cylinders vary, but can include weighing the cylinder, checking to see if it supports a flame, or filling the cylinder with water to expel any remaining content. The least costly way to remove gas is by implementing a reuse or donation program for partially filled cylinders. A reuse program will not reduce the number of cylinders managed through the program, but it will minimize the need for evacuating and capturing cylinder contents. PSI recommends that those thinking to implement a reuse program should consider the following steps: o Determine existing collection options, such as local household hazardous waste centers, recycling programs, or businesses that might collect cylinders. o Evaluate what types of residual gas are likely to be collected. Contact the heads of local agencies and non-profit organizations that might have use for these gases. o Identify any state or local regulations or restrictions that might prohibit the municipality or county from setting up a reuse program for cylinders. o Investigate liability concerns and develop language to accompany your program, where appropriate (see Appendix D). Different types of liability protection may be needed for different types of gases. Case Study - Metro Regional Government of Portland, Oregon, has a successful reuse program for cylinders containing gas. Partially filled cylinders are collected and then transferred in bulk to government agencies (e.g., highway departments), nonprofit groups (e.g., those with camping or craft programs), or others that have use for the gas. When nonprofit groups accept gas cylinders from a government entity, they are required to sign a liability waiver (see Appendix D: Sample Liability Language) Expand Market Through Partnerships: Recyclers need a consistent supply of cylinders to invest in needed equipment and training. If your municipality or county cannot provide sufficient supply to interest a contractor, you may be able to coordinate with other communities to provide a sizable and consistent regional market. Consider consolidating cylinders at a single point, or combining them through a scheduled "milk-run" collection system. The following steps may assist in coordination efforts: o Contact neighboring municipalities to determine their interest and estimate how many cylinders they might provide. 8

9 o Contact tank refurbishers and scrap metal processors to determine the quantities and specifications for accepting cylinders. o Determine how cylinders will be consolidated. Can a contractor retrieve cylinders from partnering municipalities through a milk-run collection? What is the frequency of pick-up? Does the contractor meet all state and local transportation and storage requirements? Case Study - The Vermont Department of Forests, Parks & Recreation (DFP) collects nonrefillable cylinders at special stations in its campground recycling areas. Cylinders are collected and stored at each park until the end of the season, and consolidated in the fall. They are then picked up by a tank refurbishing company and processed to make them acceptable as scrap metal. Annual costs are approximately $400 (at $1 per cylinder), and are covered by the DFP or passed on to the local solid waste entity. PRODUCT STEWARDSHIP OPPORTUNITIES While the short-term strategies above can benefit communities with the resources to develop a non-refillable cylinder reuse or recycling program, many more communities will be unable to manage cylinders along with the growing number of special wastes. Future product stewardship discussions would seek to share responsibility and costs for managing non-refillable cylinders among manufacturers, retailers, recyclers, the waste management industry, and government. Product stewardship principles stress flexible management strategies with goal-oriented results. Appendix G provides examples of sustainable financing models. SECTION II: INCREASING ACCEPTANCE BY SCRAP METAL RECYCLERS PROBLEMS Many scrap metal recycling operations either do not accept pressurized gas cylinders or have very strict acceptance criteria. These criteria depend on the equipment they use, the requirements of the steel mills they supply, and their prior experience with a product. By increasing the willingness of recyclers to accept cylinders, the value of the used cylinder will increase, which will help to offset the cost of collection. Thus, a key strategy is to make recyclers more comfortable with safe handling procedures for used cylinders. Cylinders are seen as problematic for many reasons, including: 1) Potential for explosion or fire from residual gases. When cylinders containing flammable gas are punctured or sheared, the air/gas mixture can ignite easily and endanger workers and equipment. 9

10 2) Difficulty in ascertaining previous gas content and emptiness of the cylinder. Non-refillable cylinders are not always durably marked with their original gas content. Tests or processes to guarantee that the cylinder is empty (such as by flaring or weighing) can be time-consuming, expensive, and inexact. 3) High cost of processing compared to the low cost of the processed metal. New cylinders are often sold for less than $2.00 retail, while the cost to process them for recycling appears to average about twice that amount. If a recycler can plan on processing a large volume of cylinders, they can achieve some economies of scale. However, equipment to punch or shear cylinders is often not worth the cost to a recycler if they are not supplied with a consistent or significant number of cylinders. EVALUATION FOR ACTION SAFETY: Is there an interest in training staff to safely handle pressurized gas cylinders at local scrap metal processing and recycling facilities? Is there a way to assure scrap metal processors that the cylinders are empty/safe? ECONOMICS: Can economies of scale be achieved in your area through collecting large numbers of cylinders? Are there grants available to help purchase the shearing equipment? CONTEXT: Is there a potential for local partnerships (e.g., collection, preprocessing, recycling) that would enhance the recyclability of cylinders? SHORT TERM MANAGEMENT SOLUTIONS Scrap metal recyclers indicated in the June meeting that they would be interested in helping to manage the problem cooperatively. During the two stakeholder meetings, participants came to the following agreements: The Institute of Scrap Recycling Industries (ISRI) offered its production facilities and expertise to develop a training video demonstrating that cylinders can be safely processed for recycling. This training would be designed to increase scrap recyclers understanding and familiarity with cylinders and ways they can be safely managed. Bernzomatic (a manufacturer) and Seminole County, Florida, indicated a willingness to provide demonstration sites for the video. Trademark Recycling expressed an interest in partnering with local government and other businesses to acquire or develop appropriate machinery and a system to manage cylinders. Participants agreed that management solutions for non-refillable cylinders should be combined with solutions for 20-pound propane tank management, where appropriate. These agreements support shorter-term actions that PSI has identified to enhance the recyclability of gas cylinders. 10

11 Determine Criteria for Acceptance: Most scrap recyclers do not want to extract gas from cylinders since they do not have the expertise and doing so may require additional permits. Although recyclers usually prefer that the cylinders be crushed for them to accept them, they may accept other assurances such as: o A written confirmation/guarantee by the municipality or county that the cylinders are empty of gas; and o Marking tanks to highlight a visible hole (e.g., painting around a hole left by a puncture or valve stem removal). Develop Cooperative Management Strategies: Through a cooperative agreement, another entity could prepare the cylinders for recycling by eliminating any remaining gas, and either removing the valve with a non-sparking tool or creating a hole in the cylinder. Refurbishers of 20-pound propane tanks are most likely to have existing capabilities to shred, crush, or punch the cylinders. These businesses should be involved as much as possible in the management of non-refillable containers as well. PSI suggests the following steps when pursuing a cooperative agreement for cylinders: o Contact other local or regional governments, propane tank refurbishing companies, household hazardous waste contractors, and scrap metal processing and recycling facilities to determine if there is an interest in partnering. o Identify any available local resources of machinery or expertise for managing cylinders. o Identify any staffing and funding needs, and whether these needs can be met through the existing resources of the partnership. o Identify in writing each partner s role and responsibility (e.g., assisting with research, gathering data on its own operations, contributing financially or with labor). o Identify in writing any agreements reached with partners (e.g., a scrap recycler can use county equipment for cylinder processing). Training for Cylinder Handlers: With increased knowledge of safe handling techniques, recyclers may be more willing to process cylinders. A training video that illustrated cylinder identification and safe processing techniques would be a useful tool for scrap metal recyclers. Owing to high employee turnover, this type of training would be more effective than periodic live training courses. PSI recommends the following steps for developing an effective training program: o Collect recommendations from stakeholders on what they feel would be the most relevant and useful content to include in a training video. o Work with stakeholders to illustrate cylinder processing techniques and feature cooperative agreements in the video. 11

12 PRODUCT STEWARDSHIP OPPORTUNITIES Continued discussions on the role of manufacturers and distributors of the non-refillable gas cylinders should address the need for national protocols for cylinder handling, manufacturer involvement in creating access to processing equipment, and how to improve the flow of information on safe recycling and disposal between recyclers, manufacturers, and consumers. The key product stewardship goal in this area is to create conditions in which almost all of the steel from cylinders is directed towards recycling facilities. SECTION III: EDUCATIONAL CAMPAIGN PROBLEMS Although it is relatively easy to access information on the proper handling and disposal of many recyclables and hazardous household products, it is much more difficult for consumers and municipalities to find appropriate information on non-refillable gas cylinders. 1) Incomplete labeling. Product labels often do not alert consumers to any recycling possibilities and do not inform them about the benefits and avoided risks of completely using up gas in the cylinder. 2) Inadequate communication. Information is not readily available and exchanged among manufacturers and retailers, government officials, and consumers. As a result, many consumers and municipal officials do not recognize the potential risks from pressurized gas cylinders, and municipalities have little motivation to divert cylinders from the waste stream. EVALUATION FOR ACTION CONTEXT: Are there local resources available to develop and disseminate an educational campaign targeting gas cylinders? Is the community already part of the Earth 911 network? SHORT TERM MANAGEMENT SOLUTIONS Participants of the stakeholder meetings discussed different educational initiatives. Earth 911, a national website and hotline for environmental and recycling information, can provide individuals with information on local recycling centers, and has resources to assist municipalities to conduct special publicity campaigns. Earth 911 can also provide downloadable educational materials and technical information on cylinder processing. 12

13 By the end of the meeting, participants reached the following agreements: Participants developed draft product label language that directs consumers to contact Earth 911 for recycling information (see Appendix E for proposed label language). Manufacturers agreed to consider using this proposed language. Participants agreed that Earth 911 was an appropriate way to distribute information about cylinder recycling and disposal. Municipalities and counties across the nation can improve the existing Earth 911 system by periodically updating their local information. Given appropriate funding, Earth 911 and PSI will create a special page on the Earth 911 website with information about the different types of gas cylinders. The website can also supply password-protected information (e.g., on cylinder processing equipment and techniques) to municipalities. Educational initiatives can be developed independently from, or as a supplement to, Earth 911 s service. The following steps are recommended to fill existing educational gaps: Educational materials for consumers: More education is needed to inform consumers about the best management practices for gas cylinders. These materials could be displayed at point of sale, at campgrounds, on dumpsters, or other places where cylinders might be purchased or disposed. o Promote information on websites related to outdoor recreation, recycling, household hazardous waste, solid waste management, or the environment. o Newspapers, radio stations, and other local media may also be effective means of distributing information to consumers. Education for waste workers: Education targeting waste workers should describe the types of gas cylinders and related safety risks, as well as safe handling procedures. Waste management services may also promote cylinder collections and disseminate consumer information. o Waste management workers should also be involved in developing local cylinder management programs. They may be able to provide information on the types and volumes of cylinders passing through solid waste management systems, and recommendations for a successful cylinder management program. PRODUCT STEWARDSHIP OPPORTUNITIES Product stewardship discussions should continue to explore changes that manufacturers can make to cylinder labels to include information on how to safely manage used cylinders. While Earth 911 offers the opportunity for a single national clearinghouse for local cylinder recycling information, each local government would be responsible for maintaining the Earth 911 database of recycling locations. Discussions should also determine how much funding is needed for local and national media campaigns, and how such educational programs should be funded. 13

14 SECTION IV: ADDITIONAL STRATEGIES CONTRACT LANGUAGE Municipalities and counties intending to proceed with a cylinder collection and recycling program should begin by identifying businesses that already accept processed cylinders, along with their criteria for acceptance (e.g., volume and level of processing). Recyclers at the stakeholder meetings made it clear that they would be more interested in taking nonrefillable cylinders if they were also contracted to take refillable propane tanks and white goods. If local markets exist, cylinder management could be added as a required service when renegotiating community waste collection contracts. PSI prepared sample contract language illustrating three ways to incorporate language into a municipal contract. While time did not allow for group discussion of this topic, sample language is included in Appendix F. Municipalities and counties are encouraged to use this document as a starting point for considering how to encourage successful recycling programs within their jurisdictions. ECONOMIC STRATEGIES Many municipalities are unable to implement or expand collection and management programs for non-refillable cylinders unless they are compensated for costs. Current economic barriers to cylinder management include the low cost of cylinder production and the high cost of processing. For example, some propane cylinders sell for under two dollars, and can take up to eight dollars to process for recycling.. One key to successfully removing non-refillable cylinders from the waste stream is to create incentives for consumers to return the cylinders (e.g., through bounties or deposits) or by incorporating the cost to collect and process the cylinders into the purchase price of the product (e.g., through advanced recycling fees or by manufacturer cost internalization). These economic incentives are discussed in more detail in Appendix G. Future product stewardship discussions will continue to explore and evaluate economic incentives, as well as manufacturer take-back and other product stewardship strategies. NEXT STEPS The agreements and actions resulting from the initial discussions pertaining to nonrefillable gas cylinders demonstrate the importance and effectiveness of a multistakeholder process for identifying and developing appropriate management solutions. These initial discussions also identified the need to continue working on distinct issues such as the collection and recycling infrastructure, consumer education, and sustainable financing that must be addressed both separately and together. The enthusiasm and cooperation generated in the two meetings leaves little doubt that much more can be accomplished in a continued dialogue. 14

15 At the June meeting, stakeholders strongly recommended that future discussions should combine PSI s efforts on non-refillable gas cylinders with those on refillable propane tanks, believing that recyclers will be more interested in the metal that can be recovered from both types of gas containers. In addition, some of the stakeholders and issues are the same, so combining the efforts will increase efficiency of future efforts. PSI is seeking funding to address four specific projects discussed in the dialogues for nonrefillable cylinders and refillable 20-pound propane tanks: 1. A continued national product stewardship dialogue involving a broader representation of stakeholders; 2. Cooperation with ISRI to develop a training video and explore a certification program for handlers and processors of gas cylinders and tanks; 3. Conducting demonstration projects to illustrate best management options for cylinders and tanks; and 4. Reporting the results of successful management programs for replication by other regions throughout the U.S. 15