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Landfill Prohibited Materials and Appropriate Disposal Options

Contact: Steve Sliver 517-284-6595
Agency: Environmental Quality




Memorandum dated June 9, 2006, regard the Disposal of Wastewater Treatment Plant Sludge at Type II Landfills 

Memorandum dated February 8, 2005, regarding Implementation of Solid Waste Amendments Regarding Prohibited Waste Amendment of Plans and Procedures 

List of Jurisdictions with Comparable Landfill Disposal Prohibitions (most current version) (most current version)

Solid Waste Operational Memo 115-27, Revision 1, Enforcement of Prohibited Waste Restrictions, dated October 19, 2004, provides additional information to solid waste landfill owners or operators and solid waste haulers

Memorandum dated October 13, 2004, regarding the uniform solid waste record form and other revised forms to demonstrate compliance with Section 11536a(1) of Part 115

Memorandum dated September 30, 2004, regarding the list of jurisdictions with comparable solid waste disposal requirements and the disposal of solid waste


Application for Certification of Equivalent Landfill Disposal Prohibitions Form (EQP 5221) (PDF Format)  (Word Format)  Application Form Instructions

Prohibited Waste Removal Record Form (EQP 5222) (may be used to document compliance with Section 11526a(1)(b) of Part 115 (most current version) 

Solid Waste Manifest Record Form (EQP 5223) (may be used to document compliance with Section 11526a(1)(c) of Part 115 (most current version)

Uniform Solid Waste Record (EQP 5224) (may be used to document compliance with Section 11526a(1)(a) of Part 115 (most current version)


Section 11514 of Part 115, Solid Waste Management, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (NREPA), was amended by 2004 PA 34 to prohibit a person from delivering to a landfill for disposal, and a landfill owner or operator, from permitting the disposal in a landfill, of any of the following: 

  • Medical waste, unless that medical waste has been decontaminated or is not required to be decontaminated but is packaged in the manner required under Part 138, Medical Waste Regulatory Act, (MWRA) of the Public Health Code, 1978 PA 368, as amended, MCL 333.13801 to MCL 333.13831 (MWRA). 
  • More than a de minimis amount of open, empty, or otherwise used beverage containers as defined in the Initiated Law of 1976, as amended (Deposit Law). 
  • More than a de minimis number of whole motor vehicle tires. 
  • Used oil as defined in Section 16701 of Part 167, Used Oil Recycling, of the NREPA. 
  • A lead acid battery as defined in Section 17101 of Part 171, Battery Disposal, of the NREPA. 
  • Low-level radioactive waste as defined in Section 2 of the Low-Level Radioactive Waste Authority Act, 1987 PA 204, as amended, MCL 333.26202. 
  • Hazardous waste that is required to be disposed of in a hazardous waste treatment, storage, or disposal facility under Part 111, Hazardous Waste Material, of the NREPA. 
  • More than a de minimis amount of yard clippings, unless they are diseased or infested. 
  • Liquid waste as prohibited by R 299.4432(2)(c) of the Michigan Administrative Code. 
  • Sewage. 
  • Polychlorinated Biphenyls (PCBs) as defined in federal regulations. 
  • Asbestos waste unless the landfill complies with federal regulations. 

The NREPA was also amended by 2004 PA 42 that states in Section 11527a that the DEQ shall post on its Web site a list of materials prohibited from disposal in a landfill under Section 11514 and appropriate disposal options for those materials. 

The following are appropriate disposal options for materials prohibited from disposal in a Michigan landfill:  

Medical Waste - There are five (5) categories of medical waste.  Under certain conditions, each of these categories can legally be disposed of in a sanitary landfill under the MWRA.  These categories and stipulations are as follows: 

1. Cultures and stocks of infectious agents, primarily laboratory research and production waste, may be disposed of in a landfill if they are packaged in closed, puncture-resistant containers, decontaminated by autoclaving or incineration.  

2. Blood, blood products, and body fluids may be disposed of in a landfill if a solidifying agent has been added to the liquid blood or body fluid.  No decontamination pretreatment is required. Another option is to dispose of the fluids in the sanitary sewer. Large volumes should not be disposed of into the sanitary sewer without first having obtained approval from the local sewer authority. 

3. Pathological waste (body parts and organs) may be disposed of in a landfill if the waste is first ground up so it is unrecognizable, then placed in closed, puncture-resistant, properly labeled containers.  Properly labeled means it must have a biohazard symbol on the container or the words "medical waste" or "pathological waste" in letters not less than 1 inch in height.  The waste cannot be in liquid form. Pathological waste can also be sent to a DEQ-licensed incinerator or it can be ground and disposed of in the sanitary sewer. Approval from the local sewer authority should be sought before disposing of large volumes of pathological waste in the sanitary sewer. Pathological waste can also be buried in a cemetery if properly packaged in leakproof and puncture-resistant containers. 

4. Sharps (syringes and needles, lancets, etc.) may be disposed of in a landfill if the sharps are packed in rigid, puncture-resistant containers that are properly labeled and transported to the landfill in a manner that retains the integrity of the container.  No decontamination or treatment is required.  A compacting garbage truck is not acceptable for transport. Sharps can also be disposed of by sending them to a DEQ-licensed medical waste incinerator, autoclave, or other approved treatment facility. See the publication " The Point Is…Needles Hurt " for more information. 

5. Animal waste contaminated with organisms infectious to humans may be disposed of in a landfill if the waste has been placed in properly labeled, double lined containers that are leakproof and puncture resistant and are tightly sealed to prevent escape of fluids or material.  Contaminated animal organs must be first made unrecognizable (usually by grinding) before packaging and disposing in the landfill. 

For more information regarding proper disposal of medical waste, please contact Andy Shannon at 517-335-1146.  Additional information can be found at the Medical Waste Regulatory Program Web site here. 

Information regarding options for unwanted or outdated medications can be found within the document "A Remedy for Prescription Drug Disposal"  .  

Beverage containers - A beverage container is defined as an airtight metal, glass, paper, or plastic container, or a container composed of a combination of these materials, which, at the time of sale, contains 1 gallon or less of a soft drink, soda water, carbonated natural or mineral water, or other nonalcoholic carbonated drink; beer, ale, or other malt drink of whatever alcoholic content; or a mixed wine drink or a mixed spirit drink.  If a deposit was paid on the beverage container, then the container may be redeemed for deposit at a retailer at which the beverage is sold. If a deposit was not paid on the container because it was purchased out-of-state, the container may be recycled at a local recycling curbside or drop-off recycling program. Your local recycling programs contact can be found here . 

Frequently asked questions concerning the Deposit Law can be found here . 

Whole motor vehicle tires - Part 169, Scrap Tires, of the NREPA, requires that a person deliver a scrap tire only to a registered end-user, scrap tire processor, tire retailer, or a scrap tire recycler that is in compliance with Part 169.  Whole scrap tires may be accepted at a landfill, but are prohibited from disposal in a landfill.or to landfill disposal, the tire must be cut or otherwise processed into pieces. 

Small quantities of whole motor vehicle tires may be accepted by tire retailers for a small fee.  Larger quantities of tires may be managed by contacting a registered scrap tire hauler, registered scrap tire collection site, scrap tire processor, or certified end-user.  Complete lists of registered scrap tire haulers, registered scrap tire collection sites, scrap tire processors, and certified end-users can be found here . 

A person who, as part of a commercial business, transports scrap tires is considered to be a scrap tire hauler and must register as such prior to transporting tires in the state of Michigan. 

Additional Scrap Tire Regulatory Program information including a Map of Scrap Tire Collection Sites, Common Scrap Tire Violations, Operational Memos, Lists of Facilities, Scrap Tire Laws, Scrap Tire Registration Forms, Scrap Tire Grant information, and District Scrap Tire Program Staff contacts can be found here .   For additional information, you may also contact Rhonda Oyer at or 517-284-6591. 

Used oil - Used oil should be recycled at an appropriate collection point. Many oil change locations will accept used oil that has been kept separate from other liquids. Information regarding recycling of used oil, including answers to questions such as: What is used oil? What are the legal requirements for managing used oil? How is used oil recycled? What are transporter and marketer requirements? This information can be found here .  Businesses should contact the District Office for answers to questions regarding used oil not addressed in the used oil guidance document mentioned above.  Residences can contact their local recycling coordinator here  for recycling options. 

Lead acid battery - Recycling is the only correct way to manage spent used lead acid batteries. Retailers of lead acid batteries are required to accept customers' used lead batteries. The most common and easiest way to manage spent lead acid batteries is to return them to the retailer when purchasing a new battery. Any place that sells lead acid batteries id required to accept used lead acid batteries for recycling. Lead acid batteries: 

  • Are required to be recycled in accordance with Part 171. 
  • Cannot be disposed of in a landfill. 
  • Must be stored in a manner that prevents their contents from being released into the environment; they should be stored no more than one layer high on a pallet. 

See Chapter 2.3.8.c of the Michigan Manufacturers' Guide to Environmental, Safety, and Health Regulations, here , for more information for businesses on safely storing and handling lead acid batteries.  Part 171, describing disposal of lead acid batteries, duties of retailers of lead acid batteries, acceptance of lead acid batteries by distributors, and transportation can be found (Part 171). For more questions regarding business requirements on managing batteries, contact the District Office .  Residences can contact their local recycling coordinator here  for  recycling options. 

Low-level radioactive waste - Low-level radioactive waste (LLRW) includes items that have become contaminated with radioactive material or have become radioactive through exposure to neutron radiation. LLRW typically consists of contaminated protective shoe covers and clothing, wiping rags, mops, filters, reactor water treatment residues, equipment and tools, luminous dials, medical tubes, swabs, injection needles, syringes, and laboratory animal carcasses and tissues. The radioactivity can range from just above background levels found in nature to very highly radioactive levels found in certain cases such as parts from inside the reactor vessel in a nuclear power plant. Licensees typically store LLRW waste on-site either until it has decayed away and can be disposed of as ordinary trash or until amounts are large enough for shipment to an LLRW disposal site. For more information about LLRW, see the U.S. Nuclear Regulatory Commission (NRC) publication "Radioactive Waste: Production, Storage, Disposal" here . 

For answers to questions regarding LLRW, please contact the NRC, Region III office, at 630-829-9500 or or the DEQ at 517-284-6581 (E-mail: ) 

Hazardous waste - Hazardous waste are materials that are identified by specific processes or exhibit certain properties that require more stringent controls on disposal.  Although some hazardous waste may be disposed as solid waste under certain conditions, generally, hazardous waste must be transported to an authorized hazardous waste facility for proper recovery, treatment, or disposal. 

Permitted hazardous waste treatment, storage, and disposal facilities in Michigan can be identified here . 

Information on proper disposal of hazardous waste can be found here . Summary of requirements for businesses is in Chapter 2 of the Michigan Manufacturers' Guide to Environmental, Safety, and Health Regulations can be found here .  For more information for business requirements, contact the District Office . 

Household hazardous waste (HHW) including household cleaners, household pesticides, and household chemicals are not prohibited from disposal in a landfill, but should be kept out of the trash if possible. For disposal options and household hazardous waste collection opportunities, please contact your county HHW contact here. 

Yard clippings - Yard clippings are defined as leaves, grass clippings, vegetable or other garden debris, shrubbery, or brush or tree trimmings, less than 4 feet in length and 2 inches in diameter, that can be converted to compost humus.  If the situation allows, yard clippings are best managed at the site of generation by mulching and backyard composting. If on-site management is not possible, the yard clippings should be managed according to Section 21 of Part 115:

Additional information on management of yard clippings can be found by visiting the yard clippings, composting, Web page or by contacting Duane Roskoskey at or 517-582-3445. Information on backyard composting can be found by going to Home Composting Reap a Heap of Benefits.  Alternatives to open burning of yard clippings can be found here . 

Liquid waste - Liquid waste means any waste material that is determined to contain free liquids as defined by method 9095, the paint filter liquids test. This method is described in the publication entitled "Test Methods for Evaluating Solid Wastes, Physical-Chemical Methods" SW-846 found here .  Nonhazardous liquid waste from businesses may not be disposed of in a landfill unless a solidifying agent has been added to the waste or the waste has been solidified in some other manner. Liquid wastes may be delivered to solidification processing plants that are located within an active cell at a landfill.  Dry solid wastes are mixed with liquids thereby enabling them to pass the paint filter liquids test. 

Liquid waste from households may be sent to a landfill if it is accepted by the landfill.  It is preferable to add a waste material to the liquid to absorb the liquid before disposing of the liquid waste. Households should contact their solid waste hauler and landfill for more information on what their services allow. Contact the local sewer authority about discharging any liquids to the sanitary sewer. For more information on proper disposal of nonhazardous liquid waste in landfills, please contact Margie Ring at 517-284-6592. 

For more information for businesses on proper characterization, management, and disposal of liquid industrial waste under Part 121, Liquid Industrial Waste, of the NREPA, click here , chapter 2 of the Michigan Manufacturers' Guide to Environmental, Safety, and Health Regulations can be found here  or contact the District Office . 

Sewage - Domestic sewage is disposed of by on-site septic systems, land application, lagoon systems, or wastewater treatment facilities. About 25 percent of the estimated 10 million residents in Michigan use on-site septic systems. The remainder use wastewater treatment facilities that reduce the strength of the waste prior to discharge to ground or surface water. The licensing and handling of domestic septage is regulated under Part 117, Septage Waste Servicers, of the NREPA. Septage waste can be disposed of into municipal wastewater treatment plants or by application on approved lands. For the Michigan Septic Waste Management Guide click here.

Information on proper management of waste from septic tanks including information on domestic septage, list of licensed septage waste servicers, septage licensing, land application of domestic septage, and federal septage regulations can be found here . For more information about septage, contact Matt Campbell, Water Division, at  or 517-335-4178. 

Information about biosolids or sewage sludge from wastewater treatment plants can be found here .  For more information about biosolids, contact Mike Person, at or 989-297-0779. 

PCBs - PCBs are mixtures of synthetic organic chemicals with the same basic chemical structure and similar physical properties ranging from oily liquids to waxy solids. Due to their nonflammability, chemical stability, high boiling point, and electrical insulating properties, PCBs were used in hundreds of industrial and commercial applications including electrical, heat transfer, and hydraulic equipment; as plasticizers in paints, plastics, and rubber products; in pigments, dyes, and carbonless copy paper; and many other applications. More than 1.5 billion pounds of PCBs were manufactured in the United States prior to cessation of production in 1977. 

Concern over the toxicity and persistence in the environment of PCBs led Congress in 1976 to enact §6(e) of the Toxic Substances Control Act (TSCA) that included, among other things, prohibitions on the manufacture, processing, and distribution in commerce of PCBs. Thus, TSCA legislated true "cradle to grave" (i.e., from manufacture to disposal) management of PCBs in the United States.  

The TSCA is implemented in Michigan by the U.S. Environmental Protection Agency (EPA).  Questions and concerns regarding the use or information on up-to-date disposal options of PCBs in Michigan should be addressed with the regulating authority, the EPA, Region 5 office, in Chicago, 312-353-2291.  Go to for information on federal requirements about proper management of PCBs or contact Priscilla Fonseca at 312-886-1334.  For information on PCBs in lighting ballasts, including proper disposal, please see Chapters 2 and 4 of the Michigan Manufacturers' Guide to Environmental, Safety, and Health Regulations here . 

Asbestos - Under Part 115, administered by the DEQ's Waste and Hazardous Materials Division, all asbestos-containing material regulated by any state or federal regulations must be disposed of at a Type II (municipal solid waste) landfill in compliance with federal regulations. Asbestos-containing material that is nonfriable or not easily crumbled or pulverized AND is not in poor condition or will not become friable at any time can be disposed of in a Type III (construction and demolition) landfill in compliance with federal regulations. For information on specific landfill disposal requirements and transportation of asbestos waste, contact the DEQ's Air Quality Division, Asbestos Program, at 517-373-7064. Information about asbestos management requirements at demolition and renovation projects can be found here.


The following additional items are prohibited from landfill disposal under the administrative rules promulgated pursuant to Part 115, R 299.4430, but are not listed in 2004 PA 34: 

  • Empty drums - Drums must be either full of solid waste or be crushed in order to be disposed of in a solid waste landfill. For more information, please contact Margie Ring at or 517-284-6592.  For information on where to recycle empty drums, please visit the Recycled Materials Market Directory here Materials that would adversely affect the landfill liner or leachate collection and removal system - For more information on additional materials that should not be disposed of within a landfill because it may damage the landfill liner or leachate collection and removal system, please contact Margie Ring at or 517-284-6592 . 

If you are unsure of who to call regarding your questions about proper disposal of an item, contact the DEQ's Environmental Assistance Center at 800-662-9278.