
INFOGRAPHIC: Different Sizes of Trucks & Tanks
January 20, 2025
Why PSAI’s Nuts & Bolts Educational Conference Should Be on Your Annual Schedule
January 29, 2025What happens when you’re turned away from a dump station, not once, but permanently? Unfortunately, this isn’t a hypothetical question for some portable restroom operators in the United States. Publicly owned treatment plants can refuse loads, leaving PROs scrambling to find alternatives. Finding answers or long-term solutions can consume a lot of time, and where do you even start?
In this in-depth article, we dig into the reasons behind liquid waste refusals and ways PROs can stay informed. Here’s what you need to know.
Understanding the Role of Dump Stations and Waste Management
Many portable restroom and sanitation companies use local dump stations managed at the county or municipal level. Dump stations are holding areas or collection points for non-hazardous liquid waste (NHLW) and connect to publicly owned treatment works (POTWs) systems, known as sewage treatment plants.
Regulations for clean water, human safety, and transportation guide how POTWs manage hauled waste from portable restroom operators. Each facility processes waste through several stages, including pretreatment programs, which larger facilities typically offer.
The Regulations and Guidelines Affecting Local Dump Stations
It wasn’t that long ago that liquid waste haulers could unload liquid waste into an open pit near a sewage plant or discharge into a field or lagoon. Concentrated human septage and industrial chemicals got into groundwater, rivers, and soil, making people and animals sick.
It doesn’t make financial sense for hundreds of counties and cities to run studies on identical topics, like how human waste from an open pit affects drinking water. Instead, federal agencies, like the U.S. Environmental Protection Agency (EPA), assess impact and establish guidelines so that waste goes to designated areas and gets cleaned up before re-entering the environment.
EPA regulations cover wastewater treatment, discharge, and pollutants under the Clean Water Act and the National Pollutant Discharge Elimination System (NPDES). It mandates pretreatment programs for large POTWs and governs biosolids’ use, including septage for land application or incineration. The EPA also issues general guidelines for hauled waste management, which includes chemical toilet waste. These focus on best practices for ensuring public health protection and meeting waste disposal standards.
U.S. states enforce EPA regulations and may add regional guidelines. These rules often consider local conditions like water tables, climate, or soil types. For example, Florida requires additional treatments and specific setback distances from water bodies. Texas regulates liquid waste haulers through the state, not county level, with the Texas Commission on Environmental Quality providing toilet waste licensing, handling, and disposal standards.
So, although your county or city manages dump stations, they must collaborate with state environmental agencies and the EPA to understand best practices and follow regulations. In many cases, local governments oversee plant-operating standards and issue permits to waste haulers.
How POTWs Process Portable Toilet Waste
After discharging your waste at the dump station, it moves through multiple processing stages. Each phase handles a specific aspect of treatment, from screening out debris to removing harmful chemicals. If one stage gets out of balance, it could overwhelm the system or fail to remove sufficient amounts of pathogens or chemicals.
Here’s a general overview of how the treatment process works:
- Preliminary treatment: This step filters large debris like all those items you warn customers not to put into your portable toilets, but they do anyhow. It also sifts sand and grit, removing them to sedimentation tanks.
- Primary treatment: As waste settles to the bottom, organic sludge, oils, and grease float to the top, allowing easier removal.
- Secondary treatment: During this phase, microorganisms like bacteria and protozoa break down organic matter in aeration tanks, and solids settle at the bottom.
- Tertiary treatment: Various methods like sand or membrane filters, UV light, chlorination, or ozone treatment reduce fine particles, nitrogen and phosphorus levels, and pathogens.
- Sludge treatment: This step thickens and dries the sludge to reduce its volume and allow for handling. After testing, it can be incinerated, put in landfills, or applied on land as biosolids.
- Discharge or reuse: Once the treated water has been monitored and tested to ensure it meets regulatory standards, it may be released into waterways or used for irrigation.
Why Some Dump Stations Are Refusing Portable Toilet Waste
You may think a dump station has one job to do, so why are they refusing to do it? And that’s a great question. Let’s start with how portable restroom waste differs from standard septage and then look at a few possible reasons for refusal.
Waste from Portable Toilets: Not Your Average Load
Dump stations are well equipped to handle gray and black water, as well as domestic septage. However, portable toilets often include chemical additives like deodorizers or winterizing solutions and are more concentrated than residential or commercial wastewater.
Waste from portable toilets affects systems differently because of the following factors:
- More organic matter: Standard domestic waste is diluted with greywater from washing machines, flushing toilets, and showers. Portable toilets are mostly human waste, which contains more pathogens, nitrogen, phosphorus, and organic material.
- Higher strength: PROs may service units weekly, allowing organic matter to decompose and solids to settle. Treatment plants can spot test loads to measure strength through metrics like total suspended solids and biochemical oxygen demand.
- Chemical concentration: Although household waste contains chemicals, the continual flushing dilutes its strength. Cleaning agents and blue deodorizers could be more concentrated in portable toilet waste.
Disruptions to Key Stages of the Treatment Process
High solids content, chemical additives, and pH levels can affect treatment stages. It’s not just a matter of slowing down operations. A failure at various phases can result in not enough pathogens being removed and ultimately resulting in water being discharged that doesn’t meet health and safety requirements.
The EPA addresses several concerns about slug loadings, which are abrupt, highly concentrated loads into a sewage treatment system. It notes that hauled waste can cause slug loadings that interfere with primary and secondary treatment processes, often using biological treatments that highly concentrated chemicals could harm.
Here are a few ways portable toilet waste can cause slug loading:
- Overwhelm system pollutant capacity: Smaller plants may not be able to handle a highly concentrated pollutant load that contains more solids, nutrients, organic matter, and chemicals than regular residential wastewater.
- Harm biological processes: Digesters commonly use bacteria to treat sludge and break down non-toxic organic waste. High-strength waste can kill or shock the microbes, preventing them from effectively treating wastewater.
- Strain overloaded infrastructure: When surges occur, such as an influx of concentrated waste at a single point or a major storm event combined with hauled waste, the system may operate under emergency settings and bypass steps, which could discharge untreated waste into the environment.
Pretreatment Programs: Large vs. Small POTWs
Capacity, management, and funding differ among sewage treatment programs. These differences can result in the refusal of portable restroom waste. Large POTWs, typically serving metro areas, have extensive pretreatment programs to manage highly concentrated or chemically complex liquid waste. Some of the largest plants, such as the Stickney Water Reclamation Plant in Cicero, Illinois, treat 1.2 billion gallons per day of wastewater.
However, smaller sewage treatment plants, like those found in many rural communities and cities outside populous areas, lack the resources to handle high-strength waste. When smaller POTWs experience operational issues, they have fewer options for resolving them and, as a result, may choose to refuse portable restroom waste.
To understand how these differences could affect your business, consider the following:
- Pretreatment programs: The Clean Water Act requires large waste producers to pretreat waste, which reduces pollutants that could disrupt the treatment process or environment. Small sewage plants that don’t meet the requirements for a pretreatment program may not qualify for funding or resources to develop a system to handle high-strength or diverse wastewater.
- Capacity and scale: Large POTWs are designed to manage commercial and industrial waste. These systems have infrastructure that can adjust to high volumes and concentrations. Small plants focus on household sewage and lack the equipment to monitor and dynamically adapt to waste composition or volume changes.
- Funding and resources: Dump stations outside of metro areas rely on municipal budgets and user fees. Grants for environmental infrastructure improvements may help upgrade their systems, but they often face budget constraints. Large POTWs may receive more state and federal funding for pretreatment programs, allowing them to train employees and purchase specialized equipment.
- Waste acceptance policies: With adequate funding, equipment, and staff, large POTWs can manage septage receivables programs, making them less likely to refuse portable restroom waste. Meanwhile, small facilities facing higher administrative and operational costs or concerns over regulatory fines may base decisions on a case-by-case basis.
Dodgy Waste Haulers Put All Loads at Risk
As with many things, a few rotten eggs can ruin a good thing for everyone. So, what’s happening in some cases is that POTWs with pretreatment programs are denying loads for specific reasons. These larger facilities can test and track waste haulers and their contents through more sophisticated means, so they’re typically not turning away a regular PRO who is a reputable businessperson. But when these waste haulers are refused, they head to facilities that don’t have pretreatment programs.
Since non-pretreatment POTWs have limited capabilities and small capacities, high-strength loads and unknown contents can harm their processes and even injure staff. The EPA documented a case from the 90s where a hauler falsified information and discharged waste, emitting toxic fumes, injuring a plant employee, and killing off half of the microorganisms used to treat raw sewage.
As unsavory waste haulers make their way to smaller plants to try and pull one over on them, these treatment centers must invest more funding into training and controls or decide to refuse loads.
Decisions May Reflect Higher Costs and Regulatory Risks
The bottom line is that larger facilities can measure the characteristics of the hauled waste. These repeatedly show that portable toilet waste requires more oxygen to break down organic matter, usually has more solid particles, which strains the primary treatment process, and has higher chemical oxygen demand, meaning it takes more chemical oxidants to break down matter because of the additional concentration of chemicals.
The higher pollutant load means treatment plants use more energy to manage them. And then when you add in the risks, based on the fact that the treatment plant, not the waste hauler, is responsible for issues and pays the fines, plant operators and local governments may prefer the refuse approach over the accept and watch approach.
Get the JohnTalk “ALL-ACCESS PASS” & become a member for FREE!
Benefits Include: Subscription to JohnTalk Digital & Print Newsletters • JohnTalk Vault In-Depth Content • Full Access to the JohnTalk Classifieds & Ask a PRO Forum
Consequences for PROs and the Industry
A combination of factors could impact portable restroom companies, from increased storm events to a push for privatization of public services. While there isn’t any indication of a federal or state-wide push to refuse loads from waste haulers, anecdotes from various PROs and requirements from plants suggest that these issues can pop up with little warning.
For example, the EPA mentions a Wisconsin treatment plant requiring portable toilet operators to get approval before discharging waste containing ANY chemical. Elsewhere, consultants share stories of wastewater plants sending chemical toilet waste haulers to private pretreatment centers, with some of these companies handling up to 20 tankers daily.
As government agencies look to increase operational efficiency, PROs could face additional costs and operational burdens, such as:
- Increased licensing and disposal fees: Treatment plants may impose steeper fees on waste haulers to recoup the costs of managing concentrated loads and administering permits. These could place a high burden on small and mid-sized companies already strained by economic conditions.
- More information requirements: Sewage treatment plants can require haulers to submit data on bacterial growth inhibitors present in hauled waste, including overall volume and concentrations. Shifting this burden to small businesses could pose a substantial challenge.
- Additional treatability responsibilities: Likewise, POTWs can require PROs to bear the cost of treatability studies, which test how hauled waste affects biological, chemical, and sludge processes. These are expensive and don’t guarantee approval.
- Higher transportation costs: While POTWs may serve local or regional areas, private companies may need to purchase property outside of populated places to secure permits and public approval, which can increase fuel costs.
- Potential service delays: The combination of privatizing public services, shifting cost burdens to private companies or individuals, and other challenges like increased storm events that burden infrastructure can limit the number of available dump stations, decreasing service availability.
Navigating the Current Landscape: What PROs Can Do
Although dump station refusals aren’t common, they’re an unexpected and costly risk of doing business in the industry. By staying informed, networking, and having a plan in place, you can take an active role in managing liquid waste disposal.
Ensure Waste Haulers Can Communicate Effectively
Give drivers the information they need to build trust with treatment plant staff and show that your company complies with local regulations. They should know how to check pH levels, provide permits or licenses, and locate safety data sheets (SDS).
Here’s what your team might need:
- Key information: Check local and state requirements to see what forms should be in your vehicles when hauling liquid waste. As a best practice, consider including copies of business registration, insurance documents, and wastewater discharge and transporter permits.
- Chemical and pH details: Employees should know where to find and how to use SDS for all chemicals, including deodorants, winterizing treatments, and cleaning agents. Explain how pH testing works and how to complete any forms.
- Miscellaneous documents: Some facilities may require a statement of waste origin or tracking forms to confirm that the load isn’t hazardous. Consider chatting with a legal professional before creating these forms to ensure you’re not accepting liability for anything out of your control.
Understand Your Chemical Footprint
Disposal site staff want enough information to determine how hauled waste will impact their system. By reducing your use of additives and documenting estimated concentration levels, you could have enough data to present your case and educate others.
Here are a few steps you could take:
- Check with labels, SDS, or manufacturers to identify restroom products that inhibit bacterial growth and estimate concentration levels.
- Consider going green by switching to enzyme or microbe-based treatments and avoiding formaldehyde-based chemicals or additives.
- Summarize chemical concentration levels for an average waste tank by estimating the total ounces of each product (and corresponding active ingredients) per load.
Have Backup Disposal Plans Ready
An outright refusal requires an immediate backup plan. Drivers should know who to call, how to document the situation, and what to do next.
Keep these details updated:
- Backup dump stations: Create a list of alternate stations, facility hours, and contact information. Provide drivers with the best route from their current location to the alternate stop and let them know if they need to give any additional information.
- Contact list: Maintain a list of municipal and county officials or utility-specific roles in your area with phone numbers and email addresses. These might include the public works director, environmental health officer, wastewater treatment plant manager, and utility district board members.
Work the Room: Network, Educate, and Collaborate
Networking with the right people can keep you informed about local and national situations that could affect your portable restroom business. Having the right connections can give you a heads-up to changes you might have missed or give you a chance to talk to policy influencers about the importance of accepting hauled toilet waste.
In addition to talking to PROs, stay engaged through:
- Public meetings, notices, and alerts: Utility boards, sanitation districts, planning and zoning committees, and city councils discuss operational and funding issues, like sewage treatment upgrades or compliance issues. Attend meetings, sign up for email alerts, and check newspapers or government websites for notices about changes.
- Tax documents and permits: Pay attention to local budget reports for government or utility districts, which may show funding for sewage treatment plants. In some cases, tax information for bonds or special assessments will be in public notices or on your property tax bill. Check your waste hauler’s permit and licensing information regularly to see if requirements change.
- Industry events and groups: Organizations often advocate on business owners’ behalf and ask for policy feedback. Find resources and connect with groups like the Portable Sanitation Association International (PSAI) and the National Onsite Wastewater Recycling Association (NOWRA).
The Future of Waste Disposal for Portable Restrooms
When your portable restroom business services local customers and uses shared resources, utilities, and roadways, you have a responsibility to stay informed and understand your impact. Active engagement through community networking and industry events like joining the PSAI can help guide policy decisions while protecting your business interests.
Looking to Take Your Portable Restroom Business to the NEXT LEVEL? Download our FREE Guide: “Your Guide to Operating A Portable Restroom Business.”
Thinking About GETTING INTO the Portable Restroom Industry? Download our FREE Guide: “Your Guide to Starting A Portable Restroom Business.”