Section 18954. Annual Report Compliance Criteria. (a) The annual report must contain the following: (2) Executive Summary. The purpose of the Executive Summary is to provide a broad understanding of the manufacturer or stewardship organization's program as a whole and to put into context the data and information that will follow. Provide a brief description of the manufacturer or stewardship organization's architectural paint recovery efforts during the reporting period pursuant to PRC §48705(a). This may include anticipated steps, if needed, to improve performance and a description of challenges encountered during the reporting period and how they will be addressed. This may also include a description of paint container management and market development activities if the manufacturer or stewardship organization has chosen to engage in those activities. In September 2010, Governor Schwarzenegger signed Assembly Bill 1343 (Huffman) creating the California Architectural Paint Stewardship Program (“Program”). The California Paint Stewardship Law requires manufacturers of architectural paint to develop and implement a program to reduce the generation of postconsumer architectural paint, promote the reuse of postconsumer architectural paint, and to provide a system for the management of postconsumer architectural paint in an environmentally sound manner that includes collection, transportation, processing, recycling, and proper disposal. PaintCare, on behalf of participating paint manufacturers, must submit an annual report to the California Department of Resources Recycling and Recovery (CalRecycle) each year. As prescribed in §48700 of the California Public Resources Code and further detailed in Title 14, Section 18954 of the California Code of Regulations, the information submitted in an annual report shall be organized according to this standard outline: (A) Contact Information (B) Executive Summary (C) Program Outline (D) Description of Goals and Activities Based on the Stewardship Plan (E) Financing Mechanism (F) Education and Outreach (G) Audits The California Program began October 19, 2012. The 2013 Annual Report covers the 8.5 month time period spanning from October 19, 2012 through June 30, 2013. During the course of this time, PaintCare successfully: • Implemented a sustainable funding mechanism through a per-can assessment on new containers of paint sold, which is remitted to PaintCare by paint manufacturers and used to pay for all aspects of the Program including postconsumer paint collection, transportation and end-of-life management, as well as administrative costs and outreach and education. • Established 493 public drop-off sites consisting of paint retailers, municipal household hazardous waste programs, and other voluntary locations to create a convenient network of drop-off sites for Californians. Collected and processed 632,652 gallons of postconsumer paint, 68% of which came through retail and other non-municipal sites. 96% of the processed paint was recycled back into paint, another product, or used for a beneficial purpose. 363 tons of plastic and metal paint cans were also recycled. • Implemented a comprehensive outreach campaign to educate consumers on the new California paint stewardship Program, the amount and purpose of the assessment, and convenient recycling opportunities, while also promoting buying the right amount of paint and using up leftovers. Challenges and Lessons Learned The first year of the Program presented special challenges and lessons learned which are to be expected when launching a new, large-scale, state-wide waste management Program, particularly one that creates a shift from a publicly funded system to a stewardship model managed by industry. The primary challenges in the first reporting year are discussed here. Hazardous Materials Storage Requirements. Local rules for hazardous materials storage volumes (and reporting) varied from county to county, and sometimes from city to city within a county. Many oversight agencies require a Hazardous Materials Business Plan (HMBP) with annual fees ranging from $80 to $1000 when a retailer stores 55 gallons or more of postconsumer paint onsite. This was a barrier to retail participation as a drop-off site, particularly for independently-owned stores, both because of the cost and because of the additional oversight to which they would be subjected. PaintCare will continue to work with California’s state government agencies to try to create a more accommodating and consistent interpretation of the state rules addressing HMBP requirements. Retail Storage Space. Many retailers in California have limited storage space which impedes their ability to accommodate public demand. As a result, retail sites that could only accommodate one cubic yard-sized bin sometimes filled their bin in 1-2 days, and had to turn customers away until their full bins were picked up and replaced with empty bins. For future Program expansion, the Program will give preference to retail sites that can store at least two bins. Partnering with Household Hazardous Waste Programs. An effort was made by a coalition of local governments to negotiate contracts with PaintCare through a multi-jurisdiction process. However, given the great variety of operational and contracting needs of the state’s household hazardous waste (HHW) programs, individual contract negotiations were found to be the most effective means to establish partnerships. PaintCare will continue to work with the diverse HHW programs in California to find solutions to accommodate each jurisdiction’s unique need. PaintCare was also surprised to learn that not every local government program was familiar with or supported the concept of product stewardship, and not every jurisdiction was concerned about reducing its HHW program costs or having paint costs covered by PaintCare. Staff layoffs due to decreased demand for labor were a significant concern for several programs. Product Stewardship Awareness. In addition to finding some municipalities unfamiliar with the purpose and intent of product stewardship programs, the concept of this new waste management model is still unfamiliar to much of the general public. To address this, PaintCare will continue to include product stewardship messaging in its outreach efforts, emphasizing that the Program is run by the paint manufacturing industry, that it is funded by a fee applied to the product price rather than a state tax, and that it is not a deposit program.