The Refuse Separation Compliance law will increase compliance with San Francisco’s mandatory recycling and composting requirements by auditing the refuse (compostables, recyclables, and trash) of large producers (Large Refuse Generators), and requiring them to engage staff (“Zero Waste Facilitator”) to ensure adequate material separation, when necessary. 


What is a Zero Waste Facilitator?

A Zero Waste Facilitator is a qualified person(s) who serves exclusively in helping a property comply with adequate refuse separation. This service may include sorting refuse before final collection by the hauler, and providing separation compliance feedback or education to property managers and tenants. As a resource, the Department of the Environment (SF Environment) will keep an updated list of known Zero Waste facilitators which indicates who has attended a training conducted by the Department. View a list of identified Zero Waste Facilitators.

The Department of the Environment (SF Environment) created a template Zero Waste Facilitator Job Description intended to assist property managers and owners who may need to hire a Zero Waste Facilitator or create a designated position among existing facilities staff.

How is an audit conducted?

A property’s collected refuse will be visually inspected by SF Environment or Recology to determine the percent contamination in a designated recycling, composting or trash stream. Auditors will photograph and document identified contamination and determine if the quantity of contamination has exceeded acceptable levels.

When will my property be audited?

All affected Large Refuse Generators will be audited at least once within three years of the effective date and within every three years thereafter. 

How can a property assess its compliance before a required audit?

A property can do a self-assessment through visual inspections before materials are placed in final collection bins. This can be done by intercepting material being brought from different locations within a property, such as in tenant locations, before being placed in the hauler’s collection bins. Recycling resources include:

What are the audit requirements?

If refuse contents are found to exceed contamination levels (unacceptable materials found in a designated bin) set by SF Environment, then the Large Refuse Generator will be deemed out of compliance. Contamination levels are set based on the ability to process and market materials and make progress toward zero waste. These levels may be adjusted once per year. Contamination limits for passing an audit under this ordinance are as follows: 

Contamination limits for composting

  • If the volume of unacceptable materials is under 5% AND does not include glass, e-waste, or hazardous waste: PASS

  • If the volume of unacceptable materials is above 5% OR includes any glass, e-waste, or hazardous waste: FAIL

Contamination limits for recycling:

  • If the volume of unacceptable materials is under 10% AND does not include e-waste or hazardous waste: PASS
  • If the volume of unacceptable materials is above 10% OR includes e-waste or hazardous waste: FAIL

Contamination limits for landfill (trash):

  • If the volume of unacceptable materials is under 25% AND does not include e-waste or hazardous waste: PASS
  • If the volume of unacceptable materials is above 25% OR includes e-waste or hazardous waste: FAIL

What is required if a property fails an audit?

If a Large Refuse Generator fails an audit conducted by the SF Environment or Recology, then SF Environment must issue a report on the findings of the audit, which includes photos of contamination along with a Notice of Noncompliance and an Order. The Order will require remedial actions that the property must take, including:

  • Engaging the services of a Zero Waste Facilitator for at least 24 consecutive months at a sufficient capacity.
  • Presenting a compliance plan and documentation of hiring a Zero Waste Facilitator within 60 days of the Compliance Order.

What if a Zero Waste Facilitator is not available within 60 days of a City Order?

If the property can demonstrate a lack of availability for a Zero Waste Facilitator, SF Environment may allow a property an additional 60 days (for a total of 120 days) to engage a Zero Waste Facilitator.     

What are the requirements for follow-up audits for property owners and managers?

A property that has complied for 12 consecutive months with an Order can request a follow-up audit at the property’s expense and with evidence of remediation efforts. If the property does not request a follow-up audit, a follow-up compliance audit will be conducted automatically at no expense to the property after a Zero Waste Facilitator has been engaged for 24 months.

  • If the property passes a follow-up audit, SF Environment will notify the property that it has met its compliance obligations.
  • If the property fails the audit, SF Environment will issue another Order requiring the property to take additional remediation actions. A property is not entitled to more than 3 audits within a year.

What are potential fines for noncompliance?

SF Environment may assess fines of up to $1000 a day for properties that do not comply.

Have Zero Waste Facilitators been successful?

Over 80 properties in San Francisco utilize Zero Waste Facilitators. Properties with facilitators have been able to reduce trash and/or increase recycling or composting resulting in an increased recovery (diversion) rate and discount on their Recology refuse bill. They also can help properties avoid refuse contamination charges. In many cases, Zero Waste Facilitators have been shown to provide a net savings to a property.

Refuse Separation Compliance Law