Follow-up to OIG’s Audit of Department of Streets and Sanitation Commercial and High-Density Recycling Enforcement

Executive Summary

The purpose of the 2020 audit was to determine whether DSS ensured that building owners provided recycling collection services as required by the Chicago Recycling Ordinance. The Ordinance states that owners or occupants of commercial and high-density residential buildings “shall contract with a private hauler, or cause a contract to be entered into with a private hauler, for the provision of source-separated recycling services [ … ].”The City is required to provide buildings found in violation of this requirement 30 days to come into compliance. Continued noncompliance can result in fines ranging between $500 and $5,000 per day. The Ordinance also requires private haulers to submit annual reports detailing the source, type, and amount of recyclables collected. Such information would assist DSS in calculating waste diversion rates, setting goals, and monitoring progress toward those goals. If private haulers do not submit the annual reports, DSS can notify the Department of Business Affairs and Consumer Protection (BACP) and prevent the renewal of the private hauler’s business license.

In addition, OIG evaluated DSS’ enforcement of reporting requirements for the City’s licensed private haulers—companies engaged in hauling refuse and recyclables from commercial and high-density residential buildings. OIG found that DSS did not thoroughly enforce the Ordinance. DSS’s Mobile Electronic Ticketing System (METS) did not allow DSS staff to issue citations for Ordinance violations, creating a significant barrier to enforcement. DSS did not maintain a list of commercial and high-density residential buildings subject to the Ordinance; further, DSS did not ensure that private haulers submitted complete, accurate, and timely annual reports detailing the buildings they served and the amount and type of materials hauled.