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Summary of Analysis
and Conclusions
This report examines key institutional, or nontech-
nical, factors that affect the generation of hazardous
waste by industry. It provides a framework for evaluating
public policies, both regulatory and nonregulatory, to
reduce the generation of hazardous waste. In undertaking
its task, the committee recognized that the report itself
was not expected to provide detailed solutions; rather it
was expected to provide a foundation upon which improved
public policies for hazardous waste management could be
built.
The report's underlying premise is that waste reduction
should be an integral component of any national waste
management strategy. For the purposes of this report,
"waste reductions refers not only to in-plant process
modifications that reduce the volume or degree of hazard
of hazardous waste generated, but also to reuse and
recycling practices.
This report is one of the first to deal with nontech-
nical factors affecting the generation of industrial
hazardous waste. Because little study has been devoted
to this topic, committee members have relied on the
presentations made to the committee, reports cited in
Appendix C, workshop discussions, and ultimately their
own experience-and judgment in formulating their
recommendations. The committee hopes that this report
will stimulate public discussion of this subject.
FINDINGS
1. Development of industrial waste reduction programs
is a dynamic process that can be expected to grow in
sophistication over time in three identifiable phases.
1
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The considerations affecting decisions by individual
firms to reduce hazardous waste depend on the phase of
development of the individual waste management programs.
The committee has distinguished three phases in the
development of industrial waste reduction programs. In
reality, the phases overlap; they nonetheless provide a
helpful guide for discussing the relative importance of
different considerations at different times and for
different firms.
In the initial phase, firms consider for the first
time changing their current waste management practices in
order to exploit low-cost waste reduction opportunities.
These first steps typically involve relatively unsophis-
ticated technical approaches such as "good housekeeping"
practices and separation of waste streams. Although they
are technically simple, these first steps often achieve
substantial waste reductions.
The second phase of waste reduction programs is the
development phase. In this phase, firms review and
implement more comprehensive strategies. The principal
characteristic of waste reduction activity in the
development phase is the increasing sophistication of the
technology of waste reduction and the associated challenge
to the engineering, operating, and financing skills of
the firm's management. The capital expenditures in this
phase are often greater than in the initial phase.
In the third phase of waste reduction efforts,
designated in this report as the mature phase, firms
begin to confront the political, economic, and technical
limits of waste reduction activities. This phase is
marked by requirements not only for technical sophistica-
tion in waste reduction, but also for a sophisticated
risk assessment and management program for both industry
and the nation.
2. Nontechnical considerations critical to waste
. .
reduction decisions vary in importance as waste manage-
ment programs become more sophisticated.
In the initial phase, when firms first confront the
need to change waste management practices, public
policies, to be effective, should emphasize the
dissemination and use of available technologies through
the following:
· Educational programs for waste generators and
engineers
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· Dissemination of information through state-
established authorities, university-based groups, trade
associations, and other appropriate groups
· Fostering of competition for novel means to
reduce generation
· Public demonstration of existing methods in a
wide variety of actual situations
· Assistance to waste exchanges to enable them to
play a more active role in arranging for recycling and
reuse of materials
Programs to improve information dissemination and use
are worthwhile in all phases of the waste reduction
effort, but they are especially useful in the initial
phase because of the relative lack of knowledge about
waste reduction practices among many firms. Also, they
are especially appropriate for small businesses, which
may lack specially trained personnel.
Public policies in the initial phase should also be
sensitive to the incentives for waste reduction created
by "command and control" regulatory means. This
sensitivity requires the following:
.
Evaluation of existing legal exemptions to
determine whether such exemptions inadvertently reduce
incentives for waste reduction
· Changes in procedural requirements to allow
greater flexibility for recycling and reuse
· Strengthening some standards to encourage waste
reduction practices: (1) restrictions on materials
allowed in landfills, (2) rapid phase-out of old,
inadequate fills, and (3) strengthened long-term care
requirements for land disposal options
· Effective program implementation to assure that
the incentives for waste reduction reflected in regulatory
standards are also reflected in actual practice
· Increasing the cost to waste generators for land
disposal to a level consistent with the total social cost
of land disposal options
Programs of regulatory reform and improvement are
especially important in the initial phase because
regulation can impart a critical strategic direction to
the nation's waste reduction effort.
In the development phase of the nation's waste
reduction effort, other factors can have priority.
Because many of the least costly approaches have been
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implemented in the initial phase, public policy must
address the financial challenges associated with the
implementation of increasingly sophisticated technologies
Loan or subsidy programs that were less important to the
first phase may become more important. Regulatory
approaches to provide the flexibility firms need to
exploit increasingly sophisticated and innovative waste
reduction methods are also needed.
Specific public policies important to this development
phase include the following:
Increased public education to ease siting
difficulties for recycling facilities
· Support for research and development needed to
adapt existing waste reduction technologies to individual
applications
.
Increased procurement of recycled goods for use
by government and other organizations
· Low- or no-interest loans, guaranteed loans, or
direct subsidies for waste reduction
· Tax deductions or credits for waste reduction
expenditures
· Support for joint reduction strategies and
facilities for small waste generators
.
Modification of product quality standards on a
case-by-case basis to encourage waste reduction
· Greater use of EPA authority to List and delist"
materials to encourage recycling and reuse
· Incorporation of the degree-of-hazard concept in
the regulatory framework
In the mature phase of the waste reduction effort,
research and development and risk assessment and
management programs are especially useful. Firms are
approaching the limits of technical sophistication in
waste reduction. Accordingly, basic research to develop
improved waste reduction methods is needed. Moreover,
because waste reduction is so sophisticated and costly in
this phase, there is a need for risk assessment and
management programs, which attempt to balance the
inevitably costly trade-offs that must be made between
competing social interests.
During the mature phase of the waste reduction effort,
public policies should therefore do the following:
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Define acceptable limits of waste reduction
through a program of risk assessment and management
· Support research on new waste reduction
technologies
CONCLUS IONS
1. The major portion of the industrial effort in the
nation is now in the initial phase of hazardous waste
reduction.
The committee observed that some firms and individual
plants are already well along in implementing sophis-
ticated waste reduction programs. In the committee's
judgment, however, most of the industrial efforts in the
nation are currently in the initial phase in the develop-
ment and implementation of hazardous waste reduction
programs. Significant opportunities exist to reduce the
generation of hazardous waste; priority should be given
to those public policies most suited to encourage such
efforts in the initial phase.
2. Two general policy principles apply to all phases
of the hazardous waste reduction effort:
.
It is essential to properly price treatment and
disposal during all phases of the waste reduction effort.
Industrial management will not have an incentive to
undertake waste reduction if waste treatment and disposal
options are priced below the true costs to society.
In particular, the committee believes that it is
essential to increase the cost of land disposal options,
such as landfills and surface impoundments, to bring
their costs more in line with the true social costs of
such options to the degree that these costs are currently
understood.
· It is generally desirable to reduce the
generation of hazardous waste. However waste reduction
,
should not be viewed as an end in itself. Regulatory
standards ought to be based on health and environmental
,
considerations.
Waste reduction policies should always be motivated by
the concern for environmental protection. This principle
applies in all phases of the waste reduction effort,
although it is especially important in the mature phase,
when the limits of technical, political, and economic
feasibility are approached.
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3. While policies appropriate to the initial phase of
the waste reduction effort are now needed, some actions
must also be taken now in anticipation of the nation's
transition to the second and third phases.
In particular,
· A clear definition of hazardous waste and improved
methods for obtaining data and tracking success in waste
reduction are needed.
· Efforts are needed today to assure the regulatory
flexibility necessary to accommodate the anticipated
growth in the technological sophistication of the nation's
waste reduction effort.
· Basic research on new waste reduction techniques
is central to success in the third phase. Research is an
activity requiring a long lead time, and basic research
should begin while the nation is still in the initial
phase.
.
Effective risk management is essential to success
in the mature phase, when the trade-offs between
protection of public health and the environment and costs
must be understood. Risk management requires a long lead
time and should begin while the nation is still in the
initial phase.
4. Regulation must play a continuing role in the
nation's overall waste treatment and disposal policy, but
nonregulatory means are currently most likely to lead to
waste reduction.
In encouraging the identification and implementation
of cost-effective and innovative ways to reduce the amount
of hazardous waste that will be generated, nonregulatory
approaches do not suffer from the same constraints
inherent in regulatory mechanisms that directly control
industrial processes. Nonregulatory approaches extend
the range of waste reduction alternatives available to
industrial management. As examples, information
dissemination programs make more waste generators aware
of waste reduction possibilities; financial incentives
make more of these options feasible; and support for
basic research on new waste reduction techniques
increases the options available in the mature phase.
These nonregulatory approaches to encourage waste
reduction should play a major role in the nation's waste
management strategy and should be discussed, evaluated,
and implemented as soon as possible.
Representative terms from entire chapter:
reduction effort
