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2
Factors Affecting Industrial
Decisions About Hazardous
Waste Generation
INTRODUCTION
Prior to the recent national focus on hazardous waste,
industry had few incentives to reduce the generation of
hazardous waste. As a result of legislative and regula-
tory changes implemented under the Resource Conservation
and Recovery Act of 1976 (RCRA) and increased public
awareness and concern, there now are important reasons
for waste generators to consider using methods to reduce
generation of hazardous waste. These reasons include the
following:
.
Substantially higher costs for disposal of
hazardous waste
· Prospects of substantial liability for the costs
of remedial (cleanup) actions
· Risks of third-party liability, even where a
generator may not be directly responsible for improper
disposal of hazardous waste
· Potential for adverse public relations
Public opposition to local siting of hazardous
waste management facilities
.
As discussed in the preceding chapter, the amount of
hazardous waste reduction that has occurred in response
to these incentives is difficult to document. Although
waste reduction efforts have increased to some extent,
the successes have not been uniform across different
industries and within an industry. The committee believes
that significant opportunities remain to reduce further
the generation of hazardous waste. Government will need
to make additional efforts to encourage firms to
undertake this reduction.
17
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18
The committee believes that public policies that
directly control industrial processes through regulations
would be extremely complex from an administrative and
practical point of view. The sheer number of and
variations in industrial processes throughout the country
make effective administration of a program that specifies
required changes in industrial processes very difficult.
Moreover, waste reduction involves changes in manufactur-
ing processes, which have generally been outside the
traditional purview of environmental regulations. There-
fore, public policy approaches other than direct regula-
tion of manufacturing processes, such as incentives that
reinforce industrial decisions to change production
processes, are preferable. A close examination of the
factors that affect industrial decisions about waste
generation may reveal opportunities for public policy to
encourage industries to undertake waste reduction efforts.
Industrial decisions about the generation of hazardous
waste are the result of many choices made by manufacturers
in the course of doing business and the incentives
provided by society to favor some of these choices over
others. Some of the choices that can be made by an
individual manufacturer are illustrated schematically in
Figure 2.1.
The manufacturer's choice of the final product (Step
E) prescribes the choice of raw materials and processing
procedures or process chemistry (Steps A and B). At this
step, waste reduction through minimization and abatement
could be considered (Step C). The choices, in turn,
determine the quantity and kinds of residuals (Steps D
and F). For purposes of this discussion, the noneconomic
residuals can be divided into two categories--hazardous
waste (Step G) and other waste (Step H). Management of
the other waste is outside the scope of this study.
There are three possible dispositions for the
hazardous noneconomic by-products of production processes
(Step G). First, they may be recycled, reused, or
otherwise processed to yield economically useful products
(Step I). Second, there may be opportunities, such as
those listed in Appendix A, for conversion of hazardous
by-products to make them less hazardous or nonhazardous
(Step J). Third, the waste may be placed in the
environment (Step K).
Although Figure 2.1 is a simplification of actual
manufacturing processes, it indicates that the generation
of hazardous waste is the result of numerous interdepen-
dent technological, production, and marketing considera-
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19
A
Raw Materials
B
- ~ | Processes
r
D ~ E
Waste Reduction
through Minimization
and Abatement
.
Noneconomic Manufactured Economic
Resi lua I s Products By products
G ~ ~ ~ H
Hazardous Other
Waste Waste
1
1
~ 11
_1
1
Waste Reduction Conversion to
through Recycl ing Less Hazardous
or Reuse or Nonhazardous
r ~
Placement in the
Environment
1
FIGURE 2.1 The waste production process. See text for
an explanation of the steps.
Lions. The schematic representation of Figure 2.1 would
become more complex as additional interdependencies are
identified, but in this theoretical framework the
"solutions to the hazardous waste generation problem
appears relatively simple; either increase the cost of
hazardous waste disposal to the point where business
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20
managers would choose not to generate the waste in the
first place or make the cost of recycling or reuse so low
(even negative) that industries would be moved to
undertake recycling and reuse activities.
Economic forces, however, do not work as quickly or
smoothly as theory might imply. Choices could be limited,
for example, because information about existing tech-
nologies might not be available or attitudes within firms
might impede change. Some considerations are not under
the control of the corporate manager or production
superintendent.
Table 2.1 presents the major factors affecting indus-
trial decisions about the types and amounts of hazardous
waste they generate. The previous chapter suggested that
the role of each of the factors in industrial decisions
depends on the phase of development of the particular
firm's strategy for hazardous waste reduction.
The remaining sections of this chapter contain dis-
cussions of each factor and suggestions of opportunities
for public policy to take the factor into account. The
dynamic nature of the considerations should be kept in
mind as each factor is examined in detail.
TABLE 2.1 Factors Affecting Industrial Decisions About the Generation
of Hazardous Waste
Availability of land disposal
Attitudes toward change
Availability of information about waste reduction methodologies
Regulatory issues in reducing generation of hazardous waste
Needs for research and development
Capital costs
Issues in assembling, processing, and sale of recycled materials
Product quality standards
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COST OF LAND DISPOSAL
Hazardous waste management in the past has been skewed
in favor of land disposal, largely because costs were low
and risks to human health and the environment attendant
to land disposal were not appreciated. Land disposal
historically has been the least expensive alternative.
The low cost to waste generators of land disposal,
however, has not adequately reflected the long-term costs
to society of cleanup, possible health effects, irrever-
sible environmental degradation, and various other
consequences. The committee believes that the discrepancy
between the "trues cost and the current cost of waste
management options, in this case land disposal, is a
crucial factor that must be addressed in order to promote
actions to reduce the generation of hazardous waste. If
the costs could be assessed adequately, economics would
favor waste reduction or treatment over land disposal in
many instances. However, an economic evaluation of this
long-term true cost is probably not possible for the
following reasons:
.
there are
.
The long-term transport and fate of land-disposed
hazardous waste cannot now be reliably estimated, so that
significant uncertainties in estimates of
exposure.
· The long-term health effects of exposure to
hazardous waste are largely unknown.
· There are continuing uncertainties as to how
health and environmental effects should be translated
into monetary values, even if these effects could be
determined accurately.
· There are uncertainties concerning the
appropriate discount rate for such an evaluation, i.e.,
what the appropriate discount rate would be to weigh
society's responsibilities to future generations against
its responsibilities to current generations.
The current cost of land disposal may not accurately
represent the generators' total long-term costs either.
For example, while it is generally accepted that the
immediate out-of-pocket cost for landfilling renders it a
relatively inexpensive option, some generators use
landfills more sparingly than short-term economic
considerations would indicate. This practice occurs for
a variety of reasons, such as to avoid potential
long-term liability in the event that waste leaks from
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22
the disposal sites. Recent judicial and administrative
decisions concerning the liability of generators for
disposal site cleanup under the Comprehensive Emergency
Response Compensation and Liability ACt of 1980 (CERCLA;
PL 96-510) have highlighted the fact that generators may
be held liable for very large cleanup costs. Con-
sequently, many generators are becoming aware of the
potential longer-term costs associated with land disposal
and are altering their dependence upon this waste
management option accordingly. It is not clear whether
additional liability requirements would heighten this
effect, as statutory expansion of cleanup liability and
judicial expansion of potential civil liability to
injured third parties are already having a high impact on
how companies do business (Hall 1983). In addition, in
some instances certain wastes are restricted from land
disposal on a categorical or volumetric basis.
The rising costs of land disposal already are
becoming, and are likely to continue to be, an extremely
significant factor motivating industry to consider
changing their current waste management practices. For
example, quoted prices from nine commercial waste
management firms increased from $120-168 per wet metric
tonne in 1980 to $168-240 per wet metric tonne in 1981
for landfilling of drummed hazardous waste, and increased
from $44-55 per wet metric tonne in 1980 to $55-83 per
wet metric tonne in 1981 for landfilling of bulk
hazardous waste (Booz-Allen and Hamilton, Inc. 1982).
Public policy approaches, such as taxes and restric-
tions on land disposal, that maintain the current trend
of increasing costs to generators for land disposal are
likely to continue to promote interest in waste reduction
activities. Fees and taxes on the landfilling of waste
and waste-end taxes on the generation of waste, for
example, are direct mechanisms for making other waste
management options more competitive with use of landfills
for some waste.
ATTITUDES TOWARD CHANGE
Attitudes toward changes in industrial processes or
practices vary widely from firm to firm and affect the
implementation of strategies to reduce waste generation
Waste generators may be reluctant to take risks with
unproven technologies or to compromise other goals, may
be ignorant (or mistrustful) of alternatives, or may
.
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23
simply be uninterested in changing habits. These
influences could delay or prevent consideration of waste
reduction methodologies in the early phase of implementing
a waste reduction strategy.
A large component of corporate resistance to the use
of waste reduction methods comes from the managerial
level. For example, where on-site processing of waste
streams has been proposed to enhance opportunities for
recycling or reuse, managers may be reluctant to accept
the risks associated with reliability of the technology-
This conservatism results from the business manager's
important role of controlling current costs and allocating
resources where the needs and expected economic returns
are greatest.
During the design and development of new production
processes, there may be a tendency to select proven
technologies rather than to innovate with methods that
may generate less waste. End-of-pipe treatment generally
has been preferred over waste reduction processes because
the former approaches often do not require changes in the
production processes. Once a manufacturing process is
implemented, there may be even greater reluctance to make
major modifications in the operation. The risks of
installing waste reduction methods include the following:
.
Uncertain investment returns
Production downtime
Operational difficulties or product quality
problems
· Potential loss of proprietary information to a
waste reduction consultant
A "crisis orientation" among management can also
inhibit the implementation of waste reduction programs.
As discussed in Appendix B. an organized and comprehensive
waste reduction program is centered on an exhaustive and
systematic analysis of the reduction potential for each
waste stream a firm produces. In contrast, a firm may
apply one isolated reduction measure at a time in
response to new issues or regulatory measures. In some
cases, this piecemeal approach to waste reduction may
lead firms to Reemphasize waste reduction as soon as they
have made one incremental adjustment and to reassign the
engineers responsible for the innovation to other, more
traditional tasks.
The responsibility for increased attention to waste
reduction does and should extend throughout a corporation
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24
or a manufacturing facility to the production line, where
reduction ultimately must occur. Labor may resist
technological or procedural changes either because of a
reluctance to change habitual practices or because jobs
are perceived to be at risk. But successful waste
reduction depends on the day-to-day cooperation of
production employees, who often are in the best position
to identify some kinds of waste reduction opportunities.
They also are the ones who must implement new techniques
or practices. Often one of the most effective first
steps in a waste reduction strategy is to foster good
housekeeping practices in the shop, a step only production
employees can implement.
Ideally, firms may want to ensure that a corporate-
level commitment to waste reduction is understood and
accepted at all levels. In practice, this goal often is
elusive, partly because the individuals responsible for
waste management at larger companies usually are not
those responsible for overseeing research, engineering,
or production processes. Those involved in product
development or process design may not recognize problems
with waste disposal or the benefits of waste reduction.
Waste management officers in manufacturing may see their
role as securing the lowest-cost means for legal waste
disposal, often overlooking other possible objectives of
more comprehensive management strategies such as
recycling, reuse, or process changes.
The committee believes that in the early stages of
waste reduction efforts, good housekeeping and other
opportunities for waste minimization can be effectively
exploited. These opportunities tend to cost little.
Educational programs and information dissemination
provide the most promising public policy directions for
lowering attitudinal resistance and increasing the drive
to seek out and implement these types of activities.
Education of the design and development engineer on
the desirability of waste reduction can be valuable,
either as part of the engineer's formal education or as
part of on-the-job training. Public institutions and
professional societies could work with engineering
schools to ensure that study of the impacts of concen-
tration, source separation, and internal recycling on
waste generation becomes part of the standard curriculum
for process engineers. Dissemination of information
about opportunities for waste reduction can be enhanced
through trade shows, printed material, conferences, and
perhaps via government-funded demonstration projects. It
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25
could be that those responsible for plant operation
simply are not fully aware of the actual costs in lost
yield, waste-handling costs, disposal costs, and environ-
mental liability associated with the waste stream. If
the actual costs and opportunities are clarified, reasons
for applying new waste reduction technology may become
more clear.
Application of waste-specific accounting methods could
be beneficial in overcoming initial resistance to change.
With proper accounting, information could become available
on actual waste production, characteristics, variability,
and disposal costs.
AVAILABILITY OF INFORMATION
ABOUT WASTE REDUCTION METHODOLOGIE S
Some analysts argue that there has been little exchange
of information about the waste reduction techniques
already in use by some companies (Hirschhorn 1983, Sarokin
1983). Reducing the generation of hazardous waste
provides a company with a temporary competitive advantage
in a business where waste management costs are a
significant fraction of gross production or transaction
costs. Thus many firms seem reluctant to release
information about their waste reduction practices because
doing so might provide competitors with information on
confidential processes or the technology being used.
This lack of communication may delay or prevent firms
from considering changes in their waste management
practices and implementing simple, low-cost measures to
reduce waste generation. Lack of information may
particularly inhibit the adoption of waste reduction
strategies by small businesses, which often do not have
the resources to explore opportunities for waste
reduction on their own. It is interesting to note that
the United States has very few citations in the Economic
Commission for Europe's Compendium on Low-and Non-waste
Technologies (Economic Commission for Europe 1981).
Part of the reluctance of industry to disclose
information may be attributed to the fact that the
regulatory system is information-driven. Once the
success of one company in waste reduction becomes widely
known, the regulator often wants other firms to follow
its example. The originating firm often receives little
economic return for the innovation, and its competitors
benefit from the ability to use processes in whose
development they did not participate.
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26
Opinions differ on the degree of importance of the
confidentiality problem. In industries in which
processes are fairly uniform throughout the industry,
such as the electroplating and petroleum industries,
confidentiality may be a lesser consideration. The
competitive advantage between firms is gained by more
competitive products, decreased total costs, or increased
levels of service. In industries where the competitive
advantage results from differences in processes, such as
the chemical and pharmaceutical industries, confidential-
ity considerations may be more important.
The confidential nature of waste reduction methods may
be particularly significant for limiting the availability
of information about techniques for waste abatement and
minimization involving process modifications. The
availability of information about recycling and reuse of
hazardous waste may also be limited, not only because of
the potential economic advantage gained by successfully
recycling and reusing waste, but also because of the
possibility that competitors will acquire knowledge of
production processes through examination of the waste
stream.
Most waste exchanges (see section below on issues in
assembling, processing, and sale of recycled materials
for a description of waste exchange) and commercial
recyclers offer very stringent confidentiality assurances
to the generators who use their services. These agree-
ments often incorporate elaborate nondisclosure proce-
dures. Many vendors offering recycling equipment have
proprietary processes so that potential users cannot
develop the method themselves. Attention to confidential-
ity among vendors of recycling equipment may be greater
than it is among the generators themselves. However, no
clear consensus has developed concerning the degree to
which confidentiality considerations actually inhibit the
effectiveness of waste exchanges (Herndon 1983).
Patents do not generally provide a means for protecting
the confidentiality of waste reduction methods used by a
firm. Many waste reduction methods are not patentable
because the methods involve changes in operating practices
that are well known. For example, separation of waste
streams to permit recovery or improvements in housekeeping
practices may reduce the generation of hazardous waste;
these practices are not generally patentable though they
may need to be adapted to specific circumstances.
The committee is not optimistic about the possibilities
for overcoming the problems posed by confidentiality of
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27
information through stricter agreements or other arrange-
ments. Firms will always be reluctant to disclose
information about their processes that provide them with
a competitive advantage. However, governments, trade
associations, universities, and other institutions can
provide mechanisms for dissemination of generic
information about waste reduction techniques e Some of
these opportunities include the following:
Educational programs for generators, engineers,
and plant operators
· State-established authorities, university-based
groups, trade associations, and other appropriate groups
to disseminate information
· Competition for novel means to reduce generation
Workshops, conferences, technology transfer sessions,
and other educational programs can provide generic
information on how waste can be reduced in certain
industrial categories. States or trade organizations may
wish to fund studies of these generic possibilities and
to provide estimates of return-on-investment and other
economic and technical incentives to encourage the
industries to implement the procedures. These types of
efforts would be most successful in industries where
processes are not highly confidential. In addition, in
the education of process engineers an increased emphasis
on residuals could focus on the impacts of concentration,
source separation, and internal recycling on the
generation of waste.
Publicly funded authorities or university-based groups
could explore opportunities for waste reduction in
specific industries. The information obtained would be
made freely available.
.
State-sponsored competitions for industries to develop
novel means for reducing generation of waste could be a
mechanism to encourage industries to disclose method-
ologies for waste reduction. Besides a cash prize and
some very favorable publicity, the company may have to
disclose the methodology used so that other firms can
benefit from their work.
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34
In the near term, a series of steps can be initiated
that will move toward greater program predictability.
For example, government should clearly show its regulatory
intent for these materials by developing a priority plan
for implementation of RCRA. A comprehensive review could
be undertaken to locate and eliminate inconsistencies,
such as the relationship between RCRA and the pretreat-
ment program under the Clean Water Act, and loopholes,
such as the waste-oil program, in the regulations. A
program plan could be developed by EPA detailing the
manner in which RCRA will be implemented in those states
not qualifying for delegation.
Stringency of Standards
Standards that are too strict, too weak, or highly
variable can thwart progress in reducing hazardous waste
generation. In this discussion, "standards" refers to
both design and performance standards, as well as to
procedural standards such as the manifest system mandated
by RCRA. The term does not refer solely to some specific
numerical requirement. In the preceding section, it was
suggested that overly rigorous standards affecting
techniques of reuse and recycling may discourage the use
of these techniques. Elsewhere in this report it has
been suggested that insufficiently strict standards for
landfilling also may impede the reduction in generation
of waste.
It is theoretically clear that more stringent standards
will impose additional costs and therefore reduce the
generation of waste. The committee concludes that regula-
tions should be written to achieve health or environmental
goals and should be made as stringent as necessary to
achieve these goals. Nonetheless, excessive restraints,
unwarranted in light of perceived threats to public
health or environmental quality, should be avoided.
There are certain areas where changes in the standards
would bring about a reduction in waste generated, and
where such changes are appropriate to protect public
health and the environment. For example, the following
actions may be appropriate to protect public health and,
at the same time, encourage reduction in generation of
waste: (1) restricting materials allowed to be land-
filled, (2) rapid phasing out of old, inadequate fills,
and (3) strengthening requirements for long-term care.
Such changes would raise landfilling costs and bring
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about a reduction in generation, depending on relative
costs of other treatment and disposal options.
Degree of Success in Implementation of the Program
Implementation involves the setting of standards,
issuing of permits, and inspection and enforcement.
The
slow pace with which RCRA initially was implemented
likely did not encourage industry to pursue waste
reduction as vigorously as might have been expected
during the 1970s. Recently, the situation appears to be
improving. This year, for example, EPA has established a
priority procedure that will require new permits for
landfills and incinerators under the full provisions of
RCRA.
The committee does, however, wish to emphasize that
the current trend toward stronger program implementation
must be continued if reduction efforts are to be
maximized. As EPA or states undertake implementation of
the full regulatory program of RCRA, adequate resources
must be allocated to ensure that implementation is
successful.
There is some reason to believe that this needed
vigorous allocation of resources will not take place
unless a substantial new commitment is made at both the
state and the federal level. It appears that perhaps
fewer than half the states will qualify for full
delegation of RCRA. The committee is aware of no
specific budgetary plans within EPA that would enable it
to acquire the new resources to implement a complete
regulatory program in all the unqualified states. Such a
requirement would pose a substantial challenge to EPA.
Available resources at the state level may also not be
adequate. After two years of interim authority at the
state level, the noncompliance rate for phase I of the
RCRA program is over 60 percent in the priority areas of
groundwater monitoring, financial, and closure require-
ments (W. Ruckelshaus, U.S. Environmental Protection
Agency, letter to officials in state environmental
agencies, April 4, 1984). Resources and strong program
direction will be necessary to improve this situation.
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NEEDS FOR RESEARCH AND DEVELOPMENT
Residual materials are associated with almost all
manufacturing processes. If the ultimate societal goal
is to reduce waste generation to the lowest feasible
level, then the need for research and development, taken
to mean the aggregate activities needed to devise and
demonstrate technologies leading to as-yet-unproven means
for reducing the volumes of hazardous waste generated, is
an important one.
Methodologies exist to reduce hazardous waste
generation, but they are not universally used. Often
there are obstacles to implementation. For example, in
processes employing liquid-liquid extraction to reclaim
potentially hazardous solvents, the efficiency of mass
transfer depends on fluid velocities. In specific
applications, the waste stream temperature, flow rates,
pipe sizes, and other factors affecting fluid velocities
must be evaluated; in some cases in-place testing of mass
transfer is needed. These efforts are for adapting a
developed technique to a particular situation. In the
case of liquid-liquid extraction, one would conclude that
a technique was available and that research was not
needed to develop a new technology. However, unless
scientific and engineering staff were aware of this
solvent recovery procedure and were available to conduct
tests on design and to implement this solvent recovery
process, the unavailability of methodologies would be
perceived as a major constraint to reducing generation.
A number of individual facilities, corporations, or
industrial subcategories may have already implemented
available techniques and may have reached their practical
limits of waste reduction given currently available
technology. For this group, new technologies will be
necessary for further improvement. There are relatively
few such instances, however. On a national scale,
research and development of advanced reduction tech-
nologies is not crucially needed until the existing
opportunities are implemented and their impact known.
There are a multitude of opportunities for adapting
simple, low-cost practices already available, for
example, spray rather than tank rinsing in electroplating
or similar processes to reduce the amount of contaminated
solution requiring disposal; separation of cooling water
to avoid mixing with contaminated materials and to allow
reuse of the water; substitution of water-based adhesives
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37
for solvent-based ones; and caustic and acid reclamation
and reuse.
In the national perspective, as more reduction in
waste generation occurs, new techniques to accomplish
even greater waste reduction will need to be developed.
The importance of research and development thus will
increase with time as the majority of industries implement
currently available techniques and see the need to
undertake further reduction. Facilitating research and
development In certain industries, those for which new
technologies would make a significant difference,
eventually will become an important consideration in
public policy.
The current need among a substantial majority of
industrial generators is to encourage their adoption of
existing methods. This implementation requires substan-
tial resources for technical assistance, particularly for
small firms, and will lead to a steady increase in the
need to develop more complex methods for reducing the
generation of hazardous waste. Thus the need for
research and development will generally become important
in the future when existing techniques have been fully
utilized on a national scale.
The perception that waste reduction methods are not
available currently has a much broader effect than does
the actual lack of available techniques; both the
perception and the true needs can be addressed through
public policy. For example, means to address the needs
might include the following:
.
Devoting resources to demonstration of existing
methods in a wide variety of actual situations
· Implementing educational programs for generators,
engineers, and plant operators
· Funding a limited number of groups for research
and development
Instead of devoting the majority of the resources to
research, typically at universities and research
organizations, appropriate groups could be supported to
promote actual implementation. Such groups might be
organized at the technical level to provide guidance for
the plant engineering needed to tailor available
techniques to specific industrial facilities lacking
in-house personnel.
Educational programs also could provide access to
information about available waste reduction practices or
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to those familiar with such methods. Trade associations
could be helpful in keeping the industries informed about
available techniques. Local universities and colleges,
trade associations, and other appropriate groups could
organize workshops and conferences for industry groups.
In the select cases for which existing methods have
been exhausted, research and development is needed to
achieve further reductions in the generation of hazardous
waste. Funding of groups to perform research on waste
reduction methodologies would be a valuable investment.
Because research and development has a long lead time, a
well-developed, ongoing research effort on waste reduction
methods will allow an orderly transition to future
national waste reduction efforts as more industries
utilize available methodologies and need to develop new
approaches.
CAPITAL COSTS
In many cases, the lower operating and disposal costs
achievable with more efficient processes may enable waste
reduction initiatives to pay for themselves and eventually
to improve the profitability of a process. There are
many examples cited in the trade and popular press as
well as the technical literature (Campbell and Glenn
1982, Huisingh and Bailey 1982, Ministere de l'Environ-
ment 1981, Royston 1979). However, many companies,
especially firms whose plants are antiquated, may not be
able to justify the fixed capital investment some tech-
nologies require. Competition, domestic and inter-
national, often makes companies reluctant to invest in
waste reduction equipment or process changes when
economic advantages are not clear.
Capital costs of equipment may become significant
after industries have exploited the low-cost oppor-
tunities for reducing generation that generally represent
the first steps in waste reduction. Capital costs could
be a significant constraint as more capital-intensive
approaches are needed to achieve further reductions.
Public policy approaches that lower the actual capital
costs of waste reduction to industry may be important in
the future as the nation progresses in its waste
reduction effort and incentives are needed for
implementing sophisticated, high-cost technologies.
These approaches could include the following:
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39
· Low- or no-interest loans, with liberal repayment
plans, for reduction expenditures. The loans could be
offered by government to cover the cost of an environ-
mental audit to determine the optimal ways to reduce
waste generation as well as the capital costs of the
change itself.
.
Guaranteed loans extended to firms by private
investors, to make financing of waste reduction measures
easier to obtain.
· Tax deductions, tax credits for waste reduction
initiatives, or exemptions from the sales tax or import
duties for recovery or reduction equipment.
· Direct government subsidies to firms developing
reduction methodologies, in order to reduce the start-up
price of these investments.
· Government actions to allow and encourage smaller
firms to pool their resources to implement a joint
reduction strategy or construct and operate joint
resource recovery facilities.
A problem with any type of government subsidy for
waste reduction is in implementing the program and
establishing whether the firm in fact qualifies for the
subsidy. The approaches discussed above need to be
analyzed in detail to determine their merit in various
situations.
ISSUES IN ASSEMBLING, PROCESSING,
AND SALE OF RECYCLED MATERIALS
Recycling is an important option for reducing the
generation of hazardous industrial waste. Both on-site
and off-site recycling can be significant on a national
scale. In this section, the focus is on impediments to
off-site recycling and how these can be overcome. On-site
recycling generally involves the same factors as waste
abatement and minimization, as discussed elsewhere in
this chapter.
According to EPA estimates (Westat 1984), of the 264
million metric tonnes of hazardous waste generated in
1981, only a small portion was recycled. Nevertheless,
recycling appears to be an increasingly attractive option
to generators; the number of generators recycling waste
increased from 5700 prior to 1981, to 6100 during 1981,
and to 7800 after 1981.
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Waste exchanges are one mechanism for promoting
recycling of hazardous materials. They provide a
mechanism for a user of materials to identify a waste
generator producing a reprocessed or reused material that
can be used. Typically, listings of wastes wanted and
wastes available are provided to the exchange, which
publishes the lists periodically. Inquiries about listed
materials are forwarded by the exchange to the generators.
This arrangement allows firms to advertise their feed-
stocks or waste without disclosing proprietary information
that might compromise their competitive advantage (Dorn
and McAdams 1982).
Passive exchanges or clearinghouses broker only
information on materials wanted and wastes available.
They are usually small, nonprofit groups, subsidized or
wholly funded in some instances by state and regional
governments. Because passive exchanges focus on materials
of unknown or unrecognized value (i.e., materials
generally regarded as waste), they do not compete with
commercial or industrial brokers of by-products. Active
exchanges or materials exchanges, on the other hand,
actually accept or purchase wastes, reprocess them, and
sell them at a profit. Therefore they usually handle
waste with high market value (Dorn and McAdams 1982,
Gaines 1982).
The first waste exchange in the United States began
operating in St. Louis in 1975. AS of 1982, 34 waste
exchanges were active in the United States and 17 in
foreign countries (Dorn and McAdams 1982). The effective-
ness of waste exchanges and the problems associated with
their use for hazardous waste are described by Gaines
(1982).
Waste exchanges have met with varying degrees of
success in this country (Herndon 1983). The obstacles to
successful operation of waste exchanges are largely the
same as those that impede the development of other
off-site commercial recycling facilities, as discussed
below.
Several successful recycling programs currently are
making effective and economic use of hazardous waste.
The best example is solvent recycling both on and off the
site of commercial facilities. The technology for
solvent recovery (distillation) is well established (U.S.
EPA 1981). Solvents contaminated with a wide variety of
impurities can be successfully processed. The resulting
products readily meet exacting specifications and are
sold into the market below the price of virgin solvents.
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Other waste streams may be less successfully recycled,
because of one or more technological, economic, practical,
or other factors. There are several technical obstacles
to the recycling of hazardous waste. Nominally identical
waste streams may differ between plants and between
batches from the same plant; this variability in raw
material can make processing difficult. Recyclers in
general have difficulty, and hence tend to avoid,
separating and purifying complex mixtures of waste. In
some areas, technology is not available, and in other
areas, technology has been developed but is not
economical.
There also are economic constraints to establishing
recycling facilities. Transportation costs, for example,
can be a major determinant of the economics of recycling
high-volume, low- concentration waste. The uncertainty
of quality and quantity of waste can lead generators to
lack confidence in their supply of recycled materials;
this can inhibit the development of markets for recycling
facilities.
Certain other practical considerations also make
recycling less attractive. Industry often is faced with
liabilities connected with waste transfer, such as under
the "joint and several liability provisions of CERCLA.
In general, liability issues have yet to be clearly
resolved under either state or federal regulations (see
Hall 1983). In response to this concern, many generators
prefer on-site to off-site recycling. However, industry
often may perceive on-site recycling as an undesirable
venture into another business.
Concerns about confidentiality and trade secrets often
hinder waste exchanges, as discussed under the section,
unavailability of Information About Waste Reduction
Methodologies. n In addition, continuous revisions in
regulations and uncertainties about future regulations on
recycling make entrepreneurs reluctant to develop
recycling facilities. Another factor that may limit the
availability of recycling facilities is public resistance
to the siting of such facilities.
These issues are related to many of the other factors
described in this chapter. The development of markets
for recycled materials is in part related to the
predictability of the regulatory system because a market
will develop in response to a regulatory system only if
the latter is predictable. In addition, product quality
standards are involved in situations where more lenient
product specifications would enable generators to use
recycled materials in their production processes.
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Approaches that could encourage the development of
recycling facilities include the following:
· Increasing procurement of recycled materials or
materials containing some recycled component. The
Resource Conservation and Recovery Act (42 USC 6002)
requires EPA to encourage the use of recycled material
government projects, "given reasonable levels of price
and performance. n In addition, increasing procurement by
industry would encourage recycling, although industry
would tend to procure recycled materials only if it was
economic. Study is necessary to delineate materials that
are good candidates for procurement programs, including,
for example, paints, thinners, and ferric chloride wastes
· Streamlining federal and state regulations so
that they treat recycling plants more like ordinary
chemical processing plants. With tighter enforcement and
financial assurance requirements, recyclers could be
regulated with more flexibility without unreasonable risk
to health and environmental quality.
· Increasing public education to demonstrate that
properly managed recycling can mean less danger from
waste, not more. This may ease the difficulties in
siting recycling facilities.
· Increasing financial assistance to waste
exchanges so that they can play a more active role in
arranging for recycling and reuse of materials.
PRODUCT QUALITY STANDARDS
.
A product quality standard is a description of a
commercial product. The standard may have been developed
by the supplier of the product, by the purchaser
(particularly military and civilian government procure-
ment), or by a standards-setting organization. Regardless
of its origin, the purpose of the standard is to describe
the characteristics of a product in a manner that can be
relied upon by both buyer and seller. The specifications
that make up a product standard may relate to any
characteristic of the product, including the aesthetics
of the product, its ability to function in its intended
application, health and environmental risks, and
acceptable levels of impurities.
Product quality standards can be a factor in industrial
decisions about waste generation. A nonfunctional
standard specifying the aesthetic characteristics of a
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product could, for example, limit the opportunities for
implementing waste reduction technologies. Modifying
product quality standards could increase the opportunities
for process change or redesign of products leading to
waste reduction and thereby lower the technological,
economic, or noliticallv ac~nt~hl" 1 imil" For Manic
~ .= ~ ~ ~ ~ ~ ~
generation. For example, in the electroplating industry
bright cadmium plating is important for the aesthetics of
the product but is not necessary for protection of the
finish. If existing specifications for certain cadmium-
plating applications were relaxed, cadmium and cyanide
concentrations in the waste could possibly be substan-
tially reduced.
Relaxing product quality standards would enable some
industries to reduce their generation of hazardous waste
through process changes and raw material substitution
important for waste abatement and minimization. In some
instances, recycled materials could be substituted for
virgin raw materials as feedstock in the production
process. These opportunities undoubtedly vary between
types of industries and even between processes within an
industry. The opportunities must be studied on a
case-by-case basis.
Relaxation of standards also could expand opportunities
to prevent some off-grade products from being discarded
as hazardous waste. This would be possible where out-of-
specification products are hazardous and are discarded as
waste instead of recycled, mixed with other batches of
products to produce a blend that is within specifications,
or sold for uses that can tolerate out-of-specification
products. Whether such opportunities are substantial can
vary enormously depending on current commercial practices.
In general, the initiative to alter a product standard
rests in the hands of the organization that established
the standard. For example, a standard established by a
manufacturer of a-product can be changed by the manufac-
turer, though the manufacturer may be influenced to
initiate such changes by pressures from customers,
government, other standards-setting organizations, or the
public. Unfortunately, the organization setting the
standard often does not recognize or is not aware of the
hazardous waste that may be generated because of that
standard. This gap is a severe constraint.
Changes in a standard established by a commercial
organization may be difficult to make because of
competitive pressures. Nonetheless, there may be some
instances in which either a purchaser or a seller has
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established specifications that no longer have
significant commercial importance but that do affect the
amount of hazardous waste that is generated.
The consumers of products play a significant role in
taking initiatives to change product quality standards.
Consumers include the government, both civilian and
military, and industries as well as the public at large.
Though they generally would not be aware of the relation-
ship between particular specifications and the generation
of hazardous waste, consumers nonetheless can identify
those specifications that are essential from the point of
view of the utility of the products they purchase. For
example, industrial or government consumers could invite
suppliers to bid against pared-down specifications. They
might also talk with suppliers to bring the relationship
between specifications and waste generation into better
focus. These actions could be particularly important for
government in its role as a consumer of products.
Individual corporations can examine their product
specifications to identify instances in which obsolete or
nonfunctional specifications stand in the way of reduction
of waste generation. Trade associations and standards-
setting organizations can consider whether modification
of specific, nonfunctional specifications could lead to a
reduction in the generation of hazardous waste. Also,
federal, state, and local government agencies can
initiate dialogue with suppliers to identify specific
opportunities for standard rewriting that would start to
focus on waste reduction. As noted earlier, however, the
connection between a product standard and the generation
of hazardous waste is poorly understood by the standards-
setting organization and the public. This constraint can
be overcome by (1) clearly identifying the linkage in a
reasonably quantitative way and (2) implementing an
educational program to disseminate this information.
Conceivably, explicit attention to this subject by a
specially constituted group organized under the auspices
of an appropriate private organization or public
institution could identify--industry by industry--the
specific opportunities that merit attention. Finally,
the relationship between specifications and waste
reduction may be an appropriate subject for attention at
academic institutions, particularly by means of
industry-sponsored research grants.
Representative terms from entire chapter:
hazardous waste
