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OCR for page 45
3
Approaches for Encouraging
Hazardous Waste Reduction
INTRODUCTION
The preceding chapter described the factors that
affect industrial decisions about hazardous waste
generation and the influence of public policy on the
factors. The relative importance of the factors in the
decision-making process of corporate waste management
undoubtedly varies according to the type and size of the
industry. As was pointed out earlier, small businesses
are faced with a different set of problems than are large
ones. Often the former may lack information about
existing waste reduction practices, may lack technical
personnel to investigate waste reduction, may be very
resistant to change, and may be particularly sensitive to
the capital costs of waste reduction. The importance of
each of the factors will also change with time as firms
and industries undertake and implement waste reduction
activities. The phases in a general waste reduction
program are described in Chapter 1 (see Figure 1.2).
On the basis of the discussion in Chapter 2, the
committee concludes that in the initial phase of
implementation of waste reduction strategies--when
industries or individual plants consider changing their
waste management practices and implement simple,
available, low-cost waste reduction methodologies--the
availability of relatively low-cost land disposal
options, attitudes toward change, regulatory issues, and
availability of information about existing waste
reduction methodologies are the factors that most greatly
affect industrial decisions about waste generation.
In the development phase, other factors become
important as industries require higher capital expend)
tures and research and development efforts to achieve
45
-
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46
additional waste reductions. In addition, after the
simpler, low-cost steps have been taken, firms may
investigate potentials for recycling or product changes.
Eventually, if trends to reduce generation are
encouraged to continue, a technological, political, and
economic limit for waste reduction will be reached. In
this mature phase, the challenge to society is to define
the acceptable limit of waste reduction in light of
changing political, economic, and technological
conditions.
Some firms and individual plants have achieved con-
siderable success in waste reduction and are well along
in implementing their respective reduction programs. The
committee is convinced, however, that currently the
nation as a whole is in the early stages in the develop-
ment and implementation of hazardous waste reduction
programs. Thus the major need for public policy now is
to inform and encourage generators to make the goal of
waste reduction an integral part of their day-to-day
decisions.
Because the importance of the factors discussed in
Chapter 2 changes over time and varies from industry to
industry and firm to firm, no single policy can hope to
encourage industries to reduce their generation of
hazardous waste. A complement of policies combining
educational programs, economic incentives and disincen-
tives, and regulatory approaches is needed. Because
changes in industrial processes necessary for waste
reduction are difficult to control through regulatory
action, nonregulatory approaches for public policy
require particular emphasis. All of these policies
should be flexible in order to address the changing needs
of firms. Table 3.1 summarizes opportunities suggested
throughout the report for public policies to encourage
waste reduction.
APPROACHES FOR ENCOURAGING FIRMS TO REDUCE
HAZARDOUS WASTE GENERATION IN THE INITIAL PHASE
Public policy approaches that would be most effective
in the initial phase would emphasize the following:
· Maintaining the current trend toward changing
land disposal practices
· Adjusting the regulatory system to encourage, not
impede, waste reduction efforts
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47
· Providing for nonregulatory actions such as
dissemination of information about successful, economic
waste reduction methodologies.
Cost of Land Disposal
The current cost of land disposal options is perhaps
the most significant factor affecting industrial decisions
about waste generation. Society has recognized that land
disposal options such as landfills and surface impound-
ments are not always a secure method for managing
hazardous waste. Continued reliance on such options may
impose significant risks to human health and the
environment. Although the ~true" long-term costs to
society of such options cannot be accurately determined,
it seems likely that current costs to the generator do
not reflect the net costs to society.
The committee believes that public policy should
attempt to increase the costs to generators for the use
of land disposal options that pose risks to public health
or the environment. If the costs of land disposal
adequately reflect the long-term costs to society, waste
reduction would be more economically attractive to
industry than it is now.
Recent trends show an increase in cost to generators
for land disposal. For example, costs of landfill
management have increased, due to requirements for
liners, specialized covers, leachate collection and
treatment, and groundwater monitoring systems; these
costs are passed on to the generators disposing of their
waste in landfills. Potential costs of liability for
remedial action and costs of liability insurance also add
to the costs of land disposal, as do costs of treatment
prior to disposal. In addition, assessment of fees and
taxes have increased costs to generators. Some states,
for example California and New York, have imposed
landfill restrictions on certain materials, and other
states are considering such regulatory action. All of
these factors have decreased the attractiveness of
landfills and surface impoundments as waste management
options.
The committee believes that the trend of increasing
costs of land disposal will continue. The committee
supports such increases, as long as they reflect the
costs of protecting the public health and the environ-
ment, as a positive step in encouraging a national effort
to reduce generation of hazardous waste.
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OCR for page 50
50
Regulatory Approaches
The regulatory system is an important factor shaping
industrial decisions about waste generation (see Chapter
2 on regulatory issues). The committee concludes that
regulations should be made as stringent as necessary to
achieve public health and environmental goals. Nonethe-
less, excessive restraints, unwarranted in light of
perceived threats to public health or environmental
quality, should be avoided.
The regulatory system should encourage firms to
undertake waste reduction activities where consistent
with environmental and health goals. One of the
regulatory actions that could be considered in this
regard is to evaluate existing exemptions and modify
where appropriate. Exemptions from RCRA, such as the
small generator and mining exemptions, may inhibit
progress in waste reduction even though they may exist
for valid extraregulatory considerations. The exclusion
removes external pressures on those generating the
hazardous waste to undertake reduction programs.
Certain changes in hazardous waste regulations would
be appropriate to protect public health and the environ-
ment and at the same time would encourage reduction in
waste generation. Consideration should be given to tl)
restricting materials allowed to be landfilled; (2) rapid
phasing out of old, inadequate fills; and (3) strength-
ening requirements for long-term care.
Effective implementation of the regulatory program is
also important to encourage waste reduction. As indicated
in Chapter 2, the current trend in program implementation
is favorable. Improvement must continue, however, because
illegal behavior can seriously impede the adoption of
reduction efforts.
The regulatory system could encourage movement toward
waste reduction by changing procedural requirements of
statutes to allow greater flexibility for recycling and
reuse. Once a waste is defined as hazardous, it is
generally treated in the same regulatory fashion
regardless of its ultimate fate. Thus, as the system
stands now, generators have no incentive to prefer waste
reduction to disposal unless there are economic benefits
associated with the former.
Many of the regulatory considerations concern
procedures that have been established at the federal
level. Therefore the regulatory approaches to encourage
waste reduction may require implementation at the
federal, rather than the state or local, level.
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51
Nonregulatory Approaches
Waste reduction activities involve changes in
industrial processes that are generally difficult to
control through command-and-control regulations. The
full range of public policies therefore must emphasize
nonregulatory approaches.
Although generators must develop their own techniques
for reducing waste, there are common elements that may be
incorporated in all programs. Information is gathered on
each waste stream, plans are developed for reducing the
high-priority waste in each identified waste stream, and
the economic and technical feasibility of the alternative
plans is assessed (see Appendix B).
The greatest current national need is for firms to
take advantage of the many opportunities for waste
reduction using simple, low-cost methodologies proven in
successful current programs. In general, there are few,
if any, financial impediments to this approach. The
committee concludes therefore that while financial
incentives such as funding for high-risk ventures and tax
credits for waste reduction equipment may be useful to
some industries or firms that need to undertake waste
reduction activities that entail high costs, public
policies to promote education and information dissemina-
tion are likely to be more effective in the near term.
Although the committee cannot predict how much waste will
be avoided through effective programs of information
exchange, such programs are likely to have an important
effect, particularly on the smaller firms for which the
lack of understanding of the possibilities and economics
of waste reduction represents a very critical barrier to
implementation of known techniques. The opportunities
for public policy to address these concerns include the
following:
· Educational programs for generators, engineers,
and plant operators
· Dissemination of information through conferences,
workshops, technical literature, and so on
· State-established authorities, university-based
groups, chambers of commerce, and other appropriate
groups to work with firms to implement waste reduction
practices
· Innovative approaches, such as competitions for
novel means to reduce the generation of waste or annual
awards for achievement, which encourage industries to
share information about waste reduction successes.
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52
Local and state governments, trade groups, univer-
sities, and other organizations familiar with the local
industries and waste management problems are better able
to carry out the information dissemination activities
than is the federal government. For example, workshops
can be organized by local groups to disseminate informa-
tion and provide opportunities for generators to trade
information on possibilities for waste reduction (see,
for example, Partington et al. 1983). Programs in some
states, such as North Carolina (Governor's Waste
Management Board 1983), New York (New York State
Environmental Facilities Corp. 1983), and Georgia (John
C. Nemeth, Georgia Institute of Technology, presentation
to EPA Small Business Ombudsman and Office of Compliance,
Planning and Policy, May 1984), disseminate information
on waste reduction and provide technical assistance to
waste generators. These opportunities should be reviewed
by other states embarking on such programs.
APPROACHES FOR ENCOURAGING FIRMS TO CONTINUE
WASTE REDUCTION PROGRAMS IN THE DEVELOPMENT PHASE
As firms or plants move from the initial phase, they
may have to use more sophisticated and expensive methods
to achieve further reductions. Some firms may already be
facing this challenge. As the waste reduction effort on
a national scale achieves this level of sophistication,
public policies will need to shift emphases to take into
account the factors that come into play.
Regulatory Approaches
In the development phase, the techniques for waste
reduction are increasingly sophisticated. The regulatory
program needs to be equally sophisticated and flexible.
Such regulatory approaches could include the following:
· 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.
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Nonregulatory Approaches
When waste reduction requires significant investment
of capital, policies incorporating financial incentives
and support for research and development to adapt
sophisticated waste reduction techniques to particular
circumstances may be important. Typical approaches for
public policy of this type could include the following:
· Increased procurement by government and other
organizations of recycled materials
· Low- or no-interest loans, guaranteed loans, or
direct subsidies for reduction expenditures
· Tax deductions or credits for waste reduction
expenditure;
· Support for joint reduction strategies and
facilities for small generators
· Support for groups conducting research and
development in waste reduction methodologies
For small generators with limited availability of capital
for waste reduction, financial incentives may be
particularly important.
Other types of considerations may also be addressed in
the development phase of waste reduction programs.
Examples include opportunities for altering product
quality standards and facilitating the siting of
recycling facilities.
CONSIDERATIONS IN THE MATURE PHASE
In the mature phase, the technologically, politically,
or economically acceptable lower limit of hazardous waste
generation would be approached. The challenge to society
will be to define this acceptable limit through a risk
managemen' program. The relationship between waste
reduction and reduction in risk to public health and the
environment will need to be clarified to define the
acceptable limit. Society will need to weigh the costs
of further waste reduction against benefits achieved.
To achieve waste reduction in this phase, it is likely
that increasingly sophisticated waste reduction tech-
nologies that require significant capital expenditures
will be needed. Basic research on new methods for waste
reduction may be an area of importance for public policy.
As the issues that will be important in this phase cannot
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54
be foreseen completely, the committee suggests that public
policy be implemented incrementally and be flexible to
adapt to circumstances as they arise.
Development of a risk management program and basic
research in new methods for waste reduction are both
activities that may require long lead times. The
committee suggests that these activities be initiated and
supported now to allow the nation to progress efficiently
to the mature phase of waste reduction.
Representative terms from entire chapter:
land disposal
