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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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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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53 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.