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Reducing Hazardous
Waste Generation
An Evaluation and a
Call for Action
Committee on Institutional Considerations in Reducing
the Generation of Hazardous Industrial Wastes
Environmental Studies Board
Commission on Physical Sciences, Mathematics, and Resources
National Research Council
NATIONAL ACADEMY PRESS
Washington, D.C. 1985
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NATIONAL ACADEMY PRESS 2101 CONSTITUTION AVENUE, NW WASHINGTON, DC 20418
NOTICE: The project that is the subject of this report was approved by the Governing Board of the
National Research Council, whose members are drawn from the councils of the National Academy
of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of
the committee responsible for the report were chosen for their special competences and with regard
for appropriate balance.
This report has been reviewed by a group other than the authors according to procedures
approved by a Report Review Committee consisting of members of the National Academy of
Sciences, the National Academy of Engineering, and the Institute of Medicine.
The National Research Council was established by the National Academy of Sciences in 1916
to associate the broad community of science and technology with the Academy's purposes of
furthering knowledge and of advising the federal government. The Council operates in accordance
with general policies determined by the Academy under the authority of its congressional charter of
1863, which establishes the Academy as a private, nonprofit, self-governing membership corpora-
tion. The Council has become the principal operating agency of both the National Academy of
Sciences and the National Academy of Engineering in the conduct of their services to the
government, the public, and the scientific and engineering communities. It is administered jointly
by both Academies and the Institute of Medicine. The National Academy of Engineering and the
Institute of Medicine were established in 1964 and 1970, respectively, under the charter of the
National Academy of Sciences.
Library of Congress Catalog Card Number 84-62248
International Standard Book Number 0-309-03498-1
Printed in the United States of America
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Committee on institutional Considerations
in Reducing the Generation of
Hazardous Industrial Wastes
RAYMOND C. LOEHR, Cornell University, Chairman
WILLIAM M. EICHBAUM, Maryland Department of Health and
Mental Hygiene
ANTHONY O. FACCIOLO, JR., Alexandria Metal Finishers, Inc.
(deceased)
SAMUEL GUSMAN, Taos, New Mexico
ROBERT A. LEONE, Harvard University
MICHAEL R. OVERCASH, North Carolina State University
PHILIP A. PALMER, E.I. du Pont de Nemours & Co.
STEFFEN W. PLEHN, Fred C. Hart Associates, Inc.
ROBERT B. POTASEK, Chas. T. Main, Inc.
MICHAEL E. STREM, Strem Chemical, Inc.
Staff
RUTH S. DEFRIES, Staff Officer
PAUL B. SCHUMANN, NRC Fellow
JOYCE E. FOWEER, Administrative Secretary
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Environmental Studies Board
STANLEY I. AUERBACH, Oak Ridge National Laboratory, Chairman
WILLIAM E. COOPER, Michigan State University
I. CLARENCE DAVIES, The Conservation Foundation
JOHN W. FARRINGTON, Woods Hole Oceanographic Institution
GEORGE M. HIDY, Environmental Research and Technology, Inc.
MARGARET HITCHCOCK, Fairfield, Connecticut, Consultant
WILLIAM G. HUNTER, University of Wisconsin
JULIUS JOHNSON, DOW Chemical (retired)
RAYMOND C. LOEHR, Cornell University
ROGER A. MINEAR, University of Tennessee
CLIFFORD RUSSELL, Resources for the Future
EDITH BROWN WEISS, Georgetown University Law Center
Stab
MYRON F. UMAN, Staff Director
WILLIAM M. STIGLIANI, Staff Officer
RUTH S. DEFRIES, Staff Officer
PAUL B. SCHUMANN, NRC Fellow
JANET A. STOLL, Staff Assistant
TOYCE E. FOWLER, Administrative Secretary
-
1V
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Commission on Physical Sciences,
Mathematics, and Resources
HERBERT FRIEDMAN, National Research Council, Chairman
ELKAN R. BLOUT, Harvard Medical School
WILLIAM BROWDER, Princeton University
BERNARD F. BURKE, Massachusetts Institute of Technology
HERMAN CHERNOFF, Massachusetts Institute of Technology
MILDRED S. DRESSELHAUS, Massachusetts Institute of Technology
WALTER R. ECKELMANN, Sohio Petroleum Company
JOSEPH L. FISHER, Office of the Governor, Commonwealth of
Virginia
JAMES C. FLETCHER, University of Pittsburgh
WILLIAM A. FOWLER, California Institute of Technology
GERHART FRIEDLANDER, Brookhaven National Laboratory
EDWARD A. FRIEMAN, Science Applications, Inc.
EDWARD D. GOLDBERG, Scripps Institution of Oceanography
CHARLES L. HOSLER, TR., Pennsylvania State University
KONRAD B. KRAUSKOPF, Stanford University
CHARLES I. MANKIN, Oklahoma Geological Survey
WALTER H. MUNK, University of California, San Diego
GEORGE E. PAKE, Xerox Research Center
ROBERT E. SIEVERS, University of Colorado
HOWARD E. SIMMONS, TR., E.I. du Pont de Nemours & Co., Inc.
JOHN D. SPENGLER, Harvard School of Public Health
HArrEN S. YODER, JR., Carnegie Institution of Washington
RAPHAEL G. KASPER, Executive Director
LAWRENCE E. MCCRAY, Associate Executive Director
v
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Preface
The Committee on Institutional Considerations in Reducing the Generation
of Hazardous Industrial Wastes was organized in September 1983 to explore the
nontechnical factors that influence decisions by industrial management to
reduce the generation of hazardous waste. The committee, sponsored by the
Andrew W. Mellon Foundation and National Academy of Sciences Endow-
ment funds, was asked to examine the public policy approaches that may lead
industries to reduce generation of hazardous waste. The report therefore fo-
cuses on reduction in generation of hazardous waste and not treatment, al-
though the committee recognizes that treatment alone or in conjunction with
reduction in generation can also be an effective approach to a specific problem.
Industrial decisions about waste reduction are made for varied and complex
reasons. The committee's task to understand these reasons was constrained by
the lack of comprehensive and systematic data on the amount of waste reduction
that has occurred over the broad range of industry and by the lack of extensive
literature on the nontechnical aspects of waste reduction. Therefore many of the
observations in the report are based on the presentations made to the committee,
reports on topics related to waste reduction, and workshop discussions. In
formulating its conclusions, the committee relied on these observations and on
the collective experience of its members with large and small firms, public
administration at the federal and state levels, and consultancy with industry (see
Appendix E). After considerable discussion, there was little disagreement
among members about the basic conclusions of the report.
Among the "institutional," or nontechnical, factors the committee con-
sidered were economic factors, such as capital costs of waste reduction equip-
ment; regulatory factors, such as stringency of standards; and psychological
factors, such as attitudes toward change. Many such factors were considered in
the course of the study, and some of them were not discussed separately in the
text for a variety of reasons. For example, public involvement and understand-
ing of industrial efforts to reduce the generation of hazardous waste is a factor
affecting decisions. Public involvement is related to many factors that are
vat
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presented, such as the public's role in ensuring a predictable regulatory pro-
gram; thus it is discussed in several different contexts throughout the report.
Time constraints did not permit the committee to look in detail into several
issues that members recognized as being important to the public discussion on
waste reduction. As mentioned in several places throughout the report, small
businesses face a unique set of nontechnical considerations in their decisions
about waste generation and reduction. The complex issue of the generator's
liability for remedial action and how it affects decisions about waste generation
is also important. In addition, a uniform definition of hazardous waste is
essential to devising an accepted way for collecting data on waste generation.
The committee hopes that this report will stimulate future work on these and
other issues that it has raised.
In~considering the relative importance of the various factors, the committee
concluded that no single factor or group of factors is the most important in all
circumstances. The relative importance of the factors depends on the dynamic
interplay of such variables as the type and size of the industry or plant and the
amount of waste reduction that has already been achieved. In this report, the
dynamic character of waste reduction programs is used as a framework within
which to explore the relative importance of the nontechnical factors and the
potential effectiveness of public policy alternatives at different stages in the
nation's waste reduction effort.
The committee conducted its study through a series of meetings and consulta-
tions with experts in the field. It reviewed many documents about hazardous
waste management and other related fields (see Appendix C), but, as mentioned
above, its work was constrained by the lack of peer-reviewed literature in the
area of waste reduction. Indeed, this is one of the first attempts at a comprehen-
sive work on institutional considerations. Many examples of achievements in
waste reduction were brought to the committee's attention. It is difficult to
generalize, however, from a series of examples where there are limited data to
suggest their wider applicability. Much of the report therefore represents the
personal experience and judgment of the committee after consideration of the
facts brought before it.
To test this judgment, the committee organized a workshop in May 1984 at
which a group of experienced people from industry, state and federal govern-
ment, and environmental groups (see Appendix D) were asked to discuss the
issues raised in this report. Discussion papers prepared by the committee were
circulated in advance and served as the focus of the interaction. The papers
discussed the institutional barriers to more effective waste reduction in the
United States. The workshop participants responded that to focus on the
barriers to waste reduction seemed unnecessarily negative, in that such a focus
did not highlight the achievements that have been made with waste reduction
and wrongly implied that opportunities for waste reduction are limited. The
. . .
vail
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committee then framed the ideas in this report in a more neutral tone, focusing
on "factors affecting industrial decisions about waste generation." The commit-
tee is grateful to the participants for their candid contributions to the discussion
and their helpful insights.
It is with great sadness that the committee reports that one of the members,
Anthony 0. Facciolo, Jr., passed away in June of 1984. He not only brought a
unique perspective to the committee both as a lawyer and as a manager of a
small metal finishing firm, but also brought pertinent insights and a personal
warmth.
The Hazardous and Solid Waste Amendments of 1984, the reauthorization of
the Resource Conservation and Recovery Act by the 98th session of Congress,
states that the national policy of the United States is, wherever feasible, to
reduce or eliminate the generation of hazardous waste as expeditously as
possible. Although this report was prepared before the final reauthorization of
RCRA, it analyzes actions that would accomplish the reduction in generation
called for in the Act.
The committee thanks the many people who provided data and their insights.
Adam M. Finkel assisted in the preparation of the text. Lori Segall catalogued a
considerable number of reports and other background material that were most
helpful. The committee also wishes to express appreciation to the NRC staff:
Ruth DeFries, staff officer for this study; Paul Schumann, NRC Fellow; Myron
Uman, executive director of the Environmental Studies Board; and Joyce
Fowler, administrative secretary, for their patience, long hours, dedication,
and competence. Finally, I want to thank my colleagues on the committee who
provided excellent professional experience and insight and who worked with
exceptional dedication and energy to bring this task to completion and this
report to fruition.
RAYMOND C. LOEHR
Chairman
1X
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Contents
Summary of Analysis and Conclusions .
Introduction......
Scope of the Study, 7
Definitions of Hazardous Waste, 8
Estimates of Hazardous Waste Generation, 9
The Role of Waste Reduction in Waste Management
Strategies, 11
Dynamics of Waste Reduction Strategies, 14
2 Factors Affecting Industrial Decisions About Hazardous
Waste Generation ..............................
Introduction, 17
Cost of Land Disposal, 21
Attitudes Toward Change, 22
Availability of Information About Waste Reduction
Methodologies, 25
Regulatory Issues in Reducing the Generation of Hazardous
Waste, 28
Needs for Research and Development, 36
Capital Costs, 38
Issues in Assembling, Processing, and Sale of Recycled
Materials, 39
Product Quality Standards, 42
Approaches for Encouraging Hazardous Waste Reduction
Introduction, 45
X1
17
. .45
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Approaches for Encouraging Firms to Reduce Hazardous
Waste Generation in the Initial Phase, 46
Approaches for Encouraging Firms to Continue Waste
Reduction Programs in the Development Phase, 52
Considerations in the Mature Phase, 53
References. .
Appendixes
A Hazardous Waste Management Methodologies .......
B A Typical Waste Reduction Program..............
C Additional Documents Reviewed by the Committee. .
D List of Workshop Participants................
E Biographical Sketches of Committee Members
x~
..... 55
61
64
.67
73
74
