or shift supervisor. No periodic testing is required in the operator-certification standard to ensure that the hundreds of operators who received certification in the first few years of credentialing are well versed in the newer technologies or regulations. The ASME created a sister committee to the QRO to develop operator certification for medical-waste incinerator operators.

REGULATORY COMPLIANCE AND ENFORCEMENT

The effectiveness of the panoply of regulations governing waste incineration depends on compliance by incineration facility operators and enforcement of the regulations by federal and state environmental regulators. In general, greater regulatory attention has been paid to securing initial compliance with technologic requirements than with monitoring and ensuring continuing operational compliance (Russell 1990). Audits and assessments of regulatory activity in waste incineration may be rare. Accordingly, it is difficult to assess the full extent of operator noncompliance with regulations or the efficacy of regulatory oversight in policing incineration activity. The absence of data is important. According to Reitze and Davis (1993), “the yet unproven ability of our regulators to effectively control emissions over the life of a facility” is a weakness that undercuts the conclusion that incineration “is a rational option for managing solid waste.”

Siting, Startup, and Initial Compliance

Regulations concerning the siting and permitting of new facilities are elaborate. Much regulatory attention is directed toward ensuring that the requisite technology is incorporated and operational in new facilities and that standards are satisfied. Nonetheless, among grassroots environmental activists and mainstream environmentalists there is a high level of dissatisfaction with the regulatory process regarding the siting and permitting of waste incineration. The points that follow do not constitute a complete catalog of the complaints but are among the most-often voiced. Also, it is important to keep in mind that all local residents do not necessarily share these concerns.

Citizens have several kinds of objections to risk assessments. Citizens complain that the data used are hypothetical, that they are not necessarily related to the potentially affected community and the particular facility. To the extent that the facility's risk is assessed in terms of increments to background risk, populations already subject to cumulative risks from other pollution sources are disadvantaged; poor and minority-group communities often feel especially vulnerable in this regard. Moreover, a risk assessment is not a public-health assessment. After a risk assessment has been done and a facility is sited and begins operation, there often is no follow-up to determine whether the assumptions on which the risk assessment was based are true. Community advocates argue that there



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