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2. Factors Affecting Industrial Decisions About Hazardous Waste Generation
Pages 17-44

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From page 17...
... 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 .
From page 18...
... 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.
From page 19...
... 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
From page 20...
... 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
From page 21...
... 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, irreversible 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.
From page 22...
... 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.
From page 23...
... 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 technologyThis 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.
From page 24...
... 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 concentration, source separation, and internal recycling on waste generation becomes part of the standard curriculum for process engineers.
From page 25...
... . 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.
From page 26...
... 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.
From page 27...
... 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.
From page 28...
... However, this assertion is difficult to demonstrate statistically because the formal definition of hazardous waste has changed froin time to time and the techniques for estimating volumes generated are imperfect. The increased costs of treatment and disposal imposed by a regulatory program are assumed to lead to a reduction in hazardous waste generation.
From page 29...
... The manifest system can be viewed as a unique aspect of the inspection program, virtually mandating continuous accountability for hazardous waste transported off~site regardless of the government's ability to carry out inspections. Four attributes of the regulatory program appear to be critically important for industrial decisions about hazardous waste generation.
From page 30...
... With regard to the first point, RCRA and the regulations developed to implement it contain a series of blanket exemptions. Certain hazardous wastes have been excluded from regulation for a variety of reasons including technological feasibility, economic impact, or administrative complexity.
From page 31...
... . An operator who recycles hazardous waste by removing hazardous constituents (e.g., solvents such as toluene and metals such as chromium, lead, and zinc)
From page 32...
... Although explicit regulation came about only with the passage of RCRA in 1976, many of the actual businesses and processes involved in hazardous waste management developed in response to earlier legislation, particularly the Clean Water Act and the Clean Air Act. Regulatory practices involving volatile organic chemicals and pretreatment requirements under the Clean Air and Clean Water Acts, respectively, are areas where these statutes specifically address hazardous materials.
From page 33...
... Beyond that, it is unclear as to whether the final program, when implemented, will be managed by the federal or state governments. Whatever the reasons for this delay -- bureaucratic inertia, program complexity, political considerations, inadequate technical information -- the effect has been to defer the use of many of the techniques necessary for reducing generation of hazardous waste.
From page 34...
... 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.
From page 35...
... 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.
From page 36...
... Methodologies exist to reduce hazardous waste generation, but they are not universally used. Often there are obstacles to implementation.
From page 37...
... The current need among a substantial majority of industrial generators is to encourage their adoption of existing methods. This implementation requires substantial 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.
From page 38...
... 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.
From page 39...
... , 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.
From page 40...
... . The effectiveness of waste exchanges and the problems associated with their use for hazardous waste are described by Gaines (1982)
From page 41...
... 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.
From page 42...
... Product quality standards can be a factor in industrial decisions about waste generation. A nonfunctional standard specifying the aesthetic characteristics of a
From page 43...
... 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.
From page 44...
... Trade associations and standardssetting 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.


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