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Opportunities in Applied Environmental Research and Development Appendix A Waste Reduction: Research Needs In Applied Social Sciences A Workshop Report
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Opportunities in Applied Environmental Research and Development Summary How is it possible to reduce the mounts of waste that we generate and the environmental pollution that they cause, rather than continuing to spend vast sums to dispose of them, move them somewhere else, treat them, or dean up contaminated sites? A growing consensus now argues that it would be more effective and cheaper to prevent pollution and reduce wastes at their sources instead. The U.S. Environmental Protection Agency (EPA) recently undertook major new policy and research initiatives and created a new office to address these issues. This report summarizes a workshop on applied social science research needs in waste reduction held May 8-9, 1989, in Annapolis, Maryland, under the auspices of the National Research Council's Committee on Opportunities in Applied Environmental Research and Development. The workshop was one of four held at the request of EPA, the National Institute for Environmental Health Sciences (NIEHS), and the Agency for Toxic Substances and Disease Registry (ATSDR). The committee organized the workshops with the goal of assessing the state of the science in each area and recommending long-term research needs and opportunities for advancing the state of the science. This workshop focused on specific research needs in measurement of waste reduction, institutional and behavioral barriers to waste reduction, and policy incentives for waste reduction, recognizing that considerable thought already has been given to technological research needs. It also addressed research needs for waste reduction in several specific nonindustrial sectors (agriculture, counties and municipalities, and municipal wastewater management). The workshop identified a serious deficiency in federal research attention to the societal (as opposed to technological) choices necessary for waste reduction and to the relative effectiveness of public policies that influence such choices. WASTE REDUCTION Waste reduction is defined by EPA w include industrial input substitution; product reformulation; process modification; improved housekeeping;, and on-site, dosed-loop recycling. It also includes "environmentally sound recycling" and waste-reduction opportunities beyond the industrial sector through individual behavior patterns, such as consumption or disposal habits, driving patterns, and on-the-job practices. In practice, however, EPA's waste reduction research program to date has emphasized engineering research aimed at the efficiency of industrial processes. In the view of workshop participants, waste reduction must be rooted more broadly in a systematic approach to human use of materials and energy, not just in improvements in engineering or regulatory efficiency, nor in ad hoc campaigns to reduce particular materials or change particular behavior patterns. Participants noted that waste reduction is enhanced, for example, by such measures as reducing the number of processing steps between extraction and end use and the concomitant use of intermediate products such as packaging, increasing the life span and reusability of end products, conserving energy, and substituting more benign for highly toxic materials.
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Opportunities in Applied Environmental Research and Development APPLIED SOCIAL SCIENCE RESEARCH NEEDS In the view of workshop participants, the achievement of waste reduction requires not only research on low-waste technologies and their relative impacts on the environment, but also research on the human causes of waste and pollution and on the relative effectiveness of public policies intended to promote waste reduction and pollution prevention. Effective waste reduction cannot be achieved, for instance, without operational and consistent measurement concepts that are dearly linked to environmental protection purposes and to the realities of the production and consumption processes in which they are used. It cannot be achieved without systematic understanding of human behavior toward the environment, by individuals and by organizations, and of the factors that influence those behavior patterns either toward or against waste reduction and environmental protection. Finally, it cannot be achieved without empirical evaluation of the effects of public policy incentives, existing and proposed, toward advancing or retarding the achievement of environmental protection and other public policy goals. Understanding of environmental processes, health effects, and pollution control technologies is also necessary, but, without the information gained from applied social science research, this understanding will not be sufficient to meet waste reduction goals. Three specific examples of such opportunities and needs in applied social science research identified by the workshop are (1) the measurement of waste reduction, (2) the investigation of institutional and behavioral barriers to it, and (3) the comparative study of public policy options for encouraging it. Despite the importance of these social science issues, however, most of them remain virtually unaddressed by federal programs for applied environmental research and development. In the view of workshop participants, a key reason for this lies not only in the relative novelty of waste reduction as a policy objective, but also in the institutional barriers toward the types of research questions that exist within the field of applied environmental research, within the federal environmental research programs that support it, and within the research budget oversight process. The research programs of EPA's Office of Research and Development and its laboratories, in particular, have focused almost exclusively on the technical aspects of environmental management—environmental fate and transport of pollutants, health and ecological effects, and control technologies. EPA's staff of research program managers and scientists reflects those disciplines and priorities. Some studies of policy effectiveness and economic impacts have been sponsored by EPA's Office of Policy, Planning, and Evaluation, but, in the view of workshop participants, these do not provide an adequate substitute for a coherent and adequately supported program on the social science and management aspects of waste reduction research. To carry out an effective policy of waste reduction and pollution prevention, therefore, workshop participants concluded that it is important that federal environmental research programs make applied social science research on environmental management an explicit and integral element of their agendas. Participants asserted that sustained research on these social science issues will be just as important to the achievement of waste reduction and pollution prevention as will research on the more technical aspects of environmental science and technology. Important opportunities exist for the integrated pursuit of applied social science and technical research on environmental management, as well as a serious need to redress the relative lack of attention to the former. MEASUREMENT Participants agreed that, as a public policy goal, waste reduction must be defined and measured at the level of the individual waste generator or manager (business firm or operation, household or institution, urban jurisdiction, etc.) and across the aggregate of human involvement in processes of materials and energy extraction, conversion, use, and disposal. No single definition or measurement will serve all waste reduction purposes and needs; multiple measurements are needed. Workshop participants suggested the following specific research topics: Identifying useful indicators and measurement units for each purpose and
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Opportunities in Applied Environmental Research and Development identifying relevant differences in their applicability to industry, government, and other waste-generating sectors, such as minerals extraction, agriculture, commercial and institutional activities, and consumption; Measuring the postproduction waste implications of major commodity chemicals and other products as incipient wastes over their life cycles and evaluating claims that particular products are ''environmentally friendly"; Measuring the waste reduction effects of complex capital investment decisions, such as future wastes that are avoided, in addition to incremental reductions within existing production processes; Relating plant-level measurements of waste reduction to the combined effects of waste reduction by multiple sources at regional and national scales and developing aggregate estimates of the quantifies of waste that might prove reducible; and Attempting to develop consensual definitions for terms related to waste reduction. INSTITUTIONAL AND BEHAVIORAL BARRIERS When presented with information showing the benefits of waste reduction, many waste generators show surprisingly little interest in change, even if their own apparent economic interests would be served. Important institutional and behavioral barriers to waste reduction appear to exist even within the business sector, and it seems likely that the perception of similar or additional barriers affects the behavior of other waste generators, such as agriculture, government and other nonprofit institutions, and households. Institutional and behavioral research efforts on waste reduction are in their infancy, but workshop participants identified substantial bodies of related theoretical and empirical evidence that could be applied to this task. Such evidence includes business research on accounting and financial analysis methods; on management of technological innovations; on organizational behavior and corporate strategic decision making; and on the behavior of other organizations and individuals, including recycling, energy and water conservation, and others. Workshop participants suggested the following specific research topics: Refining accounting rules to more accurately reflect waste management costs and value recovered materials and to define uniform minimum standards for disclosure of environmental impairment risks; Developing methods for incorporating waste reduction into technological innovation and capital investment decisions and for identifying the advantages waste reduction offers in strategic corporate decision issues; Systematically evaluating the anecdotal literature of waste reduction innovations to identify measures of success and major influences on waste reduction behavior (e.g., type of incentives, size of organization, type of technology, and organizational goals and internal structures); and Identifying incentives that might be most effective in influencing waste reduction behavior outside the business production sector, such as by government agencies, nonprofit institutions (e.g., schools, hospitals, and universities), households, and others. POLICY INCENTIVES Governments are the source of many initiatives intended to encourage waste reduction, such as regulations and enforcement, taxes and subsidies, and information and technical assistance programs. Governments are the largest procurers of materials and energy in society as well as major generators of wastes and, in most communities, they are also the primary providers of waste collection and disposal services and can create additional incentives through the management and pricing of those services. Nonetheless, governments also provide incentives for other purposes that might contact with waste reduction, such as subsidizing raw materials extraction. A third important set of research needs, therefore, concerns the effects of public policy incentives on promoting or retarding waste reduction. Three particular needs were distinguished by the workshop participants: documentation of existing policy incentives regarding waste reduction, including legislative and administrative mandates, and comparative evaluation of their effects; refinement of the economics of waste management to include the implications of waste reduction; and
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Opportunities in Applied Environmental Research and Development implementation and compliance issues. Workshop participants suggested the following specific research topics: Identifying existing government policies that encourage or discourage waste reduction behavior, including the effects of programs intended to promote waste reduction in the United States and abroad, and assessing the magnitude of their effects; Identifying differences in policy incentives needed to affect the waste reduction behavior of small businesses, not-for-profit institutions, and households, as opposed to large business organizations; Advancing understanding of the economics of waste reduction, especially by determining how economic analysis can be properly applied to waste reduction and used to compare it with alternative approaches to waste management; Evaluating impacts of alternative waste reduction incentives on illegal dumping and other compliance problems; and Identifying what types of educational programs or other incentives are effective in encouraging end users to make waste reduction a priority in their decisions regarding purchases and disposal NONINDUSTRIAL SECTORS: THREE EXAMPLES Beyond the general research needs identified above, workshop discussion groups identified three types of waste sources outside the industrial sector to which additional research attention should be devoted: agriculture, counties and municipalities, and public wastewater treatment operations. Other important sectors were also noted, such as building construction and the packaging of consumer products, but given the limited time available, the groups devoted their efforts to these three sectors. Agriculture Often overlooked in the focus on industrial waste reduction, the agricultural sector is a large and important source of waste discharges and consequent environmental pollution, ranging from pesticides and fertilizers to soil erosion, salination, and animal wastes. The participants thought that, in principle, waste reduction in agriculture could be advanced by a shift from chemical-and energy-intensive agricultural practices, which combine high crop yields with high costs, to ''low-input" agriculture, which combines somewhat lower crop yields with lower costs and more efficient use of chemical inputs. However, careful research is needed on the actual waste reduction benefits resulting from changes in agricultural practices. Workshop participants suggested the following specific research topics: Investigating how well low-input agriculture is working—on what crops, at what scales, and with what effects on yields, costs, and environmental impacts compared with more intensive alternatives; Identifying what factors have most strongly influenced farmers to adopt low-input practices and what policy incentives most effectively encourage these forms of agricultural waste reduction; Identifying appropriate and effective waste reduction practices for animal and other operations and for new configurations of integrated farm businesses; Identifying the waste implications of existing agricultural policies such as pesticide regulations, federal grading standards for agricultural products, grazing fees, and commodity price supports; and Determining how farmers and other consumers (such as golf-course operators, parks departments, utility firms, and homeowners) actually use high-risk pesticides and fertilizers. County and Municipal Governments Local governments are not only regulators but also sources and primary managers of many waste streams, and as a group, they represent a large number of decision makers who face similar problems in managing wastes. However, they have not received the attention and research support for waste reduction that industry has. Most have relied heavily on traditional landfilling practices, the rapidly rising costs of which now make source reduction and recycling far more attractive as alternatives than in the past. Applied
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Opportunities in Applied Environmental Research and Development research is urgently needed, therefore, on policy and technological options for waste reduction by county and municipal governments. Workshop participants suggested the following specific research topics: Developing generic protocols for identifying waste reduction opportunities for county and municipal governments, in their own operations and in the waste streams that they regulate and manage; Evaluating how well existing local waste reduction initiatives are working: their effectiveness in reducing wastes, their cost, their applicability to larger scales or more general use, and other implications; Evaluating public willingness to participate in new management programs, to comply with new costs and requirements, and more generally, to modify the material and energy intensities of the public's lifestyles; and Evaluating the economics of waste reduction for local governments, including particularly the costs and benefits of alternative methods for waste reduction and the economics of marketing and procuring recovered materials by local governments. Waste Reduction in Municipal Wastewater Management Public wastewater treatment plants discharge wastes themselves and receive wastes from others. Through such instruments as pretreatment requirements, pricing policies, and sludge management activities, treatment plants have important opportunities to further waste reduction; but by the same token, they might also be affected by chemical substitutions and other waste reduction activities of their dischargers. Workshop participants suggested the following specific research topics: Determining the effects of chemical substitutions and other waste reduction initiatives by dischargers on the operation of wastewater treatment plants and on the quantity and quality of wastewater sludges; and Identifying new waste reduction opportunities in the management of municipal wastewater sludges. The following report provides a more detailed accounting of the waste reduction research needs in applied social sciences identified by workshop participants.
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Opportunities in Applied Environmental Research and Development Waste Reduction: Research Needs in Applied Social Sciences INTRODUCTION Background This report summarizes a workshop on applied social science research needs in waste reduction held May 8-9, 1989, in Annapolis, Maryland. The workshop was one of four held under the auspices of the National Research Council's Board on Environmental Studies and Toxicology (BEST) at the request of the Environmental Protection Agency (EPA), the National Institute for Environmental Health Sciences (NIEHS), and the Agency for Toxic Substances and Disease Registry (ATSDR). BEST established the Committee on Opportunities in Applied Environmental Research and Development to organize the workshops with the goal of assessing the state of the science in each area and recommending long-term research needs and opportunities for advancing the state of the science. The other workshop topics were ecosystem and landscape change, research needs in anticipation of future problems, and research to improve predictions of long-term chemical toxicity. The workshop that developed this report identified a general need for applied social science research on waste reduction strategies, including specific research needs in measurement of waste reduction, institutional and behavioral barriers to waste reduction, and policy incentives for waste reduction. A root cause of most environmental pollution problems is the emission of waste materials and energy (in economic terms, residuals) from human activities to the air, water, and land. Policies to control such pollution focused initially on "safe" disposal (increased dilution in air and water and sanitary landfills instead of open burning in dumps) and subsequently on waste treatment technologies, which changed the physical or chemical form of the waste materials before discharging them to the environment. The effect of such policies was sometimes to reduce the quantity or toxicity of some waste streams. More often, however, it simply displaced them to other places, future times, or other environmental media, used additional material and energy inputs in the treatment processes, and left other waste streams unchecked (Andrews, 1989). These problems were well characterized by researchers in the late 1960s but were not widely popularized until a decade or more later (Kneese and Bower, 1968, 1979; Royston, 1979). At least as far back as 1968, researchers in environmental management proposed a hierarchy of waste management options in which waste reduction was identified as the preferred approach, before treatment or disposal (Kneese and Bower, 1968). EPA adopted this hierarchy of preferences in concept in 1976 (EPA, 1976); and the Hazardous and Solid Waste Act of 1984 contained an explicit policy directive "that wherever feasible, the generation of hazardous waste is to be reduced or eliminated as expeditiously as possible." In 1986, EPA authored a "waste minimization strategy" that advocated waste reduction but characterized it loosely to include all waste management approaches, including subsequent treatment, storage, and disposal as well as reduction at the source. This strategy also focused on materials legally defined as hazardous wastes and addressed only technical, rather than regulatory and economic, barriers to reduction (EPA, 1986). In a review of the 1986 strategy document, EPA's Science Advisory Board (SAB) urged that
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Opportunities in Applied Environmental Research and Development EPA take a broader view of waste minimization, not limited to hazardous wastes or even to substances traditionally viewed as wastes. The SAB recommended that this view include "any non-product substance that leaves a production process or a site of product handling or use." The SAB also urged special emphasis on "waste prevention (source reduction)," which it defined as a subset of waste minimization practices that includes in-process practices, as well as waste generation practices by product users and consumers that prevent or reduce waste generation per se (EPA, 1987a). The Congressional Office of Technology Assessment (OTA) also criticized the narrowness of EPA's approach (OTA, 1986, 1987). In 1987-1988, the SAB sponsored a committee study on environmental research strategies for the 1990s, and the report of this committee included major emphasis on research needs for "risk reduction" (EPA, 1988a,b). This report urged that risk reduction be adopted as the central goal of EPA generally and of its research and development activities specifically;, it reaffirmed waste prevention (source reduction) as the preferred strategy for risk reduction and urged that EPA develop a strong program of research related to questions in these areas that were unlikely to be undertaken by or to duplicate the research of the private sector. The report noted explicitly that such research should include technology-based strategies and strategies involving disciplines other than the physical and biological sciences and engineering. Examples of the latter included policy and economic incentives for risk reduction, risk communication and perception, environmental management and control systems, and education and training programs. In January 1989, EPA issued a draft policy statement adopting pollution prevention through source reduction and "environmentally sound recycling" as an agency-wide commitment and establishing a new Pollution Prevention Office to develop and implement this goal across all EPA programs (EPA, 1989a). Key components of this program are to include the creation of incentives and elimination of barriers to pollution prevention, efforts at cultural change emphasizing the opportunities and benefits of pollution prevention, and related research and educational activities. A pollution prevention research plan has also been prepared by EPA's Office of Research and Development. The deliberations of this workshop may thus assist EPA, as well as other federal and state agencies, in identifying important research topics as they pursue their pollution prevention initiatives. Previous Studies by the National Research Council Study committees of the National Research Council (NRC) have addressed related topics in several reports. A 1983 report on management of hazardous industrial wastes endorsed source reduction and noted the importance of nontechnical as well as technical factors but did not offer research recommendations on these topics (NRC, 1983). A 1985 report addressed institutional factors in reducing waste generation, but it was limited to hazardous wastes, and its research recommendations were limited to technological methodologies (NRC, 1985). Other recent studies on related topics include alternative agriculture (NRC, 1989), multimedia pollution control (NRC, 1987), and the use of mass-balance information in environmental management (NRC, 1990). Workshop Focus The purpose of this workshop was to provide recommendations on applied social science research needs and opportunities in the field of waste reduction. Recognizing the substantial numbers of similar workshops and reports already addressing engineering and industrial process research needs in this field, this workshop focused on research questions involving three other domains: The definition and measurement of waste reduction; Institutional and behavioral barriers to it; and Policy incentives for waste reduction. All these domains are important, transcend particular industrial processes or user activities, are unlikely to be addressed adequately by the private sector alone, and might therefore be
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Opportunities in Applied Environmental Research and Development strong candidates for research attention by EPA and other agencies. As a modus operandi, a set of six background papers was commissioned, and a substantial set of additional background materials was also distributed before the workshop. During the workshop, participants were divided into three working groups, each directed toward one of the three domains; the suggestions generated by each group were then discussed in plenary session. The charge to these groups was to identify as specifically as possible the questions related to their topic that deserve research attention, and why; to suggest methods by which these questions might usefully be approached; and insofar as possible, to recommend priorities among them. In the course of their discussions, the workshop participants also generated suggestions in two other domains: Waste reduction in nonindustrial sectors (e.g., agriculture, municipalities, and municipal wastewater); and Research implementation issues, in particular the general need for more attention to applied social science aspects of waste reduction. Additional suggestions were also provided by several participants after the workshop. A draft report was prepared by the chairman, incorporating what appeared to be the most valuable research suggestions both from the workshop discussions themselves and from the background papers and postworkshop comments from participants. All participants were given the opportunity to review and comment on the draft report, and the revised report was further reviewed and approved by the sponsoring NRC committee. A workshop is by nature primarily an idea-surfacing mechanism. It is not in the nature of such a process, especially one addressing a large and heterogeneous field, to generate an exhaustive or definitive list of all important research needs. This report does, however, reflect the best suggestions of a diverse and knowledgeable group of participants and is endorsed by the sponsoring committee; it will be a useful source of research ideas, examples, and priorities to the sponsoring agencies and to the larger research community. WASTE REDUCTION Current Definitions The concept of waste reduction has now been widely adopted, and EPA has defined it specifically to include "industrial input substitution, product reformulation, process modification, improved housekeeping, and on-site, dosed-loop recycling" (EPA, 1989a). EPA's proposed policy is specific to industrial waste reduction, although it does note that "individuals as well as industrial facilities or organizations can practice source reduction and recycling through changes in their consumption or disposal habits, their driving patterns, and their on-the-job practices." At the same time, the EPA proposal acknowledged that "there are varying views among representatives of industry, public interest groups, state and local governments and others over the role of recycling in pollution prevention," and it invited comment on the appropriate role of environmentally sound recycling in its pollution prevention program. This variance among viewpoints is due in part to semantic confusion (waste reduction, source reduction, toxic use reduction, risk reduction, waste minimization, pollution prevention, etc.), in part to restrictive definitions (hazardous waste reduction versus all materials and energy, volume versus toxicity reduction), and in part to differences among the goals and perspectives of its interpreters. From the perspective of many businesses, for instance, waste reduction means incremental steps taken in enlightened self-interest to increase the efficiency of use of materials and energy in their production processes (Royston, 1979). It might include, therefore, such activities as sale of waste materials as byproducts and on-site (not just dosed-loop) reclamation of waste materials for recycling. In contrast, to some environmental groups, it means a far more fundamental effort to reduce the overall production and use of toxic chemicals, excess packaging materials, and other harmful or wasteful products (National Toxics Campaign, 1989). From EPA's perspective, it appears. to mean a new synthesis of earlier policy reform efforts toward integrated pollution control across all environmental media, by means of
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Opportunities in Applied Environmental Research and Development source reduction. In fact, it is important to take into account the tradeoffs in moving from one hazardous substances management re, me to another. At best, if we regulate source reduction before we know what it is or how to measure it, we will add to the bureaucracy of existing inefficient and conflicting regulations. At worst, if we do not take into account the tradeoffs we may actually injure people or damage the environment. THE DEFINITION OF SOURCE REDUCTION The idea of the waste management hierarchy grew out of the unavoidable conclusion that unrestrained land disposal had been a mistake. This hierarchy includes the various elements of waste management and is commonly defined as follows: source reduction recycling physical, chemical or biological treatment thermal treatment land disposal. This hierarchy is an ordering of hazardous substances management options according to their presumed environmental consequences with those at the top posing less of a threat than those at the bottom. The concept of the hierarchy is accepted by most people today. Source reduction—the top element—is preferred over all the elements lying lower in the hierarchy because it is assumed to be environmentally safer. Source reduction includes activities that reduce the use of hazardous substances at the source before wastes are generated. In a particular plant, such measures should be identified and implemented to the maximum extent possible. Once source reduction opportunities have been exhausted, the waste manager moves to the next element, recycling. In-process recycling is preferred over on-site recycling which is in turn preferred over off-site recycling. Once all recycling opportunities have been exercised, the manager may move to various types of treatment. Again; on-site treatment is preferred over off-rite treatment. Once treatment has been practiced to the extent possible, the manager may incinerate the waste. Only after all these options have been adopted should land disposal of the waste be considered. There are a number of players in the source reduction game and the term has a range of definitions. On the one extreme, The Congressional office of Technology Assessment defines a term called waste reduction as "in-plant practices that reduce, avoid or eliminate the generation of waste so as to reduce risks to health and the environment" (OTA, 1986). This definition does not include on-and off-rite recycling as legitimate source reduction activities. In-process recycling, or dosed-loop recycling that is part of an industrial process, is the only form of recycling included in the definition. On the other extreme is a term accepted by the Environmental Protection Agency (EPA) in the past and by many in industry called waste minimization. It generally includes source reduction.' on-and off-site recycling and treatment. The EPA recently established a new Office of Pollution Prevention which was to take a primary role in source reduction. At first, the office seemed inclined to adopt the OTA definition. The final official definition, however, was broader; it included on-and off-rite recycling but excluded treatment of any kind (Fed Reg, 1989). Various other players define source reduction according to their viewpoint. In an earlier paper, I described the controversy that surrounds the definition of source reduction and its role in the hierarchy (Wolf, 1988). There appears to be a consensus that source reduction should occupy the preeminent position at the top of the hierarchy. There is considerable disagreement, however, on just exactly what adopting it "to the maximum extent possible" really means. As I discuss in the earlier paper, one extreme view is that it means that source reduction should be adopted until it is no longer technically feasible. Another extreme view is that source reduction should be adopted until it is no longer cost-effective compared to end-of-pipe treatment technologies already in place. There is and will be a continuing debate on the hierarchy and on what constitutes source reduction, waste reduction, waste minimization or pollution prevention. There may never be agreement on the best definition and it probably does not matter. As I show below, whatever term is used, there is presently no good method for measuring it or indeed, for deciding what it is. Throughout, I use the term source reduction to encompass actions that lead to better protection of human health and the environment.
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Opportunities in Applied Environmental Research and Development THE CASE STUDY To explore the questions that arise in measuring source reduction, let us consider four plants described in Table 1 that produce or use methylene chloride (METH), a chlorinated solvent. In certain laboratory tests, this chemical has caused tumors in animals. Although the International Agency for Research on Cancer (IARC) classifies METH as a possible carcinogen, EPA defines it as a probable human carcinogen. EPA and California are considering regulating it as a toxic air contaminant, the Consumer Product Safety Commission has a labelling requirement when it is used in certain products, it is regulated under Proposition 65 in California, and spent METH is considered a hazardous waste under RCRA. In the first plant, a chemical production plant, METH is produced. In the second plant, METH is used in a metal cleaning application. In the third plant, METH is used as an ingredient in an aerosol paint.-In the fourth plant, METH is used as an auxiliary blowing agent in the production of flexible slabstock foam. Table 1 provides a rough materials balance for the four plants. It lists the quantity of METH brought onto the site, released to the various media, and sent off-site in the product. These plants have very different operations as indicated by the values of Table 1. In-Plant #1, the METH producer brings in raw materials and produces METH. In this process, only small releases occur. One thousand pounds of METH is released to the air because of fugitive emissions from valves, pipes and storage tanks. An even smaller amount of METH—500 pounds—remains in the still bottoms from the final distillation at the back end of the reactor. An additional 250 pounds is released to the water. The producer runs a reasonably efficient operation; out of 25,000 pounds of production, the losses are only 7 percent. The second plant, plant #2, makes lighting fixtures from various metals. These metals arrive at the plant with an oil on them to prevent corrosion in transit and they are degreased prior to machining. After machining, the parts are cleaned with METH again to remove metal fragments, greases and oils. Degreasing is a dispersive process. METH is volatile and most of it—18,875 pounds annually—is emitted to the atmosphere. Occasionally the degreaser must be cleaned out and the sludge, containing 6,250 pounds per year of METH, is sent off-site to a recycler. None of the original 25,000 pounds of METH brought on-site goes out on the product; all of it is lost in the degreasing, process. Plant #3 purchased 25,000 pounds of METH for use in an aerosol paint formulation. A small amount of METH—500 pounds—is released to the air during the aerosol can filling operation. An even smaller amount of METH, 250 pounds, is lost to the water when the cans are tested for integrity after filling. The vast majority of the METH, 97 percent of that brought on-site, goes out-in the paint product. Plant #4, the roamer, uses METH as an auxiliary blowing agent in the production of flexible slabstock foam used in furniture, bedding and carpet underlay applications. The function of the METH, in this case, is to expand the foam cells so that the foam has buoyancy. Virtually all of the METH is emitted to the atmosphere within a few days of the foam production process; none of it goes out-in the product. REPORTING RELEASES Under Title III, Section 313 of SARA, businesses falling in certain manufacturing SIC codes must report to EPA if they produce 25,000 pounds annually after 1988, or use 10,000 pounds annually of a listed substance (Fed Reg, 1988). The list of more than 300 substances includes METH and the four plants in Table 1 are subject to reporting. Under the statute, however, all of the data in Table 1 would not be reported. In fact, only the middle three pieces of data-the air, water and hazardous waste releases-are covered by Section 313. Let us compare in more detail the plants of Table 1 and see where it leads. Plant #1, the producer, is very efficient. In chemical production, the yield is maximized by minimizing losses and, indeed, in this plant, releases are small. Once the METH has been produced in plant #1, it is sold into various markets like plants #2 through #4. The light fixture manufacturer has large losses of ME. In fact, all of the METH that is purchased from the producer is ultimately lost to the atmosphere. In this particular application, the METH is used dispersively. The same holds true for the foam producer in plant #4. This
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Opportunities in Applied Environmental Research and Development Table 1 MATERIALS BALANCE FOR METH PLANTS QUANTITY OF METH (POUNDS/YEAR) PRODUCER PLANT #1 LIGHT FIXTURE MANUFACTURER PLANT #2 PAINT FORMULATOR PAN #3 FOAM PRODUCER PLANT #4 Brought on-site 0 25,000 25,000 25,000 Released to air 1,000 18,750 500 25,000 Sent off-site as hazardous waste 500 6,250 0 0 Released to water 250 0 250 0 Sent off-site as product 25,000 0 24,250 0 SOURCE: Author's estimates. NOTE: The values are only representative of actual values and are used for exposition purposes. In fact, METH production plants likely have much lower losses than indicated in the figures for Plant #1. plant purchases the METH from the METH producer and all of it is lost to the air. Plant #3 has much lower losses. As was true for the producer, the paint formulator wants to maximize the METH that goes out in the product. The losses to the atmosphere are accordingly minimal. In examining the figures of Table 1, we could conclude that plants #1 and #3 are efficient in their use of hazardous substances and plants #2 and #4 are not. Of course, this conclusion is silly because the different operations have different characteristic. Indeed, all of the METE the producer in plant #1 makes is ultimately released to the atmosphere, although not from his plant. The producer sells the METH to the other three plants and it is released according to the characteristics of release of plants #2 through #4. Plants #2 and #4 release it directly during their manufacturing operations. Plant #3 puts it in a product that consumers and commercial painters buy. When they in turn use the product at thousands of locations across the country, the METH is emitted to the atmosphere or thrown into landfills. The bottomline is that virtually all of the ME that is produced and used is eventually released to the atmosphere whether it be in plants during metal cleaning or foam production or by consumers in their use of a product. MEASURING SOURCE REDUCTION Many people in the source reduction community are calling for the reporting of rough materials balance information. They believe it would help track trends in hazardous substances use if-throughput information could be collected in addition to the Title III release data. They claim that collecting two additional pieces of data, the first and last lines of Table 1, the amount of the substance brought on-site and the amount produced or sent off-site in the product, would allow a throughput analysis that could be used to measure progress in source reduction. Now that we have set the stage with the four plants, let us consider how we might measure progress in source reduction if we could have all the data in Table I reported. There appears to be a consensus that
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Opportunities in Applied Environmental Research and Development source reduction applies to all media—air, land and water. As mentioned earlier, there is no dear consensus on what source reduction actually encompasses—whether it is restricted to in-process recycling or whether on-or off-site recycling and on-site treatment should be included. Ignoring this issue for the moment, we need to decide how to measure progress in source reduction if we can agree on what it is and this is not a simple undertaking. There are changes in economic activity from year to year and many people have suggested that to normalize out the effects of growth or a decline in economic activity, we must measure source reduction from year to year on a per unit of product output basis. In plant #1, for instance, if air, waste and water releases declined from one year to the next and the production level of METH remained the same or increased, then we could agree that source reduction had been accomplished. In effect, the total releases per pound of METH produced declined, signalling progress in source reduction. It is much more difficult in the case of the other plants in Table I to normalize according to the weight of product produced. The light fixture manufacturer may change his product mix from year to year depending on orders. Should the plant report the number of fixtures, the pounds of each type of metal cleaned or the surface area of metal cleaned? The paint formulator faces the same problem. Should he report on the number of units filled even if some types of paint require more METH in the formulation than others? The foam producer could report METH use per pound of foam output. Even here, this is a problem, however, since softer foam requires more auxiliary blowing agent. The mix of foam may also vary from year to year. A second way of normsilzing that has been suggested is to use sales. Perhaps we could measure METH use per sales value of the product. Again, however, product prices vary from year to year and the mix of products will often determine the sales value realized. Another approach that has been discussed is to simply measure source reduction as a reduction in use or releases from year to year. This technique has problems too, and they arise because there is no clear definition of source reduction. The light fixture manufacturer may put in a carbon absorption unit that captures 50 percent of the METH that was previously emitted to the air. The plant reduces its air releases by 3,125 pounds and reduces purchases by the same amount by reusing the captured METH. However, carbon adsorption does not fit most definitions of source reduction which exclude on-site treatment. Under the strict definition, in this case, the plant has not accomplished source reduction, even though air releases have been cut in half and use of the substance has declined. The plant currently sends its spent solvent to an off-site recycler, but purchases virgin solvent for use in the cleaning operation. What happens if that plant decides to purchase recycled solvent and use it in place of virgin solvent? All of the values in Table 1 remain the same so that this plant has not accomplished any source reduction. Virgin solvent purchases have declined in the economy, however, so source reduction has in fact been accomplished on a nationwide basis, reducing the requirement for virgin production. Under some definitions there has been no net source reduction because off-site recycling is not considered a permissible source reduction option. What if the light fixture manufacturer converts to a new heavy hydrocarbon solvent that is not on the Section 313 list. All definitions of source reduction include substitution as a viable option. This heavy hydrocarbon is combustible and poses a danger to workers. It is not exempt as a contributor to photochemical smog, and it is relatively unscrutinized in terms of chronic health effects. In fact, it may ultimately prove to be a carcinogen even though it is not currently on the Section 313 list. Through substitution of this new solvent, has source reduction really been accomplished and if so, how much? A similar measurement problem arises if the light fixture manufacturer converts to an aqueous cleaning system. The water, after it has been used for cleaning, contains 13 greases, oils and metals from the machining process. If the local sanitation district does not require treatment before release to the sewer, then metals are being placed in the sewer where they would not make their way if METH were still being used. Has source reduction been accomplished and if so, how much? If the sanitation district does require the water to be treated, the light fixture manufacturer might have to install an ion exchange process to treat the metals. Ion exchange is an on-site treatment method that generates a metal sludge requiring disposal. We thus have a situation where a substitution—allowed under the strict definition of source reduction—forces
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Opportunities in Applied Environmental Research and Development the adoption of on-site treatment, a procedure discouraged by some source reduction advocates. Has source reduction been accomplished and, if so, how much? A similar problem with chemical substitutes might arise in the case of plant #4. In July,, an EPA regulation will cap the production of the fully halogenated chlorofluorocarbons (CFCS) at 1986 levels. The CFCs-will be phased out altogether over the next decade. Roughly half of the auxiliary blowing agent currently used in flexible slabstock foam production is CFC-11; the other half is METH. In July, after the production of CFC-11 is restricted, its price will rise and some foamers will switch from CFC-11 to METH. Other alternatives are being investigated but they probably will not be available on a wide scale for several years. Because of the regulation on CFC-11, the foamers are unable to practice source reduction of METH and they will likely increase its use in the next few years. We have a situation where one office of EPA, concerned about damage to the ozone layer in the stratosphere is regulating a chemical—CFC-11-that poses a threat to the ozone layer. This office has imposed a regulation that will increase use of another chemical under scrutiny for various reasons by other offices of EPA. The most comprehensive method for measuring source reduction has been proposed by the Natural Resources Defense Council (NRDC) (Smith, 1988). The concept of throughput is defined to include the sum of total releases, the mount leaving a plant in or on a product, the change in inventory, the amount transformed on-site, the amount recycled on-site or sent off-site for recycling, and the amount entering all downstream processes. Another term—efficiency—is defined by NRDC as ''the ratio of the total amount of each hazardous chemical released annually from the processes at a facility (and from subsequent recycling operations) to the throughput in the same year of that chemical at the facility.'' Releases are the sum of losses from the manufacturing process prior to treatment, from losses from on-site recycling and losses leaving the facility as impurities in a product. Note that the NRDC definition of efficiency is at odds with the common definition. In the NRDC model, a lower "efficiency" (ratio of releases to throughput) is more desirable than a higher "efficiency". The NRDC analysis includes an example similar to the light manufacturer of Plant #2 in Table 1. In this case, a facility uses another chlorinated solvent—1,1,1-trichloroethane (TCA)—for degreasing metal parts. Losses include 14,000 pounds of atmospheric emissions and 7,000 pounds of waste spent solvent that is sent off-site to a recycler. There is no solvent sent off-site in the product, none in inventory, and none converted on-site to another substance and none entering downstream processes. Thus, the total throughput is 21,000 pounds. Since the facility receives credit for the recycling, the only release is the atmospheric emission. The "efficiency," therefore, is 67 percent, the ratio of the atmospheric loss to the throughput. In this definitional regime, reducing the "efficiency" (the release) is equivalent to adopting source reduction measures. Again, we can do this in several ways. A carbon adsorption device could capture emitted TCA before it is released to the atmosphere. Under the NRDC definition, carbon adsorption would be defined as a treatment option bemuse the TCA is released from the process (the degreaser). Use of this treatment option does not reduce releases from the process. The facility could substitute a heavy hydrocarbon solvent with unknown health and environmental effects or it might change the process to aqueous cleaning. In these cases, the plant has no releases of a listed chemical and has therefore achieved zero "effidency"—a perfect score. The problem with these alternatives as discussed earlier, however, is that they might actually increase damage to health and the environment. Another problem with this approach is that it may not accomplish what is intends. The NRDC model gives a credit for spent solvent sent to an off-site recycler and does not consider it to be released The recycler, however, may not recycle the material at all It may end up in an incinerator, it may be illegally disposed of in a landfill, it may be allowed to evaporate, or it may be poured into a water system. None of these destinations is allowed under the NRDC definition of "efficiency". On balance, no very good way to measure source reduction has yet been proposed and the NRDC model has significant problems. There remain in all schemes, the problem of the definition of source reduction or an equivalent term. The other problem that arises in all cases is the increase in-use or release of alternative chemicals or outputs from process modifications. These may themselves prove to be dangerous but simply in a different way. This suggests that there is no generic way to measure or accomplish source reduction across or within industries. In fact, we must do the accounting on a case-by-case basis and evaluating whether or not
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Opportunities in Applied Environmental Research and Development progress in source reduction has been accomplished involves making a value judgement. Each industrial process and, indeed, each plant involved in a particular industrial process, is unique. Source reduction options that are appropriate for one operation may actually endanger workers or increase hazardous materials generation in another plant. Deciding on the best way to protect human health and the environment will require a great deal of study. Understanding industrial processes, their release characteristics and the implications of the feasible source reduction options is essential. REGULATION OF SOURCE REDUCTION There is a growing movement that believes industry has been slow to embrace source reduction. This group believes that only through regulation will there be widespread awareness and adoption of source reduction measures. Two type, of regulation are being proposed. The first would require all firms falling under the rubric of Section 313 of SARA to report on the source reduction and recycling activity for the chemicals on the 313 list (H.R. 1457, 1989). The second, based on the NRDC model, would require firms to accomplish 95 percent source reduction over the next decade (RCRA Reauthorization Bill, 1988). It would also apply to the chemicals on the 313 list and the firms in the manufacturing sectors specified in the Title III legislation. There are three types of firms affected by Section 313 of SARA. The first type is the chemical producers which are very familiar with the chemicals that are the target of source reduction because these chemicals are the product they manufacture. Producers generally have made good progress in source reduction; indeed, it is their business to do so. They must continually attempt to further maximize their yield and the way to do that is to minimize releases. The second type of firm is also large—an electronics manufacturer or an aerospace firm, for instance—but is not familiar with the target chemicals. These firms do not manufacture chemicals but rather use them in the course of making another product. In the last few years, these manufacturers have established large staffs and correspondingly large budgets to focus on Waste minimization because they believe they can reduce costs and minimize liability in doing so. They have thousands of different chemical formulations moving into their plants each year and they are trying to track these and understand their uses.' The large manufacturing firms are not as far ahead as the chemical producers but some of them have made impressive progress and others-will do so in the next few years. The third type of firm is small or medium sized and, like the large firms, uses chemicals only to make a product. Some of these firms are examining source reduction but many of them have neither the resources nor the expertise to adopt source reduction and this is unlikely to change significantly in the future. In fact, although many of these companies fall under the rubric of Section 313, most of them are probably unaware that it applies to them and it is likely that they have not submitted data to EPA on their releases. The proponents of the so-called information regulation argue that we need data on what is actually happening out there today and we need to continue to collect data to measure source reduction trends. In fact, there are really only two reasons to collect such data. First, we don't know ourselves what source reduction is or how to measure it and we are hoping that an immense data collection effort will somehow tell us. Rather than doing the work of understand the industrial processes ourselves, we want industry—the only people who really do understand the processes—to tell us. In effect, this is similar to other data collection efforts where we don't know what to ask initially so we cannot analyze the data that are received. Second, we want the data to establish a baseline for a more prescriptive mandatory source reduction regulation. The large firms described above would probably be able to cope well with a data submission. They already have staffs who fill out the numerous forms required under various regulations. In contrast, a data requirement would impose a significant burden on small and medium sized firms. Some of these firms would likely have to hire consultants to analyze their records or release streams for them because they lack the expertise or the time to do it themselves. Some would not have the resources to hire a consultant and they would go out of business. Still others would probably simply not respond at all. Title HI of SARA actually applies to thousands of small quantity generators in the nation. The
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Opportunities in Applied Environmental Research and Development statute requires reporting from users of 10,000 pounds annually of a listed chemical. Looking again at Table 1, a metal fabricator like plant #2 using 10,000 pounds of METH would probably emit three-fourths of it, or 7,500 pounds to the air. The balance, or 2,500 pounds would be hazardous waste. We define small quantity generators (SQGs) and very small quantity generators (VSQGs) as firms that generate 2,200 pounds and 220 pounds per month respectively. This translates into 26,400 pounds per year for an SQG and 2,640 pounds per year for a VSQG. If the release characteristics are similar to those of Plant #2, a metal fabricator using 10,000 pounds per year would fall below the cutoff of a VSQG and there are thousands, perhaps tens of thousands of them in the nation. Those who want source reduction reporting would impose a financial burden on these small businesses that could prove intolerable in many eases. The other proposed regulation would actually require firms to accomplish source reduction. How would we implement such a regulation? Who would decide whether source reduction had been achieved and who would decide whether it amounted to 95 percent as required? In fact, the bill avoids this question altogether by chafing the administrator to specify how throughput should be calculated to establish a baseline for the required 95 percent source reduction. To illustrate that such a regulation would be an undertaking beyond current public sector capabilities, let us once more refer to Table 1. The chemical producer of Plant #1 already has a fairly low release. The plant manager has worked hard to minimize the losses. The firm already recycles still bottoms back into the reactor and the waste Cannot be reduced further with current technology. All the valves and pipe fittings have been checked and those that were leaking have been replaced and a regular maintenance program has been initiated to inspect for leakage. The "efficiency" according to the NRDC model of this product is currently 7 percent. To meet the regulation, the plant will have to reduce the "efficiency" further, to 5 percent. Is it fair to ask the chemical producer who has already instituted source reduction measures to reduce the releases further? It may prove technically impossible to do SO. It is even more unfair to ask facilities that use chemicals dispersively to achieve a 5 percent "efficiency." A case in point is the light fixture manufacturer who used METH in the course of making a product. The plant's current "efficiency" is 75 percent, significantly higher than the 5 percent mandated by the regulation. The plant presently sends the spent waste solvent to an off-site recycler but does not buy back or use recycled solvent in the process. If the manufacturer instead decides to recycle the solvent on-site-a source reduction option that allows the plant to reuse the spent solvent-then the plant actually pays a penalty. If we assume that 90 percent of the solvent can be recycled in this process, then "efficiency," in this case increases to 77.5 percent. This occurs because atmospheric losses remain the same but the waste loss increases because the plant generates a still bottom from the distillation that must be sent off-site for disposal. The details of this calculation are described in the Appendix. What happens if we try to do something about the much larger atmospheric loss? The plant likely has an old vapor degreaser. Replacing it with a new unit with a second set of condensing cods and a higher free board might reduce annual atmospheric losses by 30 percent, from 18,750 pounds to 13,125 pounds. If we assume the plant sends its waste to an off-site recycler, then "efficiency" with the new degreaser is 68 percent—still very far from the 5 percent required. Let's assume that instead of buying a new degreaser, the plant puts in a carbon adsorption unit. This unit can reduce atmospheric releases by 80 percent, from 18,750 pounds to 3,750 pounds. This lowers the "efficiency" to 15 percent and to lower it further would probably not be technically feasible. The plant, even to adopt these measures which are insufficient, would incur significant capital costs. Together the still and the carbon adsorption device would require at least a $10,000 investment if steam were already installed. If not, as is generally the case in California the cost would be much higher (Mooz et al, 1982). Furthermore, under most definitions of source reduction, carbon adsorption, a treatment technology, is not included and it might not be allowed under the proposed regulation. The only real alternatives the plant has—and the plant is-after all an SQG—is to switch away from the listed chemical or to go out of business. As discussed earlier, the plant might convert to a combustible heavy hydrocarbon solvent that may eventually cause health or environmental problems. Or it might convert to an aqueous cleaning system which carries metals and organics into the sewer. By definition, in either of these cases, the conversion to a non-listed chemical accomplishes 100 percent source reduction or leads to
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Opportunities in Applied Environmental Research and Development perfect "efficiency.' Unfortunately, we have no way of knowing if the conversion will better protect human health and the environment. Indeed, it may cause other, more dangerous problems than exist currently. THE REAL ISSUE What is really driving the movement toward regulation of source reduction? one of the reasons for this intense focus is that pollution of air, water and land is truly serious and we must address our widespread use of hazardous substances. Source reduction—which, in principle, has no opponents—is a vehicle that allows us to question the life cycle production and use of these substances to minimize pollution. Another related reason for imposing a regulation requiring source reduction is that such a regulation may be able to reduce, and indeed eliminate, the hazardous substances that we have not been able to eliminate through other regulatory statutes. We devote significant resources to regulating hazardous substances once they have entered commerce through a variety of statutes. The Occupational Safety and health Act (OSHA) regulates exposure in the workplace; the Clean Water Act (CWA) and the Clean Air Act (CAA) prevent pollutants from entering the water and air respectively; the Resource Conservation and Recovery Act (RCRA) regulates hazardous waste; The Comprehensive Environmental Response and Compensation Act (CERCLA) governs the cleanup of contaminated sites; and Proposition 65 in California is intended to prevent substances that cause cancer and birth abnormalities from entering drinking water supplies. We have in place a set of expensive, frequently ineffective and often inconsistent regulations. They are largely command and control; that is, they prescribe exactly what kind of equipment or procedures to use for specific situations. Because such regulations are generally not cost-effective, they depend on government enforcement to exact compliance. Indeed, compliance with the regulations is likely to be low unless there is a very large inspection staff and the funds for such staffs are rarely available. Furthermore, because of the fragmented statutes, each inspector focuses only on the medium in question. That is, the hazardous waste inspector does not inspect a plant for CAA violations involving atmospheric emissions. Even within a statute, there is conflict; the inspector looking for violations of tropospheric smog regulations will encourage the substitution of stratospheric ozone depleters. A final problem is that some inspectors are not well trained and they may not be knowledgeable. How has this situation come to pass? The regulatory regime has evolved to its present state because policy makers did not assemble it using a systems approach. The prevailing view, at least implicitly and often explicitly, was that pollution could not be prevented or minimized unless industry was told what to do and how to do it in considerable detail. No one wants carcinogens in the ground water or in their basements. For this reason, there is a huge constituency for regulations like the Clean Air Act and CERLA, which may be termed "back end" regulations. The CWA and RCRA also fall into this category. There is no constituency for hazardous substances once they have been used and no one wants them in the air, land or water. The emphasis on a regulation requiring source reduction signals the failure to achieve appropriate, efficient and consistent controls on hazardous substances once they have been used. Some proponents believe that, in one stroke, a regulation requiring source reduction will do what all the other regulations together have not been able to do—eliminate or significantly reduce the use of hazardous substances in commerce. The real question that requires societal debate is "do we want to eliminate or significantly reduce the use of hazardous substances in commerce, and if so, how should we best do it?" There are a number of substances in commerce today that cause cancer in laboratory animals. The Toxic Substances Control Act (TSCA) and the Federal Insecticide, Fungicide and Rodenticicide Act (FIFRA) have been largely ineffective in preventing these substances from entering the market in the first place or in taking them off the market once they are there. Once a substance enters commerce, it is woven within the fabric of society. Workers produce it; it may be used to produce other chemicals; it is used in products or to make products. There is a vested interest in continued use of this chemical because of the revenue it generates for the producer, the jobs it creates, and the convenience it offers to all of us to maintain a good
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Opportunities in Applied Environmental Research and Development standard of living. In effect, these sunk costs guarantee a large constituency for continued use of the chemical. Once the substance is "spent," however, it no longer has a constituency and herein lies the paradox. We want to use the substance for the benefits it provides but we don't want to pollute our environment with it. Thus we have been led to the inefficient "back end" regulatory regime that exists today. At this stage, we must admit the error, come to terms with it, try to understand it and open up to societal debate the questions about how to solve it. Do we want human or animal carcinogens on the market? H so, we must focus on the best way to minimize their impact on human health and the environment. There may be efficient ways to do this or there may not. If not, we should concentrate on removing them from the market from the outset through TSCA and FIFRA which were designed exactly for that purpose. RECOMMENDATIONS Any kind of field work leads to the unavoidable conclusion that firms need help in manning the hazardous substances they use. The concept of source reduction remains confusing. Mandating source reduction without understanding what it is and without understanding what its consequences are would be a mistake. There is no assurance that a source reduction regulation would lead to better protection of human health and the environment. Indeed, it might end up forcing firms to adopt other products, processes and chemicals that will ultimately prove dangerous in a different manner. We are at a critical juncture now and we have the opportunity to re-evaluate toxic chemical regulation under the rubric of source reduction. The incentive we supply in the current regulatory regime is compliance. Bemuse most of the regulations are ill conceived and in conflict with one another, compliance may not lead to better management of hazardous substances. We should consider carefully what the best course is, not to exact "compliance" through another command and control regulation but to better ensure environmental and human health protection. I have personally become convinced that command and control regulations on source reduction now would be a mistake. Our top priority now should be to provide technical assistance to small and medium sized plants on an industry-by-industry, plant-by-plant basis. Although a component of the assistance would obviously be source reduction, the major effort would focus on better hazardous substances management. We should take the next few years to try to understand what source reduction is and the only way of doing this is to learn about the industrial processes in-depth. This will require a significant time investment, an open mind and considerable dedication. Small and medium sized firms are not the only ones who would benefit from a concerted technical assistance program. As the technical assistance teams increased their knowledge of particular industries, they could also provide a valuable service to large firms who use hazardous substances. Although such firms have technically trained staffs devoted to waste minimization, knowledgeable outsiders can facilitate better hazardous substances management in a variety of ways. They can act as ombudsmen between firms offering alternative chemicals, products and processes and firms looking for alternatives. Because of their knowledge of processes, they can critically evaluate the alternatives and try to understand their consequences. They can use informed judgement to suggest promising alternatives. They can hold meetings on specific processes to identify common problems and common solutions. Finally, they can document the successes and failures of various options for widespread dissemination. Everyone wants to play a role in spurring society toward source reduction. It is the seminal issue of the decade. We must take care that these efforts do not waste resources and that they do not make things worse than they are. It is the responsibility of the source reduction community to learn what source reduction really is before mandating that it occur. It is the responsibility of the source reduction community to learn about the complexities of chemical use and about the industrial processes that employ them. It is the responsibility of the source reduction community to understand the tradeoffs involved in the adoption of source reduction measures. It is the responsibility of the source reduction community to examine the issue of how to better protect human health and the environment.
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Opportunities in Applied Environmental Research and Development APPENDIX "EFFICIENCY" CALCULATION FOR THE METAL FIXTURE MANUFACTURER The NRDC model contains two concepts. The first is throughput which is defined as the sum of: total releases, the amount leaving a plant in the product, the inventory change, the amount recycled on-site or sent off-site for recycling, the amount entering-all-downstream processes. The second concept is "efficiency," which is defined as the ratio of releases to the throughput. The light fixture manufacturer in Table 1 in the text purchases 25,000 pounds of METH annually. The losses are 18,750 pounds of atmospheric-emissions and 6,250 pounds of spent waste solvent. This firm currently sends the waste solvent off-site to a recycler. The "efficiency" is therefore 75 percent. That is the releases are 18,750 pounds and the throughput is 25,000 pounds. USE OF OFF-SITE RECYCLED SOLVENT The plant sends its contaminated solvent off-site to a recycler but buys virgin solvent for use in the process. If the plant decides to instead purchase recycled solvent, the "efficiency" would remain the same as above—75 percent. The firm does not receive a credit for converting from the use of virgin solvent to the use of recycled solvent. Indeed, according to the NRDC model, the plant does not even have to use recycled solvent to get a benefit for sending solvent to a reclaimer. As mentioned in the text, there is no way of knowing the ultimate destination of the solvent. This is a failing in the model. ON-SITE RECYCLING What if the plant decides to purchase a still for recycling on-site? If we assume the still to be 90 percent efficient, then out of the 6,250 pounds of spent solvent, 5,625 pounds goes back into the-process and 625 pounds is sent off-site for disposal. In this case, releases are the sum of the atmospheric loss (18,750 pounds) and the waste loss (625 pounds) or 19,375 pounds. The throughput is the sum of the releases (19,375 pounds) and the amount recycled on-site (5,625 pounds) or 25,000 pounds. "Efficiency," in this case, is 77.5 percent. This value is higher than the "efficiency' of off-site recycling, an anomaly of the model. Indeed, a regulation patterned on this model would provide a disincentive to adopt on-site over off-site recycling, an outcome that is probably not desirable. PURCHASE NEW DEGREASER Purchasing a new degreaser would lower the atmospheric losses by 30 percent, from 18,750 pounds to 13,125 pounds. If we assume the plant sends spent solvent to an off-site recycler, the throughput would be the sum of the atmospheric losses (13,125 pounds) and the spent solvent sent off-site (6,250 pounds) or
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Opportunities in Applied Environmental Research and Development 19,375 pounds. "Efficiency" is the ratio of the releases (13,125 pounds) to the throughput (19,375 pounds), or 68 percent. PURCHASE CARBON ADSORPTION DEVICE If the firm purchases a carbon absorption unit instead of a new degreaser, the atmospheric emissions can be reduced by 80 percent, from 18,750 pounds to 3,750 pounds. In this case, releases are the remaining atmospheric emissions (3,750 pounds). Assuming the adsorbed METE is desorbed and reused,. then throughput is the sum of the releases (3,750 pounds), the amount sent off-site for recycling (7,000 pounds) and the amount reused on-site (15,000 pounds) or 25,000 pounds. "Efficiency" is therefore 15 percent. Note here that carbon adsorption is extremely expensive and most plants would be unable to purchase it. It also takes significant expertise to operate. Furthermore, it is not dear that this method-which, in fact, is a treatment technology-would be allowed under the regulation. SUMMARY OF SOURCE REDUCTION OPTIONS It is doubtful that plants could reduce their atmospheric losses further than with the carbon adsorption device. The more cost-effective option would be to convert to another solvent not on the Section 313 list or to an aqueous cleaning system. As discussed in the text, this conversion may pose problems but simply in a different way from METH. This example raises another point as well After the carbon adsorption device has been purchased, virgin purchases for the firm amount to 10,000 pounds annually. This includes the waste loss (6,250 pounds) and the atmospheric loss (3,750 pounds). Although the plant actually uses 25,000 pounds of solvent, the 15,000 pounds of solvent captured by the carbon adsorption device is reused in the cleaning process and substitutes for virgin solvent. Section 313 of SARA requires chemical users of 10,000 pounds annually to report. If the light fixture manufacturer lowered "use" one pound further, the plant would escape the reporting regime altogether and would no longer have to report. Because the regulation requiring "efficiency" of 5 percent in ten years is patterned on Section 313, this plant would escape the requirement after achieving an "efficiency" of 15 percent-not 5 percent. This is an anomaly of the regulation. REFERENCES Federal Register, "Toxic Chemical Release Reporting: Community Right-to-Know; Final Rule," 40 CFR Part 372, February 16, 1988, p. 4500. H.R. 1457, March 15, 1989. RCRA Reauthorization Bill, September 9, 1988. Smith, Ned Clarence, "The Use of Mass Balance Data in the Natural Resources Defense Council's Proposed Model Waste Reduction Program," March 1988. Wolf, Katy, "Source Reduction and the Waste Minimization Hierarchy," Journal of the Air Pollution Control Association, Vol 38, #5, p. 681, May, 1988.
Representative terms from entire chapter: