Hazardous waste: Prevention or cleanup? Critical issues are involved in the way hazardous wastes are viewed By Joel S. Hirschhorn and Kirsten U.Oldenburg
a lack of technology or economic bene-
The subject of why and how hazardous wastes ought to be handled is receiving increasing attention. The main question is whether it is better to reduce the amount of hazardous waste generated than it is to treat or dispose of wastes once they are generated. The idea of reducing wastes-or of preventing them from being produced at all-has gained a good deal of recent popular support. But support for waste reduction can be misleading. Because there is a lack of a common definition, those who discuss waste reduction are not necessarily talking about the same thing. And although it is easy to s u p port the concept, support for specific action and programs is quite another matter. Several important areas are often overlooked. As with many other beneficial activities, it is easy to agree in principle without moving the debate ahead intekCNdly and without providing the tangible policy, organizational, and financial support necessary to make pollution prevention a reality. Although the concept of waste reduction is not new, current economic reality provides a completely new context in which pollution prevention can take its place as an important strategy for environmental protection, complementing the prevailing strategy of pollution control. Prevention is attractive because it offers economic benefit and because it is the best way to safeguard public health and the environment. Regulatory programs aimed at pollution control have greatly increased waste management costs and liabilities and make waste reduction attractive today. But the obstacles they pose to waste reduction must be recognized. The realities of rising costs and increased liabilities do nothing to ensure that waste generators will turn to waste reduction.
Primacy and responsibility The meaning of “reducing the generation of hazardous wastes” is the most fundamental issue requiring attention. Phrases such as waste reduction, source reduction, and waste minimization often are used interchangeably even though there is no assurance that they mean the same thing. There is uncertainty too about what “hazardous” and “waste” mean. We interpret hazardous waste very broadly, and we do not use a definition associated with any government regulatory program, especially that of the Resource Conservation and Recovery Act. Hazardous waste is all pollutionwastes, discharges to water or land, and emissions to the air-regardless of how it is generated or whether it is regulated. We choose the term hazardous-waste reduction because it was used early on and because it conveys the most information. Waste reduction encompasses a broad range of actions that take place within the confines of a specific process before a waste is generated. This obviates the need for the alternative: Once it is generated, a waste must be managed, transported, or stored, and such activities pose risks and require government regulation. We would like to see changes in raw materials, processes, operations, and products and an adoption of in-process recycling that will reduce waste at its source. Our definition of waste reduction, and our restricted approach to achieving it, is problematic in some circles, especially because we exclude certain preferred waste management activities. Those who favor off-site recycling or incineration of waste, for example, disagree with the preference we give to changes within plant operations. But because waste reduction (as we define
552 Environ. Sci. Technol.. Vol. 21. No. 6. 1987
tit limits the effort to reduce costs.
Joel S. Hirschhorn
K;rsY~nU. O/dcIrhurg
In fact, other responses to the proliferation of waste are more common: Changing waste management techniques (such as disposing of wastes by incineration rather than by burial), closing industrial plants or relocating them abroad, using litigation and regulatory opportunities to delay or reduce compliance, and even engaging in illegal waste management practices are some of the options available. Compliance with pollution control regulations consumes resources that might otherwise be applied to waste reduction. The predilection for the familiar rather than
w13936W87109210u2$01.5010 0 1987 American Chemical Soeiery
it) poses fewer risks than do waste man agement or pollution control, we believe it should receive unequivocal and explicit primacy. Although reducinp waste is not always possible, it shoulc always be carefully examined as thf preferred option. Many waste generators are more comfortable with managing waste and concentrating on pollution control than they are with changing their methods of production. A major obstacle to waste reduction is that it must be done by those responsible for production rather than by their counterpats in waste management. Waste managers are trained in end-of-pipe control. And because production people often consider waste inevitable, insignificant, or someone else's problem, they have no motivation to reduce waste generation. They are not held responsible for the short- or long-term consequences of the wastes they generate. There must be a way to bridge this gap in philosophies.
Does government have a role? Although it is relatively easy to say that waste reduction's time has come, it is quite another matter to assess the role of government. The government devotes less than one percent of current environmental spending to waste reduction. This historical imbalance toward end-of-pipe control has been caused,in part, by industry's desires to keep the government and its regulations out of production processes. Waste reduction, which a few pioneering companies have pursued aggressively, has been a voluntary endeavor. But as it gains visibility and popularity, public pressure increases to have the government mandate waste reduction. Given the enormous variety of industrial waste-generating activities, the regulatory approach would be extraordinarily difficult and extremely expensive to design and implement. If waste reduction is beneficial, then its social good justifies government attention, leadership, and support. A number of states and some foreign countries have established uselid waste reduction programs based entirely on a helping-hand approach. Most notable of these are North Carolina's Pollution Prevention Pays program and the waste reduction program in Ventura County, Calif. Such programs, however, rarely equate waste reduction with waste prevention. As a consequence, many of them spend a large portion of their limited resources on management rather than on reduction of wastes. A report of the congressional Office of Technology Assessment, "Serious Reduction of Hazardous Waste," suggests a number of ways the federalstate partnership could help generators
The OTA report outlines a number c
avenues available toward a natio support system for waste reducti Establish an Office of Wa Reduction within EPA and form pendent waste reduction boar the state level. Establish a federal grants gram that will provide technical sistance, inlormation and tech cgy transfer,education and traini and research and development the area of aeneric waste reduc techniques. Enact federal leaislation th clearly defines waste ;eduction an&,its primacy over waste management;, This would include establishment *.' a voluntary national goal of a year-teyear reduction tor five cot): secutive years. It also would providp a legal basis tor offering trade-otls qt:. regulatory concessions that woulp onset the disincentives posed bfj, current regulations. Establish a waste reduction r&i' porting requirement under the Feb.: era1 Securities and Exchange Co?: mission's reporting requirements W& locus the attention 01 corporate maw::: agement on the problem and enabl& potential investors to fully evaluap,:' future corporate liability
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to pay more attention to waste reduction and to use technically and economically sensible ways to achieve it (1). Hazardous-waste reduction is a trendy notion, but it is not yet clear whether there is a comprehensive shift occurring or whether that shift will be toward generating less waste in the first place. Changes in the private and public sectors will be necessary to increase the pace and scope of waste reduction; organizational, institutional, and attitudinal obstacles abound. In the industrial, environmental, and public policy areas there is neither the consensus nor the organized advocacy required for a major national commitment to reduce the generation of hazardous wastes. That force may be coming. Reference (1) "Serious Reduction of Hazardous Waste,"
OTA-IT-317; GPO stock no. 052-00301048-8; Office of Technology Assessment: Washington, D.C.,1986.
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The views expressed in this article are those of the authors and not necessarily those of the Office of Technology Assessment. Joel S. Hirschhorn is a senior associate and Kirsren (I. Oldenburg is an analyst ar the congressional QEce of Technology h-
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sessment. Environ. Sci. Technol., Val. 21. NO.6. 1987 533
