The importance of waste minimization

It makes good environmental, economic, and business sense.

By Lynn Bergeson, regulatory editor

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Waste minimization is an increasingly essential element of solids management. It is the Environmental Protection Agency’s (EPA) preferred approach to protecting the environment.  Not only does it make good environmental sense, it makes good economic and business sense.

To encourage companies to make voluntary waste minimization commitments, EPA bestows annual National Partnership for Environmental Priorities (NPEP) awards. The agency held its first awards ceremony, on October 25 in the Washington, D.C. area, to recognize companies that completed their enrollment goals. These companies include: Region 2 — Madison Industries, and Old Bridge Chemicals; Region 3 — American Video Glass Company, Baldwin Hardware Corporation, Federal-Mogul, Flowserve Corporation, Material Sciences Corporation, Moog Components Group, Sylvin Technologies, Inc., U.S. Steel Corporation, and Wirerope Works, Inc.; Region 4 —  Chase Scientific Glass, Inc., and Johnson Controls, Inc. - Battery Group; Region 5 —  Bowling Green State University, Crown Equipment Corporation, International Truck and Engine Corporation, Norco Cleaners, Inc., Toyota Motor Manufacturing - Indiana, and Uniseal, Incorporated - Foam Division; Region 6 —  General Motors Corporation - Shreveport, Shell Chemical, and Sheppard Air Force Base.  Success stories highlighting each company’s accomplishments are available on EPA’s website at http://www.epa.gov/epaoswer/hazwaste/minimize/success.htm.

The first national NPEP workshop took place in concert with the October 25 award ceremony.  The workshop focused on training issues and was intended for regional and state waste-minimization staff.
EPA emphasizes that reducing waste generation through waste minimization has helped hundreds of companies save money by eliminating waste management cost and enabling them to change their Resource Conservation and Recovery Act (RCRA) regulatory status from a large quantity generator (1,000 or more kilograms per month) to a small quantity generator (between 100 and 1,000 kilograms per month). Even better, some companies have been able to change to a conditionally exempted small quantity generator (up to 100 kilograms per month). Ideally, all companies would eliminate generation of hazardous waste and avoid RCRA regulatory compliance cost entirely. Not everyone can do this. Everyone can, however, try to minimize generation of hazardous and solid waste.

The benefits of partnerships
EPA encourages greater waste minimization through various partnership programs such as NPEP to encourage public and private organizations to form voluntary partnerships with EPA to reduce use or release of any of 31 so-called priority chemicals (PCs).

Under the Government Performance and Results Act (GPRA), EPA seeks a 10% reduction by 2008 in PCs reported to the Toxics Release Inventory (TRI) Program mandated under the Emergency Planning and Community Right-to-Know Act (EPCRA). The year 2001 is used as a baseline.

To demonstrate the value EPA attributes to NPEP partnership, it offers many benefits. These include: public recognition for achieving voluntary PCs reductions; information about organizations and projects posted on its website at http://www.epa.gov/epaoswer/hazwaste/minimize/projects.htm; company environmental achievements. EPA recently published the NPEP Bulletin. It is prepared quarterly, and participating companies are invited to submit articles, news, and comments.

Additionally, membership plaques are awarded to participants. At the company’s request, EPA notifies local media and other media sources of the membership. Companies achieving any goals in their involvement application are eligible for achievement awards. To receive the award, companies must provide NPEP with a “success story” following the outline posted on the EPA website. The success story is also posted on the NPEP success story showcase on the website.

The NPEP website shows the diversity of public and private participants. The many chemicals offered up for reduction include: lead, mercury, polychlorinated biphenyls (PCBs) cadmium, dioxin, methyl ethyl ketone, naphthalene, chromium, chromic acid, sulfur dioxide, nitrogen dioxide, and carbon monoxide. Posted on the website are the organization’s name, location, and summary listing of goals for each targeted chemical, which include the reduction commitment (in pounds), enrollment date, and projected achievement date.

Waste minimization is a sound environmental practice and a sound business practice. As managing waste would only become more costly, reducing its generation will reduce operating cost and minimize long-term liabilities for waste remediation and other forms of cleanup cost.

By Lynn Bergeson, regulatory editor. She is managing director of Bergeson & Campbell, P.C., a Washington, D.C.-based law firm that concentrates on chemical industry issues. Contact here at lbergeson@putman.net. The views expressed herein are solely those of the author. This column is not intended to provide, nor should be construed as, legal advice.

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