RACHEL's Hazardous Waste News #360

=======================Electronic Edition========================

RACHEL’S HAZARDOUS WASTE NEWS #360
—October 21, 1993—
News and resources for environmental justice.
——
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org
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INTELLIGENT PRODUCTS

During the last 50 years humans have developed thousands of
products for which no environmentally sound method of disposal
exists. To help set “acceptable limits” on the damage we do,
government developed “risk assessment.” Unfortunately, risk
assessment fails because (1) it is focused on damage to the “most
exposed individual,” not the general environment; (2) we will
forever lack key information; and (3) science can never provide
the needed analytic techniques (for example, health effects from
exposure to multiple chemicals are too complex to analyze). As a
result, we are now faced with the steady buildup of poisons
planet-wide in places and ways that are poorly documented and
even more poorly understood.

It is time we turned our attention to re-designing the way things
are made. Dr. Michael Braungart at the Environmental Protection
Encouragement Agency (EPEA) Environmental Institute has developed
criteria for sustainable manufacturing. [EPEA’s address:
Feldstrasse 36, D-20357 Hamburg, Germany; fax from the U.S.: 011
49 40 4382085.]

EPEA sees 3 categories of products: CONSUMPTION PRODUCTS, SERVICE
PRODUCTS and UNMARKETABLE PRODUCTS.

CONSUMPTION PRODUCTS are purchased, then converted by chemical
reaction into energy or by-products; examples are soap and food.
They are normally used once, then released into the environment.
To be compatible with a sustainable civilization, they must be
biodegradable (or degradable by non-living systems); they must
not bioaccumulate (build up in food chains); they must not cause
cancer or birth defects or developmental disorders or changes in
the genetic makeup of living things, and they must not exhibit
toxicity. Finally, they must be analyzed at the picogram level.
(A picogram is a millionth of a millionth of a gram [10-12];
there are 28 grams in an ounce.)

SERVICE PRODUCTS are goods that provide services, such as
automobiles, TV sets, etc. Consumers should not own such
products, but should lease them from the manufacturer, who would
remain responsible for their ultimate destiny. An alternative
would be purchase with a refundable deposit on the item, just as
many states now require a nickel deposit on bottles to assure
their return. After the product has served its function and has
to be renewed, the consumer returns it to the producer, who is
responsible for disassembly and recycling.

Return can be achieved via “waste supermarkets” which would
accept service products (packaging materials, TV sets, washing
machines, etc.). A waste supermarket is not a dump but a
compartmentalized source-separation warehouse for various used
products. Interim storage would be needed for items for which no
recycling technology has yet been developed.

UNMARKETABLE PRODUCTS are those that cannot be consumed or used
in an environmentally sound way; an example is waste from
aluminum production. These are products (or by-products) for
which no recycling technology exists because they are dangerous
and because the market provides no financial incentives.

EPEA advocates a “parking lot” storage building for interim,
retrievable storage, similar to the above-ground concrete
buildings we have described previously. (See RHWN #260.) EPEA
emphasizes that the “parking lot” only makes sense if the entire
“intelligent products” system is established; otherwise the
amount of waste will grow to be unmanageable.

Criteria for safe storage include: no spontaneous combustion; no
release of gas; no release of liquids. To simplify retrieval,
different kinds of wastes and substances would be stored
separately in the building until a satisfactory treatment method
was developed. The user of the building has to prove every 3 to
5 years that no treatment method has yet been developed to
prevent, reduce or dispose of the waste in an environmentally
sound way. Ownership of the building remains under public
control. The owner of the waste remains responsible for the
waste (and rents space in the building) and has to guarantee
safety and solve any problems arising from the waste. THIS MEANS
THAT LOCAL COMMUNITIES WOULD ONLY HANDLE BIODEGRADABLE WASTES.

Advantages of the “parking lot” (above-ground concrete building)
concept are: It enforces the “polluter pays” principle; splits
responsibility between the owner of the waste and the owner of
the building; encourages development of new technologies for
specific waste problems; avoids over-capacity of waste treatment
facilities; promotes re-thinking of products that now produce
unmanageable wastes; discourages waste export and false labeling
of waste; puts the market to work minimizing unmanageable waste;
encourages re-use of waste because wastes are not mixed together;
puts the burden of proof for environmentally sound management on
the producer; guarantees zero discharge from the facility.

EPEA has developed five key goals and 25 detailed criteria for
all manufacturers:

1. Producers must establish long term environmental goals for
worldwide operations, plus dates for achieving these.

2. Chemicals or products released into the environment must be
biodegradable and not accumulate in environmental media or food
chains. They must not be teratogenic, mutagenic or carcinogenic
and they must not be acutely toxic to human beings in the
concentrations occurring under field conditions. These chemicals
must not disrupt ecological systems.

3. Producers must not produce organisms which disrupt ecological
systems. It is the responsibility of the company to prove that
this goal is being met.

4. Producers must only use renewable energy resources and must
minimize energy consumption.

5. Producers must actively protect the existence of animals and
plants in their natural habitats.

Twenty-Five Detailed Criteria

Further criteria are necessary to evaluate fulfillment of those
goals. Twenty-five criteria for environmentally sustainable
production are listed below. They require from producers:

1. LONG TERM GOALS: Acknowledge long term environmental goals as
priorities. The company will make training and education
available to the management and staff in order to translate long
term goals into reality.

2. GLOBAL STANDARDS: Apply the same environmental standards for
products and production and provide enforcement possibilities by
independent authorities globally.

3. DECLARATIONS: Make complete declarations of the contents of
all products publicly available.

4. ANALYZABLE SUBSTANCES: Produce only analyzable chemicals, so
that each substance can be traced to concentrations of parts per
billion.

5. DEGRADATION KNOWLEDGE: Have full knowledge of the degradation
processes of each product. The degradation should not produce
any unknown or potentially harmful interim products.

6. LIFE CYCLE ASSESSMENTS OF PRODUCTS: Conduct life cycle
assessments for each product. Production processes for newly
developed or persistent, bio-accumulative and highly toxic
substances are top priority.

7. LIFE CYCLE ASSESSMENTS OF FACILITIES: Conduct life cycle
assessments for production plants and waste/sewage treatment
equipment. The basic elements to include in these analyses are
energy, raw material and waste balances.

8. FREEDOM OF INFORMATION: Make all environmentally relevant data
and information on the toxicological hazards of its products
publicly available.

9. TECHNICAL ADVICE: Ensure that individuals or citizens’ groups
opposing specific technical processes or facilities can receive
technical advice similar to the project’s proponents.

10. CATASTROPHIC ACCIDENT PREVENTION: Ensure that production
processes and facilities eliminate the possibility of
catastrophic accident.

11. PROLIFERATION PREVENTION: Drastically reduce the variety of
chemicals produced and only put substances on the market which
can be completely defined in chemical and degradation terms.

12. HAZARDOUS WASTE RETENTION: Retain possession of all
unmarketable products until an environmentally sound use or
elimination is possible.

13. REDUCTION OF NON-RENEWABLE RESOURCES USE: Drastically reduce
consumption of non-renewable energy and raw material resources,
as well as the production of hazardous wastes.

14. WATER CONSERVATION: Establish closed-loop systems for water
used in cooling and production. The quality of the used
resources –air, water and soil –will not be diminished during
the production process.

15. GROUNDWATER CONTAMINATION ELIMINATION: Avoid contaminating
any groundwater either by production processes or by the use of
the products themselves.

16. BIOTECHNOLOGIES GUIDELINES: Establish publicly analyzable
guidelines on the use of biotechnologies, especially genetic
engineering, and translate them into action plans.

17. COMPETITION IN ENVIRONMENTAL ACTIVITIES: Promote
environmental protection in order to encourage environmental
activities in competing corporations.

18. SPECIES PROTECTION: Acquire an appropriate plot of land to
reduce the extinction of animal and plant species.

19. PHASE OUT ANIMAL TESTS: Strive to abolish animal tests and
set up a phase-out schedule for this purpose.

20. ELIMINATE WEAPONS: Not produce any biological or chemical
weapons.

21. OLD PRODUCT RESPONSIBILITY: Take responsibility for all
substances it has produced in the past.

22. LIABILITY ACCEPTANCE: Accept liability for its products.

23. RETURN POLICY: Take back products which cannot be disposed of
in an environmentally sound manner. Provide clear instructions
to consumers for this procedure, e.g. environmental passport,
background information.

24. PHASE OUT UNSUSTAINABLE TECHNOLOGIES: The company will set a
time limit and phase-out schedule for the use of environmentally
unsustainable technologies which it now uses.

25. SUPPORT ENVIRONMENTAL ORGANIZATIONS: Actively support
international environmental groups and international committees
in establishing standardized global environmental regulations and
a qualified independent supervisory agency.

Evaluation of production activities according to these criteria
eliminates the need for “environmental auditing” which is
currently based on non-standardized conditions and conducted by
companies voluntarily. Life cycle assessment represents a
practical tool for the investigation of production activities
only if these criteria are applied.
–Peter Montague, Ph.D.

Descriptor terms: manufacturing; hazardous waste; risk
assessment; michael braungart; epea; environmental protection
encouragement agency; products; waste avoidance; pollution
prevention; above-ground storage buildings; standards;
regulation; accidents; prevention; cbw; waste disposal;
environmental audits; auditing; life cycle assessment; life cycle
analysis;

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