RACHEL's Hazardous Waste News #113

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

RACHEL’S HAZARDOUS WASTE NEWS #113
—January 24, 1989—
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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WHAT WE MUST DO–PART 13: MORE ON POLLUTION PREVENTION.

After pollution has been prevented at the manufacturing site (see
RHWN #112), we will still have the problem of consumer products
being discarded. If these consumer products contain toxic
materials, their discharge into the environment through
landfills or incinerators will damage humans and the environment.

Therefore, the prevention of pollution at the manufacturing site
is only a partial solution. Preventing pollution by consumer
products is an equally important aspect of the problem. This
week, we consider pollution prevention from the viewpoint of
consumer products.

One way to prevent pollution is through regulation. For example,
some kinds of consumer products could simply be banned. For
instance, beverage cans made from metal and plastic (which makes
recycling of those cans nearly impossible) could be banned.
Plastic packaging that is not biodegradable could be banned.
Certain “convenience” items, such as non-refillable cigarette
lighters, or disposable plastic cameras, could simply be banned.
An alternative to banning such items outright is to lay on a
large tax, to drive them off the market by making them expensive.

More subtle product design regulations could be imposed (or
encouraged through taxes). For example, the percentage of
secondary material used in the manufacture of certain products
can be regulated. For instance, the amount of recycled paper in
certain paper products, the proportion of recycled glass in glass
containers, and the amount of scrap aluminum or scrap steel in
new metal items can be specified by regulation. In the extreme
case, the use of a virgin material could be outlawed entirely;
for example, virgin cadmium could be outlawed, forcing all users
of cadmium to adopt recycled cadmium. This would create a market
for recycled cadmium and would induce people to recover cadmium,
a very toxic metal, rather than dump it.

An alternative is to establish procurement guidelines for local,
state and federal government agencies. For example, if a state
government can only purchase recycled paper, this alone creates a
substantial market for recycled paper in that state.

The durability of products, extending their useful lifetime, can
be encouraged by regulations (or through taxes). For example,
requiring unconditional warranty on specified products for
specified minimum periods would quickly result in design changes
to increase product life. Manufacturers could be charged a fee to
pay the administrative and enforcement costs of such a program.
There is a precedent for this type of regulation in the federal
energy efficiency standards set for certain home appliances. All
governments could encourage product durability by including
minimum warranty provisions in the purchasing specifications for
their own purchases. A danger in imposing product durability
standards is that it could force manufacturers to change to more
toxic materials (for example, increasing durability by changing
from glass to PVC plastic). This danger would need to be
addressed specifically in any regulations (not a simple matter).

Regulations can require that products be made reusable. An
obvious example is beverage containers, which can be designed to
be reusable.

Economic Incentives–Alternatives to Regulation

The simple, familiar bottle deposit can be (and, in a few places,
has been) extended to other products, such as automobile
batteries, which contain toxic lead. Other products that are good
candidates for a deposit are major household appliances,
automobiles, automobile tires, automotive lubricating oil, dry
cell batteries (which may contain toxic lead, cadmium, and
nickel), and containers for pesticides, petroleum products,
organic solvents, and some kinds of paints. To work well, such
deposits require that consumers be able to return used products
easily, and an environmentally safe means of recycling or reusing
the products must be developed.

A related, but different, idea is the “product disposal tax.”
This is a fee charged on a new product when it is manufactured;
the fee is to cover the hidden costs of disposing of the product,
including long-term costs such as groundwater contamination. The
fee would be set larger or smaller, depending on such items as
(1) the eventual disposal costs of the product; (2) the amount of
waste generated by the manufacture of the product; (3) the
environmental impact of disposing of the product and of its
manufacturing byproducts.

In principal, the product disposal tax is an excellent way to
encourage manufacturers to produce smaller amounts of waste, and
less-hazardous products. Products made by the least-polluting
methods using the least-polluting materials would carry the
smallest disposal tax. Low-pollution products would thus be
cheaper to buy and would enjoy an economic advantage over
more-polluting products in the marketplace. This would cause
market forces to tend to drive pollution out of existence. There
is no more powerful force than the market.

Money collected from the disposal tax could be used to fund the
tax collectors, enforcement efforts, and research to make sure
the taxes were being set properly to penalize the worst polluters
the most.

To set such a tax properly, we would need to classify chemicals
according to “degree of hazard.” High-hazard chemicals would be
taxed more than low-hazard chemicals. A simple system, ranking
chemicals on a scale of 1 to 3, should suffice to begin with;
later the system can be refined. Irving Sax’s book, DANGEROUS
PROPERTIES OF INDUSTRIAL MATERIALS, ranks chemicals by acute
(immediate) hazard on a 1 to 3 scale from the viewpoint of
workers handling those chemicals. What is now needed is a similar
system ranking chemicals according to their environmental impacts
and their chronic (delayed) hazard. High-impact chemicals can be
taxed heavily, to make them more expensive and thus less popular.
[Degree-of-hazard ranking systems are discussed in Joel
Hirschhorn, TECHNOLOGIES AND MANAGEMENT STRATEGIES FOR HAZARDOUS
WASTE CONTROL (Washington, DC: Congress’s Office of Technology
Assessment, 1983), pgs. 233-242, 259-261.] It is pathetic that
the U.S. government in 1989 still has no hazard ranking system to
guide development of waste management policies.

The federal Community Right to Know law (SARA Title III) goes one
short step toward the system that is needed. It requires large
manufacturers to report discharges of 300-or-so toxic chemicals.
If SARA looked at more chemicals, and if it looked at them in
relation to the amount of product a facility produced each year,
we’d have the necessary information to begin to set a “product
disposal tax” for consumer products. This would put the
marketplace to work driving toxics out of products, a major step
toward preventing pollution.

Many of these ideas are taken from Elliott Zimmerman, SOLID WASTE
MANAGEMENT ALTERNATIVES: REVIEW OF POLICY OPTIONS TO ENCOURAGE
WASTE REDUCTION. Springfield, IL: Illinois Department of Energy
and Natural Resources [325 West Adams, Room 300; zip:
62704-1892], Feb., 1988. Available from: National Technical
Information Service, Springfield, VA 22161; order PB 88-188-560;
$15.95. Phone (703) 487-4650.
–Peter Montague, Ph.D.

Descriptor terms: pollution prevention; bans; regulation;
pollution tax; taxation; public policy; sensible public policies;
materials policy; durability; deposit; deposits; reuse; reusing;
product disposal tax;

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