We finish the discussion started last time.

To further assist the public, the EPA published a set of 23 documents (398 pages total) called the Definition of Solid Waste Compendium. The preamble contains the following confession: “A frequently mentioned comment from stakeholders is the need for EPA to improve the user-friendliness of the existing regulations … stakeholders have difficulty understanding the regulations and identifying solid waste.”  

Are we surprised that stakeholders are confused when the EPA expects the regulated community to adopt and appreciate concepts such as: Inherently Waste-Like Materials (which means chemical by-products that often contain dioxins), Use Constituting Disposal (meaning materials used to make cement, fertilizer and anti-skid agents), and Universal Wastes (which applies “universally” to a few types of batteries, pesticides, thermostats and lamps)?  

Delving a bit deeper into the seemingly oxymoronic category “Solid Waste, even when Used/Re-used,” we find that some materials are solid wastes even if they are recycled, used, re-used or returned to the original process. This includes materials that are burned for energy recovery or used to produce a fuel. Thus, while one branch of regulators wants to encourage conservation of energy (ostensibly to reduce emissions of greenhouse gases), another branch wants to micro-manage how industry goes about doing it.  

As Benjamin Franklin put it, “Only a virtuous people are capable of freedom. As nations become more corrupt and vicious, they have more need of masters.” In the realm where industry intersects with the environment, today’s master is the regulator.  

One way for industry to liberate itself from this exasperating ruler would be to develop a market-based system to handle the disposition of all forms of waste material – gas, liquid and solid. Since generating and discarding waste material causes varying degrees of negative consequences to neighboring businesses and individuals, the system would have to account for those negative impacts in a manner commensurate with the potential damage.  

This blogger welcomes reader input on the subject and hopes to assemble a futureIndustrial Heatingcolumn enumerating promising ideas.