Waste Minimization:

Major Problems of Data Reliability and Validity Identified

PEMD-92-16: Published: Mar 23, 1992. Publicly Released: Mar 23, 1992.

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Pursuant to a congressional request, GAO evaluated the quality of the Environmental Protection Agency (EPA) data used to determine the need for mandatory waste minimization requirements, focusing on: (1) the degree and causes of measurement error in the EPA National Survey of Hazardous Waste Generators; (2) how to reduce or eliminate those errors; and (3) how to minimize future problems.

GAO found that: (1) the EPA baseline hazardous waste minimization data are fraught with reliability and validity problems that are severe enough to limit the data's usefulness in examining the extent of waste minimization progress; (2) EPA has not sufficiently defined several concepts, terms, and questions used in its survey instruments, causing respondents to make an array of individual judgments when completing waste minimization questionnaires; (3) since EPA has not refined the Resource Conservation and Recovery Act (RCRA) categories that use codes to profile hazardous waste types, it cannot accurately profile the extent and determinants of minimization for specific hazardous wastes; (4) the lack of stringent EPA reporting requirements has caused company recordkeeping systems to vary greatly in quality and accessibility; (5) due to the lack of sufficient recordkeeping capabilities, individual respondents are led to make judgments and estimations of data that may not be representative of information collected; (6) because data on waste stream production amounts are flawed, EPA does not accurately characterize production mix as it relates to waste output; (7) such nonproduction activities as research and such one-time events as spill cleanups generate waste, but are not accounted for by production activities; and (8) due to such ambiguities, EPA waste minimization data cannot be adjusted to account for imperfect measurement, and waste minimization progress cannot be ascertained.

Status Legend:

More Info
  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: The Administrator, EPA, should direct the Assistant Administrator, Solid Waste and Emergency Response, to request that hazardous-waste-generating industries maintain recordkeeping systems that provide sufficient detail on goals, activities, and progress of waste minimization activities.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: EPA has required industries to do so. They will be required to maintain records that more fully record waste minimization activities and progress.

    Recommendation: The Administrator, EPA, should direct the Assistant Administrator, Solid Waste and Emergency Response, to request that hazardous-waste-generating industries define waste minimization programs to ensure that goals, budgeting, incentive programs, use of technical assistance, and assessments are well delineated.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: EPA will add reference to 1993 biennial reporting mechanisms which will help regulated industries define waste minimization programs.

    Recommendation: The Administrator, EPA, should direct the Assistant Administrator, Solid Waste and Emergency Response, to clarify regulatory status so that respondents do not confuse RCRA-defined hazardous wastes, hazardous wastes exempt from RCRA, and wastewater.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: EPA has taken a number of steps to clarify the regulatory status of various wastes. It has: (1) added a regulatory status data element to the biennial hazardous waste reporting system; (2) clarified the hazardous waste reporting instructions with respect to regulatory status; (3) added discussions on regulatory status distinctions within training sessions for hazardous waste generators and is including these distinctions in the revised biennial reporting regulations.

    Recommendation: The Administrator, EPA, should direct the Assistant Administrator, Solid Waste and Emergency Response, to clarify waste stream definitions by making RCRA waste code categories more definitive.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: EPA has continued to redefine waste code categories.

    Recommendation: The Administrator, EPA, should direct the Assistant Administrator, Solid Waste and Emergency Response, to investigate alternatives to the production mix measure in order to accurately depict the extent of waste minimization progress.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: EPA has implemented several efforts which should improve its ability to measure trends in waste minimization. It has improved its waste minimization data collection instruments; it has incorporated an activity/production index into its data development activity; it is refining its methodologies for measuring minimization trends.

    Recommendation: The Administrator, EPA, should direct the Assistant Administrator, Solid Waste and Emergency Response, to conduct site visits of a sample of hazardous waste generators in order to maintain quality assurance and control in waste minimization program activities.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: The agency is conducting site visits. In these reviews, EPA plans to evaluate generation and management data that are submitted by the generators and treatment, storage, and disposal facilities responsible for generating and managing approximately 90 percent of the total hazardous waste.

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